NC0000272_Historical_File_1997thru1999_20210201

a
BLUE RtD(aE PAPER,,, PRODUCT'S, INC.
C� ANT ��NI' MILL"
COIYIlVLUNITY ADVISORY COIVWI !: TEE

/f vv
� P
xc: Paul Davis
Director, Water Pollution Control
Tennessee Department of Environment and
Conservation
150 9" Avenue, 4" Floor
Nashville, Tennessee 37243-1534
Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville, NC 28801 '
Keith Haynes
Environmental Specialist
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville, NC 28801
FEB 2 6 2001 `
WATER QUALITY SEOTIOM
ASHEUILLE REGIONAL OFF{CF

BLUE RIDGE
PAPER PRODUCTS INC.
February 21, 2001
Mr. Dave Goodrich, NPDES Unit Supervisor
North Carolina Department of
Environment and Natural Resources
512 North Salisbury Street
Raleigh, NC 27604
Dear Mr. Goodrich:
Please find the enclosed EPA Forms 1 and 2C for the renewal of Blue Ridge
Paper Products Inc.'s (BRPP) Canton Mill NPDES permit NC0000272. As you
are aware, this facility is subject to the EPA's Cluster Rules codified at 40 CFR
part 430.
We look forward to working with you and your staff in order to assure this
application meets your requirements. Please call Derric Brown, Manager -
Environmental Affairs at [phone] or Bob Williams, Director —
Environmental, Health and Safety Affairs at [phone] if you have any
questions or need additional information.
Sincerely,
A�6,c"(,
Bob Cicale
Vice President of Manufacturing and Mill Manager
Canton Mill
175 Main Street ® P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

Please print or type in the unshaded areas only
(rill-in areas ale spaced for elite type,i.e., 12 characteynch). Farm Approved.OMB him 2040,0086. Approval expires 531-9
FORM U.S.ENVIR NMENTAL PROTECTION AGENCY 1.EPA I.D.NUMBER
GENERAL INFORMATION _
F NC0000272
GENERAL (Read the"General instructions"before starting.) 1 z 14 15
1 EPA Consolidated Permits Program
LABEL ITEMS GENERALINSTRUCTIONS
If a prepnnte,J late l has been provided,affix it in the designated space.
Review Me IVennation carefully,if any of it is incorrect wss through it
and enter the caned data in the appropriate fl4 In area below. Also,if
s �'i) �`i,.,R.�•1� Yam,:`�y„ � ^•i y, W i ^ ' any or the phe hfm,d data is et sent hould a area to leashe e provide
Me label
" \., r*,� �( rtahC � a a t i `2� � ` S'. �•` F ` a `�� apace lists lhehbrtnatlon Nal should appear,)please pmvitle it in the
r` '. ty, .`,. v 8'.±�,,}. �. e`!•te. ,,�.qka. 0 i 'k C P ct.you
proper fig-In areas) below. If the label is complete entl mice
A needs not rngenclo a.)Ite Complete
to and VI(except
no
betVI- which must be
completed mAarOlessJ Complete all items it no label has been
•`�` A �` s1,yCi. ;,:s`E l ti\ •�,,. provided. Referto the instructions for detailed item descriptions and for
'•tt r `e t`.� t � '�� �� the legal auNcdmtions untlerwhirh this data Is collected.
,47P
� wa� ap ,�'��, .``��
�,a..<
II.POLLUTANT CHARACTERISTICS
INSTRUCTIONS: Complete A through J to determine whether you need to submit any permit application forms to the EPA. If youanswer'yes" to any questions,you must
submit this form and the supplemental forth listed in the parenthesis following the question. Mark'Y'in the box in the third column if the supplemental form is attached. If you
answer"no"to each question,you need not submit any of these forms. You may answer"no"if your activity is excluded from permit requirements;see Section C of the
instructions. See also,Section D of the instructions for definitions of bold-faced terms.
MARK'X"
SPECIFIC QUESTIONS vEs No ATTACHED SPECIFIC QUESTIONS vas No ATTACHED
A. Is this facility a publicly owned treatment B. Does or will this facility(either existing or proposed) includes
works which results in a discharge to waters of the X concentrated animal feeding operation or aquatic animal production X
U.S. facility which results in a discharge to waters of the U.S.? (FORM
(FORM 2A) 16 17 18 2B) 16 17 18
C. Is this facility which curently results in discharges X X D. Is this a proposed facility(other than those described in A ore X
to waters of the U.S.other than those described in A above)which will result in a discharge to waters of the U.S.?
or B above?(FORM 2C) 22 23 24 (FORM 2D) 22 23 24
F. Do you or will you inject at this facility industrial or"unicipal
E. Does or will this facility treat,store or dispose of X effluent below the lowermost stratum containin,within one quarter X
hazardous wastes? (FORM 3) mile of the well bore,underground sources of drinking water?
28 29 30 FORM 4 28 28 29
G.Do you or will you inject at this facility any produced water H. Do you or will you Inject at this facility Fluids for special
or other fluids which are brought to the surface In connection X processes wuch as mining of sulfur by the Frasch process,solution X
with conventional oil or natural gas production,inject fluids mining of minerals,in situ combustion of fossil fuel,or rE:CAVery of
used for enhanced recovery of oil or natural gas,or inject
fluids for storage of liquid hydrocarbons?(FORM 4) 34 35 36 geothermal energy?(FORM 4)
34 35 36
I.Is this facility a proposed stationary source which is one of J. Is this facility a proposed stationary source which is NOT one of
the 28 industrial categories listed in the instruction and which X the 28 industrial Categories listed in the instruction and which will X
will potentially emit 100 tons per year of any air pollutant potentially emit 250 tons per year of any air pollutant regulated
regulated under the Clean Air Act and may affect or be located under the Clean Air Act and may affect or be located In an
in an attainment area?(FORM 5) 40 1 41 1 42 attainment area?(FORM 6) qp q1 q2
III.NAME OF FACILITY
t SKIP I Blue Ridge Paper Products Inc.
A.NAME&TITLE(last,first&tilthellB.PHONE(area code
2,1 Derric Brown - Manager of Environmental Affairs 828 646 2318
V.FACILITY MAILING ADDRESS
A.STREET OR P.O.BOX
3 P.O. Box 4000
B.CITY OR TOWN C.STATE D_ ZIP CODE
41 Canton NC 2-8716
VI.FACILITY LOCATION
A. STREET,ROUTE NO.OR OTHER SPECIFIC IDENTIFIER
s 175 Main Street 45
B. COUNTY NAME
Haywood
C. CITY OR TOWN C.STATE D-ZIP CODE plemownJ
s Canton NC 28716

CONTINUED FROM THE FRONT
rgl,in order orpnonty) Will
B.SECOND
7 # 2621 (SPECIFY) Integrated Pulp Mill SPECIFY
C.THIRD D.FOURTH
C (SPECIFY) 0 (SPECIFY)
7 7
15 i6 19 15 6 19
Igr,in order o pnon y
A.NAME B. Is the name listed
Blue Ridge Paper Products Inc. Item VIII-A also the owner?
8 YES [::]NO15 16 35 66
C.STATUS OF OPERATOR(Enter the appropriate letter into the answerhox;if"Other',specify) D.PHONE(area code&no.)
F=FtULKAL M= spec
S=STATE O=OTHER(SPECIFf) P A $28 454 0676
P=PRIVATE 54 1 19-21 1 22.2s
E.STREET OR P.O.BOX
1 West Pack Square, Suite 1100
24 55
F.CITY OR TOWN G.STATE H.ZIP CODE
c (SPECIFY) Is the facility located on Indian lands?
B Asheville NC 28801 YES ^ IND
151 16 141 42 47 51 52
A. NPDES(Dsshcarge to Surface Wafer) D.PSD(Air Emissions Irony Proposed Sources)
s N NC0000272 s P 20294
15 16 111 18 30 15 16 17 18 30
B. UIC(Underground Injection of Fluids) E. OTHER(Specify)
(SPECIFY)
s U s See Attachment I for List of Permits
1] 18 30 15 16 17 16 30 15 16
C. RCRA(Hazardous Wastes) E. OTHER(Specify)
SPECIFY)
9 R 9
I. 17 18 301 18 30
MAP
Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must show the outline of the facility,the location of each
of its existing and proposed intake and discharge structures,each of its hazardous waste treatment,storage,or disposal facilities,and each well where it injects fluids underground.
Include all springs,rivers and other surface water bodies in the map area. See instructions for precise requirements.
(provide a brief descnpyra:��
The Canton Mill is an integrated bleached papergrade kraft pulp and paper manufacturing facility producing
paperboard and fine papers.
see in5wcuons
I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and all attachments and that,
based on my inquiry of those perons immediately respnsible for obtaining the information contained in the application, I beleive that the information is true,
accurate and complete. I am aware that there are significant penalites for submitting false information,including the possibilty of fine and imprisonment.
A. NAME&OFFICIAL TITLE(type orprint) B.SIG URE C.DATE SIGNED
Robert Cicale-Vice President of �7
Manufacturing and MiAC 1ll Managerlz4 �j/ C
c
C
15 16 55
EPA Form 3510-1 (8-90)

Attachment I
Form 1
NC0000272
X. Existing Environmental Permits
Permit Type Permit No. Agency Unit
A. NPDES NC0000272 N.C. Dept. of Environment Wastewater
and Natural Resources-DWQ Treatment
Facility
NCS000105 N.C. Dept. of Environment Stormwater
and Natural Resources-DWQ
D. PSD 20294 N.C. Dept. of Environment No. 4 Coal Fired
and Natural Resources-DAQ Power Boiler
E. Other 44-06 N.C. Dept. of Environment No. 6 Landfill
and Natural Resources-DAQ
44-159(C) N.C. Dept. of Environment No. 19 Project
and Natural Resources-DAQ
44-819C2 N.C. Dept. of Environment Causticizing Project
and Natural Resources-DAQ
11740 N.C. Dept. of Environment Pump Station
and Natural Resources-DAQ for No. 6
Landfill leachate
20065* N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ
20066* N.C. Dept. of Environment Bark/Coal Boiler
and Natural Resources-DAQ
20067* N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ
20068* N.C. Dept. of Environment Coal Boiler
and Natural Resources-DAQ
20069* N.C. Dept. of Environment Coal Boiler
and Natural Resources-DAQ
20070* N.C. Dept. of Environment Coal Boiler
and Natural Resources-DAQ
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

Attachment I continued
NC0000272
20152* N.C. Dept. of Environment Black Liquor
and Natural Resources-DAQ Oxidation
20386* N.C. Dept. of Environment Lime Slaker
and Natural Resources-DAQ
20392* N.C. Dept. of Environment No. 4 Limekiln
and Natural Resources-DAQ and NCG system
20427* N.C. Dept. of Environment Tall Oil Scrubber
and Natural Resources-DAQ
20451* N.C. Dept. of Environment No. 5 Limekiln
and Natural Resources-DAQ and NCG system
20452* N.C. Dept. of Environment Chlorine Dioxide
and Natural Resources-DAQ Scrubber
20463* N.C. Dept. of Environment No. 4 Lime
and Natural Resources-DAQ Unloading System
20485* N.C. Dept. of Environment No. 1 Fiberline
and Natural Resources-DAQ Scrubber
20486* N.C. Dept. of Environment No. 2 Fiberline
and Natural Resources-DAQ Scrubber
20487* N.C. Dept. of Environment No. 5 Lime Slaker
and Natural Resources-DAQ
20488* N.C. Dept. of Environment No. 5 Lime
and Natural Resources-DAQ Unloading System
20496* N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ Dissolv.Tank Vent
20497* N.C. Dept. of Environment White Liquor
and Natural Resources-DAQ Oxidizer Seperator
20498* N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ Dissolv.Tank Vent
On July 1, 2000, the air program was re-delegated from the Western North Carolina Regional
Air Pollution Control Agency to the North Carolina Department of Environment and Natural
Resources, Division of Air Quality. Effective October 27, 2000,the new Air Quality Permit
No. is 08961.
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

EPA I.D. NUMBER (copy from Item 1 of Form 1) Form Approved
NC0000272 OMB No.2040-0086
Please print or type in the unshaded areas only Approval expires 5-31-92
FORM j '� _ US ENVIRONMENTAIPROTEGTIONGENCY � xi<
2'C 1 I APPLICATION FOR PERMMT TO DISCHARGEWASTEWATERt
NPDES a R ({ EXISTING MANUFACTURING,COMMERCIAk,MII LING AND SIL�IICULTURAk OPERATION
�"`r.f... :`' _#I`."l. .?CU(lsojl({at�df,'emlts Proll
grarlS "',�i, ,,......a^'' *r,3,.
L•OUTFALL kQCATION.�
For each 7outfall, ls_t the latitude and longitude ofits locatiorttothe nearest15 secontls"andthename bf the;receiving water
A.OUTFACE B. LATITUDE` C. LONGITUDE
NUMBER"• " D. RECEIVING WATER{name) ,
(list) _DEG. 12:,NIIN. 3. SEC:',1.DEG. ' 2;,MIN:, 3.SEC. ,
001 35 32 8 82 50 42 Pigeon River
II'.FLOWS,SOURCES OF P-OLLUTION,,AND TREATMENT TECHNOLOGIES j _
A.Attach a line drawing showing the water flow through the facility. Indicate sources of intake water,:operations.contributing wastewater to the effluent, -
}
and treatment units labeled to correspond to.the more detailed description in Item 8., Construct awater balance on the Imo=drawing by showing average- '-
flows between intakes,operations,trealmentunit's;.and outfalls.'If a water balance cannot be determined ag,.forcedain!7rining acbwtfesjyovide,a
pictorial description of the nature and amount of.any sources of water and any collection or treatment-measures. ,
S.For ea&oulfall;provide a description of.(1)All operations contributing wastewater,toahe effluent,including,process wastewater,sanitargwastewater;
cooling water,and storm water runoff;.(2)The average flow contributed by each operation;and(3)The treatment recieved by the wastewater;. Continue
on additional sheets if necessary.; - ¢%
1.,OUTFALL _., 2.',OPERATION(S)�CONTRIBUTlNG;FLOW „3.1"T,REATMENT-
NUMBER, a. OPERATION (list)' a b.AVERAGE FLOW a.:DESCRIPTIQN' b LIST CODES FROM.
(list) ' (include units) "as; TABLE'2C=4
Pulp Mill:Chip Cooking 9.82 mgd Grit Chamber 32'X8'X16' 1-M
001 pulp washing, screening & 29.9 mgd, 1 minute retention
bleaching, recovery and solids to landfill 5-Q
regeneration of cooking
chemicals, production of Bar screens,two 6'wide each, 1-T
chlorine dioxide for pH control by CO2 injection. 2-K
bleaching. Coagulation by polymer addition. 2-D
Paper Mill 8.1 mgd Primary clarifiers, circular two 1-U
001 Production of fine papers 200'dia.X 14.75'deep 12.7 mgd ea.,
and paperboard 6.6 hour retention
one, 125'diam x 11'deep for spill
Steam and Power 3.9 mgd control, 1.01 mg capacity
001 Generation skimmed floating solids to landfill 5-Q
Settled solids dewatered by belt 5-C
press to landfill 5-Q
Unmetered and Misc., 2.93 mgd
001 Raw water, Sludge Secondary treatment by activated 3-A
WWTP Use sludge process
Average Stormwater 0.17 mgd based on 1998 rainfall Aeration basin 408'x240', 11.4 mg
Town of Canton 0.65 mgd rapacity,29.9 mgd plus recycle, 9.4
001 Municipal Wastewater and hrs retention
Landfill leachate-Variable
depending on storm events Continued on Attachment II-B1
OFFICIAL.USE.ONL'Y (efgbentguideliges.sub=categories)` ;
EPA Form 3510-2C(8-90) PAGE 1 OF 4 CONTINUE ON REVERSE

Attachment II — B1
Form 2C
NC0000272
Continued from IIB (3)(a) — (b)
a. Description b. List Codes from Table 2C-1
At low influent loading 3-A
Secondary Treatment by
activated sludge process
(and stand-by capacity
of 4.6 mg) with 6.8 mg
treatment and 5.6 hours
retention.
Secondary clarifiers,
circular, two, 200' dia. x 1-U
12' deep, 11 mgd, one
150' dia. x 14' deep,
6.2 hours retention
Aeration cascade, with 4-A
oxygen injection discharge
to Pigeon River
Oxygen injection capability XX
at 0.9 and 2.1 miles downstream
of discharge.
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

Attachment II - A
PIGEON RIVER
29.9 WCLUDESAVG-
STORMWATER FLOW
31.63 OF 0.17 MGD
WASTEWATER �'`P o.s
PUMP HOUSE TREATMENT
PLANT
RAW WATER USE 2.03
SLUDGE 0.30
L
ILTER PLANTMI 8.0 0.6 0.60
COOLING WTP USE
PAPER MII.L EVAP 0.7
NO. 11 PM 1.8
10.8 N0. 12 PM 1.3 8.1
NO.20 PM 1.7
NO. 19 PM 2.9
CHEM PREP 1.3
PCC PLANT 0.3
PULP DIST. 1.5
20 WFM WATER
11.5 PULP MILL
13.50
ERCO CL02 1.2
CHEM PREP 0.6
COOKING 1.4
BLEACHING 4.9
RECOVERY 3.4
EVAP 1.1
5.0 S& 3.9
POWER
GENERATION
0.9 MISCELLANEOUS 0.9
UNMETERED
BLUE RIDGE PAPER PRODUCTS INC. TOWN OF CANTON 0.9
CANTON MILL-WATER BALANCE WASTEWATER AND
PERMIT NO.-NC 0000272 MILL LANDILL
FLOWS IN MGD DATE:2/14/01 LEACHATE

MNITINUEOFROMTIEFRDM D NC0000272
C.Excepffor storm runoff,leaks,or spills,are any of the discharges described in Items'II=A or B inter nittentor'seasonallm
Yes(complete.the following table}:- - �- : X NO(yb to,section 111) --
' _ �-: .� `"g� :" -3,•.,-_ REQUNCY'- '. I• .a .FLOW
t'.OUTFACE '2:OPERATION(S) - . _ �a:DAYS b'.MONTHS a.FLOW RATE w b:TOTAL"VOLUME"
NUMBER CONTRIBUTING FLOW PER,WEEK[PER YEAR:1 (fn Ingot ` '_ '". (specify with units)' c.DUR
(list)' (list) _ (specify (Specify. -1.LONGTERM :'2.Mp](IINUM'. ALONG TERM 2:MAXIMUM ATION.
averege ��-average) r AVERAG6 :1 . DAILY : AVERAGE' DAILY 4 (in days)..
IIGPRODUCTION
A.Doeslaneffiuentguldellnelimitalibnpromulgated,by,EPA under'Section'3Q4of the,Clean WaterAct'apply,toyourfacility?
X YES'(complete4fem 111-B).` `, -' `NO(go to:section lV) '_ "• ".
B.Are the limitations'in the applicable efiluent.g_uideline expressed interns of productiom(_or othermeasure:of open Ucnj�
" X YES(complete.Item III-C) __ ` _ _ • F I NO(go to:Section IV)
C.If youanswered'yes"to Item III-B;list the quantity which'represents an actual measurement of your level of protluclion, expressed in terms and units
used in ihe-applicable ef�uent guideline,.and indicate the affectedloulfalfs:'a •`t �`°�
1i AVERAGE,DAICY PRODUCTION - - "" 2.AFFECTED --
a.OUANTiTY b.UNITS OF:' C.OPERATION.PRODUCTION MATERIAL,ETC:: :. OUTFALLS :.
PER'DAY MEASURE' (specify) ° (list outfail numbers.
721.0 ADMT Bleached Papergrade Kraft and Soda paperboard
001
746.8 ADMT Bleached Papergrade Kraft and Soda fine papers
ADMT=Air Dry Metric Tons
NOTE:A project was completed on the No.19 Paperboard Machine in 2000 which increased
our capacity to produce paperboard in future years to 908 ADMT.
(See Attachment IV for correspondence with NCDENR-DWQ with respect
to the paperboard project.)
IV.IMPROVEMENTS. - -- - -� - - J- --
A.Are you now required by any Federal,State.or.lpcal authority to meet any,implementation schedule for the construction, upgrade or operation of waste- ".
walertrealment equipment or practices or any other environmental programs which rday:affect theAlschargesrdescribed in this application?This includes„
but not limited'to„permit conditions,administrative or enforcement orders,enforcement compliance schedule letters,.stipulations,court,o"rders,.and grant. ..
or loan conditions - -
YES(comptete.the foHowing':table) X ! Iic4go to.Item Iv--B)
2.AFFECTED OUTFALLS - ,, ,-r ,- `^": . A;FINAL COM7
1.IDENTIFICATION+OF CONDITIQN, ' ' 3.BRIEF DESCRIPTION OF PROJECT ;`` PLIANCE DATE=
AGREEMENT,ETC. R.No. 6:SOURCE OF DISCHARGE • - _ a.RE-- b.PRO-,
QUIRED EJECTED,
B.OPTIONAL:You may attach additional sheets describing-any additional water pollution control programs(ocother environmental projects'which may effecf:
your discharges)you now have underway or which you plan:Indicate whether each program is now.underway orplan4d;and indicate your actual or -
plannedschedules:for construction.
MARK X"IF-DESCRIPTION OFADDITIONAL CONTROL PROGRAMS IS ATTACHED ;,•� , '
EPA Form 3510-2C(Rev.2-85) PAGE 2 OF 4 CONTINUE ON PAGEY3

Attachment IV
Form 2C, III-C-1
NC0000272
Average Daily Production
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

ivlak1ng ur mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
October 5,1999
Mr.Forrest Westall
North Carolina Department
Environmental and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
Re: NPDES Permit NC0000272
Blue Ridge Paper Products Inc.
No.19 Paper Machine Improvement Project
Mr. Westall:
Blue Ridge Paper Products Inc., (BRPP),Canton,North Carolina Facility, NPDES Permit No.NC0000272,
is notifying you of planned improvements to No. 19 Paper Machine. The improvements will involve the
replacement of the paper machine's second press with a press of different design and the replacement of
the calendar stacks with two calendar nips. In addition, non-contact cooling towers will be installed to
mmunize fresh water usage. The improvements will enhance both product quality and yield and the
paper machine will be able to process lighter weight products at maximum production rates. The No.19
Paper Machine annual calendar day production rate is projected to be less than 1,000 air dried toms of
finished product per day.
This project includes no physical or operational changes that would increase the mill's current pulp
production capacity. Therefore, there will be no additional color loading resulting from this project The
current maximum annual average production capacity of the pulp mill is not sufficient to supply all four
paper machines. The Canton Mill has purchased an average of approximately 39,000 tons of dry
furnished pulp per year for each of the last six years to supplement on-site pulp production and supply
the paper machines. The pulp mill will continue to nm as efficiently as possible, but additional dry
furnish purchases will be necessary to support production at the paper machines.
Blue Ridge Paper Products Inc., is not requesting any revisions or modifications to the NPDES Permit
effluent limitations, monitoring requirements, or other conditions. Completion of the No.19 Paper .
Machine Project will result in continued full compliance with the Settlement Agreement, Color Variance
and NPDES Permit
If you have any questions or need additional information please contact me at(828) 646-2033.
Sincerely, q ,, / /•
Robert V.Williams
Director,Environmental,Health&Safety Affairs

-• NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
® � ASHEVILLE REGIONAL OFFICE
NCDENR '. WATER QUALITY SECTION
November 19, 1999
IAME59.HUNTJR. t5
;OVERNOR _ id
Mr. Robert Williams
Blue Ridge Paper Products Inc.
175 Main Street
VAYNE MCDEVITr :yl Post Office Box 4000
iECRETARY .,r � Canton, North Carolina 28716
`ERRT!ss.;eN®• .-,=a} Subject: Improvements to No. 19
Paper Machine
w, a Blue Ridge Paper Products Inc.
NPDES Permit Number NCO00O272
Haywood County
"; Ya Dear Mr. Williams :
We have reviewed your letter . dated October 5, 1999
concerning planned improvements to the No. 19 Paper Machine
and offer the following comments .
As you are aware, stipulation 30 of the NPDES Permit
Settlement Agreement states, "The 1997 Permit shall also
provide that neither Champion nor any successor-in-interest
;..' to Champion' s ownership and/or operation of the Canton mill
will increase the mill ' s current pulp production capacity
during the, permit term, unless this can be done in a way
that also "reduces color loading. " Since the Mill will be
purchasing dry furnished pulp to supplement this
improvement, and there will be no increase in the mill ' s
current pulp production capacity, the improvements to the
µ No. 19 paper machine meet the condition of the
,..:..: . aforementioned stipulation.
:In discussing this matter with Mr. Don Anderson,
Ff
q�. Chairman of the Technical Work Group, he agrees that .no
significant changes will occur in the quality of the
effluent with regards to color loading. He also agrees that
"' = these improvements are allowed under the settlement
agreement. .
y�«1 INTERCHANGE BUILDING, 59 WOOSi1N PLACE, AeHEYILLE, NC 21B601-2414
` PHONE O29-251-6200 FAX 9Z8-251.6452
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST-CONSUMER PAPER

Mr. Robert Williams
November 19, 1999
Page Two
If you have any questions concerning this matter,
please do not hesitate to contact Keith Haynes or me at 251-
6208 .
Sincerely,
Forrest R. Westall
Water Quality Regional Supervisor
cc: Don Anderson
Keith Haynes
N019IMP.LET

EPA I.D. NUMBER (copy from Item 1 of Form 1)
CONTINUED FROM PAGE 2 NC0000272
,V.'INTAl AND_EFFLUENT CHARACTERISTICS`° „` ' ' ;• t '; _ " a '
See instructions before,proceeding-complete:one,set of tables for each outfall-Annotate the outfall numbednthe.space provided.
Note:Tattles V-A,V-B,and V-C are included on seperate sheets numbered V 7 through V-9. `
D.Use the spac6below to list anpof the pollutants lasted In Tattle 2G3 of the instructions,which you knovhor have reason to 4elieve Is discharged or maybe.
discharged from any outfall For `rypolltanyo ,:briefi decrii"4h 'reasonsyo ti < analytical dafa in your e ttbe ray y ri F
.V ,
possession 3 ;_ `M
1:POLL'-USANT 2. SOURCE 1. POLLUTANT '2.;SOURCE
N/A
VI.'POTENTIAL DISCHARGES,NOT COVERED'BY•ANALYSIS '
a
is any,pollutant listed,in Item V-C'amsubstance or a component of a substance which you:currently use!or manufacture as ara,intermedlate or final product or,_-
byproduct? _
YES(fist all,_sugh.pottutants.below). X NO (go to,ltem 1t B)",
N/A Pollutant analysis is included with V-C
EPA Form 3510-2C (8-90) PAGE 3 OF 4 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT NCO000272
YVIL BIO�OGICALTOXICIT,.YTESTINO'D�AT-A
ij)6,youlhav I aa-1 idge&4asoh'to a hroni,�mAcitihas Seen--r;ad f
I re--iving wateiih relationto,yourdison'
arge Within theittest13 yeam?
YE9, bei NIO�(jo to seduon�vfil)'
(Adentihythe test(s)�and descilbetheirpuropse F
See Attachment V
VIIL CONTRACT ANALYSIS,INFORMATION '�u
Whene any of the analyses reported in Item V performed by a contract laboratory or
oultingfirm?
ih mamd,�ad?ess, and ta�je�hone;nufliber 6f,.and 001i"t hi�
j X� (#st a
by, each such-laboratory or firm below)
ALNAME B.ADDRESS C.TELEPHONE 0. POLLUTANTS ANALYZED
- 1 4"
a co ;& I
(q.re . d6 no) (list)
8540 Baycenter Road [phone] Adl 2C Analysis except Dioxin, Mercury
Columbia Analytical Jacksonville, FL 32256 and self monitoring
Brooks Rand 3950 6th Ave NW
Seattle,WA 98107 [phone] r%Aercury
Severn Trent Laboratories 880 Riverside Parkway
West Sacramento, CA 95605 [phone] C)ioxin
IX CERTIFICATION:
I oertify,uncler,pen�lty,of la,W that thls�dQoumeht andlali� achments wereil"pared under,my-
dinection or superyis'lon in aocordan,:6,'� a syst. d -dt
".Ptt' *ith, erq, eiqne,. 0
assure that qualified,personnel,0roperly gather and,
eva[uatethe informat16n,submitted.Sased,on my inquiry of the jperson or perOnemho manage ttiesysiann",
those persons diredly responsiblejorgathering the information,the infounationrsubmitted fs,�to the best ormy k'novAedge and belie-!t f,',true,awurate,'ind cornplate.
I am aw6ra thatthereare significant Penalties fusubmiffing false information in ludin t ep sbil ovving,violations:
C g h os i lt;of fine and'imprisonment for'!
A. NAME AND OFFICIAL TITLE (type orprint) B. PHONE NO.(area coi &no.)
Robert Cicale-Vice President of Manufacturing and Mill Manager [phone]
C.S D. DATE SIGNED
EPA Form 3510-2C(8-90) PAGE 4 OF 4

tFA LU.INUMNtK(Copy fmm[[am 7 of f-erm 7 )
PLEASE PRINT OR TYPE IN THE UNSHADED AREAS ONLY.You report some or all of Form Approved.
this information on separate sheets(use the same format) instead of completing these pages. NC0000272 OMB No.2040-0086
SEE INSTRUCTIONS. Approval expires 7-31-88
nor
OUTFALL NO.
V.INTAKE AND EFFLUENT CHARACTERISTICS(pontinued from page 3 of Form 2-C)
PART A :Yowmust provide the results of at least one analysis for every pollutant in.this table Complete orie table for:eacluoulfall. See instructionsioi'.add-Atonal details`- _. __,.._._ _`_ _ _..._
001
- 2.EFFLUENT 3.UNITS: d:INTAKE optional:
1.POLLUTANT .'- a.MAXIMUM_ DAILY VALUE,' b.'MAXIMUM 30 DAY VALUE ci LONGTERM AVRG.VALUE ` ^ "' *-7s�tlyAblsnkj: •:_ a.'LONG°TERM
` (4amUamej (ifayallawa) - d.NO.OF - _ AVERAGE VALUE - b.`NO,OF
(1)' (1) (21 MA55: ANALYSES a.CONCENf bMA6a (1) - _ ANALYSES
(2)MASS (2).MASS 2)MASS CONCENTRATION CONCENTRATION - _._ TRATION. CONCENTRATION
a.8iochemt6al.Oxygen'' 36.2 8,761 10.98 2,299 6.68 1,386 1096 mg/1 Ibs/day
'Demand(BOD) -'
b.Chemical Oxygen 480 54,467 256 52,326 118 24,498 49 mg/l Ibs/day
Damand,(COD)
c Total Organic 33.2 7141 33.2 7141 1 mg/1 Ibs/day
Carbon'(TOC) '
d;Total Suspended 86 19,771 24 4,999 14.98 3,099 1096 mg/1 Ibs/day
SO*(fSS)
e.Ammonia(as N) 4.12 1,049 0.77 179 0.267 55.36 1096 mg/1 Ibs/day
VALUE VALUE VALUE VALUE
frFlow 58 27.93 24.87 1096 MGD
` VALUE VALUE VALUE VALUE
g.Temperature 33.6 31.3 29.8 92
(winter) °C
? VALUE VALUE VALUE VALUE
h.Temperature. .. 38.7 36.4 36.0 92 °
(summer) c
-- MINIMUM MAXIMUM MINIMUM MAXIMUM -
�'i:.PH- 7.3 8.4 7.68 7.92 366 STANDARD UNITS ,.
PART @,.-` . Mark"X"in columrf2-a for each pollutant you know or have reason to believe is-present.Mark'X"in columnrZ-b for each,pollutant you believe to be absent If you mark column 2a for any pollutant , «
which is lim0ed eithendireclly,.or lndirectlybutexpressly,in an effluent limitations guideline,you must provide the results of at least one analysis for that pollutant.For other pollutants for which you mark
columd,2a,you must.provide quantitative data or an explanation of their presence in your discharge,Complete on table for each outfall.See the instructions for additional details and'requirements.. '
I.P.OL^LUT- -2"MARK'W' 3.EFFLUENT _ _ « ^ " 4 t1NITS - „' S.INTAKE(Options -
^ ANTAND' eleE -b.BE- a..MAXIMUM DAILY VALUE b.MAXIMUM,30 DAY VALUE c.LONGTERM AVRG:VALUE rspeayueranx) s.LONGTERM - --
G�SNfl `l1EVEQ t1EVEU = _ ( aYalla4 ) _ (raYai(ouly =A t1D,QP = ;PVERAGEvpLUE b..No OF
(IavaJabre) PRE- (1) (1)° - (1). - 'ANALYSES a.CONCEN (1} ANALYSES
(2)MASS - (2)MASS -I2)MASS - b,MASS `(21MASS -
.:,,`- SENT ABSENT CONCENTRATION ;, CONCENTRATION CONCENTRATION - TRATION,,. -, CONCENTRATION
^
a'Biomde I X <0.2 ND 2 mgll
(24959-67-g)
b.Chlori(ie X*see V-9
Total Residual'
c.Color`- X 425 89,403 256 58,009 210 43,382 366 mg/I Ibs/day
d.'Fecal '- X 110 17 10.63 49 N/100 ml
Coliform.: .
e Fluodoe X 0.34 61.11 0.17 31.49 2 n ll Ibs/day
(16989�48-6j `
t.Nitiate- X <2.0 ND 2 mg/I
Nitnte.(asN
EPA Forth 3510-2C(Rev.2-85) "PI aalimdm Cobalt Units NO=Non-Detect PAGE VA CONTINUE ON REVERSE

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tFALU.NUMbLK(Cepyrrpm Item i OF Feml TJ UU I VALL NUMOtR
Form Approved.
OMB No.2040-0086
CONTINUED FROM PAGE 2 OF FORM 2-C NC0000272 001 Approval expires 7-31-88
PART C- u If you are a primary Industry and this outfall contains prxess wastewater,refer-to:Table 2c-2 in the instructions to determine.which of the GCIMS fractions you-must test for.Mark"X"to column - -
- 2•a.for all such.GC(MS fractions that apply to your,industry and focALL loxfc metals,cyanides,and total phenois.If you are not required Je mark column 2•a(secandarylndus(nes;ngnprocess
wastewater outialls,iand nonrequired GCIMS fractions) mark'X;in column'2=b_7or each pollutanty bknow or have reason to bellave is presenit Mark'X'in coluhIffic for each p646f,you
'.:.,believe is absent.Ifyou mark column 2a,for anypollutanL you must provide ihe,regults of at least one analysis for that pollutant.If you mark column 2bfor any pollufanL You(inust prpvideiheresults, ,x '+of at least one analysis for that pollutant of you know ochave reason to believe it will be discharged in concentrations pf 10 ppb,or greater.gyou mark column 2b'for acrolein,scrylonnrlel2,4
Einftmphenol,dr2-methyl-4,6 dinitrophenol,you must provide,me results of.at least one analysisforeach of these pollutants which you know or have reason tolbelieve that you discharge,in
concentrations of 100 ppb orgreater.Otherwise,for,poll utantsfor which you mark;column2b,:ydu must either submit at least one analysis or briefly describeffie reasons the,Pollutant is expected to
be discharged.;Note that there are.T pages to this part:please review eachearefuuy,Completeone fable(all.7pagesiJor each ougail.See'instructions for additional decals and requirements. .,
`1.POCLUTANTs 2 MARK"aC'. _' "' - 3:EFFLUENT . ,•4.`UNITS.. S,INTAKE(optional)
. .AND.CAS I', afEST b 8E=. +'aeE• a,MAXINIUMOAILY VALUE "' b.MAXIMUM 30 DAY VALUE " 1c"LONG TERMAVftG:NALUE �: `,Ya• • a LONGTERM
NUMBER—, 'ING UEVEu uEVEtl'' _ Craw#a61e) a' (tlavenabfe). "' d.NO-OF AVERAGEVALUE - b.f5a &'.,,
(lava,laNe) RC-0UIR- PRE` A& if} ANALYSES a.CONCEN- b:MASS , ' (t) . - ANALYSES
QU $EM .$ENT CONCENTRATION (2)MASS CONCENTRATION �) S' CONCENTRATION (2)MASS TRATION - CONCENTRATION {2)MASS _ -I
METALS,CYANIDE;AND TOTAL PHENOLS -
tMrAntimony X <0.005 ND 2 mg/I
Total (7440 36-0)
2M.Arsenic,Total X 0.009 1.62 0.0088 1.63 2 mgll Ibs/day
(7440-38-2)
3M.Beryllium, , X <0.003 ND 2 mg/I
Total(7440-41-7)
4Calmtum " X <0.01 ND 2 mgll
Total(744047 g)
5M:;Chromium,a X <0.005 ND 2 tng/I
Total,(7440-47-3),
8M.Copper,Totalf
X <0.005 ND 2 moll
7M Lead Total X <0.002 ND 2 mg/I
(7439-8271)- .
bm..Mercury total] X <0.2 ND 24 ug/I
0M.Nickel Tofel t X 0.0063 1.1 0.0032 0.59 2 mgll
M.Selenium, X <0.005 ND 2 moll
Total.CT782-49-2Y!
11 M.Silver Tatar. X <0.001 NO 2 ri
12M.Thalilum, X <0.002 ND 2 moll
Total.(7440-2801)
10M,Zinc Total '' X <0.02 ND 2 mg/I
14M.oydmde X <0.01 ND 2 mg/1
To((67.12
iSM.Fhenvls,' i X <0.01 ND 2 mgn
Tgtat
DIOXINS � ,: • . -•- -
2,3;78Tetm ..... DESCRIBE RESULTS
chlorodibeLz P = X All data for permit term were non-detect 0ess than the detection Iimit of 10 pgn)by Method EPA-15 1613A.
DIox1n(1764-tit fi)
EPA FORM 3510-2C(Rev.2-85) PAGE V-3 CONTINUE ON REVERSE

GUN I INUFU FKUM I MF FRUN I NGUUUUZ/Z
1.POLLUTANT 2.MARK'X" :_t9. -` 3..EFFLUENT - -_A.UNITS. 5.INTAKE(optional
AND CAS _
T
EST
- o;BE' - - - -a.MAXIMUM DAILY VALUE- bi MAXIMUM,30,DAY VALUE c LONGTERM AVRG:VALUE -- a.LONGTERM
NUMBER fKG 1 6 iLIEVEa _ .{davanaale). . (dare6amo). . d.NO.OF AVERAGEVALUE 'b-NO,OF 1
'Oa uaore), REOUIR. PRE-:�MBv - r .:-it) :- (1), 11!"` - ANALYSES a.COtLGEN- 4, MASS .`ro(i 'ANALYSES
''(2)MASS• (2)MASS R)MAe9 - •• ,•.",l tMSS
- 'Et) SENT „SENT CONCENTRATION - CONCENTRATION CONCENTRATION ,' TRATION - CONCENTRATION -', "�
_
GCIMSFRACTION-VOLATILE COMPOUNDS
1V.Acrolem X <25 ND 2 ug/l
(107;02-8).
2V.A#yfortilrile(107-13-1) X <8 ND 2 ug/I
3V.Benzene X <7 ND 2 ugfl
(71-43-2). , .
4,V!BiS((Ptr1010-
methyl}'Ether
(542-88-1)
5V..Bromof6mn X <1 ND 2 ug/1
eV;Carbon
Tetrachforl8e X <1 ND 2 ugfl
(56-23-5).
7V.Clilarobenzene X <1 ND 2 ug/1
BV:.Chlorod(
bromorn hane X <1 ND 2 ug/l
(12448-1)
9v.Chloroethane X <1 ND 2 u9/1
(75.O0 3):
IOV,2+Chlam-,
ethylviny(Ether X <1 ND 2 ugh
(110-75-8).
I IV.Chloroform. X 1 0.191 1 0.185 2 ug/1 Ibs/day
(67-6&3y,-.
12V.Dichloro=
bromomethane X <1 ND 2 ug/l
(75-27-4j
[ehane
Dichtoro
ororne[hane ` X <1 ND 2 ug/1
71'i6,
1;j-Dichloro- X <1 ND 2 ug/1
ethane
2-Dichloro- X <1 ND 2 ugfl
-(1p7c06-2)j;� tGjl�Oi X <1 ND 2 ugfl
ethylene(75,354),
17V.414chl0ro; ' X <1 ND 2 ugfl
propane
18V.t; awhm- X <1 ND 2 ugfl
PmFylen(542-75-6),
19V.Et'hylbenzeriei X <1 ND 2 ugfl
2oV.Methyl X <1 ND 2 Ug/1
Bromide(74-83-9)
21V-Metjlyl - X <1 ND 2 ugfl
Chlonda.(/4 87-3)
EPA FORM 3510-2C(Rev.2-85) ND=Non-Detect PAGE V-4 CONTINUE ON PAGE V-5

ern W.NUMCeN(copyn-am rem T or rorm Ty UU I DHLL NUMULK
Forth Approved.
NCOOD0272 001 OMB No.2040-0086
CONTINUED FROM PAGE V-4 Approval expires 7-31-88
L;POCLUTANT'3 - 4:!MARK°X r ., .. _ ..:_ __ ...- =-..3:.EFFLUENT .. ._ `".. - , -. _. 4'.UNITS` r^ 5.`INTAKE,(o eanap
AND CAS " a:TEST- b.8E- c eE- a..MAXIMUM DAILY:VALUE .b.MAXIMUM 30 DAYVALUE !a LONG-TERM AVRG.VALUE --- - - "-- a.LONG-TERM
NUMBER n ING uEVEo LIEVEO ,' _` `(raveilable) fravePabra) =._ d.NO.OF' ' AVERAGE VALUE- b,NO,OF
((ayallablej REOUIR [,P,(RE-;i- AB '(A). ``R}MASS f1} z- (2j`MAS9 (Q ,S (2}MgSSr ANALYSES a.CONCSN b.MASS "v .4'll > � ' (2),iMAS5,` ANA},YtiS.
EO -SENT'' SFNS CONCENTRATON _.. CONCENTRATON -_ ;CONCENTRATO'N - '" TRATION=,.� - CONCENTRATION
GC/A75',.FRACTION-VOLATILE COMPOUNDS'(eontinueco -- '-- - - - - -" -
22V,Methylene, X <5 ND 2 ug/I
ChlonAe.(75-09.2)
23V„1 1,2,2-Tetra;
chlcmethene X <1 ND 2 ug/I =
79-34-5)
24V Te�fachlorar` X <1 ND 2 Ug/1
ethylene,(127-18-4)
25V.Toluene X <1 ND 2 Ugll
(108-88-3)
26V,1i2-Trans- `!
Dldlitoroethylene X <1 ND 2 ug/1
(156-60-5)
27V,1111 TrI
chloreethane. X <1 ND 2 ug/I
p155-S) .
28V.1.1,2-Tri-
Chloroethane.. X <1 ND 2 ugll
ps°BDs>
29V.'J" loro- - X <1 ND 2 ugll
ethylene(79-01-6)
30V.Trichlom-
8uoromethane X <1 ND 2 ugll
(75-6 ,4).. ..._
im Vinyl X <1 ND 2 ugll
GCUbS FRACTION `ACID COMPOUNDS
IA.2-Chlorophenol X <5 ND 2 Ug/1
2A.2;4-t)ichlora X <5 ND 2 ug/I
phenol(420 83 2)
m.2'4-0lmethyl- X <5 ND
phenoE(105-67-9p=; 2 ugll
4A.4nitro-0 X <20 ND 2 ugll
Cresoli(534-52-1)
a�r�)gv)Fliu� X 420 ND 2 ugh
phenol(51 28;5)
6A.2-NHroplienol.- X <5 ND 2 Ug/1
7Ai4-NtropherinLl X <20 ND 2 ug/1
(to002-2)
BA.P-,Chloro-M- - X <20 ND 2 Ugn
Cresat(59-50-j) -;
9A.Pen achlonr: X <20 ND 2 Ug/1
phen6t(87-86-5) :s
10A._P ienol ' X <5 ND 2 Ugl1
(108-05-2)
11A.2;4,6-TrF r
chlorophenol X <5 ND 2 ug/l
EPA FORM 351 U-2C(ReV.2-85) ND=NDR-Detect PAGE V-5 CONTINUE ON REVERSE

1 POLLUTANT " 2.MARK W' - '3.EFFLUENT- - '- - '� _ " '- _ "4.:UNITS '" "" -5'.INTAKEi(o tionalJ - -"
AND CAS a TEST. e.eE= a eE- a.MAXIMUM DAILY VALUE b',MAXIMUMi30 DAY VALUE"" e.LONG TERM AVRG.'VALUE '- a.LONGTERM. -
•:NUMBER' `:ING LIZ". UEBIEO -' filaGSllzbre} (uarairabref - d.NO.OF � '��. _ -AVERAGE VALUE 1'ti`NO.OF-:,
(lai-miable). REOUIR PFE, Aa - (1l - (i} '- - (1) ANALYSES a.CONCEN- b.MASS (l) - ANALYSES
(2)Mass (2)Muss (2)MAW - - -- (z),�uss ,.
FD SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION TRATION - �CONCENTRAT1dN
GC%MSFRACTION-BASEINEUTRAL COMPOUNDS
1B.Acenaphthene X ... - <5 NO - ;.. .. 2 ugll "
83-32-9
28.Acenaphylene• X <5 NO 2 ug/l
(208-96-8)
W.Anthracene X <5 NO 2 ug/I
120-42-7). .
4B.Benzldlne,e
9 2-87-5) X <20 NO 2 ugll
5BiBenzo:(a):-
nthracene" X <5 NO 2 Ug/1
(56-65-3)
6B.Benzo(a) - X <5 NO 2 ug/l
F,Yre,n,e(5032.6):
7B:3)4-Benz6
floumntnene X <5 NO 2 ug/I
(205-99-2).
BB,aenzo(gfii)_
Perylene X <5 NO 2 ugll
(191-24-2) -
9B:-Benzo:(k):.'
Flouranthene` X <5 NO 2 ugn
207-06-9
1OB.,Bis:(2-Chlam-
etfiozy),,Methane X <5 NO 2 ug/l
(11 Y•91-1)
11 B.!B13(2-CAlorp
ethyQBbher ,. X <5 NO 2 ugll
(111-44-4) -
12B.Bis,(2-Ch(alo-
Isoprepyi)Ether X <5 NO 2 Ugll
(102..'60-1)
13B.,Bis(2-Chtoro-
ethyll Phthalate:.. X <5 NO 2 ug/I
1 f7=84.7
14B:.4-Bromo-`
pheRyI,Pheny(_ X <5 NO 2 ugll
Ether(101-55-3).
15B,Butyl Benzyl'
Phthalate 65-6e-7 X <5 NO 2 ugll
napthe,le,ne X <5 ND 2 ugll
178;4=,Chloro-"
ptenyfPhenyl X <5 NO 2 ugll
Ethel,(700572J)
16B.Chrysene -' X <5 NO 2 ugll
(21B-
1 BB.Dibenzo PIP)
nth Gene X <5 NO 2 ugll
(63-70-3
20B..1,2-Dichtoro- X <5 NO 2 ugll
benzeie(95=50-1).
21B:1;3-Dichloro= X <5 NO 2 ug/l
benzene. 541-73-1
EPA FORM 3510-2C(Rev.2-65) NO=Non-Detect PAGE V-6 CONTINUE ON PAGE V-7

,.e.nmr,ern PuPy nem nem,mrvuu,� ,muu numuo�
Form Approved.
NC0000272 001 OMB No.2040-0oe6
n
F
CONTINUED FROM PAGE V-6 Approval expires 7-31-88
}:POLLUTANTr1INGT]
` 2.MARK"X' -- — - -� -- 3..EFFLUENT -- - -' - - - - - - _-'-4.UNITS'_ -" 5;.INTAKE(op6onao
AND CA_S'. ES 6.9E-` a BE- a.MAXJMUM DAILY VALUE b7MAXIMUM 3t7DAY VALUE- o.LONG TERM AVRG.VALUE: - . a.LONG'.TERM'
NUMBER uEVEo UEVEO =a;� 9lavdllab}e) .ip(evauable)r d..M OF ?+ AVERAGEVALUE a' b NO.OF -
(favalable) �UIR PRE- A6 -(1) (1) - (1}; -" ANALYSES 'a.CONCEN- ti;;MASS 6(1) - ANALYSES'.
EO SENT 'SENT CONCENTRATION (2)MASS CONCENTRATION ITj MASS CONCENTRATION (2)W� - TRATION 'CONCENTRATION (2)hj!SS
GCIMS FRACTION-BASEINEUTRAL COMPOUNDS!(coaffnueog!
228.1,4-Dichlor X <5 ND 2 Ug/l
benzene(106-46-7)'
23B..3,3'-Dichlor
benzidlne X <20 ND 2 ugll
e1-94-1)
2413.Methyl
Phthalate X <5 ND 2 ugll
(84-66-2).
25B Dimethyl."
Phthalate X <5 ND 2 Ug/I
(131:11-3)
26BC_DpN-Butyl
Phthalate X <5 ND 2 Ug/l
e4'-74-2)
27B,2;4-Dinitro X <5 ND 2 Ug/l
toluene(121-14-2)
288,,2;6-Dinitro4; X <5 ND 2 ug/l
toluede(608-20-2)
29B.01-N-Octyl.
Phthalate X <5 ND 2 ug/l
(117.84-0)
30e rg-0lpnedyc
hyd} one(asP , X <5 ND 2 Ugll
bgmi,ne)(122N&7)
318.Fluorathene X <5 ND 2 Ug/I
(206-44-0
32B,.,Fluorene X <5 ND 2 ugll
33B Hexachloro- X <$ ND 2 Ugll
benzene:(116-74.1)
34B:Hexe-
chlo6obutadiene. X <5 ND 2 Ugll
je7-se-3)
35B:.Mexachloro_-.-
cydopantadlerie °� X <5 ND 2 ugll
(77-474)
36Bk Hexacnlorq X <5 ND 2 ue n
elfiag2�67�17v1) :
378:Indeno - -
(1,2,3_ed)Pyrene X <5 ND 2 ug/l
(193.39-5
r41BN
pKarone X <5 ND 2 ug/1
)
phthalene; X <5 ND 2 Ugll
)
robenzene X <5 ND 2 ug/l
Nitro-
hylamine(52 X <5 ND 2 ugll
428.N-Nitrosodl-N1
Propylemina. �- - X <5 ND 2 ug
s21-64-7 _
EPA FORM 3510-2C(Rev.2-85) ND=Non-Detect PAGE V-7 CONTINUE ON REVERSE

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NC0000272 001 OMB No.2040-0086
CONTINUED FROM PAGE V-B I Approval expires 7-31-88
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EPA FORM 3510-2C(Rev.2.85) PAGE V-9
ND=Non-Detect
footnote from page V-1
*One of the two secondary effluent priority pollutant scans showed a 0.05 ppm concentration for residual chlorine. The second scan resulted in a non-detect at 0.01 ppm.
BRPP has evaluated this reported residual chlorine result and,in consultation with NCASI,does not believe residual chlorine can exist in our effluent.
This is based on the very reactive nature of chlorine,which readily combines with all elements except rare gases and nitrogen(source:The Merck Index,111h edition).
In addition,Standard Methods,18th-20th editions,states known analytical interferences(organic matter)with the colodmetdc method used for our type of wastewater.
Therefore,"Believed Absent"is checked for residual chlorine.

Attachment V
Quarterly Chronic Toxicity Data
NC0000272
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

NPDES Permit Renewal Application
2C-Atttachment V
Summary of Historical Toxicity Data from 1998 -2000
Results of 7-Day Ceriodaphnia Survival and Reproduction
No Observable Effect Concentration (NOEC)
Sample Date NOEC % Effluent
3/23198 100
6/8/98 100
9/7/98 100
12/14/98 100
3/8/99 100
6/14/99 100
10/14/99 100
12/6/99 75
12/28/99 100
2114/00 100
3/10/00 100
6/5/00 100
9/11/00 100
12/11/00 100
Testing performed by Burlington Research Laboraoty
1302 Belmont Street
Burlington, NC 27215-6935
[phone]
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC
NC0000272

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON,D.C.20460
J��S£O STgTt•S
�iFyTq(PRd3£G�O=
MEMORANDUM
DATE: DRAFT May 4,2001
SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue
Ridge Paper Products, Canton, NC
FROM: EPA Tech Teaml
TO: Technology Review Work Group
Purpose of this Analysis
This memorandum responds to a request made by the Technology Review Work Group for
analysis of available technologies that may be employed to further reduce color discharges from
the Blue Ridge Paper Products mill in Canton,NC. Available technologies are defined as those
that are both technically and economically feasible,therefore this memorandum includes a
summary of the analysis of the economic impact of the implementation of identified color
reduction technologies.
Background and History
Blue Ridge Paper Products, Inc. (BRPP) operates a bleached papergrade kraft pulp mill in
Canton, NC,which it purchased from Champion International Corporation in May, 1999.
Operations at the mill began in 1908, but the mill has been extensively modernized since start-
up. The mill currently operates an 800 tpd hardwood pulping line and a 600 tpd softwood
pulping line. After cooking, pulp from each line is further delignified in single-stage oxygen
I EPA Tech Team is comprised of Mark Perez,EPA/EAD;Karrie-Jo Shell,EPA Region 4;Don Anderson,
EPA/EAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,subcontractor to
ERG.

Draft Memorandum
May 4, 2001
Page 2
delignification systems installed in 1993. Hardwood pulp is subsequently bleached with a DEoD
sequence; pine pulp is bleached with a DEopD sequence. Target brightness is 85 ISO. Up to 80
percent of the filtrate flow from the pine bleach line is returned to the recovery cycle using the
unique bleach filtrate recovery (BFR:")process,developed by Champion. A portion of the
hardwood line bleach plant Eo-stage filtrate flow is also recovered. BRPP produces 250,000
tons per year of uncoated paper including offset,tablet and envelope grades. The mill also
produces 281,000 tons per year of paperboard used for liquid packaging and paper cups,
including FDA approved grades for milk and juice cartons.
Continued Color Reduction Since the 1997 NPDES Permit
The Canton Mill's 1997 NPDES permit included a schedule requiring continued study,
evaluation, and pursuit of effluent color reduction. Champion and BRPP submitted a series of
reports to the NC Department of Water Quality evaluating the performance of the BFRrm
process, end-of-pipe color reduction technologies, and practices for minimizing color losses from
manufacturing processes. Since 1997 BRPP has:
• continued full-scale operation of BFR for the pine line;
• concluded that full-scale BFR is not feasible for the hardwood line,but implemented
partial reuse of a portion of the Eo-stage filtrate as an effective color-reduction approach;
• identified and implemented several practices for reducing losses of highly-colored black
liquor from manufacturing processes;and
• evaluated 16 end-of-pipe color removal technologies and determined that they were
presently economically and/or technically infeasible for the Canton mill.
Process Improvements Analyzed by the Tech Team
The Tech Team identified five mill improvements capable of further reducing the discharge of
color in the mill effluent. For each of these improvements, technical feasibility, capital and
operating costs and potential color reduction were reviewed. Each improvement can be
implemented independently of the others or in any combination, and the color reductions
achieved and costs incurred are additive. End-of-pipe color control treatments are typically not
economically feasible because they require initial capital investment and ongoing operating
expenses, not savings. For this reason, the Tech Team focused on potentially cost effective
approaches: color reduction in low flow,highly color concentrated wastestreams,through
manufacturing process changes or in-process treatment.

Draft Memorandum
May 4,2001
Page 3
Process improvements one and two, listed below, are improvements also identified by BRPP as
feasible color reduction opportunities. Process improvements three through five, identified by
the Tech Team, have the potential for additional color reduction. Additional technical review
and/or laboratory testing is required, however, to reliably determine technical feasibility of these
processes and to predict their achievable color reduction. All color reductions resulting from the
mill improvements are estimates based solely on available data and information. While the Tech
Team has identified that these technologies would reduce the color discharge from the Canton
mill,there is a lack of directly comparable operating experience with these technologies in other
bleach papergrade kraft mills that can be used to develop precise predictions of the extent of the
benefits.
1. BFR reliability improvement. A key element in BFR is the Metals Removal Process (MRP).
BRPP has found that this process element has been more challenging and expensive to maintain
than originally planned. Target BFR recycle rate (percent closure) for the pine line is 80 percent,
which is a lower rate of closure than originally planned. Due to equipment failures in the MRP,
however, from October 1998 to the present, the pine line closure has averaged only 74 percent.
BRPP has undertaken improvements to the MRP system in order to maintain closure rate and
maintain uptime. Improvements include rebuilding piping and valves, and changing construction
materials to better withstand the corrosive environment. BRPP estimate that if BFR closure is
maintained at 80 percent, annual average final effluent color discharge will be reduced by 1,000
to 1,200 lbs/day. At this time,the Tech Team has no means of making quantitative predictions
of final effluent color reductions to compare to BRPP estimates.
2. Improved black liattor leak&spill collection and control. The Canton mill has an extensive
spill recovery system. Sumps in this system are equipped with pumps that are activated
automatically when sensors detect wastewaters with high conductivity and thus also with high
elevated color. High conductivity material is routed to the recovery system. Further
improvements to the black liquor collection system include:
• 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;
• minimization of clean water that continuously runs into sewers to prevent dilution of
smaller spills and facilitate recovery of highly colored wastewaters; and

Draft Memorandum
May 4, 2001
Page 4
• improvement in the equipment used for handling of screen rejects to prevent black liquor
leaks into the recovery sumps.
The plot below shows the color of wastewater treatment influent at the Canton mill. The high
variability of color discharge is attributed to color peaks that represent unplanned spills or leaks
discharged to sewers or intentional diversions of highly-colored black liquor or other color
sources routed to sewers during mill equipment shutdowns.
100 .
kgft
75
50
25
Daily color at influent to W WTP for Canton
0 30 60 90 120 150 180
A comparison of the variability of the Canton mill color data and available primary influent color
data at another bleached papergrade kraft mill shows that, through improved planning of mill
equipment shutdowns, continuing efforts to minimize process operation variability, and
increased recovery of highly-colored leaks and spills, discharges of highly colored material to the
wastewater treatment system can be reduced, resulting in reduction in the average color
discharged from the mill.
Clean water, such as packing gland water, presently flows in several sewers with recovery
sumps. These colorless streams dilute other colored wastestreams, such as small black liquor
leaks and spills, to the point where the in-stream conductivity is too low to trigger recovery. By
eliminating clean water streams or diverting them away from sewers that collect black liquor
leaks and spills, colored wastestreams can be recovered more readily, resulting in a reduction in
primary influent color discharge. Also, the unintentional but continuous discharge of filtrate
from knots and screen rejects to the sewer can be recovered for additional reduction in primary
influent color discharge.

Draft Memorandum
May 4,2001
Page 5
A detailed review of the spill prevention and recovery system (by mill staff or external
consultants), including involvement by the mill operators, can uncover the causes of black liquor
losses and other color sources that can be avoided or recovered, resulting in an overall reduction
in primary influent color. For example, limiting the color of the primary clarifier influent to
70,000 lb/day(by eliminating color peaks and preventing highly colored flows from reaching the
wastewater treatment system)would reduce the discharge to the treatment system by 8,000
lb/day, equivalent to a 6,1001b/day decrease in the average final effluent color load.
For this analysis, the Tech Team estimated that improved black liquor leak and spill collection
and control could reduce final effluent color by more than 5,000 lbs/day.
3. Ozone/Chlorine dioxide stage for hardwood bleach line. Ozone is used in more than ten kraft
mills around the world to bleach pulp, including two in the US and one in Canada. There are
several process configurations, but the most common is to operate an ozone (Z) mixer and
reactor immediately upstream of a chlorine dioxide reactor, without any washing between the
application of the two chemicals. This is known as a"ZD"stage. A system of this type was
retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999.2 Bleaching with ozone on
the hardwood line, one of the Domtar mill's two pulp lines,resulted in a 27 percent reduction in
the discharge of color in the combined mill treated effluent 3
As of September 2000, the average color discharge from Canton's hardwood bleach line was
12,800 pounds/day4. The Espanola experience suggests that implementation of a ZD stage in the
hardwood bleach plant could reduce the filtrate color discharge by 3,000 to 6,400 lbs/day. These
estimates are based solely on the performance demonstrated at the Espanola mill and the Tech
Team's assumption of color sources at the Domtar mill. Laboratory bleaching trials are required
to reliably predict the technical feasibility of and achievable color reduction possible with this
option for the Canton mill.
4. 2ml stage OD for Dine line, with increased BFR closure. Oxygen delignification (OD) on the
Canton Mill pine line is a single stage system installed in 1993. The Tech Team concluded that
retrofitting a second OD stage for the pine line could contribute to reduced color discharges in
two ways. The first would be a reduction in color for those filtrates presently not captured and
2 Munro,Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching Sequence,Tappi,2000.
3 Ibid.
4 Jacobs Engineering Group,2001 Color Removal Technology Assessment,February 2001.

Draft Memorandum
May 4, 2001
Page 6
reused in the BFR process. The second would be to facilitate increased recovery(BFR recycle
rate) of the pine line bleach plant filtrates.
The Tech Team estimated the cost of a reactor with oxygen mixer and chemical charge
equipment installed upstream of the existing reactor. The new two-stage OD system would
reduce pulp kappa (lignin content) into the bleach plant from 32 to about 11. Pine is typically
cooked to kappa 30, but the Canton mill presently cooks softwood pulp to approximately 24
kappa, in part to minimize color generation when removing remaining lignin in the incoming
pulp in the downstream bleaching process. OD is more selective in lignin removal than
conventional cooking, therefore by increasing the kappa number of the cooked pulp from kappa
24 to 32 and allowing the two-stage OD system to reduce kappa from 32 rather than 24, an
overall gain in pulping yield of 1.5 percentage points or more can be achieved. By decreasing
the kappa number of the pulp fed to the bleach plant from kappa 16 to 11 with a two-stage OD
system,the quantity of chemicals required in the first two stages of the bleach plant can be
reduced, because there is less lignin present in the incoming pulp to remove by bleaching. The
quantity of color released from the bleach plant will be reduced in proportion to the reduction of
the input kappa number.
Approximately 80 percent of the pine line bleach plant filtrate is recovered by the BFR process.
The principal limit on the efficiency of BFR recovery is the quantity of bleach plant filtrate that
can be reused in the upstream pulp washing system and ultimately recovered. A benefit of the
reduced chemical charge, as a result of additional reduction of incoming pulp kappa with a two-
stage OD system, will be a reduction of 50 gpm water presently used to carry chlorine dioxide
into the pulp. In addition, with the reduced amount of bleaching required with two-stage OD, the
volume of wash water used on the Do and Eop stages may also be reduced. With a lower bleach
plant filtrate volume, it may be possible to use an increased proportion of filtrate in the upstream
pulp washing system. Based on the above, Do and Eop bleach plant filtrate volume could be
reduced such that 90 to 100 percent of the reduced-volume filtrate could be recovered. The
increased percent BFR recycle would result in a decrease in color discharged to the sewer.
Based on a BFR efficiency increase to 93 percent by this modification, the reduction in pine line
bleach plant filtrate color discharge would be 1,950 lb/day. For this analysis, it was estimated
that a second OD stage could reduce pine line bleach plant filtrate color discharge by 1,500 to
2,000 lb/day. A thorough review of the technical feasibility of increased BFR closure rate with a
second-stage OD system is required to reliably predict achievable color reduction possible with
this option for the Canton mill.

Draft Memorandum
May 4,2001
Page 7
5. Color Precipitation of CRP purge stream. The Chloride Removal Process (CRP) purge is a
low flow, highly concentrated waste stream. Color is typically 50,000 pcu, in a 10 gpm (0.01
MGD) flow. The CRP purge contributes approximately 6000 lbs/day(16 percent)to the total
mill color discharge,but only 0.06 percent of the discharge flow.
The Tech Team originally speculated that it may be feasible to reduce the color in this stream by
precipitating the colored organic material with lime at a dosage of 20 g/L5, and burning the
resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials
would be required to test the feasibility of color removal from the CRP purge stream by lime
treatment.
BRPP subsequently conducted laboratory trials of color precipitation using four calcium
compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The
preliminary results of these trials show that at a dosage of 20 g/L, none of the compounds tested
reduced color in the CRP purge stream. Although color removal was demonstrated at higher
dosage rates, increased chemical usage would result in substantially higher operating costs,
require larger size equipment at higher capital cost, and also result in a higher production rate of
sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not
burned must be landfilled at additional cost.
Based on preliminary laboratory trials, BRPP concluded that lime treatment of the CRP purge is
not a feasible color reduction option for the Canton mill. However, the Tech Team recommends
additional review of other innovative technologies for color precipitation of the CRP purge
stream. This stream is a highly-colored, low-flow stream that contributes roughly 16 percent of
the total primary influent color discharge. By minimizing color contributions from this stream, a
reduction in primary influent color discharge of up to 6,000 lbs/day is possible.
Color Reduction Summary
The Tech Team estimates that by improving BFR reliability and black liquor leak and spill
collection and control, the Canton mill final effluent will be reduced by more than 6,000 lbs/day.
Additional potential mill improvements to reduce color discharge at the Canton mill were also
identified. These process improvements require further review to determine technical feasibility
5 NCASI Technical Bulleting No.239,The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching
Effluents with Lime.1. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970.

Draft Memorandum
May 4, 2001
Page 8
and predict achievable color reduction. These improvements include implementation of a ZD
stage in the hardwood bleach plant, with a preliminary estimate of a 3,000 to 6,400 lbs/day
primary influent color reduction, and a second OD stage for the pine line bleach plant, with a
preliminary estimate of a 1,500 to 2,000 lb/day primary influent color reduction.
Additional review and implementation of available color removal technologies for the CRP
purge stream could result in additional primary influent color reduction up to 6,000 Ibs/day.
Economic Analysis
The estimated capital and operating costs for the process improvements one through four are
summarized below.
Table 1: Estimated Costs
Process Improvement Capital Cost Annual O&M
$) ($/ ear
1 BFR reliability improvement
2 Improved black liquor leak& spill collection and $100,000 $50,000
control
3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000)
line savings
4 2 Id stage OD for pine line,with increased BFR $2,000,000 ($3,100,000)
closure I savings
BRPP was formed in May 1999 when Champion International Corporation sold its mill in
Canton,NC, its converting facility in Waynesville, NC, and its DairyPak liquid packaging
business. BRPP is a corporation created by KPS Special Situations Fund, L.P. and the
employees who worked in those facilities. EPA collected financial data about the Canton,NC
mill when it was under Champion ownership as part of the previous NPDES permit renewal
process. The change in ownership,however, completely changes the financial basis for the mill.
BRPP provided EPA with confidential financial information in 2001. As described above,the
Tech Team estimated the costs of several mill improvements. EPA economists used these
estimates along with the BRPP financial information to analyze the effects of incremental
pollution control, as recommended in Worksheets H and I in Interim Economic Guidance for
Water Quality Standards: Workbook, EPA 823-B-95-002, March 1995. Results of the analysis
are pending additional clarification of financial information submitted by BRPP.

References
Blue Ridge Paper Products, Inc. Canton Mill Canton Mill Environmental Performance Update,
Prepared for U.S. EPA Technology Review Workgroup. March 14, 2001.
Jacobs Engineering Group, 2001 Color Removal Technology Assessment,Blue Ridge Paper
Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001.
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence,Proc. International Bleaching Conference, Halifax, Canada,2000. TAPPI Press.
NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of
Pulping and Bleaching Effluents with Lime. L Treatment of Caustic Extraction Stage Bleaching
Effluent. July, 1970.
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry. Page 182
Wiley Interscience, 1986.
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry, 3'd edition.
Page 286. TAPPI Press, 2000.

Appendix 1: Color Balance (9/1/00 to 12/31/00)
Figure 2.6, Presented by BRPP on March 14, 2001
Sewer Description Color Load
ID bslda )
213 Digester area sewer: Digesters, HW 4,323
line, knot rejects
3A Alkaline sewer: Pine and HW Eo, 12,954
Pine line BSW, 02 Deli
1 PMs11 & 12, HW weak liquor tank .1,991
513 Recovery, BLOx, CRP* 7,852
6A Acid sewer: Pine and HW D1 17,345
filtrate+Pine D2 filtrate
Contaminated Condensate 1,591
Combined Condensate 260
Total 46,316
IEPrimary Influent (PI 49,284**
Unaccounted Color Z968
PI minus Total
Secondary Effluent 37,696
Percent Removal in Treatment 23 %
* CRP contributes 5,000 to 6,000 ppd to 5B sewer
** Measured using test method in NCASI Tech.Bull.803,An Update ofProceduresfor the Measurement of
Color in Pulp Mill Wastewaters,May 2000.

Appendix 2: Table of Effluent Color Limits, 1997 to Present
Colm-Lisrit True Color Qbs/da
Monthly Average Annual (Long-term)
Average
1997 Permit 125,434 98,168
Settlement Agreement, February 1998 69,000 60,000
(starting December 1, 1998)
Settlement Agreement, February 1998 --- 48,000 to 52,000
Ultimate Target)
Interim Limits, May 2001 55,000 48,000
r
e As recommended by Technology Review Workgroup(TRW)

Appendix 3: Ozone Bleaching
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.

Appendix 4: Two-Stage Oxygen Delignification
Comparison of one- and two-stage oxygen delignification systems
Item Current Single-Stage System Pro osed Two-Stage System
-Oxygen Reactors One two
Input Kappa Number 24 32
-Output Kappa Number 16 11
Yield increased by 1.5%
Total C102 Used 28 k ton* 22 k ton*
-Oxygen Used 23.4 k ton* 28.3 k ton*
Total NaOH Used 45 k ton* 37 k ton*
'air-dried metric ton of bleached pulp

TsbRe of (ConteLl is
The Buy-Out and Employee Ownership
Formation of Blue Ridge Paper Products
MLBackground on the Canton Mill
Settlement Agreement
MUOpinions on Settlement Agreement
1
• Purpose of Community Advisory
Committee and Membership
OE_Progress in Pigeon River Water Quality
Improvements
M Canton Mill NPDES Discharge Permit
• Plans and Progress to Meet Revised
Permit
LF.VERV READY INDEX'INDEXING SYSTEM

U Champion News Release
Champion International Corporation
One Champion Plaza
Stamfora.Connecticut 06921
5
LC4,C-_'_
CHAMPION INTERNATIONAL CORPORATION AGREES TO SELL CANTON
MILL AND DAIRYPAK OPERATIONS TO THE CAROLINA PAPER COMPANY
Stamford, CT, March 29, 1999—Champion International Corporation(NYSE: CHA)
announced today that it has agreed to sell its mill in Canton, North Carolina, an extruding
and converting facility in Waynesville, North Carolina, and its DairyPak liquid packaging
business to The Carolina Paper Company. The sale price is $200 million, consisting of
$170 million in cash and a $30 million note. The agreement also provides the opportunity
for Champion to receive an additional contingency payment in the future.
The Carolina Paper Company is a new corporation created by KPS Special Situations
Fund, LP, a New York-based investment fund, for the purpose of purchasing and
operating this business. The operations include a pulp, paper, and bleached board mill in
Canton, North Carolina; an extruding and converting facility in Waynesville, North
Carolina; and five plants that produce milk and juice cartons. These plants are located in
Morristown, New Jersey; Athens, Georgia; Olmsted Falls, Ohio; Clinton, Iowa; and Ft.
Worth, Texas. Approximately 2400 people are employed at the facilities to be sold.
This sale is part of Champion's plan, which the company announced in October of 1997,
to divest non-strategic product segments and facilities. At that time, the company adopted
a three-pronged strategy to maximize total shareholder return by focusing on strategic
businesses, increasing profitability, and improving financial discipline.
-more -

Page 2/Champion International Corporation Agrees To Sell Canton Mill And DairyPak
Operations To The Carolina Paper Company
This agreement is subject to several conditions, including an affirmative vote of the
membership of the unions that represent some of the employees at these facilities. All
Canton, Waynesville, and DairyPak employees will have an equity investment in The
Carolina Paper Company through an Employee Stock Ownership Plan, or ESOP. In
addition, Champion has negotiated an agreement to sell wood chips to The Carolina Paper
Company for use at the Canton mill.
Richard E. Olson, Champion's chairman and chief executive officer, said, "We are pleased
to have reached an agreement to sell these facilities. This is another important step toward
accomplishing the objectives we have set for our company. Our employees at these
facilities have served Champion well in the past and now will have a new and exciting
future as part of The Carolina Paper Company." He added that he expected the
transaction to close in the second quarter.
Champion International Corporation is an integrated forest products company with
significant operations in the United States, Canada, and Brazil. Champion is a major
producer and distributor of coated and uncoated papers. The company's other products
include market pulp, lumber and plywood, and selected paper for packaging. Champion
has the responsibility for the sustainable management of more than eleven million acres of
forestlands supporting its manufacturing facilities.
For more information contact:
Champion: Media—Gael Doar [phone]
Investors—Tom Hart [phone]
The Carolina Paper Company: Michael Psaros [phone]
99CH06GD03/29

THE NEWPORT PLAIN TALK
WEDNESDAY, MARCH 31, IM
Buywout deal
. Closed
Employees to buy Cantos
a mm
pperll
Sunburst Papers to be environmentally conscious,
leaders say
By Gary Butler Canton,North Carolina,paper mill. for labor relations across the pulp
An employee group at Chain- "Phis is a true victory for work- and a r Indus
Pion International Corporation and ing peoplesaid Boyd Young,Ares- KPS 3 uSS"he said.
no investment banking firm an- ident of the Paper,AI Red-Industrial, New York ,vestment tons Fund, a
pounced reached that an agreement Chemical, and Energy Workers own the other 55 percent of the
will
has been reached which creates an International Union (PACE). '-We newly created Sunburst Papers, and
Employee Stock Ownership Plan believe it will create long-term job will contribute the bulk of the$and
(ESOP) that will allow employees security in the affected facilities, million purchase price:
to own 45 percent of Champion's and will provide a positive model .
We're very pleased to. have
month buy-out effort
been able to participate in this Chris Just, a SACCO associate, R
transaction," said KPS` partner said there will be several positive Ivl
David Shapiro. We see a great deal aspects about the new ownership.
Of potential in these operations •It will definitely:be a more
Union leaders praised associates democratically-inn company,, (�
from the Southern Appalachian `1�J+
said. "And the fact that the cy'' Just
ompa-
Center for Cooperative Ownership ny's headquarters will be here in
(SACCO) in Asheville who con- Western North Carolina,rather than
sulted with them throughout the 17- in Stanford, Connecticut, will be a
plus.
(eotttlnued on page gA)

i
"And I believe it will be easier to meetings on ESOP education about a the environment;"Lindsey said. from 376,000 pounds per day in
identify niche markets, being a month ago, and will continue meet- COcke County Executive Charles April 1989 to the present
smaller company;'he said. ings with employees until everyone Lewis Moore was equally enthusias- 50,000—and a projected 48,000 of
And Just had some news for understands what the transition tic about efforts by the ESOP to con- less by May 2001.
downstream residents concerning entails. tinue to clean up the Pigeon River. After negotiations were con
the mill's pollution of the Pigeon It is die only option we have to "I am glad they were able to work eluded in 1997,Tennessee Governdt
River. survive;"Higgins said, out the sale of the plant to the bene- Don Sundquist s�id, "We have bro-
;,;i;,the p potential
toe pew.coinPany, Higgins said the employees will fit of the employees,'Moore said. ken a long-standilig deadlock to win
has the trotential to•be an environ- get stock options;Waprofit-sharing; "live have never had any Aker an 'agreement that will clean-tip thg
mental model;' lie said:'"Markets and contintiatiim gj,their hga M,omit towards the employees of Champion Pigeon River and end a centry o�
they will go after will likely be as pension.plans.. ... ,, International;' a said."Th0y have a injgsGce,to,ciyzens,who.live alon
environmentally sound as possible. But, most fMpP'0' n0y, we will lot of relatives in Cocke County and its course."
"77iIs buy-out ends 18 months of have a say in our own futures;' he we have always wanted what was On February 15, 1999, almost
uncertainty,' said ESOP leader Alton said, best for them and us a clean river. year and a half after Champion ail-
Higgins, a member of PACE Local Higgins said that, as employees "I am very Itappy to hear that the nounced that it was putting the
507. "It brings hope Tor the future, as well as owners,they feel a need to new owners intends to continue ef- Canton System, which includes th4
job security, and control of our own be the best environmental neighbors Forts to clean the niter and keep it Canton mill,Waynesville plant, and
destinies;'he said. possible. clean;'Moore said.Higgins said the Sunburst Trait- "We want this plant to be here for Cocke County residents who have of all a divestiture program for 'eSm as oky
siston f six which to chairs, con- our children and their children;' lie been concerned about dioxin and Mountain Local 507 of PACE sent a
sists of six mill employees and has said. "if we don't deal with envi- other contaminants in the Pigeon letter to all its members. The letter
been working on the buy-out project ronmental issues properly,that's just River have been able to breathe a lit- said,in part:
since October of 1997. He said the one more thing that can put our tle easier in the last year or two, as "Champion is committed to gel-
team's name cause from what has futures at risk. We are very con- clean-up efforts by Champion have Ling out of Canton,and Champion Is
been chosen as the new name for die cenied about keeping the river clean, proven to have been significant, not turning back.This leaves us only
paper mill,'stSunburst Papers. here and down the river into according to the US Environmental two choices: sit back and see who
Suti a he is a small community Tennessee as well:, Protection Agency (EPA) ends up buying these facilities and
near tlrc headwaters of the Pigcott Higgins said several major envi- Administrator John Hankinson Jr. hope they care about us,or take con-
from which logs for early Champion ronmental groups have supported the "In 1997, after legal proceedings trol of our own future:'
Pape were obtained. buy-out, including WNOCA, an brought a proposed permit renewal Tuesday's announcement indi-
"T'here have been a lot of mill Asheville affiliate of the Sierra Club, to a standstill, intensive nearly year- cates that the ESOP, along with
employees who thought the buy-out Western North Carolina Alliance, long negotiations for the first time KPS, has in fact taken control of its
would never happen, but it has hap- Dogwood Alliance, and the Clean enabled all parties—federal,state,and own destiny.
paned;" Higgins said. Water Fund of North Carolina. regulated industry—to agree oil The only remaining obstacle to
"This mill is almost 100 years Ginny Lindsey, spokesperson for enforceable terms and conditions the buy-out is the ratification of:a
old, and many of the employees are the Clean Water Fund of North that would move, step-by-step, new labor contract with the new
second-, third-, and even fourth- Carolina, said her organization is toward ultimately achieving the goal Sunburst Papers, said Alton Hi
generation mill workers. Many of endmsiastic about Ilse buyout. of a cleaner Pigeon River," gins.
them just couldn't bring themselves "We have met with the employ- Hankinson said.to believe it would happen;'he said. ees,and we reel that they're commit- Hankinson said that in less than the"next twoltoikel threetweeks;' Hig-
Higgins said his team started ted to making changes iha6will help 10 years, color discharges are down gins said.

Blue Ridge Paper Products Inc.
Headquartered in Asheville,N.C.,Blue Ridge Paper Products Inc. is a leading producer of liquid
packaging,envelope papers and coated bleached board for food service packaging. The company
also produces specialty uncoated and extrusion coated papers. The company was created in May
1999 through the acquisition of the seven-plant"Canton System"from Champion International
Corporation. The company promises to"raise your expectations,"offering a competitive
advantage to customers through its experienced employee-owners:
Blue Ridge is a leading producer of envelope-grade papers,with a market share of approximately
20%,and of value-added cupstock,also with a market share of approximately 20%. Blue Ridge's
DairyPak®Division is the second-largest producer of"gable top"milk and juice cartons in the
United States,with a market share of approximately 35%. The current purchase of the liquid
packaging business of Westvaco,based in Richmond,Virginia,will increase Blue Ridge's market
share and strengthen DairyPak's capabilities as a high-end packaging producer of juice and milk
cartons.
Ownership: 55%owned by the KPS Special Situations Fund,L.Y.(New York,N.Y.);
45%owned by Blue Ridge's employees through an employee stock ownership
plan.
Headquarters: Asheville,North Carolina
Facilities: Seven plants in six states,including:
Pulp and paper mill-Canton,NC
Extrusion plant-Waynesville,NC
DairyPak converting plants:
Athens,Georgia
Clinton,Iowa
Fort Worth,Texas
Morristown,New Jersey
Olmsted Falls, Ohio
CEO: Gordon L.Jones
Employees: 2,100
Unions: The hourly employees at six of the plants are represented by PACE International
Union (Paper,Allied-Industrial, Chemical and Energy Workers);the hourly
employees at the seventh plant(Morristown,New Jersey)are represented by the
UAW(United Automobile,Aerospace and Agricultural Implement Workers
of America International Union).

BLUE RIDGE
PAPER PRODUCTS INC.
Gordon L.Jones
Gordon L. Jones is Chief Executive Officer of Blue Ridge Paper Products, Inc., a leading
producer of envelope-grade paper and coated board used in liquid packaging. Blue Ridge
Paper Products, headquartered in Asheville,North Carolina, has seven plants in six states,
including a pulp and paper mill in Canton, NC, an extruding plant in Waynesville, NC,
and five converting plants in Athens, Georgia; Fort Worth, Texas; Clinton, Iowa;
Olmsted Falls, Ohio, and Morristown,New Jersey.
Mr. Jones has 23 years' experience in worldwide sales, marketing and manufacturing of
pulp and paper products. Prior to becoming CEO in April 1999, he was Vice President
and an Executive Officer of Smurfit-Stone Container Corporation, where he was
responsible for the worldwide sales and marketing of containerboard/kraft paper and of
pulp, as well as all logistical activities of the corporation. He had previously spent 16
years with Stone Container Corporation.
From April 1997 through November 1998, Mr. Jones was a Senior Vice President of
Stone Container Corporation, where he was responsible for all of Stone's 85 U.S.
container plants and other support facilities, representing 3 million tons of containerboard
consumption and approximately 3 billion dollars annually in total sales. Prior to that, he
was President of Stone Container International Corporation,where he was responsible for
Stone's worldwide Market Pulp business as well as the worldwide sale of all
containerboard and kraft paper from the company's North American mill operations.
Mr. Jones began his career at Procter&Gamble, where he worked for seven years. He is
a graduate of the University of Nebraska and holds a Master of Science degree in
Business Administration from Boston University.
1 West Pack Square,Suite 1100 BB&T Building
Asheville,North Carolina 28801-3425 Phot>c:828.253-6542 Fax:[phone]
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
Executive Management Biographies
George Henson
Vice President,Mill Division
George Henson is a 30-year veteran of the paper industry. As vice president of the Mill Division,Mr.
Henson is responsible for the functions of the Canton Mill as well as all upstream supply and coordination
to support the mill. Prior to joining Blue Ridge Paper Products,he was vice president of process
improvement at Weyerhaeuser, focusing his efforts on total quality and work system improvement.
Howard J. Gidez
President,DairyPak/Vice President Sales &Marketing
Howard Gidez began his career in the paper industry with Champion International in 1967 as a sales
representative for fine papers. During the course of his 32-year career with the company,he has held a
number of managerial positions. He most recently was vice president and general manager of Champion's
DairyPak Division. Currently,Mr. Gidez serves as president of the DairyPak Division,now part of Blue
Ridge Paper Products. fn addition,he is also vice president, sales and marketing for the company.
Thomas K Carter
rice President,Human Resources
Thomas Carter supervises all labor/employee relations issues,organizational development,
compensation/benefits, safety and community relations in his role as vice president,human resources.
A 17-year veteran of the Sara Lee Corporation, and most recently,vice president of human resources of
Sara Lee Foods Worldwide,Mr. Carter has held a number of senior level human resources responsibilities.
Prior to Sara Lee,he held senior human resources positions with Bristol-Myers and the Coca-Cola Company.
Richard Lozyniak
Chief Financial Officer
As chief financial officer,Richard Lozyniak supervises all accounting,treasury,risk management and
management information systems. A 15-year veteran of GE Capital,Mr.Lozyniak has held positions in
audit,account management and credit. He has considerable financial expertise in buyout situations as
well as corporate financing and restructuring issues.
Phillip E. Bowen
rice President,Business Development
Phillip Bowen is a 20-year veteran of the paper industry with both manufacturing and corporate
experience. As Vice President,Business Development,Mr.Bowen is responsible for the marketing,
product development, research and development and business planting functions for the company. Prior
to his current assignment, he served as the General Manager of the company's extrusion coating plant in
Waynesville,NC.
1 West Pack Square,Suite 1100 BB&T Building
Asheville,North Carolina 28801-3425 Phoae:828-253-6542 Fu:828-254-6461
Raising Your Expectatious

„ uv.
e &
” 3s
c k
FACTS
5 .
• R e ryk
--YOUR LIQUID PACKAGING EXPERTS • '
'DarryPak is a leading produce of extruded '
46c rd used in hgwd packagrna IINrthw
more than b brllron m Cartons sold in'1998 ,
�it.is the;sacond-Largest manufacturerbf a ,,dam �� ✓
+?a- s c•-r••i
finishedu'gable top"milk and juice.carton" �=
in the anted States. - - - - -- -
PROUD_HISTORY..-BRIGHT--FUTURE .*c
Founded more Than half a centur.ago
DairypA was for man,y,years par.•+of` r•' - -
,Champion'lni rnational Corporations
�> t
x, Canton System In May, 1999 the.
• 45%
" Canton System Sive.DairyPak f ciiitne5 rr _ Employee
A Owned
rts pulp and paper mill}and r s y
t -
• extruding pi�nz became fa new companj s g
"Blue Ridde;Paper P.-oduds Inc aTli7s
independent employee-owned business ,"µaa's�
.rsded{cbtpd toprovidirio rnnoz alive:and `ate: - • "' '
' responsive service to ail custome4d.90s
$`•backc d by KPS Speoa1 Situations Fund,LLP-4
a$205 millron,private equity
a p y M33

From - Paper
C."T.
qp N FW, Chemical AddlHves
and Reactions
A.White liquor added to wood
T°Mn z' Dlow4w ) 1 --. — chips—starts to dissolve Itgnin.
e B.Black liquor(while liquor+lignln
Pulp Sa f u residue)washed out.
r; 11,11 Rrm.rae°n°. C.Oxygen Reactor for further
M-° V—� mew.Tow Cw ahMfipT delignitication.
D.Pulp bleached to Increase
M-Wro c r Evyvmr whiteness. '
1--` ( ) -• Pup w°i1i1iP R°`OY1r cy� E.Pulp extracted with caustic soda
G to further remove lignln.
11 F.Pulp bleached to increase
°ems° whiteness.
raud,ru.r P,.°ems G.Bleached pulp slurry. Paper C$W
additives(such as pH adjusted
Drrr SW — dyes,rosin,alum,clay,titanium
dloxlde)added to enhance
paper properties.
H.Paper sheet formed here
through dewatedng.
fSm. r� 1. Black liquor concentrated.
R'm101eO�iMi Wr°' /NPi°" J.Black liquor converted to
green liquor.
° K.Green liquor manufactured.
Pu.Pr°u L.Green liquor,converted to
white liquor.
C•1°^a°�Pi.d� M.Calclum carbonate settled out
n.x 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 lowers for reuse in
the mill.
eking : ur mark for you.
PLUS RIDGE PAPER PRODUCTS INC.

Canton Mill-'1998 "Statistics
(per calendar day) (per operating day)
Wood 5,287 tons Pulp 1,368 tons Wood (chips) $70,717,000 Employees:
Coal 1,141 tons pine 605 tons Freight $11,327,000 Canton Mill 1,185
Fuel Oil 18,940 gal. Hardwood 763 tons Purchased electricity $8,833,000 Waynesville Plant 240
Fresh Lime 89"tons Paper and Board" 1,584 tons Telephone $481,000 Total 1,425
Starch 71 tons paper 784 tons Coal, oil, gas, bark fuel $18,674,000
PCC's 118 tons board 800 tons
Caustic 62 tons Tall Oil 32 tons Taxes:
Turpentine 1,084gal. Canton $1,155,817
Haywood County $1,356,759
Total $2,512,576
All numbers,with the exception of Taxes and Employees,reflect Canton Mill only
Making our mark for you.
aLU F. alhl;IE PA I'I:a 11It 0 1)11 CTR 114 C.

Overview of the Canton Manufacturing Process
Blue Ridge Paper Products' Canton, North Carolina, facility is a pulp and paper mill that
manufactures uncoated paper and bleached paperboard. During the $330 million Canton
Modernization Project, completed in June of 1994, the mill incorporated the latest in
manufacturing and environmental technology. The result is an operation designed to produce
superior paper products and to meet or exceed the Environmental Protection Agency's (EPA)
strict standards for air and water emissions.
The Canton mill employs approximately 1,150 people and operates around the clock three
uncoated paper machines and one board machine. The four machines manufacture nearly
560,000 packed tons each year. The uncoated paper is used for a variety of end uses such as
letterheads, envelops, notepads, and books. The bleached paperboard is used for packaging.
The papermaking process begins with wood chips shipped to the mill from various suppliers.
The first step in turning wood chips into paper and paperboard involves pulping or cooking them.
The chips and a cooking solution, called white liquor, are heated in a digester (essentially a large
pressure cooker) to dissolve lignin, the natural glue that holds wood fibers together. The result is
brown kraft pulp that is then washed, screened, and bleached to a bright white.
The pulp cooking and bleaching time varies depending on the brightness required, but the
process from chips to bleached pulp generally takes about 18 hours. At this point, the pulp is
held in storage tanks until it is needed on the machines.
During the pulping and bleaching process, the mill uses oxygen and chlorine dioxide. Canton
also recovers, recycles, and makes ready for reuse most of the spent pulping chemicals, the
remainder of which is burned as fuel.
The pulp is then mixed with water, called slurry, and is pumped to one of the four machines. The
slurry, which is 99.5 percent water at this stage, flows onto a fast-moving, fine mesh screen
called the wire. On the wire, a uniform sheet is formed and excess water is drained away. The
sheet of paper is then run through a calender stack, a set of rolls that irons the paper to reduce its
thickness and increase smoothness. As it leaves the calenders, the paper is wound onto large
reels. When the reel is full, the paper goes to the winder where it is cut into smaller rolls. Those
rolls are wrapped or converted into sheets and shipped to customers.

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 come from residual sources such as chip mills,
etc. The mill's four machines —three paper and one board—produce close to 1,600 packed tons
each day, adding up to approximately 560,000 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
Project (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 wood: 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 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 is 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 OD100.
The OD100 process was designed to improve the quality of the mill's wastewater. The bleaching
time for pulp varies 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 775 packed tons of uncoated paper each day, while No. 19 makes
approximately 760 packed tons of paperboard a day for a combined total of nearly 560,000
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 wire. A uniform sheet is formed as excess water is drained
away. The continuous web of paper is formed and dried at approximately 2,000 feet a 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 calendar stack, a set of rolls stacked one
above the other, irons the paper to reduce its thickness and increases smoothness. Then, as it
leaves the calendars, the paper is wound onto large reels. When the reel is full, it s taken to he
winder where it is cut into smaller rolls converted into sheets of various sizes.
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 cauticizing 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. 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 013100; and bleached filtrate
recycle, or BFR. The OD100 Process captures and recycles many dissolved wood chemicals that
might otherwise be discharged with wastewater. The OD100 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. 013100 and BFR demonstrate a commitment to
investing in the technologies that both protect the environment and make quality paper products.

Mill Overview
• Built in 1908 to produce pulp
• 3 uncoated paper machines, Nos. 11, 12, and 20, producing 275,000 tons per year
• 1 paperboard machine, No. 19, producing 281,000 tons per year.
• $526 million invested over last 10 years
• Significant improvements to mill operations
o Improved environmental performance
• Pulp bleaching system replaced
• Improved quality/productivity
• All machines converted to alkaline

Environmental Performance
• Both fiber lines exceed Cluster Rules requirements
• Minimum impact mill with world class environmental performance through combination of
• Oxygen delignification with 100% substitution of chlorine dioxide for elemental chlorine
(OD IooT M)
• Bleach Filtrate Recycle (BFRTI)
• One of the leading bleached kraft mills in North America for effluent water quality.

,rTED STjTA�
?, A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
s owl REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW
ATLANTA. GEORGIA30303-8909
RECEIVED
AN 1 3 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 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. rlk¢s
Associate gio ttomey
Attachment
Encl.
Rec7cIeNRetyctable•Primed witty vegelamle oil Basso Inks on 100%RecV,*0 Paper(40%Postoom mer) - ,

ADDRESS LIST
Bam• Turner
Depute Attomev Generai
Office of the Attorney Generai
Cordell Hull Building'. -'.id Floor
425 fth 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 Deputv Attorney General
NC Department of Justice
114 West Edenton Street
Suite 311
Raleigh, NC 27602
Forrest R. Westall
Regional Water Qualitv 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
SorinQfiPId, VA 22 1 50-23 1 1

John Noel
Pigeon River Coordinator
Tennessee Environmental Council
1700 Haves Street. Suite l o l
Nashville. T\ 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

ASHEVILLE CITIZEN-TIMES OTHER VIEWS WEDNESDAY,APRIL 14. 1999
GUEST COLUMN
Pigeon River clean-up positive
example of environmental win
i For years it one-third the previous level, the As EPA Administrator Carol M.
• had been acon- river's downstream discoloration Browner has add: "We can have
n
tentious, seeming- remained a highly charged and strong environmental and public
;�s ..� . - ly irreconcilable unresolved issue. health protections and still have
f' dispute between Since it began Canton operations robust economic growth. We can
` two neighbors - in 1908, Champion had brought jobs save jobs, we can even create jobs,
the states of North -currently lOW,plus several thou- and still safeguard our environment
Carolina and Ten- sand more indirectly-and prosperi- and health."
nessee, ty to an economically depressed Key provisions of the agreement
At issue was mountain community. But as the were: 1)a further 40 percent reduces
John H. the coffee-brown industry grew, so too did scientific tion in Champion's color discharges
J
Ilan ohn Jr. color of the Pigeon awareness and public concern over to the Pigeon River by December
River, a scenic the adverse effects of pulp and 1998; and 2) another 13-20 percent
mountain stream paper nulls on water quality. aft by May 2001 through continuing
" which travels 75 miles from Hay- In 1997, after legal proceedings implementation of new technology..
wood County in western North Car- brought a proposed permit renewal As a result,both states have been
olina to a confluence with the to a standstill,intensive nearly year- able to modify their fishing advi-
' French Broad River just east of long negotiations for the lust time sories. And river rafting has
Knoxville,Tenn. ', ' enabled all parties - federal, state, increased from a saint 200 users in
Tennesseans argued that because and regulated industry-to agree on 1994 to mote than 50,000 in 1998.
of a pulp and paper mill upstream in enforceable terms and conditions The bottom line is less than 10
-North Carolina, it.bad become the that would move, step-by-step, years, color discharges are down
"Dead"Pigeon River-all but devoid toward ultimately achieving the goal from 376,000 pounds per day in
-of fish,nearly useless for rafting and of a cleaner Pigeon River. April 1989 to the present 50,000(the
other water recreation,and a serious With that hard-won agreement year-end-target had been 60,000) -
health worry for nearby residents. aurae a new lease on life for a once and a projected 48,000 or less by
North Carolinians foresaw devas- severely endangered stream. The May 2001.That will be an overall 87
rating consequences if the mill, for happy ending testifies to the power percent decline, dramatic evidence
i.,90 years the economic backbone of of environmental landmarks such as of what investment is cost-effective
their mountain region, were forced the Clean Water Act,which became pollution-prevention technology by
to close. law in 1977,to fulfill its promise as a Champion, coupled with strict
This classic confrontation centers tool both to protect and - just as enforcement of permit limits, can
,.on water discharges by Champion importantly-to restore vital natural aa:ompiish.
International Corporation at Can- resources. Such-a surds makes clear that
ton,just 37 miles upstream from the Today,there is ample new reason our Nation's bold and far sighted
Tennessee border. to celebrate the Pigeon River settle- commitment, beginning with the
The mill uses nearly 30 million ment. Last December, one of its National Environmental Policy Act
.gallons of water a day-virtually the most ambitious and critical color- passed by Congress in 1969,may be
;;hPigeon.River's entire flow-to pro reduction milestones not only was among our beat "new millennium"
duce up to 1,420 tons of bleached met but far exceeded.-and on the gifts to ourselves and future genera-
pulp that is turned into milk cartons, parties'agreed-on schedule. 'lions.
„juice containers,fast-food soda cups, The insult is a."win-win" which The Environmental Protection
rapier paper, and similar products. shows that economic and environ- Agency is proud of a proactive role
'_—_But process waters also' pick up mental interests can in fact, .go that led to a clear-cut victory for all
brown color from tannins and hand-in-hand. Both states reap parties is the Pigeon River dispute.
lignins,organic compounds in wood, tremendous belefits: a healthy
Even after a $330 million mill region-wide economy that retains John H. Hankinson Jr. is
modernization in 1990, which jobs while not losing a valued recre- regional administrator for EPA
reduced the brown color to-less than ational and scenic resource. Region 4.

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ullution in the Pigeon River has long been an issue of The proposed agreement includes five key points:
debate. emotion and frustration for[he citizens of continuous improvement with lower numbers and fixed
Cocke County. dates
Located on the bank of the Pigeon in North Caroliu't' 0 decisions made by regulators from Tennessee and
the Champion International paper plant discharges have .North Carolina and not by Champion.
at(ected both water quality and the beaun'of the river as it compliance measured by testing, not models.
flows into Tennessee. • a study of tic river system, including Waterville Lake.
Gov. Sundquist. in cooperation with the Ncsvporr Cin' g
Council, the Cocke County Commission, the State of and
North Carolina, the U.S. EPA and Champion, finalized an 0 a anmuanhenE from all parties for a clean river.
agreement in 1997 to clean up the Pigeon Riser. Independent technical experts provided by the U.S.
Local approval of the Pigeon Riser agrcenhcur brings EPA during the negotiations helped finalize the agreement.
to a close more than a ,year of intense negotiations. Wilson said.
Further, it will end nearly a century of water pollution in
the Pigeon River.
"This agreement is a triumph for Elie people of
Newport and Cocke County because it reflects the chances hf,
in the permit they insisted upon."said Justin R Wilson.
Deputy to the Governor For Policy "It scuuhl nor be pussi-
ble withouE their strong advocacy.'•
Outdoor recreation and environn[ental groups endorsed ; [
the plan,which requires significant reductions in color pol-
lutants in the Pigeon River. It also sets the goal of meeting
Tennessee and North Carolina water quality standards with-
tit variance.
"The agreement is revolutionan' because it conunirs all
parties to meet state water quality standards in the Pigeon v
River for the first time in 100 years.-Wilson said. a
The revised permit resulting from Ehe agreement 0
0.
puts water quality in the hands of state regulaors in 'z
Tennessee and North Carolina. taking that control away "
from the Champion Paper plant. as Elie people of Cocke Gov. Sundquist talks with Cocke County students during a visit
County asked Governor Sundquist to do.- to the Pigeon River.
cl?ea b
The Division of Water Supply is rated by the U.S. technical assistance.
EPA as one of the top drinking water programs in The Division helps resolve community water prob-
the nation and the best in the southeastern U.S. The lems, such as recurring treatment problems in the town
Division makes sure that our public water supply sys- of Red Boiling Springs, low seater pressure issues in
tems comply with standards and regulations, guarantee- Carter County and locating a new water source for the
ing that Tennesseans have clean and safe drinking seater. Scotts Hill community.
"There are many naturally occurring organisms that Another accomplishment of 1997 was the comple-
pose continuing risks to public health by entering our tion of plans by many water supply systems to protect
water supply systems. It is our role to see that seater their seater sources. This includes identifying potential
suppliers provide proper treatment before it goes to our cbntahninants to the water supply and planning for
hmes and businesses," said Director David Draughon. emergency protections.
e credits the cooperation of local water systems for the - Looking ahead, the TDEC is excited about the State
state's enviable record. Revolving Fund promoted by Gov. Sundquist to provide
Division staff also work with water systems on a a stable and reliable funding source for systems needing
continuous improvement program that includes reduc- money to improve their water supply.
ing lead levels, controlling corrosion and providing
PEOPLE AND PROGRESS XV

Canton Mill
Community Advisory Committee
Background
The NPDES Settlement Agreement signed between North Carolina, Tennessee, Cocke
County,the City of Newport, the Tennessee Environmental Council, the American Canoe
Association, the Environmental Protection Agency, and Champion International
Corporation provides that the Canton Mill establish a Community Advisory Committee
(CAC). Since the Settlement Agreement was signed, the Canton Mill was purchased by
an Employee Stock Option Plan (ESOP) and now operates under the name of Blue Ridge
Paper Product, Inc. The terms of the NPDES Settlement Agreement require that CAC go
forward.
Mission
The CAC will be a forum to report on the progress made to meet the milestones and
requirements of the revised the NPDES Permit.
Purpose
• Educate the CAC on the requirements of the revised permit
• Report on plans and progress to meet the permit requirements
• Report on the water quality of the Pigeon River
Membership
Criteria for Selection
Members of CAC will be selected from:
• Community Leaders
• Business and Trade
• Government
• Education
• Recreation

Canton Community Advisory Committee
Page 2
Membership Profile
Members of the CAC will be chosen according to the position they hold. Representation
is maintained by the position,not by the individual.
County Executive/Manager:
Charles Lewis Moore, Cocke County
Jack Horton, Haywood County
Town Mayors:
Roland Dykes,Newport
Pat Smathers, Canton
County Superintendent of Schools:
Larry Blazer, Cocke County
Bill Upton, Haywood County
Economic Development Commission:
Dean Williams, Cocke County
Jay Hinson Haywood County
Publisher (or Co-Publisher) of Local Newspaper:
David Popiel,Newport Plain Talk
Jonathan Key, Enterprise-Mountaineer
Business, Trade and Tourism
Patsy Williams, Chairperson, Cocke County Tourism Council
Matt Moses, Cocke County,President of the Rafters Permitees
Gay Webb,Newport, Wilton Springs Hardware
Blue Ridge Paper Products Representatives:
George Henson, VP & Operations Manager
Bob Williams, Director, Environmental, Health and Safety Affairs
Alton Higgins,Union Representative, Chairman, Employee Stock Ownership Plan
Leadership
The CAC will be facilitated by Blue Ridge, Director of EHS. The agenda will focus
around the permit and objectives as stated. The agenda for each meeting will be set in
advance by the CAC.

Canton Community Advisory Committee
Page 3
Meetings
The CAC will meet semi-annually (or quarterly as agreed to by the CAC) with the initial
meeting tentatively scheduled for the first quarter of 2000.
Meetings will be rotated among sites in Cocke and Haywood Counties.

What would you like to see for the outcome of the Community Advisory
Committee?
• Would like to see the Pigeon River be totally clean and crystal clear.
• Clear presentation of the facts that can be made available to the citizens.
• Would like to know the impact that BRPP is having on the environment and economy and
what they are doing to positively effect both. Also,what they need from the community.
• Ways to improve life and the river in both states.
• Positive communication between communities.
• Bring the Haywood Community and Cocke County Communities closer together.
• Increased communication between counties, states, and business.
• Realistic goals set for all.
• Identify current water quality concerns.
• Select a joint TN/NC Pigeon River Project.
• Identify ways for Blue Ridge Paper to remain active and visible in the community.
• Recommendations for continued improvement of environment.
• Development of improved relations between mill and Tennessee communities.
• Community Trust Building/Development.
• Meeting some of the employees and families.
• Create worthwhile project for both communities.
• Promote communication and understanding between the Canton Mill and the community.
• Improved communication and understanding between the Canton Mill and community
members.

3LUE RIDGE PAPER PRODUCTS i\C.
Community Advisory Committee Members
Larry Blazer
Superintendent of Schools
Cocke County Schools
305 Hedrick Drive
Newport,TN 37821
423/623-7821
Roland Dykes
Mayor of Newport
P.O. Box 370
Newport,TN 37821
423/623-7327 (0)
423/623-7180 (H)
George Henson
Vice President Mill Operations
Blue Ridge Paper
P.O. Box 4000
Canton,NC 28716
828/646-2840
Alton Higgins
Union Representative
Blue Ridge Paper
P.O. Box 4000
Canton,NC 28716
828/646-2294
Jay Hinson
Executive Director
Economic Development Commission
100 Industrial Park Drive
Waynesville,NC 28786
828/456-3737
Jack Horton
Haywood County Manager
Court House Annex
Waynesville,NC 28786
828/452-6625
Jonathan Key
Publisher
The Enterprise Mountaineer
220 North Main Street
Waynesville,NC 28786
828/452-0661

BLUE RIDGE -.-..DER PROD ',CTS INC..
Community Advisory Committee Members
Charles Lewis Moore
Countv Executive- Cocke County
360 Main Street East
Newport,TN 37821
423/623-8791
Matt Moses
USA Raft
P.O. Box 16
Hartford,TN 37753
423/487-4303
Dave Popiel
Publisher
Newport Plain Talk
P.O. Box 279
Newport,TN 37822
423/623-6171
Pat Smathers
Mayor of Canton
2 Church Street
Canton, NC 28716
828/648-8249
Bill Upton
Superintendent of Schools
Haywood County Schools
1615 North Main Street
Waynesville, NC 28786
828/456-2400
Gay Webb
303 Wilton Springs Road
Newport,TN 37821
423/623-3660
Bob Williams
Director EHS
Blue Ridge Paper
P.O.Box 4000
Canton,NC 28716
828/646-2033

BLUE RIDGE PAPER PRODUCTS INC.
Community Advisory Committee Members
Dean Williams
Executive Director
Economic Development Commission
433 Prospect Avenue
Newport,TN 37821
423/623-3008
Ms. Patsy Williams
Chairperson,Cocke County
Tourism Council
P.O. Box 709
Newport,TN 37822
423/623-2324
423/625-0356 (F)

TN 140&SLc
Actual Measured Color at the NC/TN Line for the Canton Mill
Monthly Averages from 1/88-12199
225
200 -— -
175 - - -
150 - —
125 —
100 -
75
50
25
0
%•, n _ ri> J O O N ^J r7 M M -y- 7 if? Ln tD CO I— n 00 00 00 0� O)
0 0�• CO r• 00 .'M 0- M 0l 0� M M M m M. M M Ol 0l M 0�
i I I I I I I I I I I 1 I I
>
--*-ACTUAL MEASURED TNI40 CLR ST mg/1 mon avg
Blue Ridge Paper Products, Inc.
Canton, NC SKK/CMS/MSH 1/25/00

Secondary Effluent Flow in mgd for the Canton Mill
Monthly Averages from 1/88-12/99
50.0 -
45.0 -- -- -- --- --- ---- --- -- - -------------------------------------------------I----------------------- -----------------------------------------I............
40.0 - ------ --- --- ------- - ------ -------------- - ---- ------ ------------- ---------------------------------------------------------------------------------------------------------------------
35.0 - - - -- ---- -- ----------------- --- ...... ...... ................................ ----------------------------------------------------------------------------------------------------------
Permit Limit = 29.9 mgd as of 1/1/97
30.0 -- ...... -- - - --- --- --- - - --- - ----- - ------------------------------------- ------- ------------------------ -- - --- ----------------------------------------------------------------
25.0 - ---------------- - ------ - ------------ -------------------------------- -------------------------- ---- --- --- --------------------------------------------- ------------ ----- - - ------
20,0
75 Z -6 -5 15
Blue Ridge Paper Products, Inc.
CNIVIVISH 1/26/00

Measured Color in the Pigeon River at Hepco
Monthly Averages 1188 - 12/99
350
300 --
250
t Hepco Sp.T Color monthly ave.
-
E 200
o`
0
U
N
N 150
0
100
50 --
0
oo� o� a� u� � c, wa0000 - - - - NN �� � r-> � .� r� vd- v vin �n �n v> cn cc �o cc � � � rmao ao o� a� rnrna�
a� ce a: co ce co a, a rnee ao a� T a arnrno� o� o� aernrna� o� av wrnrna� rno� a> a� a� rnrnrnae orrnrno� rnrnrn
p c ¢ OUcc Q O ¢ C 8- O ¢ O ¢ O ¢ O
Blue Ridge Paper Products, Inc.
Canton, NC MSH 1/25/00

HYIPROVEMENTS TO THE PIGEON RIVER FOLLOWING
MODERNIZATION OF THE CHAMPION
INTERNATIONAL CANTON MILL
Greg Seegert
Chief Ichthyologist
EA Engineering, Science, and Technology
Deerfield, IL 60015
Derric Brown
Environmental Supervisor
Champion International
Canton, NC 28716
Ed Clem
Vice President, Environmental Quality
Champion International
Stamford, Cr 06921
ABSTRACT
Since 1987, Champion International has spent approximately
330 million dollars upgrading the Canton mill. These upgrades
have reduced color levels by about 75% and reduced effluent
flows by about 40%. To determine how the biota responded to
these and other improvements in water quality, surveys were
conducted in 1995 and compared to a baseline study in 1987.
Components studied were periphyton, macroinvertebrates,
fishes, habitat, light attenuation, and water chemistry. The
study area covered approximately 45 river miles, extending
from just upstream of Canton, NC to near Bluffton, TN.
Concentrations of most constituents in the river decreased by
50-807o, including color which declined by 80%. Dissolved
oxygen concentrations in the mill effluent improved 91%, from
3.9 mg/l in 1987 to 7.4 mg/l in 1995.
These improvements in water quality have resulted in
significant improvements in the aquatic communities. The fish
community improved dramatically. Downstream Index of
Biotic Integrity (IBI) scores improved by an average of 38%
from 1987 to 1995 and species richness improved by an average
of 81% during the same period. All downstream stations also
yielded fair to good numbers of young-of-the-year fish and had
a high number of species represented by multiple age classes
indicating good survival and propagation of fishes downstream

of the Canton mill. The health of redbreast sunfish throughout
the study area was evaluated using the Health Assessment
Index (HAI) method. HAI scores were similar throughout the
study areas indicating a lack of impacts from the Canton mill.
The Pigeon River benthic community has also improved
substantially since 1987 as judged by:
(1) A substantial improvement in total taxa richness,
(2) An even more marked improvement in EPT
(Bphemeropterans=mayflies,Plecopterans=stoneflies,
and Trichopterans=caddisflies) taxa richness,
(3) Snails and aquatic earthworms, groups that are very
pollution tolerant, declined in density by 98%between
1987 and 1995, and
(4) An improvement in the narrative ratings at many sites.
OVERVIEW OF THE CANTON MODERNIZATION
PROJECT (CMP)
Champion International operates a large bleached kraft paper
mill on the Pigeon River in Canton, North Carolina. The mill
currently produces about 1600 tons of paper and paperboard
per day. In 1990, Champion began the Canton Modernization
Project (CMP). The goals of the CMP were to use"state-of-
the-art" technology to assure the continued operation of the
Canton Mill and to reduce the long-term average color load by
50%. Changes and improvements in plant operations that
were made to achieve these goals included:
• changing from molecular chlorine to 100% chlorine
dioxide for pulp bleaching,
• reducing the color discharge to 27 pounds per thousand
pounds of pulp, one of the lowest figures in the United
States,
• installing a cooling tower to allow hot water from the
mill to be re-used,
• filtering and/or cleaning existing white water streams so
that they can be re-used,

• replacing several existing pine fiber lines with a new
fiber line that includes oxygen delignification and
improved recovery of pulping liquor and chemicals,
• modify an existing fiber line for the manufacture of
hardwood pulp, which includes oxygen deligmfication
and 100% chlorine dioxide, to further minimize
chemical usage and maximize recovery of pulping
chemicals and fiber,
• rebuilding the black liquor evaporators to improve
condensate segregation and reduce process losses and
color to the VA=,
• upgrading the WWTP to reduce volume and stabilize
performance.
These and other improvements during the CMP have resulted
in a 35-40% reduction in effluent flows from the WWTP and a
70-80%reduction in instream color levels downstream of the
Mill.
AQUATIC RESOURCES AND WATER QUALITY OF THE
PIGEON RIVER
A biological, physical and water chemistry survey of the Pigeon
River and tributaries in North Carolina and Tennessee was
conducted in late August and early September 1995. The study
area extended from just upstream of Canton, NC (RM 64.5) to
near Bluffton, TN (RM 19.3) (Figure 1). Samples were
collected at 13 biological stations (10 mainstem and 3
tributary) and 18 water chemistry stations.
The 10 mainstem locations were divided into four segments:
Segment 1 - reference area upstream of Canton mill-
1 station
Segment 2 - between Canton mill and Richland Creek-
3 stations
Segment 3 - Richland Creek to Waterville Lake -
4 stations
Segment 4 - downstream of Waterville Lake and CP&L
hydro plant- 2 stations
Segment 2 reflects inputs from the Canton mill while Segment
3 is immediately downstream of Richland Creek and the

Waynesville Wastewater Treatment Plant (WWTP) and is
affected by discharges from them. Segment 4 is downstream of
the Carolina Power & Light (CP&L) hydro plant where water
levels rapidly rise and fall approximately 2 feet during each
generation cycle along with concomitant changes in river
velocity. Sampling methodologies for all phases of the study
followed those developed or approved by North Carolina
Department of Environmental Health and Natural Resources
(DEHNR). Objectives of the 1995 synoptic survey were:
• Compare conditions in the river prior to and following
the Canton Modernization Project.
• Document existing biological and water quality
conditions in the study area.
• Determine whether Class C uses are being attained
downstream of the Canton mill and, if not, what
factor(s) are preventing attainment.
• Determine whether any further reductions in color can
reasonably be expected to improve the aquatic biota
substantially.
METHODS
Habitat Assessment
The habitat at each biological station was evaluated using
procedures recently developed by the North Carolina
Department of Environmental Health and Natural Resources
(1). Parameters considered as part of the DEHNR procedure
are:
Parameter Score
Channel characteristics 1-10
Instream habitat/cover 0-20
Pool variety 0-10
Riffle quality 0-10
Substrate 1-10
Bank stability 1-10
Bank vegetation 0-10
Riparian zone quality 0-10
Riparian zone quantity 0-10

Thus, the maximum habitat score is 100. The total score for
each biological station can be compared to either ecoregion or
instream reference stations. The state has not established
minimum scores needed to assure attainment of various
aquatic life uses.
Benthic Macroinvertebrates
All 13 biological stations were sampled according to DEHNR
methodologies (1,2). This approach involved the collection of
six multihabitat qualitative samples at each station: kick,
sweep, fine mesh, leaf pack, sand, and visual search. The
samples from the various habitat types were combined and
field sorted in grided white enamel pans. In addition to
qualitative collections, three quantitative samples were taken
at each of the 10 Pigeon River mainstem stations. Sampling
was conducted in riffles using a modified Hess sampler with a
net mesh size of 500 microns that enclosed a 0.0885 m' area of
the substrate.
Macroinvertebrates from all samples were identified to the
lowest practical taxonomic level using the most current
literature available. Identifications followed those
recommended by the DEHNR (1), when possible. If numbers
of Chironomidae larvae were excessive, they were subsampled
to a more manageable number. Chironomidae larvae were
cleared in 10% potassium hydroxide and mounted in CMC-10
prior to identification. A voucher collection was created to
retain at least one good specimen of all taxa identified during
this survey.
Data obtained from qualitative collections were used to
generate the North Carolina Biotic Index (NCBI). The index
is based on values derived for individual macroinvertebrate
taxa that reflect an increasing level of pollution tolerance from
0 (least tolerant) to 10 (most tolerant). The NCBI takes into
account the abundance values of each taxa (1=1-2
individuals/sample, 3=3-9 individuals/sample, 10=Z 10
individuals/sample), and is calculated as:
NCBI=E(TV,•)(n,)/N
where:

TV;= ith taxa's tolerance value
q.= ith taxa's abundance value (1, 3, or 10)
N= sum of all abundance values
Bioclassification criteria for the NCBI differ by ecoregion
(mountain, piedmont, and coastal plain) and season. All
collections for this survey were made during the"normal"
summer sampling period (June-September) within the
mountain ecoregion.
Scoring criteria and associated bioclassifications were as
follows:
MountainEcoregion
BioBio lasssification NCBI Values EPT Values
Excellent s 4.05 i 42
Good 4.06-4.88 32-41
Good-Fair 4.89-5.74 22-31
Fair 5.75-7.00 12-21
The resultant classifications for each station downstream of the
Canton mill discharge were compared with the upstream
control site and with data collected by other investigators.
Fish
DEHNR does not currently have standardized fish sampling
methods for non-wadable streams (1). In wadable streams,
they rely exclusively on backpack electrofishers, with more
backpack units used as the size (width) of the stream increases.
However, for a stream the size and depth of the Pigeon River
(20-50m wide and up to 4 m deep), backpack electrofishers
alone are not adequate to sample the complete fish
community. To adequately sample the fish community, an
approach similar to that used on the Pigeon River by Saylor et
al. (3)was followed. To sample deeper runs and pools, we
used a 12' boat that contained a 4000 watt generator and a
Smith-Root Type VI electrofisher. We sampled riffle and
shallow run areas using a Coeffelt VVP-2C electroshocker
mounted in a towed pram. This unit uses a 1500-1800 watt
generator and thus has considerably more power than a
backpack electrofisher, and therefore is more effective in
larger wadeable streams like the Pigeon River (4). At each
location, all microhabitats were sampled until the crew leader

felt the area had been thoroughly sampled and all species had
been collected.
All specimens were identified. Sportfish and large nonsport
fish were measured (total length) and weighed. Length ranges
and/or life stages were noted for nonsport fishes. Incidence of
parasites, disease, and other morphological anomalies were
also noted. Selected smaller fishes were preserved in 10
percent formalin as voucher specimens or for laboratory
confirmation or identification; all other specimens were
released onsite. Identification typically was to the species
level. However, two subspecies of greenside darter
( .theostoma blennioides utsell and Ftheostomab.
newmannii) were differentiated on any greenside darters
brought back to the lab. The two subspecies were treated as a
single taxon when calculating IBI metrics.
The condition of individual fish was assessed using condition
(K) factors and relative weight (W,) to measure the robustness
of fish (5,6). Fish community data were incorporated in the
Index of Biotic Integrity (IBI) (7) to characterize the biotic
condition of the surveyed length of the Pigeon River. North
Carolina has developed a state-specific version of the IBI, the
NCIBI (1). The assessment of biological integrity using the
NCIBI is provided by the cumulative assessment of 12
parameters, or metrics. The values calculated for the metrics
are converted into scores on a 1, 3, 5 scale. A score of 5
represents conditions expected for undisturbed streams in a
specific river basin or ecoregion, while a score of 1 indicates
that the conditions vary greatly from those expected in
undisturbed streams of the region. The scores for each metric
are summed to attain the overall IBI score. The 12 metrics
used by NC in the mountain region are:
• Number of Species
• Percent Tolerant Fish
• Number of Individuals
• Percentages of Omnivores
• Number of Darter Species
• Number of Piscivorous Species
• Number of Sunfish and Salmonid (Trout) Species
• Percent Insectivores or Percent Specialized Insectivores
• Number of Sucker Species
• Percent of Diseased Fish
• Number of Intolerant Species
• Percent of Species with Multiple Age Classes

To further assess the"health" of fishes in the Pigeon River,
redbreast sunfish from seven mainstem locations were
evaluated using the Health Assessment Index (HAI) (8,9). The
HAI consists of 14 variables that can be grouped into the
following categories: (1) three blood parameters (hematocrit,
leukocrit, and plasma protein); (2) percentage of fish with
normal or abnormal eyes, gills, pseudobranchs, spleens,
kidneys, and livers; and (3) index values of damage to skin,
fins, thymus, and hindgut inflammation, and degree of parasitic
infestation. For half(7) the variables, a score of zero is
assigned if the variable falls within the normal or expected
range for that variable, and a score of 30 is assigned if it falls
outside the expected range. For the other 7 variables, scores of
0, 10, 20, or 30 are assigned depending on the degree to which
the variable deviates from the expected range. We compared
fish health scores at six stations downstream of the Canton mill
with the reference station upstream of the mill.
Water Chemistry
Water samples were collected on consecutive days from each
of the 13 biological stations and from several effluents
including the Canton mill. These samples were analyzed using
standard protocols for a variety of inorganic constituents,
metals, and nutrients.
RESULTS
Whenever possible, the 1995 results were compared against
those from a similar study conducted in 1987 (2), the last
intensive survey of the river and representative of pre-CMP
conditions.
Water Chemistry
Based on water samples collected throughout the study area,
we noted the following:
• No violations of North Carolina or Tennessee water
quality standards were found.
• Parameters exhibiting the greatest decreases in the mill
effluent compared to 1987 were nitrogen (52-100%
depending on form) and color (approximately 70%).

• Numerous other constituents (e.g., sulfate, COD,
aluminum, calcium, and zinc) also declined significantly.
• Dissolved oxygen concentrations in the mill effluent
improved 9117o, from 3.9 mg/1 in 1987 to 7.4 mg/1 in
1995.
• Concentrations of most constituents in the river
decreased by 50-800/c, including color which has
declined by 8001o.
Habitat
Habitat scores at 7 of the 10 mainstem sampling stations
including the upstream reference station were in a fairly
narrow range of 70-77. Scores were noticeably higher at RM
19.3 (85) and RM 59 (88), and noticeably lower (52) at RM 63.
The high score at RM 59 was the result of good scores for all
metrics. RM 19.3 scored higher than average despite lower
than average scores for the instream habitat metric. Station
RM 19.3 received a perfect score for 7 of the 9 metrics.
The low score at RM 63 was primarily the result of this station
scoring the lowest of all stations on four of the nine metrics
(channel, bank stability, canopy, and riparian zone width). The
low channel score is a result of past channelization and a
nearly straight channel at this point. The low scores for the
bank stability, canopy, and riparian zone width metrics are the
result of this urban/industrial area being largely devoid of
shrubs and trees.
Thus, overall habitats were good, except at RM 63, and not
limiting to the aquatic fauna.
Fish
Electrofishing collections at the 10 mainstem stations produced
a total of 3602 fish representing 43 species (Table 1).
The distribution of fish species in the Pigeon River was
examined for spatial patterns. Lack of definable patterns
indicates a random distribution of fishes. On the other hand,
well defined spatial patterns indicate that fishes are responding
differentially to physical factors (e.g., depth, substrate type,
water temperature, velocity, cover, etc.) or chemical factors
(e.g., pH, dissolved oxygen, toxics). Also, the

presence/absence of certain species provides valuable
information on impacts (or lack of same) from point or non
point source dischargers (e.g., the Canton mill, the Waynesville
and Clyde WWTPs) and what factor(s) may be responsible for
any differences observed.
The distribution of most species followed one of four well
defined spatial patterns (Table 2):
(1) fairly evenly distributed throughout the study area,
(2) restricted to or noticeably more abundant upstream of the
Canton mill,
(3) restricted to or noticeably more abundant downstream of
Waterville Lake (and the CP&L hydra plant), or
(4) most abundant in the middle two reaches, between the mill
and Waterville Lake.
Eight species were distributed rather uniformly throughout the
mainstem (Table 2).
Eight species--river chub; warpaint, saffron, and mirror shiner;
greenfin and tangerine darter; the gutselli subspecies of
greenside darter; and mottled sculpin--were all restricted to or
much more common upstream of the Canton mill. This
pattern appears to be the result of biogeographical
considerations and thermal preferences rather than changes in
water quality downstream of the mill. Saffron shiner, mirror
shiner, greenfin darter, the gutsell subspecies of greenside
darter, all are nearly restricted to the Blue Ridge physiographic
province and all are cool water forms, often being found in
trout streams (10). Mottled sculpin,warpaint shiner, and
tangerine darter also are cool water species (11). Only river
chub can be considered a warmwater species, and, probably
not coincidentally, it is the species that shows the least fidelity
to the area upstream of the mill (Table 1). Thus, water
temperature at RM 64.5, which was 1-50 cooler compared to
the downstream locations, appears to be the principal reason
for the restriction of these eight species to the area upstream of
the mill.
Even more species (15) were unique to the Tennessee portion
of the study area (i.e., downstream of Waterville Lake and the
CP&L power house. Six of these species were common
(gizzard shad, greenside darter [newmani subspecies], redline
darter, snubnose darter, logperch, and banded sculpin), while
the other 9 were either rare (one or two individuals) or

uncommon (3-6 individuals) (Table 1). However, despite the
fact that several of the species were common in Tennessee,
none were collected in the North Carolina portion of the river.
This pattern is not consistent with what would be expected if
the Canton mill were the principal factor affecting the
distribution of fishes in the Pigeon River. If the Canton mill
was the reason these 15 species were absent downstream of the
mill, then they still should be present upstream of the mill.
The fact that none of the 15 was collected upstream of the mill
indicates that their absence in the middle segments is primarily
biogeographical (i.e., they are not Blue Ridge species). As
opposed to the eight species more common upstream of the
mill which are predominantly cool water forms, the 15 species
restricted to the Tennessee portion of the study area are
predominantly either warmwater fishes (e.g., gizzard shad and
spotted bass) or are fishes typically associated with larger rivers
(e.g., sauger, walleye, freshwater drum, and smallmouth
buffalo). The fact that these species are absent from the upper
portion of the study area indicates that this area is simply too
cool and too small for many of the species found in the
Tennessee portion of the study area. Conversely, the area
downstream of the mill is too warm and too big for most of the
Blue Ridge fishes found upstream of the mill.
Finally, there is a group of six species (Table 2) that is
restricted to or most abundant in the middle two segments of
the study area. The increased abundance of bluegill and black
crappie in this area is certainly the result of emigration from
Waterville Lake. For example, bluegill was decidedly more
abundant at RM 42.6 at the head of Waterville Lake. The
other species typically increase in response to greater food
availability (i.e., benthic organisms) and, except for white
sucker, prefer warm water. Thus, their higher abundance in
the middle reaches is probably the result of more food being
available and warmer temperatures. The bedrock substrates
and higher percentage of long deep pools in the middle section
also favor these species.
Species richness was noticeably higher (23 species) at RM 19.3
than at any other station (12-18 species) (Table 1). Species
richness in the middle two segments of the Pigeon River was
lower (12-17 species) than at the upstream reference station
(18 species at RM 64.5), however, the difference was small,
typically one to three species (Figure 2). Although species
richness was relatively similar among all stations except RM
19.3, there were obvious differences in composition and

relative abundance among the segments, as described
previously.
K factor results indicated that (1) the condition of common
carp, northern hog sucker, rock bass, smallmouth bass,
redbreast sunfish, green sunfish, and bluegill from the Pigeon
River is comparable to the condition of these species from
other areas in the Southeast, and (2) the condition of these
species downstream of the Canton mill is comparable to or
better than in specimens collected upstream of the mill. In
general, the spatial pattern in W, values was similar to that
seen for the K values. Thus, the condition of individual fish
does not appear to be adversely affected by the effluent from
the Canton mill.
The NCIBI results for Pigeon River fisheries sites are
presented in Figure 3, the score for each NCIBI metric is
presented in Table 3. The station upstream of the mill (RM
64.5) ranked good/excellent. Of the 9 downstream stations,
two ranked fair, three ranked fair/good, three ranked good,
and the most downstream station (RM 19.3) ranked
good/excellent (Figure 3). In fact, NCIBI scores at the most
upstream and most downstream stations were identical (54 at
each). Although the extreme upstream and downstream
stations had identical NCIBI scores (Table 3), the fish
community at each was very different (Table 1). For example,
both had good representation by darters, both in terms of kinds
and numbers, yet there was almost no overlap in the darter
species present at the two locations (Table 1). There was a
decline between RM 64.5 and RM 63 immediately downstream
of the mill, but it was fairly small (8 IBI units) and as discussed
later, it may have been due to the change from a coolwater to
warm water community or from passage through an urbanized
area with associated development, runoff, etc. Also, sites with
scores that differ by s 8 IBI units are often statistically
indistinguishable (i.e., differences of s 8 may be due to random
chance) (12). The largest drop (10 IBI units) occurred
between RM 55.5 and 54.5,(Figure 3). Richland Creek and
effluent from the Waynesville WWTP enter the river between
these two stations and it is likely that one or the other, or both,
contributed to the decline seen at RM 54.5. A small decline (6
IBI units) was noted between RM 48.2 and 42.6 (Figure 3).
Even if this decline is real, it quite possibly is the result of
water being backed up from Waterville Lake.rather than from
any water quality problem. On the date RM 42.6 was sampled,
much of the riffle habitat at this station was inundated, which

reduced sampling effectiveness, especially for the pram
electrofisher, which in turn may have artificially depressed IBI
scores.
IBI scores at all mainstem downstream sites improved
noticeably in 1995 compared to 1987 (Figure 3)...a clear
indication of the fish community responding positively to the
CMP.
Fish Health
Mean Health Assessment Index (HAI) (8,9) scores for adult
redbreast sunfish were distributed as follows:
Mean
HAI
RM E Score
64.5 15 40.0
63 15 37.3
59 15 42.9
55.5 20 37.0
54.5 20 33.0
42.6 10 47.0
19.3/24.9 8 50.5
Thus, scores (33-43) at four of the five North Carolina sites
downstream of the mill were comparable to the score (40) at
the upstream reference station. The scores at RM 42.6 and at
RM 19.3/24.9 were slightly higher (=poorer) than at the
reference station (40). In a previous study of the Pigeon River,
Adams et al. (9) reported mean HAI scores of 60 and 51 for
redbreast sunfish collected at RM 59 and 21.7, respectively.
The score of 51 at RM 21.7 reported by Adams et al. (9) is
nearly identical to the score of 50.5 we found in this same
segment of the river. Adams' et al. (9) score of 60 at RM 59 is
higher (=poorer) than the score of 43 we report for the same
location. Thus we conclude that the health of individual fish
has improved post CMP. Also it is clear that HAI scores are
similar upstream and downstream of the Canton mill,
indicating a lack of impacts to fish health by the Canton mill.
Benthos
The Ephemeroptera (mayflies), which are generally considered
to be one of the most perturbation-sensitive groups of benthic

macroinvertebrates, were the dominant group in the
quantitative samples at the reference station (RM 64.5) and at
RM 24.9. Ephemeroptera also constituted > 10 percent of the
benthic population at RM 52.3 (18 percent), RM 48.2 (15
percent), and RM 42.6 (28 percent). The majority of the
stations downstream of the Canton mill were dominated by
Chironomidae (midge larvae), with relative abundance values
ranging from 36 percent at RM 52.3 to 87 percent at RM 63.0.
Although Chironomidae, which is a moderately tolerant group,
was dominant at many stations, Trichoptera(caddisflies), a
moderately sensitive group, were very abundant as well.
Trichoptera was the dominant group at RM 59.0 and RM 42.6
and the second most abundant group at all other stations
downstream of the Canton mill discharge.
In 1987, the benthic fauna at RM 63 and RM 59, the two
downstream stations closest to the mill, was dominated by
Oligochaetes (aquatic worms) and Mollusca (snails), two
pollution tolerant groups. The density of these tolerant taxa
decreased dramatically at all stations downstream of the
Canton mill, except RM 24.9 and 19.3 where their abundance
was already low in 1987 (Figures 4 and 5) (2). The shift in
dominance at RM 63.0 and RM 59.0 from Oligochaeta and
Mollusca in 1987 to Chironomidae and Trichoptera in 1995,
and the increased abundance of Trichoptera at many other
downstream stations in 1995 are examples of substantial
improvement in the Pigeon River benthic community
downstream of the Canton mill discharge.
Taxa richness in the quantitative samples was lower at all
downstream stations in 1995 than in 1987 due primarily to a
greater majority of tolerant Oligochaeta and Chironomidae
taxa in 1987. However, the number of EPT taxa was higher in
1995 than in 1987 except at RM 48.2, 24.9, and 19.3. This shift
in community structure from a high number of tolerant taxa to
fewer, but more sensitive taxa was apparent throughout
Segment 2 and most of Segment 3, the segments closest to the
mill, another indication of improved water quality in 1995.
EPT taxa richness in the qualitative samples ranged from 9 at
RM 63.0 to 23 at RM 64.5 with a mean of 16 (Table 4). Of
those stations in Segments 2 and 3, the highest number of EPT
taxa (18) was taken at RM 42.6 (which also yielded the highest
number of total taxa). Although EPT taxa richness declined
noticeably at RM 63.0 immediately downstream of the Canton

mill (Figure 6), it immediately rebounded at RM 59.0 and 16-
18 EPT taxa were present throughout the rest of the study
area, except RM 54.5 (Table 4). A second decline in EPT taxa
richness was noted at RM 54.5, downstream of Richland Creek
and the Wavnesville WWTP. The decline at RM 63.0 was due
to a decrease in the number of ephemeropteran taxa from 10
at RM 64.5 to 1 at RM 63.0 (Table 4). The habitat at RM 63
was noticeably poorer than at any other location. Thus, the
decline in EPT taxa richness at RM 63 was probably due, at
least partially, to the noticeably poorer habitat at this location.
Among the mainstem locations, the lowest (i.e.,best) NCBI
value (4.49) occurred at RM 24.9 in Tennessee and the highest
(6.73) (i.e., poorest) at RM 63.0 immediately downstream of
the mill (Table 4). Although NCBI values were highest at RM
63.0, this station as well as all others in Segments 2 and 3 were
classified as"Fair' (Figure 7). This represents only a slight
decline from the"Good-Fair" classification for Segment 1. The
higher (=poorer) NCIBI at RM 63.0 was due to both a
decrease in EPT taxa as well as the presence of more tolerant
taxa, such as Oligochaeta, Chironomidae, and Mollusca.
The final bioclassification for each station, based on the
average of the EPT taxa richness score and NCBI score,
displayed a trend comparable to those observed in the NCBI,
EPT taxa richness, and EPT BI preliminary classifications
(Table 4). The best final bioclassification level assigned to any
of the mainstem stations was"Good-Fair" at RM 64.5, 24.9,
and 19.3 (i.e., Segments 1 and 4). All stations in Segments 2
and 3 were assigned a final bioclassification of"Fait'.
Comparisons between the present study and a 1987 study (2)
demonstrate a substantial improvement in the Pigeon River
benthic community since 1987 (Figures 6 and 8). In 1995, the
average percent increase in the total number of taxa was 49
percent in all segments. This improvement was most evident in
Segments 2 and 3 where total taxa richness improved by an
average of 70 percent. The differences in EPT taxa richness
were even more obvious (Figure 6), an average improvement
of 135 percent. Again, these changes were most obvious in
Segments 2 and 3, where the mean percent increase was 207
percent. Similar results at the reference station (RM 64.5) in
both 1987 and 1995 indicate that the downstream
improvements between 1987 and 1995 are real rather than an
artifact caused by changes throughout the system.

Compositional changes also occurred between 1987 and 1995.
For example, the number of Ephemeroptera taxa collected
between RM 63.0 and 48.2 increased from only one taxon in
1987 to 11 taxa in 1995. Within the same reach, Trichoptera
taxa richness nearly doubled from 8 taxa in 1987 to 15 taxa in
1995.
Of the four stations that would have been classified as"Poor'
in 1987 according to current scoring procedures, three (RM
59.0, 52.3, and 48.2) were elevated to a"Fau° bioclassification
in 1995. Despite an improvement of 50 percent in the number
of EPT taxa from 1987 to 1995, RM 63.0 would still be
classified as"Pooe according to the number of EPT taxa.
In summary, principal findings of the 1995 benthic study were:
1. The macroinvertebrate community at the reference
station upstream of the Canton mill (RM 64.5) was
dominated by mayflies, whereas most locations
downstream of the mill were dominated by midges.
2. The highly tolerant groups (i.e., aquatic worms and
snails) that dominated the community immediately
downstream of the Canton mill in 1987 declined greatly
in abundance in 1995.
3. The variety of pollution sensitive mayflies and
caddisflies increased substantially in the two segments
immediately downstream of the Canton mill.
4. Final bioclassifications, which consider both the biotic
index scores and EPT taxa richness, placed the
reference station (RM 64.5) and the two Tennessee
stations (RM 24.9 and 19.3) in the good-fair category,
and all other stations in the fair category.
5. Stations previously rated as poor in 1987 all improved
to fair in 1995.
SUMMARY AND RECOMMENDATIONS
Compared to pre-CMP in 1987, conditions in 1995 can be
described as follows:
• water quality has improved noticeably; dissolved oxygen
levels are higher while nutrient and contaminant levels are
lower,

• habitat conditions are generally good and probably do not
limit the aquatic fauna appreciably,
• the fish community has improved measurably as
demonstrated by:
(1) higher species richness at all locations
downstream of the mill, and
(2) higher IBI scores at all downstream locations
• The condition of individual fish is generally good and
unaffected by mill effluents as evidenced by similar K-
factor, W„ and HAI scores upstream and downstream of
the Canton mill,
• the benthic community has also improved measurably as
indicated by:
(1) greater total taxa richness
(2) higher numbers of EPT taxa
(3) better Biotic Index scores
(4) a decline in tolerant organisms (e.g., worms and
snails) downstream of the mill
Thus, overall it is clear that the aquatic biota of the Pigeon
River has improved considerably as a result of the CMP.
We recommend that similar surveys be conducted at 2-3 year
intervals in the future to assess changes that may not be fully
manifested as a result of the CMP.
REFERENCES
1. North Carolina Dept. Environmental Health and Natural
Resources (DEHNR),"Standard Operating Procedure for
Biological Monitoring, January 1995", North Carolina
Department of Environmental Health and Natural Resources,
Division of Environmental Management, Water Quality
Section, Raleigh, NC, (1995).
2. EA Engineering, Science, and Technology, Inc.,"Synoptic
Survey of Physical and Biological Condition of the Pigeon
River in the Vicinity of Champion International's Canton
MiT, EA Engineering, Science, and Technology, Inc., Sparks,
MD, (1988).

3. Savior, C.F., McKinnev, A., and Schacher, W., TVA Biol.
Rpt. 19,"Case Study of the Pigeon River in the Tennessee
River Drainage", TVA, Norris, TN, (1993).
4. Ohio Environmental Protection Agency,"Biological Criteria
for the Protection of Aquatic Life: Vol. III. Standardized Field
and Laboratory Methods for Assessing Fish and
Macroinvertebrate Communities', Div. Water Quality
Monitoring and Assess., Surface Water Sect., Columbus, OH,
(1989).
5. Carlander, K.D.,Handbook of Freshwater Fishery Biology,
Vol. 1. Life History Data on Freshwater Fish of the United States
and Canada, Exclusive of the Perciformes, Iowa State University
Press, Ames, Iowa, 1969, 752 p.
6. Wege, G.J. and Anderson, R.O.,New Approaches to the
Management of Small Impoundments, "Relative Weight (W,):
A New Index of Condition for Largemouth Bass", G.D.
Novinger and J.G. Dillard, eds., North Central Division,
American Fisheries Society, Special Publication 5, 1978, pages
79-91.
7. Karr, J., Fausch, K.D., Angermeier, P.L., Yant, P.R.,
Schlosser, I.J.,Ill. Nat. Hist. Surv. Spec. Publ. 5, "Assessing
Biological Integrity in Running Waters: A Method and its
Rationale", Champaign, 111 (1986).
8. Goede, R.W. and Barton, B.A.,"Organism Indices and an
Autopsy-Based Assessment as Indicators of Health and
Condition of Fish", American Fisheries Society Symposium,
8:93-108 (1990).
9. Adams, S.M., Brown, A., and Goede, R., Trans.Am. Fish.
Soc., "A Quantitative Health Assessment Index for Rapid
Evaluation of Fish Condition in the Field", (122):63-73 (1993).
10. Menhinick, E.F., The Freshwater Fishes of North
CarolingThe Delmar Company, Charlotte, NC, 1991.
11. Etnier, D.A., and Starnes, W.C.,.The Fishes of Tennessee,
Univ. Tenn.Press, Knoxville, TN, 1993, 681 p.
12. Fore, L.S. and Karr, J.B., Can J.Aquatic ScL, "Statistical
Properties of an Index of Biotic Integrity Used to Evaluate
Water Resources", 5:1077-1087 (1994).

TABLE 1 NUMBER AND SPECIES OF FISH COLLECTED ELECTROFISHIN• FROM THE MAIN T M PIGEON RIVER AUGUST-S PT MB R 1995
LOCATION
North Carolina Tennessee
64.5 63.0 59.0 55.5 54.5 52.3 48.2 42.6 24.9 19.3
Up/s d/s up/s d/s d/s Old Ferguson New d/s Bluffton
Mill Mill Clyde Clyde Richland Rt. 209 Bridge Hepco CPBL TN TOTAL
SPECIES _ _ _ _ Crk• Bridge
SPORT FISH RAINBOW TROUT -- -- -- -- -- -- -- -- 3 3 6
BROWN TROUT 2 -• -- -- -- -- -- 1 -- -- 3
UNID BULLHEAD -- -- -- -- -- -- -- 1 -- -- 1
FLATHEAD CATFISH -- -- -- -- 1 -- -- 1 -- -- 2
ROCK BASS 78 13 B 3 6 3 1 -- 8 2 122
REDBREAST SUNFISH 29 77 119 192 132 177 112 18 5 12 873
GREEN SUNFISH -- 13 7 2 6 1 9 -- -- -- 38
WARMOUTH -- -- 1 -- -- -- -- -- -- -- 1
BLUEGILL -- -- 1 3 4 1 6 33 6 1 55
HYBRID SUNFISH -- 1 -- -- 1 -• -- 1 -- -- 3
SMALLMOUTH BASS 3 2 3 2 3 11 3 1 40 24 92
SPOTTED BASS -- -- -- -- -- -- -- -- -- 1 1
LARGEMOUTH BASS 2 2 1 4 11 8 3 14 2 -- 47
BLACK CRAPPIE -- -- 1 9 30 11 6 2 -- -- 59
SAUGER -- -- -- -- -- -- -- -- -- 2 2
WALLEYE -- -- -- -- -- -- -- -• 1 -- 1
FRESHWATER DRUM -- -- -- -- -- -- -- -- -- 2 2
SPECIMEN SUBTOTAL 114 108 141 215 194 212 140 72 65 47 1308
NON-SPORT FISH OHIO LAMPREY -- -- -- -- -- -- -- -- -- 1 1
GIZZARD SHAD -- -- -- -- -- -- -- -- 23 156 179
CENTRAL STONEROLLER 30 1 83 17 7 68 40 3 8 147 404
GOLDFISH 2 -- 3 19 11 -- 4 -- -- -- 39
COMMON CARP -- 6 14 20 17 16 13 -- •- -- 86
BIGEYE CHUB -- -- -- -- -- -- -- -- -- 1 1
RIVER CHUB 147 3 23 1 -- -- -- 3 -- -- 177
GOLDEN SHINER -- -- -- 1 -- -- -- -- -- -- 1
WARPAINT SHINER 32 -- 6 -- -- -- -- -- -- -- 38
WHITETAIL SHINER 6 2 16 36 15 16 22 3 53 32 203
SILVER SHINER -- -- -- -- -- -- -- -- -- 6 6
SAFFRON SHINER 3 -- -- -- -- -- -- -- -- -- 3
MIRROR SHINER 18 -- -- -- -- -- -- -- -- -- 18
BLACKNOSE DACE -- -- -- -- -- 1 •- -- -- -- 1
LONGNOSE DACE -- -- 1 1 -- 1 4 1 -- 2 10
WHITE SUCKER -- -- -- 1 6 12 4 -- -- -- 23
NORTHERN HOG SUCKER 37 18 67 50 58 49 54 74 19 137 563
SMALLMOUTH BUFFALO -- -- -- -- -- -- -- -- -- 3 3
BLACK REDHORSE 8 5 -- -- -- 2 1 1 -- 7 24
GREENSIDE DARTER -- -- -- -- -- -- -- -- 29 28 57
GREENSIDE DARTER (gutselli) 41 -- -- -- -- -- 1 -- -- 4 46
GREENSIDE DARTER (newmani) -- -- -- -- -- -- -- -- -- 12 12
GREENFIN DARTER 83 -- -- 1 -- -- -- -- -- -- 84
REDLINE DARTER -- -- -- -- -- -- -- -- 1 31 32
SNUSNOSE DARTER -- -- -- -- -- -- -- -- -- 21 21
TANGERINE DARTER 28 1 -- •- -- -- -- -- -- -- 29
LOGPERCN -- -- -- -- -- -- -- -- 27 41 68
MOTTLED SCULPIN 33 -- -- -- -- -- -- -- -- -- 33
BANDED SCULPIN -- -- -- -- -- -- -- -- 63 69 132
SPECIMEN SUBTOTAL 470 36 213 147 114 165 143 85 223 698 2294
TOTAL SPECIMENS 584 144 354 362 308 377 283 157 288 745 3602
TOTAL SPECIES 18 12 16 17 14 15 16 14 15 23 43

Table 7 Longitudinal distribution of fiches in the Pion River mainstem August and September 1995
Species restricted to Species restricted to Species restricted to or
Species distributed or much more abundant or much more abundant most abundant between
throughout the upstream of the downstream of Waterville Lake and
study area Canton mill CP&L Hydro Plant Canton mill
Redbreast sunfish River chub Gizzard shad Common carp
N. hog sucker Greenfin darter Banded sculpin Black crappie
Central stoneroller Greenside darter Logperch Bluegill
Whitetail shiner (g rt�lli subsp.) Redline darter Goldfish
Rock bass Warpaint shiner T. snubnose darter Green sunfish
Smallmouth bass Mottled sculpin Greenside darter White sucker
Largemouth bass Tangerine darter (newmani subsp.)
Black redhorse Mirror shiner Rainbow trout
Saffron shiner Silver shiner
Smallmouth buffalo
Sanger
Freshwater drum
Spotted bass
Walleye
Ohio brook lamprey
Bigeye chub

Table 3. Measured values and associated IBI metric scores (in parenthesis) for Pigeon River mainstem and tributary locations,
Aug tc�__t/September 1995
Nveon River Mainslen _ Tributaries
Richland Jonathan Fines
Metric 59 ad LI 52.2 4U 42.5 242 12.3 Creek Creek Creek
No. of Species I8 (5) 12(3) 16(3) 17 (5) 14 (3) 15 (3) 16 (3) 14 (3) 15 (3) 23 (5) 11 (3) 14 (3) 6 (1)
No. of Individuals 584 (5) 144 (I) 354 (3) 362 (3) 308 (3) 377 (3) 283 (3) 157 (l) 288 (3) 745 (5) 98 (1) 455 (5) 144 (1)
(shock only)
No. of Darter spp. 3 (5) 1 (3) 0 0) l (3) 0 (1) 0 (1) 1 (3) 0 (1) 3 (5) 4 (5) 0 (l) 2 (3) 1 (3)
No. of Sunfish +
Sahnonid spp. 3 (5) 3 (5) 5 (5) 4 (5) 4 (5) 4(5) 4 (5) 3 (5) 4 (5) 4 (5) 4 (5) 4 (5) I (3)
No. of Sucker spp. 2(5) 2 (5) 1(3) 2 (5) 2 (5) 3 (5) 3 (5) 2(S) 1 (3) 3 (5) 1 (3) 4 (5) 2 (5)
No. of Intolerant spp. 2(3) 1 (3) 0 0) 1 (3) 1 (1) 0 (1) 0(1) 0(1) 0 (1) 1 (3) 0 (1) l (3) 1 (3)
Percent Tolerant Fish 0.2(5) 13.1 (S) 6.8 (5) 11.0 (5) 11.0 (5) 4.5 (5) 9.2(5) 0.6 (5) O(S) 0 (5) 6.1 (5) 0 (5) 0 (5)
Percent Orunivores 24.6 (3) 6.3 (5) 11.3 (5) 11.6(5) 11.0 (5) 7.4(5) 7.4 (5) 1.9 (5) 0(5) 0.3 (5) 2.0 (5) 4.4 (5) 2.8 (5)
Percent Insectivores 14.5 79.9 (3) 59.6 (3) 78.5 (3) 69.8 (3) 65.8 (3) 74.9 (3) 84.1 (5) 51.7(3) 35.7(1) 80.6 (5) 71.0 (3) 73.6 (3)
(or % Specialized
Insectivores) 47.4 (3) 0.7 1.7 0.3 0 0 0.4 0 1908 19.3 0 SA 1.4
No. of Piscivorous spp. 3 (5) 3 (5) 4 (5) 4 (S) 5 (5) 4(S) 4 (5) 4 (5) 4 (5) 4 (5) 2 (5) 2 (5) 0 (1)
% Diseased 0 (5) 2.7 (3) 0 (5) O(S) 5.2 (1) 1.1 (5) 1.4 (5) 2.5 (3) 0.7 (5) 0.1 (5) 0 (5) 0.7 (5) 0 (5)
% of Species with
multiple age classes 67 (5) SO (5) 69 (S) 47 (5) 71 (5) 60(5) 44 (5) 36 (3) 67 (5) 57 (5) 36 (3) 57 (5) 50 (5)
Total IBI Score 54 46 44 52 42 46 48 42 48 54 42 52 40
Inlegrity Class Goal/ Fair/ Fair Good Fair Fair/ Good Fair Good Good/ Fair Good Fair
Excellent Good Good Excellent

Table 4. Summary of data for qualitative collections from the Pigeon River drainage August and September- 1995
Pigeon River Stations (RM) Richland Jonathan Fines
b4..5 b3,4 52-0 5L5 5Ld 52.I 4&2 42-6 24,2 12.a Creek Greek Creek
Total Taxa 61 46 53 56 55 48 46 60 43 49 45 55 55
Total EPT Taxa 23 9 16 16 13 17 16 18 18 16 14 20 18
Total Ephemeroptera Taxa 10 1 4 2 5 7 9 9 11 9 7 11 10
Total Trichoptera Taxa 9 7 9 11 8 8 7 6 5 4 5 5 5
Total Diptera Taxa 21 15 15 19 20 16 16 19 13 15 15 21 22
Total EPT Abundancet't 75 37 54 50 34 79 76 74 88 84 65 82 86
EPT BI Score 3.12 4.37 4.12 4.22 4.37 4.46 4.23 4.16 3.31 3.88 4.31 3.10 4.02
NCBI Score 5.03 6.73 6.05 6.23 6.45 6.25 6.07 5.90 4.49 5.12 5.52 4.18 5.36
Final Bioclassification(b) G-F F 14 F F F F F G-F G-F G-F G-F G-F
t'1 Sum of assigned abundance values given to individual taxa based on the number/sample, 1= 1-2/sample, 3=3-9/sample,
10=z 10/sample
rol E=Excellent, G=Good, G-F=Good-Fair, F=Fair, and P=Poor

Bluflom TH H"04 TH
(192)
Below Powerhouse
st W TENNESSEE N
Above Cosby (2/.7) ,/•�.,
Creek �.._..i' �..�.._..�
(IU) ./ NORTH
CAROUNA
(P5.9)
e
n11
NOTE: Rlvu mlln of matnatnam camping location ar
Hydra Plant if
tributary mouth shorn in pusnlhaaea.
(26.0)
Water OuaHy.Fish,Benlhos,Periphl90
6 Ir
1a i1, O Water Ouafty,Fish.Sengws
9
\� E3 Water Ouaary Only
Fish,Beneos.Pedplyton
Waken,Oam KabrWle take
Cawoorlwe
Croak Hap=,NC
(3L1) (416) Crack
f (42.7) CrAW"Creak
Nw He Bridge Rlventldo WaBI
Hepco Gaga (aLl)
(45.1) Above Crabtree
FLOW (532)
doneorant
Creek Clyde W WTP
(46D) (57.11
Below Clyde
Ferguson,Bridge (5U) Above Clyde RbuNae
(59.0) Fberville (6�)
Below Mill Ounak
Waynuville WWTP (632) ContoR NC
(54S)
W�viige RkAland CNde,NC Canton
Creak (64s (65s
(54a) (54•9) Pien Farm
Addluon
r
Figure 1. Stations for the water quality,periphyton,fisheries,and benthie surveys,AugustfSeptember 1995.

FIGURE 2. COMPARISON OF THE NUMBER OF FISH SPECIES COLLECTED AMONG PIGEON RIVER
MAINSTEM LOCATIONS, 1995.
2s
24 ..........................................................................................................................................................................................................................._.................................................................................................................
22 ......................................................_............................................................................................................................................................................................................._..........................................
................... ........
20 ............................................................................................................................................................................................................................................................................................................................ .................
18 . .....................................:.....................................................................................................................................................................................................................
..........................................................................
w16 ....... ............................... ......................... ............................................... ..........................................................................................................................................................................................................
U
W
w14 ........................... ................................................. ..............................................................................
U.
O
12 ............
m
10
Z
8 ..............................._................................................................................................................._........................................................................................................................_.................................................................
g ......................................................................................................................................................................................._................................_.
q ...............................................................................................................................................................................................................................................................................................................................................
CANTON RICHLAND WAYNESVILLE JONATHAN CRK. WALTERS DAM CP&L HYDRO
MILL CRK. WWTP DISCHARGE
2 ............. ....................................................i'*****.................................................. .............................................................................t...............................................
D �
64.6 69 64.6 48.2 24.9
63 66.6 62.3 42.6 19.3
RIVER MILE

FIGURE 3. COMPARISON OF NCIBI SCORES IN THE MAINSTEM PIGEON RIVER BETWEEN 1987 AND 1995.
60-
1995 EXCELLENT
56-
GOOD-EXCELLENT
50- GOOD
46- FAIR-GO
FAIR
40- 1
........+ POOR-FA IR
.........................
..............
4................... ..........0 35 . ... .
...........
0
V) 30- POOR
Z 26- VERY POOR-POOR
20-
16- VERY POOR
10- CANTON RICHLAND WAYNESVILLE JONATHAN CRK. WALTERS DAM CP&L HYDRO
MILL CRK. W)AITP DISCHARGE
6- 1 � #
0-T- 111111111ii TTTTTTT 111111iiIIIIII -FTTTTTTT-T-1 I I I I I I I I I I iiiiiiiiiiFTT
64.6 59 64.6 48.2 24.9
63 66.5 62.3 42.6 19.3
RIVER MILE

- .IGURE4. COMPARISON OF OLIGOCHAETj zNSITIES IN THE MAINSTEM PIGEON RIVE. .
BETWEEN 1987 AND 1995.
7940.1 8411.0 3781.7 1303.3
1000- ....... I
............ ...............
900-
.%
600- %
700-
cc 1987
tu
LU 600-
LU
0:
600 i
a %
w
cc
LU
9L 400O
-
z
300- 11995
:CANTON CP&L HYDRO
MILL DISCHARGE
200-
WAYNESVILLE
100 JONATHAN CRK WALTERS DAM
- WWTP
.. ...........................
0
�#Fffff I"I I
64.6 59 64.6 48.2 24.9
63 66.6 62.3 42.6 19.3
RIVER MILE

FIGURE 5. COMPARISON OF MOLLUSCA -'NSITIES IN THE MAINSTEM PIGEON RIVEI .
BETWEEN 1987 AND 1995.
5376.0 1062.2 1318.3
1000-
900-
800-
4
700-
cc
Lu
LU 600-
Lu
It
=0 600-
a
U)
ILI
0. 400-
c;
z
300-
ICANTON
MILL 1995
WALTERS DAM
200-
JONATHAN CRK-
WAYNESVILLE CP&L HYDRO
100- WWTP DISCHARGE
0 Fri I I 1 1, 1 1 1 1 1 I-Fl I I I I I I I I I I I I I I I I I I I I I
64.5 59 64.6 48.2 24.9
63 1536.5 62.3 42.6 19.3
RIVER MILE

FIGURE 6. COMPARISON OF QUALITATIVE EPT TAXA RICHNESS IN THE MAINSTEM PIGEON RIVER
BETWEEN 1987 AND 1995.
26-
FAIR-GOOD
20-
1995
FAIR
IL ......
Lu
LL ............................................ ........
....................
0
m
10-
z
POOR
6-
CANTON ................................. JONATHAN CRK. WALTERS DAM CP&LHYDRO
MILL RICHLAND ......_F DISCHARGE
CRK. WAYNESVILLE
i AAr VAvTp
0-IF FT-, TT7 1111111111111 rrTTTTT- 1111111111111
64.6 59 54.5 48.2 24.9
63 66.6 62.3 42.6 19.3
RIVER MILE

FIGURE 7. COMPARISON OF QUALITATIVE BI SCORES AMONG MAINSTEM PIGEON RIVER LOCATIONS, 1995.
WORST 8
7.8
7.6
POOR
7.4
7.2
7
6.8
6.6
6.4 FAIR
a 6.2
U 6
U)
on 6.8
6.6
6.4
FAIR-GOOD CP&L HYDRO
6.2 DISCHARGE
6
4.8
4.6 CANTON RICHLAND WAYNESVILLE JONATHAN CRK. WALTERS DAM
4.4 MILL CRK. WWTP GOOD
4.2 1BEST 4
64.5 69 64.5 48.2 24.9
63 56.6 62.3 42.6 19.3
RIVER MILE

FIGURE 8. COMPARISON OF QUALITATIVE TOTAL TAXA RICHNESS IN THE MAINSTEM PIGEON RIVER
BETWEEN 1987 AND 1995.
66
60
66
60 + 1995
46
-}.,.
....................................
N 40
1987
W
= 36
;.
it
30 ....+
~ 26
20 }
16
10 CANTON RICHLAND WAYNESVILLE JONATHAN CRK. WALTERS DAM CP&L HYDRO
MILL CRK. WWTP DISCHARGE
61 'A� i
64.6 69 64.6 48.2 24.9
63 66.6 62.3 42.6 19.3
RIVER MILE

State of North Carolina
Department of Environment
and Natural Resources
Division of :"later Quality •
James B. Hunt, Jr., Governor
Wayne McDevitt. Secretary ® L
A. Preston Howard, Jr., P.E.. Director 1 V
December 22. 1997 Received
EOH$S
DEC 2 9 1997
Champion Int. Corp.
Mr. William,blanzer, Vice President and Operations Manager. i
Champion Intemational Corporation
P.O. Box 4000
Canton. North Carolina 23716
Subject: NPDES Pennit Modification
Permit INC). -C0000272
Champion International
Haywood County
Dear Mr. Manzer:
In accordance with the 1997 Settlement Agreement retarding the 1996 Color Variance and
NPDES Permit for the Canton facility, we are forwarding herewith the modified State-NPDES Permit
to discharge. This modification 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 December 6, 1983 and as subsequently amended.
Note that the changes to the December 12, 1996 permit reflected in the attached modified permit
address only those conditions of the original permit modified by the Settlement Agreement and North
he
Carolina's Revised Color Variance. T permit doesn't contain all the provisions of the Agreement or
the Revised Variance. Those non-permit related conditions are enforceable under the provisions of the
Agreement and Revised Variance and are considered "freestanding." Therefore. please refer to the
permit, the Agreement, and the Revised Variance for all the administrative, procedural and regulatory
requirements related to water quality and the Canton Mill.
In accordance with the Agreement, Champion has agreed to accept the attached modified permit
provided that the modifications are consistent with the Senlement. If any parts. measurement
frequencies or sampling requirements contained in this permit are considered to be inconsistent with the
1997 Settlement Agreement, that dispute is to be resolved in accordance with the procedures outlined in
Pan VII of the Settlement Agreement.
Please take nor_r: that this permit is not transferable without authorization from the Division of
Water Quality. Part II, E.4. and Part III F. 3 addresses the requirements to be followed in case of
change in ownership or control of this discharge.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/10%post-consumer paper

Mr. William lfanzer
December_'=. 1997
Page Two
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
.-Urea Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Ms. COleen Sullins at telephone
number 9191733-5083, extension 550, Mr. Dave Goodrich at telephone number 919/733-5083,
extension 517 or-Mr. Forrest R. Westall at telephone number 704/251-6208. extension 251.
Sincerely,
A. Preston Howard. Jr.. P.
cc: Central Files
Mr. Roosevelt Childress, EPA
Asheville Regional Office/VVater Quality Section
NPDES Unit
Planning & Assessment Unit
Aquatic Toxicology Unit
Mr. Richard Diforio. Jr.
Paul Davis

Permit No. NC0000272
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compiiance with the provision of North Carolina General Statute 143-215.1. other lawful standazds
and resulations promuigated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended.
Champion International Corporation
is hereby authorized to discharge wastewater from a facility located at
Champion Canton Mill Wastewater Treatment Plant
off Highway 213
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.
The permit shall become effec[ive December 31, 1997.
This permit and the authorization to discharge shall expire at midnight on November 30, 2001.
Signed this day December 22, 1997. l
Q I
A. Preston Howard, Jr., P.E. i eector
Division of Water Quality
By Authority of the Environmental Mangement Commission

Permit NO. \C0000272
SUPPLEMENT TO PER-%UT COVER SHEET
Champion International Corporation
Canton \fill Wastewater Treatment Plant
is hereby authorized to:
1• Continue to operate an existing wastewater treatment facility for the treatment of wastewater
ands water. ter associated with the pulp and paper mill. the Town of Canton's chlorinated domestic
wastewater. and Champion's landfill leachate consisting of a grit chamber. bar screens, lift pumps.
Polymer addition. pH controi (CO2 injection or H2SO4 backup), three primary clarifiers. nutrient
feed. aeration basins, three secondary clarifiers, residual belt presses, effluent flow measurement.
cascade aeration (with oxygen injection), and oxygen injection facilities (as specified Part III.
Condition I) located at the Champion Canton Mill Wastewater Treatment Plant, off Highway 215.
Canton, Haywood Count%. and
2. Discharge from said treatment works at the location specified on the attached map into the
Pigeon River which is a Class C waters in the French Broad River Basin.

A. (1). EFL > �r NT LIMITATIONS AND MONITORIN(i REQUIREMENTS FINAL
I'crniit No . N(:00002y2
During file period beginning on the el'I'eclive date of the pert,if and lase jig until cxpiralioo of Ibe Perini 1. the Perini[ice is authorized w diseh;u ge hum uu dal I(s)
serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations Jt"Wo-rin -__ge u emn Lbsldav � a_1L ts
Units (� 11fYJ �e_
M
Mon. Avg, P;111 gil.S_tLLepteal �ampls .. 'S:dnl(llc
Y_MM M9a, Avg
Flow �ilx—r7ax. Etegyencyr__ SYee 1-ocation
BODs 29.9 MI Continuous Recording I of E
3598.0 12458.0 Daily y Composite E.1
TSS 12549.0 49560.0 Weekly Composite E
NH3-N Daily Composite E,I
Fecal Coliform Daily Composile L
Dissolved oxygen 2 200 /100 ml 400 /100 ml Weekly Grab E
Total Nitrogen (NO2 + NO3 + TKN) Daily Grab E
Total Phosphorus Monthly Composile E
Temperature 3 Monthly Composile E
Chronic Toxicity 4 Dail
Grab L
Total Residue Quarlcrl
Y Cornpusnu
Total Dissolved Solids Daily Composile E
Hardness Daily Composile t-
Mercury 5 014 2/Month Composile E
It 2/Month Grab E
I Sample locations: F - Effluent. 1 - Inllucui. Instreamm sopling is specified in fall I, A (2).
2 The daily average dissolved oxygen el'Iluenl conccllb:diun shall nut he less than 6.0 mg/I. See part 1, Section A (2)and P;of 111. Condition I.
3 The monthly average insircam temperature measured at if point 0.4 miles downstream of the discharge location shall nut exceed 32.0"C during [Ile months of July, August, and
September and shall not exceed 29.0°C during the months of October through June. The monthly average instremn lcmperaturc measured at this location shall ❑ol exceed the
monthly average insircam temperature of the upstream monitoring location by more than 13.9°C. See Parr Ill, Condition L.
4 Chronie'l'oxicity'1'esling al 87 1X; March, June, September, and December; See Part Ill. C'ondiliun G.
5 Values delected at less than 0.2 fig/I will be considered zeu, fur purposes of cuuq,liance.
The effluent pH shall not be less than 6.0 standard unils nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other(Iran trace amounts.

A. (I). EF. —,, NT LIMITATIONS AND MONITORING REQUIREMENTS FINAL ((2onitnual)
I'crntil No. N('0000272)
During the period beginning on the criective date of the permit and lasting until expir:dion of the permit, the PenoiIlee is authorized lu discl III gC Ii"i uullaII(sl
serial number001. Such discharges shall be limited and monitored by the pennillec as specilied below:
Effluent -ha.a..+
D haroe Limitation I M-Qnitoripg__gequfteUlen(;,
Units (-U=iw
_ 10 as ur eofUSn`Avg. Q MQ11, Avg, Daily _bax, Frcquetcy Tync I ocolionTrlchlorophenol ax, -�5atnPle_ t5amPle
ally
Pentachlorophenol Quarterly Composite E
Zinc Quarterly Composite E
Cadmium 2/Month Composite E
Selenium Quarterly
Y Composite E
Silver
SOX Quarterly Composite E
Quarterly Composite E
2,3,7,8 Telrachloro-dibenzo-p- Monthly Composite E
dioxin (See Part III, Condition H) 0.1 p9/l Quarterly Composite E
Color (See Part III, Condition E)
Conducllvily Daily Composite E.1
pH Daily Grab E
Daily Grab E

Part I NPDES \',. NC0000272
A- (2). 1NSTRE:\\I %IONI T CR:NG REQUIRE\TENTS
Stream Mile Location Description Parameter Frequency
Designation Marker q
LP - 64.5 Pigeon River upstream of the Temperature Daily
.vaste treatment Dlant outfall D.O. Daily
.::nor to miffing with the BOD5 I/Week
aschame; Conductivity Daily
Color ` 2/Week
Flow ` Daily
Fecal coliforrn I/Week
DNI 62.9 Pigeon Rner a[Fibervdle Bnd_= Temperature Daily
D.O. Daily
Conductivity Daily
Fecal Coliform I/Week
DN2 Color • 2/Week
57.7 Pigeon R ver Above Clyde Temperature Daily
D.O. Daily
DN3 55.5 Pigeon River Below Clyde Temperature I/Week
D.O. Meek
DN4 Color • 2/Week
53.5 Pigeon River at NCSR 1625 Temperature 1/Week
b4fze D.O.
- I/Week
DNS Color ' 2/Week
42.6 Pigeon River at Hepco Temperature I/Week
D.O. 1/Week
Color " 2/Week
Flow ' Daily
Waterville Reservoir (See Part III. Condition Annually
DN6 - -- - --..
26.0 Pigeon River prior to mixing Color ' 2/Week
with Big Creek -
BC - 26.0 Mouth of Big Creek prior to Color • 2/Week
mixing with the Pigeon River
D`17 24.7 Pigeon River at Browns Bridge Temperature 1/Week
(-NC/rN State Line) D.O. I/Week
BODS Meek
Color i 2/Week
All instream samples shall be grab samples.
' Color(Additional, See Pan III.Condition E) All instream samp!es collected for these streams shall be
representative of the Pigeon River and Big Creek.respectively. Bch true and apparent color shall be monitored using
the methods specified in Part III• Condition E. Samples shall be ceilected at stations DN&BC,and DN7 only during
times when at least one generator at CP&L is in operation and rel:sing water to the Pigeon River. Flow monitoring
is necessary,as specified above, for the True Color calculation stip_lated in Part III•Condition E.
Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River.'file 62.9 (DN1),57.7
(DN2),and 55.5 (DN3)shall not be less than 5.0 mg/I and the inst_ntaneous minimum dissolved oxygen
concentration shall not be less than 4.0 mg/l (See Part III, Condition 1).

PART :
`�cnon ? :.•he.;,.to of r'.,....,iiznce
1. The rn ;;ee shall comply with Fi ai E: uent L:-titatto-s sceclfied for d;;&a:ees in accordance
with the following scheduie:
Permt:tee shall comply with Finai H"Itient Limitations by the eifecttce date of the permit unless
specified below.
2. Permtttee shall at all times provide the operation and maintenance necessary to operate the
existing facilities at optimum eifinenw.
3. No later than 14 calendar days following a date identified in the above schedule of compliance,
the permittee shall submit either a report of progress or, in the case of specific actions being
required by identified dates, a written notice of compliance or noncompliance. In the latter case,
the notice shall include the cause of noncompliance, any remedial actions taken, and the
probability of meeting the next schedule requirements.

Pan if
Pasc i of 14
PART 1!
ST \'DARD CONDITIONS FOR \ DS.P_RMITS
2ECI ON _ T-)Em\'1TIONS
1. Permit I«uinr Authoriry
The Director of the Division of Water Qualitv.
2. 2EIv1 or Division"
Means the Division of Water Quality, Department of Environment, Health and Natural Resources.
3. EMC
Used herein means the North Carolina Environmental Management Commission.
4. Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended,33 USC
1231,et.sea.
5. Mass/Dav Measurements
a. The "monthly average discharge' is defined as the total mass of all daily discharges sampled
and/or measured during a calendar month on which daily discharges are sampled and
measured, divided by the number of daily discharges sampled and/or measured during such
month. It is therefore, an arithmetic mean found by adding the weights of the pollutant found
each day of the month and then dividing this sum by the number of days the tests were
reported. The limitation is identified as "Monthly Average" in Part I of the permit.
b. The "weekly average discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar week (Sunday- Saturday) on which daily discharges are
sampled and measured, divided by the number of daily discharges sampled and/or measured
during such week. It is, therefore, an arithmetic mean found by adding the weights of
pollutants found each day of the week and then dividing this sum by the number of days the
tests were reported. This limitation is identified as "Weekly Average" in Part I of the permit.
c. The "maximum daily discharge" is the total mass (weight) of a pollutant discharged during a
calendar day. If only one sample is taken during any calendar day the weight of pollutant
calculated from it is the "maximum daily discharge." This limitation is identified as "Daily
Maximum," in Part I of the permit. '
d. The "average annual discharge- is defined as the total mass of all daily discharges sampled
and/or measured during the calendar year on which daily discharges are sampled and
measured, divided by the number of daily discharges samples and/or measured during such
year. It is, therefore, an arithmetic mean found by adding the weights of pollutants found each
day of the year and then dividing this sum by the number of days the tests were reported. This
limitation is defined as "Annual Average" in Part 1 of the permit.

Part II
Page 3 of 14
o. Concentra^c- to=_suremer:
a. The "average monthly concentration,' other than tor tecai col:iorm bacteria, is the sum of the
concenaations of all daily discharges sam::ed andior measured during a calendar month on
which daily discharges are sampied and measured, divided by the number of daily discharges
sampied and/or measured during such month (arithmetic mean of the daily conrencation
values). The daily concentration value is equal to the concentration of a composite saziple or in
the case of grab samples is the arithmetic mean (weighted by flow value) of all Lie samples
collected during that calendar day. The average monthly count for fecal coliform bacteria is
the geometric mean of the counts for samples collected during a calendar month. This
limitation is identified as "Monthly Average" under "Other Limits" in Part I of the permit.
b. The "average weekly concentration," other than for fecal coliform bacteria, is the stem of the
concentrations of all daily discharges sampled and/or measured during a calendar week
(Sunday/Saturday) on which daily discharges are sampled and measured divided by the
number of daily discharges sampled and/or measured during such week (arithmetic mean of the
daily concentration values). The daily concentration value is equal to the concenaation of a
composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day. Tne average weekly count for
fecal coliform bacteria is the geometric mean of the counts for samples collected during a
calendar week. This limitation is identified as "Weekly Average" under "Other Limits" in
Part I of the permit.
C. The "maximum daily concentration" is the concentration of a pollutant discharz? during a
calendar day. if only one sample is taken during any calendar day the conr�n of
pollutant calculated from it is the "Maximum Daily Concentration". It is identified as -Daily
Maximum" under "Other Limits" in Part I of the permit.
d. The "average annual concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a Galen-,_ year on
which daily discharges are sampled and measured divided by the number of daily disharges
sampled and/or measured during such ,year (arithmetic mean of the daily cc..ceu--ation
values). The daily concentration value is equal to the concentration of a composite sa�or in
the case of grab samples is the arithmetic mean (weighted by flow value) of all :e samples
collected during that calendar day . The average yearly count for fecal coliform ba�.z is the
geometric mean of the counts for samples collected during a calendar year. This IL-timiion is
identified as "Annual Average" under "Other Limits" in Part I of the permit.
e. The "daily average concentration" (for dissolved oxygen) is the minimum allowable amount of
dissolved oxygen required to be available in the effluent prior to discharge averapied over a
calendar day. If only one dissolved oxygen sample is taken over a calendar day, to sample is
considered to be the "daily average concentration" for the discharge. It is identified as-daily
average" in the text of Part I.
f. The "quarterly average concentration" is the average of all samples taken over a aiendar
quarter. It is identified as "Quarterly Average Limitation" in the text of Part I of he permit.
g. A calendar quarter is defined as one of the following distinct periods: January through March,
April through June,July through September,and October through December.

Pan i i
t -- of 14
Other "a� _reme
a. Flow, Flow iinit expressed in this -t:t is the 24 hours a•:era¢e flow, averaged
montitiv. It is determmeo as the arithmetic mean of me total daily ;'ows recorded during the
calendar month.
b. An "instantaneous flow measurement' is a measure of flow taken at the time of sampling, when
both the sample and flow will be representative of the total discharge.
C. A "continuous flow measurement'is a measure of discharge flow from the facility which occurs
continually without interruption throughout the operating hours of the facility. Flow shall be
monitored connnually except for the infrequent times when there may be no flow or for
infrequent maintenance activities on the flow device.
8. Types of Samples
a. Composite Sample: A composite sample shall consist of:
(1) a series of grab sampies collected at equal time intervals over a 24 hour period of discharge
and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(2) a series of grab samples of equal volume collected over a 24 hour period with the time
intervals between samples determined by a preset number of gallons passing the sampling
point. Flow measurement between sample intervals shall be determined by use of a flow
recorder and totalizer, and the present gallon interval between sample collection fixed at
no greater than 1/24 of the expected total daily flow at the treatment system, or
(3)a single, continuous sample collected over a 24 hour period proportional to the rate of flow.
In accordance with (1) above, the time interval between influent grab samples shall be no
greater than once per hour, and the time interval between effluent grab samples shall be no
greater than once per hour except at wastewater treatment systems having a detention time of
greater than 24 hours. In such cases, effluent grab samples may be collected at time intervals
evenly spaced over the 24 hour period which are equal in number of hours to the detention time
of the system in number of days. However, in no case may the time interval between effluent
grab samples be greater than six (6) hours nor the number of samples less than four (4)during a
24 hour sampling period.
b. Grab Sample: Grab samples are individual samples collected over a period of time not
exceeding 15 minutes; the grab sample can be taken manually. Grab samples must be
representative of the discharge or the receiving waters.
9. Calculation of Means
a Arithmetic Mean: The arithmetic mean of any set of values is the summation of the individual
values divided by the number of individual values.
b. Geometric Mean: The geometric mean of any set of values is the Nth root of the product of the
individual values where N is equai to the number of individual values. The geometric mean is
equivalent to the antilog of the arithmetic mean of the logarithms of the individual values.
For purposes of calculating the geometric mean, values of zero (0) shall be considered to be one
(1).
c. Weighted by Flow Value: Weighted by flow value means the summation of each concentration
times its respective flow divided by the summation of the respective flows.

Pan F
Pas-- 1 o 11'
10. Calendar Dav
A calendar clay is defined as the :-e :od ;rom midn:eht o. o..e day uniii ratan:=.`.: of the next day.
However, for purposes of this permit, any consecutive _=-hour perioa that re_vnabiv represents
the calendar day may be used for sampi:nz.
11. Hazardous Substance
A hazardous substance means any substance designated under 40 CFR Part 116=ursuant to Section
311 of the Clean Water Act.
12.Toxic Pollutant
A toxic pollutant is any pollutant listed as toxic under Section 307(a)(1) of the Gean Water Act.
SEC ?ON B. GENERAL COND1TiONS
1. Duty to Comply
The permittee must comply with all conditions of this permit. Any per-:*, noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcemen: action; for permit
termination, revocation and reissuance, or modification;or denial of a permit renewal application.
a. The permittee shall comply with effluent standards or prohibitions established under section
307(a) of the Clean Water Act for toxic pollutants and with standards for ss—age sludge use or
disposal established under section 405(d) of the Clean Water Act within t;c time provided in
the regulations that establish these standards or prohibitions or standards for sewage sludge
use or disposal, even if the permit has not yet been modified to incorporate La requirement.
b. The Clean Water Act provides that any person who violates a permit conc:don is subject to a
civil penalty not to exceed 525,000 per day for each .Iolation. Any person who negligently
violates any permit condition is subject to criminal penalties of 52,500 to 525,000 per day of
violation, or imprisonment for not more than 1 vear, or both. Any person who knowingly
violates permit conditions is subject to criminal penalties of 55,000 to S30,000 per day of
violation, or imprisonment for not more than 3 years,or both. Also, any p_son who violates a
permit condition may be assessed an administrative penalty not to exceed 5:0,000 per violation
with the maximum amount not to exceed 5125,000. [Ref: Section 309 of the Federal Act 33
U.S.C. 1319 and 40 CFR 12-7.41 (a)]
c. Under state law, a civil penalty of not more than ten thousand dollars (51'v,000) per violation
may be assessed against any person who violates or fails to act in accordance with the terms;
conditions, or requirements of a permit. (Ref: North Carolina General Statems§ 143-215.6A[
d. Any person may be assessed an administrative penalty by the Adminisuator for violating
section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit con:ition or limitation
implementing any of such sections in a permit issued under sectic: 402 of the Act.
Administrative penalties for Class 1 violations arc not taexceed 510,000 per violation, with
the maximum amount of any Class 1 penalty assessed not to exceed S25,000 Penalties for Class
11 violations are not to exceed 510,000 per day for each day during which the violation
continues,with the maximum amount of any Class 11 penalty not to exceed 5:25,OW.

Pan iI
Pane 5 Jf i�
_. Duty ty .o
The permtttee shall take ail reasonable steps to minimize or =revent any discharge or sludge use or
disposal in violation of this oermtt whit'- has a reasona=ie iikeiihood of adversely affecting
human health or the environment.
.. Civil and Criminal Liabiliry
Except as provided in permit conditions on "Bypassing" (Pan 11, C-4) and "Power Failures" (Part II,
C-7), nothing in this permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of
the Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages,
such as fish kills, even though the responsibility for ef
suspended. fective compliance may be temporarily
4. Oil and I?azardous Substance Liabiiiry
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may
be subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321.
Furthermore, the permittee is responsible for consequential damages, such as fish kills, even
though the responsibility for effective compliance may be temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property,
or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State or local laws or regulations.
6. Onshore or Offshore Consrrucron
This permit does not authorize or approve the construction of any onshore or offshore physical -
structures or facilities or the undertaking of any work in any navigable waters.
7. Severability
The provisions of this permit are severable, and if any provision of this permit, or the application
of any provision of this permit to any circumstances, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit, shall not be affected thereby.
8. Duty to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any
information which the Permit Issuing Authority may request to determine whether cause exists for
modifying,revoking and reissuing, or terminating this permit or to determine compliance with this
permit. The permittee shall also furnish to the Permit Issuing Authority upon request. copies of
records required to be kept by this permit.
9. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit.

Par; i 1
Pas= :� of I,'
10. Fxpi-anr of Pe—
he perrttttee is not autho^zed to discharee after the expratton date. in order to receive
automatic authonza:ton to d:scharge bevond the expiration date. the permit tee shall submit such
information, forms. and fees as are reoutred by the agency authorized to issue perrruts no later than
180 days prior to the exp:ranon date. Any permittee that has not requested renewal at least 180
days prior to expiration, or any permittee that does not have a permit after the expiration and has
not requested renewal at least I80 days prior to expiration, will subject the perrnittee to enforcement
procedures as provided in NCGS 143-215.6 and 33 USC 1251 et.seq.
11. Sfznatory p uirernenrs
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed
and certified.
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a
responsible corporate cit.icer means: (a) a president, secretary, treasurer or vice president
of the corporation to charge of a principal business runction, or any other person who
performs similar policy or decision making functions for the corporation, or (b) the manager
of one or more manufacturing production or operating facilities employing more than 250
persons or having gross annual sales or expenditures exceeding 25[trillion(in second quarter
1480 dollars), if authority to sign documents has been assigned or delegated to the manager
in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official.
b. All reports required by the permit and other information requested by the Permit Issuing
Authority shall be signed by a person described above or by a duly authorized representative of
that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
responsibility, or an individual or position having overall responsibility for environmental
matters for the company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.);and
(3) The written authorization is submitted to the Permit Issuing Authority.
c. Certification. Any person signing a document under paragraphs a. or b. of this section shall
make the following certification:
"I certify, under penalty of law, that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the system, or those persons directly responsible for gathering
the information, the information submftted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations."

Part i I
P,oe 7 14
Permit A.ct:cns '
This permit may be modified, re•:oked and reissued. or ;e.^n:rated for cause. -he fiiin, of a request
by the permittee a oe.^:: modification, revocation and re!ssuance. termination, or a
notification of planned chanees or anticipated noncompiiance does not stay ariv perm condition.
i3. Permit .%fodifican,,n. Revocanon and Reissuance or Termmanon
The issuance of this permit does not prohibit the permit issuing authority from reopening and
modifying the permit, :evoking and reissuing the permit, or terminating the pernut as allowed by
the laws, rules, and regulations contained in Title 40, Code of Federal Reguiations, Parts 122 and
123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North
Carolina General Statute 143 215.1 et. al.
14. Previous Permits
All previous National Pollutant Discharge Elimination System Permits issued to this facility,
whether for operation or discharge, are hereby revoked by issuance of this permit. IThe exclusive
authority to operate this facility arises under this permit. The authority to operate the facility
under previously issued permits bearing this number is no longer effective. I The conditions,
requirements, terms, and provisions of this permit authorizing discharge under the National
Pollutant Discharge Elimination System govern discharges from this facility.
SECTION C. OPERATION AND MAINTENANCE OF POLLL71ON CONTROLS
1. Certified Operator '
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the
facility by the Certification Commission, the permittee shall employ a certified wastewater
treatment plant operator in responsible charge (ORC) of the wastewater treatment facilities. Such
operator must hold a certification of the grade equivalent to or greater than the classification
assigned to the wastewater treatment facilities by the Certification Commission. The permittee
must also employ a certified back-up operator of the appropriate type and any grade to comply
with the conditions of Title 15A, Chapter 8A .0202. The ORC of the facility must visit each Class I
facility at least weekly and each Class 1i, III, and iV facility at least daily, excluding weekends
and holidays, and must property manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A .0202. Once the
facility is classified, the permittee shall submit a letter to the Certification Commission which
designates the operator in responsible charge within thirty days after the wastewater treatment
facilities are 50% complete.
2. Proper Qperation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the permittee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also
includes adequate laboratory controls and appropriate quality assurance procedures. This provision
requires the operation of back-up or auxiliary facilities or similar systems which are installed by a
permittee only when the operation is necessary to achieve compliance with the conditions of the
permit.

Par, iI
Pace S of 14
\eed tc - 3- D=
It shall not be a defense fora Pe—. .::tee in an enrorcemen: acton ;hat it wouid 'nave been necessary
to halt o, reduce the perrnttted actmw in order to maintain comoitance with the condition of this
Permit.
4. Bypassing �; =atme -=,thties
a. Definitions
(1) "Bypass" means the known diversion of waste streams from any portion of a treatment
facility including the collection system, which is not a designed or established or operating
mode,for the facility.
(2) "Severe property damage" means substantial physical damage to property, damage to the
treatment facilities which causes them to become inoperable, or substantial and permanent
loss of natural resources which can reasonably be expected to occur in the absence of a
by Severe property damage does not mean economic loss caused by delays in
producnon.
b. Bypass not exceeding limitations.
The permittee may allow any bypass to occur which does not cause effluent limitations to be
exceeded, but only if it also is for essential maintenance to assure efficient operation. These
bypasses are not subject to the provisions of Paragraphs c.and d. of this section.
c. Notice
(1) Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall
submit prior notice, if possible at least ten days before the date of the bypass; including an
evaluation of the anticipated quality and affect of the bypass.
(2) Unanticipated bypass. The permittee shall submit notice of an unanticipated bypass as
required in Part il, E. 6.of this permit. (24 hour nonce).
d. Prohibition of Bypass
(1) Bypass is prohibited and the Permit Issuing Authority may take enforcement action against
a permittee for bypass,unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or seveie property
damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment
facilities, retention of untreated wastes or maintenance during normal periods of
equipment downtime. This condition is not satisfied if adequate backup equipment should
have been installed in the exercise of reasonable engineering judgment to prevent a bypass
which occurred during normal periods of equipment downtime or preventive maintenance:
and
(C)The permittee submitted notices as required under Paragraph c. of this section.
(2) The Permit Issuing Authority may approve an anticipated bypass, after considering its
adverse affects, if the Permit Issuing Authority determines that it will meet the three
conditions listed above in Paragraph d. (1) of this Sectjon.

part iI
-=C 9 of 1-
a. Defintp:on.
"Upset means an exceptional incident :.. which .here is unmtennonai and temx ary
noncomoiiance with technoioev based permit effluent limitations bacause of factors bey—:.' phe
reasonabie controi of the permrttee. An upset does not include noncompliance to the ^:ent
caused by operational error, improperly designed treatment raaitpies. inadequate trca—ent
facilities, lack or preventive maintenance, or careless or improper operanon.
b. Effect of an upset.
An upset constitutes an affirmative defense to an action brought for noncompliance Hi Bch
technology based permit effluent limitations if the requirements of paragraph c. c; this
condition are met. No determination made during adminis.—tire review of clai,: that
noncompliance was caused by upset, and before an action for noncompliance, is "nal
administrative action subject to judicial review.
C. Conditions necessary for a demonstration of upset.
A permittee who wishes to establish the affirmative defense of upset shall demo=ate,
through properly signed, contemporaneous operating logs, or other:elevant evidence th_
(1) An upset occurred and that the permittee can identify the causes) of the upset;
(2) The permittee facility was at the time being properly operated; and
(3)The permittee submitted notice of the upset as required in Pa- il,E.6. (b) (B) of this
(4) The permittee complied with any remedial measures required under Part 11, B. 2. this
permit.
d. Burden of proof.
In am•enforcement proceeding the pt:rmtttee seeking to establish the occurrence ut do
the burden of proof.
6. Removed cuintances
Solids,sludges, filter backwash, or other pollutants removed in the ccu:se of treatment or co-=1 of
wastewaters shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manrr_ itch
as to prevent any pollutant from such materials from entering waters of the State or na—ble
waters of the United States. The permittee shall comply with air existing federal regL:_otss
governing the disposal of sewage sludge. Upon promulgation of 40 C-R Part 503,any perrrd:sled
by the Permit Issuing Authority for the utilization/disposal of sludge may be reopen= and
modified, or revoked and reissued, to incorporate applicable requirements at 40 CFR Part 5.=_ The
permittee shall comply with applicable 40 CFR Part 503 Standards for the Use and Disv--1 of
Sewage Sludge(when promulgated) within the time provided in the regulation, even if the=e rift
is not modified to incorporate the requirement. The permittee shall notify the Permit _brig
Authority of any significant change in its sludge use or disposal practices.
7. Power Failures
The permittee is responsible for maintaining adequate safeguards as required by DEM Reg--on.
Title 15A, North Carolina Administrative Code, Subchapter 2H, .0:24 Reliability, to prey= the
discharge of untreated or inadequately treated wastes during electrical power failures en er by
means of alternate power sources, standby generators or retention of inadcquately treated efrcy:,t_

Part iI
Paze iQ o:
HC'O\ D. MON703TN - ' \'D .R-C^7.r5
I. Rep•e.=r —ye ;=M
Samples collected and measurements taken. as required I•.erein. shall be charactemsz:c of the
volume and nature of the permitted discharge. Sampies coliected at a frequencv ie_ an daily
shall be taken on a day and time that is characteristic of the d:charge over the a-..a-a period
which the sampie represents. All sampies shall be taken at the monitoring points spec__ in this
permit and, unless otherwise specified, before the effluent joins or is diluted by anv other
wastestream, body of water, or substance. Monitoring points shall not be than_:= without
notification to and the approval of the Permit Issuing Authority.
2. Repomng
Monitoring results obtained during the previous month(s) shall be summarized for eat.=nth and
reported on a monthly Discharge Monitoring Report (D,IMR) Form (DEM No. MR L L,2, 3) or
alternative forms approved by the Director, DEM, postmarked no later than the Stith day
following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit c="-he case
of a new facility, on the last day of the month following the commencement c' discharge.
Duplicate signed copies of these, and all other reports required herein, shall be sub-4.Md to the
following address:
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
Post Office Box 29335 --
Raleigh, North Carolina 27626-0333
3. Fiow Measurements
Appropriate flow measurement devices and methods consistent with accepted scien_:c -actices
shall be selected and used to ensure the accuracv and reliability of measurements of z.e sciume of
monitored discharges. The devices shall be installed, calibrated and maintained to en:— that the
accuracy of the measurements are consistent with the accepted capability of that t1� w device.
Devices selected shall be capable of measuring flows with a maximum deviation of 1�z + 10%
from the true discharge rates throughout the range of expected discharge volumes. Crze--dirough
condenser cooling water flow which is monitored by pump logs,or pump hour meters-=xified in
Part I of this permit and based on the manufacturer's pump curves shall not be s=^ec to this
requirement.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulatio=s =dished
pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and t =ilations
published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Gz—i Act,as
Amended,and Regulation 40 CFR 13F; or in the case of sludge use or disposal, approv alder 40
CFR 136,unless otherwise specified in 40 CFR 503, unless other test procedures have i—:specified
in this permit.
To meet the intent of the monitoring required by this permit, all test procedures rust produce
minimum detection and reporting levels that are below the permit discharge require�.:s and all
data generated must be reported down to the minimum detection or lower reportin_!e--1 of the
procedure. If no approved methods are determined capable of achieving minimum "-•.won and

Par[ i I
Paee : '. of l'
reporting levels below perm:; d:scharge requ:.emen:s, then the most sensrr':e tme[ho :.;th the
lowest posstbie detection and reoornng ievell approved method must be used.
3- ----nne7nz
The Clean Water Act provides that any person who falsifies. tampers with, or knovvinzh- 3[ders
inaccurate, ar,v monitoring device or method required to be maintained under this pa=jr shall,
upon conviction. be punished by a fine of not more than 510,000 per violation, or by imprisot[rment for
not more than two years per v-toiation, or by both. If a conviction of a person is for a violation
committed after a first conviction of such person under this paragraph, punishment is a tine of not
more than 520.000 per day of vioiatton, or by imprisonment of not more than 4 vears, or bow.
6. Records Retennon
Except for records of mon[tonnz information required by this permit related to the permince's
sewage sludge use and disposal activities, which shall be retained for a period of at least five
years (or longer as required by 40 CFR 503), the permtttee shall retain records of all r:anrtoring
information, including all caiibratton and maintenance records and all original stnp chart
recordings for continuous monitoring instrumentation, copies of all reports required by this permit,
for a period of at least 3 vears from the date of the sample. measurement, report or application.
This period may be extended by request of the Director at any time.
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the perdttee
shall record the following information:
a. The date,exact place. and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The dates) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used;and
f. The results of such analvses.
8. Inspection and E-rry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director). upon the presentation of credentials and other
documents as may be required by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or
conducted,or where records must be kept under the conditions of this permit;
b. Have access to and copy,at reasonable times, any records that must be kept under the conditions
of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment),practices,or operations regulated or required under this permit;and
d.- Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as
otherwise authorized by the Clean Water Act,any substances or parameters at any)cation

Pan if
Page i'_ of
Change n Discharge
All discharges authorized herein shall be consistent with the terms and conditions o., this permit.
The discharge of any pollutant tdennfied in this permit more rTeauentiy than or at a level in excess
of that authorized shall constitute a violation of the permit.
2. Planned Changes
The permittee .shall give notice to the Director as soon as possible of any plarmed physical
alterations or additions to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for determining
whether a facility is a new source in 40 CFR Part 122.29 (b);or
b. The alteration or addition could significantly change the nature or increase the qudttttty of
pollutants discharged. -his notification applies to pollutants which are ruble; neither to
effluent limitations in the permit, nor to notification requirements under 40 CFR Pat 122.42 (a)
c. The alteration or addition results in a significant change to the permtttee's sludge use or
disposal practices, and such alternation, addition or change may )ustifv the a:olication of
permit conditions that are different from or absent in the existing permit, includir.= notification
of additional use or disposal sites not reported during the permit application F^cess or not
reported pursuant to an approved land application plan.
3. Anticipated Noncompliance -
The permittee shall give advance notice to the Director of any planned changes in =-.e permitted
facility or activity which may result in noncompliance with permit requirements.
4. Transfers
This permit is not transferable to any person except after notice to the Director. The Dihector may
require modification or revocation and reissuance of the permittee and incorpora= such other
requirements as may be necessary under the Clean Water Act.
5. Monitorine Reports
Monitoring results shall be reported at the intervals specified elsewhere in this pem•:L
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (5•- Part If. D. 2
of this permit)or forms provided by the Director for reporting results of monitorin_of sludge use
or disposal practices.
b. If the permittee monitors any pollutant more frequently than required by the per:t, using test
procedures specified in Part 11, D. 4. of this permit or in the case of sludge use or disposal,
approved under 40 CFR 503,or as specified in this permit,the results of this montziring shall be
included in the calculation and reporting of the data submitted in the DMR.
c. Calculations for all limitations which require averaging of measurements shall utilize an
arithmetic mean unless otherwise specified by the Director in the permit.

Pan iI
Paee i 3 of i=
a. The permittee shall report the cer.rai office or ; .e appropriate regional ffice any
noncompliance which may endanger heaith or the environment. Any informaric- shall be
provided orally within 24 hours from the t.me the permittee became aw--e of the
circumstances. A written submission shall aiso .oe provided within 5 days oft time the
perittee becomes aware of the circumstances. The written submission shall contain a
description of the noncompliance, and its cause; the period of noncompliance, incluz!ing exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce.eliminate, and prevent rzccurrence
of the noncompiiance.
b. The following shall be included as information which must be reported within 24 h- s under
this paragraph:
(1) Any unanricipated bypass which exceeds any effluent limitation in the permit.
(2) Any upset which exceeds any effluent limitation in the permit.
(3) Violation of a maximum daily discharge limitation for any of the pollutants lis;;d by the
Director in the permit to be reported within 24 hours.
c. The Director may waive the written report on a case-by-case basis for reports under=aragraph
b. above of this condition if the oral report has been received within 24 hours..
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under Part II. E. _and 6. of
this permit at the time monitoring reports are submitted. The reports shall contain the i=ormation
listed in Part II. E. 6. of this permit.
8. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts is a permit
application, or submitted incorrect information in a permit application or in any re---ort to the
Director, it shall promptly submit such facts or information.
9. Noncompliance Notification
The permittee shall report by telephone to either the central office or the appropria= regional
office of the Division as soon as possible, but in no case more than 24 hours or on the next working
day following the occurrence or first knowledge of the occurrence of any of the following.
a. Any occurrence at the water pollution control facility which results in the d `£large of
significant amounts of wastes which are abnormal in quantity or characteristic, s=ch as the
dumping of the contents of a sludge digester;the known passage of a slug of hazardots substance
through the facility;or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility:-capable of
adequate wastewater treatment such as mechanical or electrical failures of purl.aerators,
compressors,etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to such
station or facility.

Pl, 11
p°tee of 14
Persons re:orring such occcrcences by teiephone s^ail also file a written repo- in letter form within
5 days following first knowiedge or the occu-ence.
10. Availability of Reports
Except for data determined to be confidential under NCCS 143-2i5.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for
public inspection at the offices of the Division of Water Quality. As required by the Act, effluent
data shall not be considered confidential. Knowingly making any false statement on any such
report may result in the imposition of criminal penalties as provided for in \'CGS 143-215.1(b)(2) or
in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that anv person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be p ,00
punished by a fine of not more than 5100 per violation,
or by imprisonment for not more than two years per%iolation,or by both.

PART `ii
O i HER REQ:;:RE\;E�N.
A. Congrrucnon
No construction of wastewater treatment facilities or additions to add to the plant's treatment
capacity or to change the type of process utilized at the treatment plant shall be begun until Final
Plans and Specifications have been submitted to the Division of Water Quality and written approval
and Authorization to Construct has been issued.
B. Groundwater Monitoring
The permitteeshall,upon written notice from the Director of the Division of Water Qualitv,conduct
groundwater monitoring as may be required to determine the compliance of this NPD): permitted
facility with the current groundwater standards.
C. Changes in Discharges of Toxic substance
The perminee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe:
a.That any activity has occurred or will occur which would result in the discharge, on _ routine or
frequent basis, of any toxic pollutant which is not limited in the permit, if that discharge will
exceed the highest of the following "notification levels";
(1)One hundred micrograms per liter(100 ug/1);
(2)Two hundred :micrograms per liter (200 ug/1) for acrolein and acrylonitrile; five hundred
micrograms per liter(500 ug/I) for 2.4-dinitrophenol and for 2-methyl-4.6-dinitr henol;and
one milligram per liter(I mg/1)for antimony;
(3) Five (5) times the maximum concentration value repotted for that pollutant in the permit
application.
b. .That any activity has occurred or will occur which would result in any discharge, on a non-routine
or infrequent basis, of a toxic pollutant which is not limited in the permit, if that dLG-taro will
exceed the highest of the following"notification levels;
(1)Five hundred micrograms per liter(500 ug/1);
(2)One milligram per liter(I mg/1) for antimony;
(3) Ten (10) times the maximum concentration value reported for that pollutant in the permit "
application.
D. Requirement to Continually Evaluate Alternatives to Wastewater Discharges
The permittee shall continually evaluate all wastewater disposal alternatives and pursue the most
environmentally sound alternative of the reasonably cost effective alternatives. If the facirry is to
substantial non-compliance with the terms and conditions of the NPOES permit or governing rules,
regulations or laws, the permittee shall submit a report in such form and detail as req�_red by the
Division evaluating these alternatives and a plan of action within sixty(60)days of notifi¢son by the
Division. -

i
PART III
PAGE 2 C= 1' -
r
SPECIAL CONDITION'S SECTION-Pan III
E. REQUIREMENTS FOR COLOR COMPLIA\CE AND A�NAL.YSIS
The following requirements reflect the permit actions related to effluent color necess_:fo
implement the or' ions described in the December 1997 Settlement Agreement for_ rermit
and North Caroiina's 1997 Revised Color Variance. Both the Settlement Agreement_d the
Revised Color Variance include several other provisions that must be fulfilled in accc-=mince with
those documents.
1) Until December 1. 1998. when revised effluent color limitations take effect that asp= color
levels at the State line meet 50 true color units, the permittee shall take such action as=ecessary to
prevent their contribution of true color from causing true color at the North Carolina., -:anessee
state line from exceeding 50 true color units at all flows equal to or exceeding 126 cf_.S 1.4
MGD, the seven day, ten year low flow level).
Compliance with this requirement shall be measured through a calculation of instrear==_e color
levels at the North Carolina/Tennessee state line by the following equation:
SLc = {WTpc /8.341 + ((HEf.- WTP f) x Dc)
HE f x 10 (-0.224 x LOG (HE f) +0.781)
Where: WTPc = Monthly average Waste Treatment Plant discharge ;:Ior.
Calculated as the average of all daily loading value_
(pounds of true color per day) for a calendar mont-
WTP f = Monthly average Waste Treatment Plant discharge _;w(mad).
HE f = Monthly average HEPCO. North Carolina flow (m__: -daily
flow values less than 81.4 mad shall be entered as °.= mad.
SLc = Monthly average Instream true color at North
Carolina/Tennessee border(state line).
Do = Color concentration of all dilution streams (13 C.L. .
The SLc shall be calculated for each calendar month. The SLc values for each mono -L-11 not
exceed 50 true color units. Any exceedance of 50 true color units for this average vzza shall be
considered a violation of this permit.
2) Beginning January 1, 1998, the monthly average discharge of true color from the',I shall not
exceed 95,000 lbs./day. For the purpose of this permit/variance only, "pounds of trr color" is
calculated by the following equation:
Effluent Flow (mgd) x Effluent True Color Level
(Platinum Cobalt Units) x 8.34:
3) The method of analyses used to measure true color for this calculation shall be the =rocedure
referenced in FR 39 430.11(b) (May 29, 1974). _

PART III
PAGE 3 OF 1,�
4) All samples collected for color analysis shall be measured and reported as true color and
apparent color using the procedure referenced in FR 39 430.11 (b) (May 29. 1974) - rue and
apparent color.
5) This model limitation may be extended beyond December 1, 1998, if the NPDES Committee of
the Environmental Management Commission establishes. in accordance with the December 1997
Settlement Agreement for this NPDES Pemnt and the 1997 Revised Color Variance. alternate
interim limits which require the model to be used to assure compliance with 50 true color units at
the State line.
6) Based on the results of the demonstration effort, the permittee shall continue the full operation
of the BFRT"A technology on the mill's pine line on a continuing basis, subject to the process set
forth in Paragraph E 10.
7) Working with the Technology Review Workgroup, Champion has already begun the process
of identifying and implementing possible prevention and control measures which can be taken to
further reduce color discharges from the mill. The permittee is directed to further evaluate mill
operation so as to fully identify opportunities for preventing and controlling measurable black
liquor leaks and spills (best management practices-BMPs).-This evaluation will include gathering
more extensive and detailed data on sources of color within the[Hill 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 mo.aitoring (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. The perminee also is directed to thoroughly evaluate additional
measures to modify its process operations and controls to remove or reduce sewer generated
color.
8)The permittee shall provide a report to the Division of Water Quality, the Technology Review
Workgroup and the NPDES Committee no later than June 1, 1998. This report will identify a
strategy and time line for implementing those color reduction measures identified in Paragrah E 7
until the target effluent limitations in Paragraph E 12 are met or all measures in Paragraph E 7 p
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 Paragrzph E 10 are
not achieved by the color reduction measures specified in that paragraph.
9) Four BMPs which have already been identified as having both a high potential for achieving
color reduction and a high level of implement ability 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 uonntaininnenr, and; (d)c=ection 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. The permiace shall
fully implement all four of these BMPs by June 1, 1998.

PART III
PAGE 4 OF i,-r A
10) Beginning December 1. 1998, the annual average discharge of true color shall r,,N exceed
60,000 lbs/dav and the monthh average true color loading shall not exceed 69,000 1-_iday.
However. is by October 1. 1998. in accordance with the Settlement Agreement and*_`e Revised
Color Variance, the Technology Review Workgroup determines. and the NPDES Committee
agrees. that there are overwhelming technical, economic or operational barriers to the permittee's
ability to attain the above-stated color loading limits. the Technoiogv Review Work shall
recommend to the NPDES Committee the altemate 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 annual average color loading limit of 60,000 lbs/day. T'oese.
recommendations shall be based on what the Workgroup concludes Champion can reasonably be
expected to achieve, giving due consideration to the demonstrated discharge levels w—hich the mill
has, in fact, achieved and taking into account the evaluations conducted pursuant to Paragraph E 7
and the report submitted by the permittee pursuant to Paragraph E 8. 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 accordanc`with North
Carolina's permitting process to reflect these determinations.
11) The permittee shall begin implementation of that portion of the BFRTM technoh�r which
involves the recycling of the Eo stage of the hardwood line by no later than Janua l "hi The
permittee further shall provide an evaluation of that implementation as well as the po�ndal for full
implementation of the BFRTM technology on the mill's hardwood line to the Division of Water
Quality, the Technology Review Workgroup and the NPDES Committee by DecemYr 1, 1999.
The evaluation will include data reflecting the color reduction benefit gained from die partial
implementation and a projection of potential color reduction benefit to be gained from-full
implementation of the BFR technology on the hardwood line.
12) Based on the work that Champion and the Technology Review Workgroup have already
done in the area of in-mill color reduction measures, it is anticipated that further cola-reductions,
beyond those to be obtained by the BFRTM on the pine line in combination with the-four BMPs
identified in Paragraph E 9, could be expected after implementation of the BMPs and measures to
reduce and/or remove sewer generated color identified in Paragraph E 7, and partial 3FRTM
(e.g:,recycle of Eo filtrate) on the hardwood line. This combined package of in-mill zolor
reduction measures (i.e., the four BMPs in Paragraph E 9, the additional BMPs and
sewer-generated color reduction measures identified in Paragraph E 7 as implemen[ pursuant to
Paragraph E 8, full implementation of BFR on the pine line, and partial BFR on the ysdaoan
line) shall hereinafter collectively be referteod
d to as the Near-Term Package. It is fut-Ler
anticipated that full implementation of the Near-Term Package could be effectuated b r June 1,
2000,resulting in a target color annual average loading within a range of 48,000-52!:00 lbs/day.
The permittee shall submit to the Division of Water Quality and the Technology Re%7Zw
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 lbs/dav based on full implem [anon of the
shall include ail available data necessary to derive tx lowest
Near-Term Package. This report
achievable annual average and monthly color loading limits. By April I, 2001, the T chnology
Review Workgroup shall recommend, considering the feasibility report submitted by ae permittee
and the demonstrated performance of the mill, the lowest achievable annual average=d monthly
color loading effluent limitations. The Workgroup evaluation and recommendatin-
submitted to the NPDES Committee and the other parties to the Settlement Agreemer_ If the Vy
recommended limits are within the target range,the limits shall become effective on Mav 1,2001,
by written notification from the Director of the North Carolina Division of Water Quaity. If the
limits determined to be achievable by the Workgroup are not within the target range.re 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 accomt
appropriate effluent variability.

PART III
PAGE 5 OF 14 a
13) As the 1997 Revised Color Variance recognizes, there ,:ouid 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. The permittee shall develop a contingency Dian for mitigating . occurrence
and degree of these potential exceedances which correlates measures designed to achieve
mitigation with periods of lowest flow, with particular attention being given to periods of higher
recreational use in the river. In developing the plan. the permittee shall evaluate anv 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 to the Division of Water Quality by December 1. 1998, for review ov the
Technology Review Workgroup. The permittee shall 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 Comminee 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.
14) By March 1, 2001. the permittee will evaluate and report on end-of-pipe color reduction
technologies in conjunction with the Triennial Review of*,.C. Water Quality Standards. The
evaluation shall include an incremental color improvement analysis. This analysis will concentrate
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 must look
particularly at periods of low river flow. The report will identify specific economic and
implementation issues associated with the incremental improvement of color levels expected by
installing these technologies at the mill. The report will also project the expected additional color
reduction for each technology evaluated and the maximum color reduction possible Using the
identified technology. The permittee shall provide this evaluation/report, together with an updated
report on the results of all ongoing and any additional planned color reduction activities, to the
Division of Water Quality, the Technology Review Workgroup and the NPDES Committee by
March 1, 2001. The Technology Review Workgroup shall evaluate this combined reporr and
make recommendations to the NPDES Committee for further color reduction targets for inclusion
in the next NPDES permit. By June 1, 2001, the permittee will submit a report to Lhe NPDES
Committee and N.C. DENR, Division of Water Quality, on the comparative evaluation of the
above collective efforts as part of the Variance review process (Triennial Review of North
Carolina Water Quality Standards). Further, based on the continued development of color
discharge information from the reconfigured mill, the perminee will statistically evaluate its
monthly average color discharge, its annual average color discharge, and the performance of the
mill in relation to color discharged. This evaluation process shall be ongoing and the results of
the evaluation shall be reported to the NPDES Committee with the June 1, 2001. report. The
results of this evaluation process will be utilized by the Technology Review Workgroup to make
recommendations to the NPDES Committee for revisions to the 1997 permit and variance.
15)The permittee will not increase the mill's current pulp production capacity during the permit
term,unless this can be done in way that also reduces color loading. Even if this requirement is
met,increasing current pulp production capacity at this facility may require permit -vision in
accordance with North Carolina's NPDES Permitting rules.

PART III .
PAGE 6 OF J4 Cl
F. OTHER REQliIREMENTS RELATED TO COLOR \ID�LIIZATION. THE 1997 REVISED
COLOR VARIANCE AND THE 1997 SETTLENIE\T AGREEMENT
1) By March 1. 1998 the permittee will submit a status report to the Division of W'ater Quality and
the NPDES Committee on the analyses prepared for other rertnitting agencies concerning the
effects of the BFRTM technologv on air emissions.
?) 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:
a. Any breakthrough in color removal technologies. Such breakthroughs shall be brought to
the NPDES Committee for consideration, by the pertnittee and the Division of Water
Quality, as soon as they are discovered.
b. An acceptable statistical analysis of effluent color discharge data demonstrating
significantly better color removal performance than that currently prescribed in the
variance and permit.
c. Successful application of end-of-pipe color reduction technology or in-mill color
minimization effort that results in sigttiucant and measurable reduced mass color
discharge.
3) Transfer of this NPDES permit will not proceed until any successor-in-interest to th
owner has agreed to accept the provisions of the 1997 Settlement Agreement and rzeuested of and e current
received from the NPDES Committee a transfer of the 1997 Revised Color Variance.
4)The Canton Mill already meets or exceeds the technology requirements of the EPA Pulp and
Paper Cluster Rule for limits on dioxin. This permit requires that the Canton Mill continue to
meet those requirements. All other requirements of the Cluster Rule, including any monitoring
requirements, will apply to the permittee in accordance with time frames established oursuant to
the Rule.

PART III
PAGE 7 OF 1�X
G. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QARTLY)
The permittee is required to perform th
test as approved by the Division. e toxicity test as specified 'below or an equivalent toxicity
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November 1995,
or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 87% (defined as treatment two in the procedure document). The permit
holder shall perform quarterly monitoring using this procedure to establish compliance with the
permit condition. The tests will be performed during the months of March. June. September. and
December. Effluent sampling for this testing shall be performed at the NPDES permitted final
effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on
the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using
the parameter code TGP3B. Additionally, DWQ Form AT-I (original) is to be sent to the
following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
4-401 Reedy Creek Road
Raleigh, North Carolina 27607
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests. as well as all doselresponse data.
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 perm m
ittee will complete the inforation 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 any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately until such time that a single test is passed Upon
passing, this monthly test requirement will revert to quarterly in the months specified above.
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 strew ri, 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.

PART III
PAGE S OF}�
H. DIOXL\ MONITORING
For permit compliance purposes. the point of compliance shall be defined as the fin-! :---went
before discharge. Compiiance with the daily maximum permit limit shall be demon z_— by
determining the TCDD concentration at the final discharge point.
Adequate sample voiume shall be collected to perform the analysis. The total sample volume shall
be collected and preserved in accordance with Pan II,Section D Monitoring and Rec;rdz. The
sample shall be analyzed in accordance with the appropriate method of analvsis specLfed in
Analvtical Procedures and Oualitv Assurance for Multimedia Analvsis of Pol chlori>.:_-;d Dibenzo- ara-dioxins and Polvchlorinated Dibenzofurans by High Resolution Gas
Chromatographv/High Resolution Mass Spectrometry, EPA, 1987 (EPA Method S�?J). or
another equivalent analytical protocol approved by DWQ. A single sample may be a7_11,vZed to
determine compliance with the daily maximum effluent limitation. Alternatively, a sz=!e volume
may be collected to enable the sample to be split (duplicate•analvsis). If the analysis zither split
sample is below the detection limit, the quantity, for the purposes of compliance ev3 won.is
considered to be zero. If both splits are positive, the results of the two analyses shaL--e averaged
to determine compliance with the daily maximum effluent limitation. If the measure>-ep[is below detection limits the quantity for the purposes of compliance evaluation is considered-0 re zero.
The detection limit using these methods for the purpose of compliance evaluation is azrrsidered to
be 10 picograms per liter. The dioxin isomer to be limited at the effluent by this pe =t is 2,3,7,8
TCDD. The chlorodibenzo dioxins and furans to be monitored are:
DIOXIN DIBENZOFURAN
I mer Is mer
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 HxCDF
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
Fish tissue analysis will be performed in accordance with the Division of Water QuaL—_;approved
monitoring plan, which shall be reviewed as necessary. The monitoring plan is an e=,r[xable
part of this permit. All dioxin data collected as part of this monitoring requirement u-=be
reported as required in the plan, no later than 180 days after sampling.
The permittee shall perform the following analyses for the above listed isomers:
1. Influent to wastewater treatment facility Quarterly COMPOSITE
2. Sludge Quarterly COMPOSITE
3. Landfill leachate Quarterly COMPOSITE
4. Effluent Quarterly COMPOSITE

PART III
PAGE 9 OF L4'
I. DISSOLVED OXYGEN REQUIRE.�fE-�,T
The permittee shall maintain an average daily dissoived oxygen concentration of not less than 5.0
mg/1 with a minimum instantaneous value of not less than 4.0 mgA at River Jiiles 62.9 (DNI),
57.7 (DN2), and 55.5 (D\3). The perrrittee shall operate oxvgen 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. Champion shall report the date and duration of oxvgen injection use
as a supplement to the monthly Discharge Monitoring Report (DMR) forms.
J. WFLOW/INFILTRATION AT THE TOWN OF CAS NTON
The permittee shall make continued efforts to promote reduction of inflow/infiltration to the Town
of Canton's wastewater collection system.
K. WATERVILLE RESERVOIR SAMPLING REQUIREMENT
Sampling for Waterville Reservoir shall be conducted once annually during 1997, 1999, and
2000. Sampling shall be performed during a low flow period to correspond with the fish tissue
study. Sampling parameters and stations are as follows:
Sam'lin Station Parameters
Waterville Reservoir prior to Laurel Temperature. D.O., conductivity, pH, TN,
Branch NO2 + NO3, NH3-N, TKN. PO4, TP,
Chlorophyll-a, Secchi Depth - - --
Waterville Reservoir near Wilkins Creek Same as above
Waterville Reservoir near the dam Same as above
* All samples shall be collected at 0.1 meters beneath the surface of the water in the lake.
L. TEMPERATURE VARIANCE REVIEW
During the next permit renewal, the permittee shall complete an analysis of temperature data using
the period of record and simulations specified in the supplement to the hearing record. As part of
this analysis, the permittee shall submit a complete temperature variance report documenting the
need for a continued temperature variance in accordance with 40 CFR 125, Subpart H. The
report shall be submitted with the request for permit renewal, no later than June 1, 2001.
M. BALANCED AND INDIGENOUS SPECIES STUDY.
The permittee shall submit a balanced and indigenous species study prior to the next permit
renewal, no later than June 1, 2001. The study shall be performed in accordance with the
Division of Water Quality approved plan. This plan shall be submitted for approval no later than
March 1, 2000. The balanced and indigenous study plan shall conform to the specifications
outlined in 40 CFR 125 Subpart H. _

PART IV
A\'\TU:.L ADMI\?Si:. 1G AND COMP 1 ONCE MO\TITOR\G itt
REQUIREMENTS
_ A. The permitter_ must pay the annual administ_—ing and compliance monitoring fee
within 30--(thirtt) days after being billed by the Division. Failure to pal• the fee in a
timed- manner in accordance with 13A NCAC 2H .0105(b)(4) may cause this Division to
initiate action to re%•oke the pemit.

i
PART III
PAGE '_ CF
SPECL-`.L CONDITIONS SECTION-Past HI
E. REQUIRE'.IENTS FOR COLOR COMPLIANCE AND ANALYSIS
The following requirements reriec: : e permit actions related to effluent color necess-: :o
mplement h erovisions described ;,. the December 1997 Settlement Agreement for_ rzrmit
and North Carolina's 1997 Revised Color Variance. Both the Settlement Agreemen: -d.[he
Revised Color Variance include several other provisions that must be fulfilled in acci•= ice with
those documents.
l) until December 1. 1998. when revised effluent color limitadons take effect that asc= color
levels at the Stale line meet 50 true color units, the permittee shall take such action as_ecessary to
prevent their contribution of true color from causing true color at the North Carolina -=anessee
state line from exceeding 50 true color units at all flows equal to or exceeding 126 cfs .S 1.4
MGD, the seven day, ten year low Clow level). ®� ��
Compliance .vr[h this requirement shall be measured le Ito
through a calculation of ins[ream =_e color
levels at the North Carolinai Tennessee state line by the following equation:
SLc = (WTPc /8.34) + ((HEf- WTPf) x Dcj
HEfx 10 (-0.224 x LOG (HE,) + 0.78 1)
Where: WTPc = Monthly average Waste Treatment Plant discharge
Calculated as the average of all daily loading values
(pounds of true color per day) for a calendar monr=
WTPf = Monthly average Waste Treatment Plant discharge =aw (mgd).
HE f = Monthly average HEPCO. North Carolina flow (m__; - daily
flow values less than 81.4 mgd shall be entered as mad.
SLc = Monthly average Instream true color at North
Carolina/Tennessee border(state line).
Dc = Color concentration of all dilution streams (13 C.L. .
The SLc shall be calculated for each calendar month. The SLc values for each mont): _'..all not
exceed 50 true color units. Any exceedance of 50 true color units for this average =aze shall be
considered a violation of this permit.
2) Beginning January 1, 1998. the monthly average discharge of true color from the "E l shall not
exceed 95,000 lbs./day. For the purpose of this permn/variance only, "pounds of trat color" is
calculated by the following equation:
Effluent Flow (mgd) x Effluent True Color Level P901 it a
(Platinum Cobalt Units) x 8.34.
3) The method of analyses used to measure true color for this calculation shall be the =rccedure
referenced in FR 39 430.11(b) (May 29, 1974).
co

PART III
PAGE 3 OF J�
4) All sampies collected for color anah sis shail be measured and reported as true color and
apparent color using the procedure "erencea in FR 39 130, i 1 N (�lav =9. 1974) - rue and
apparent color. ellM Ib&of Cb
5) This model limitation may be extended beyond December i, 1998, if the \PDES Co tee of
the Environmental Management Commission establishes, in accordance with the December 1997
Settlement Agreement for thus NPDES Permit and the 1997 Revised Color Variance. alternate
interim iimits which require the model to be used to assure compliance with 50 true color units at
the State line. �®�
6) Based on the results of the demonstration effort, the perminee shall continue the full operation
of the BFRTM technology is, subject to the process set
on the troll's pine line on a continuing bas
forth in Paragraph E 10.
7) Working with the Technolog IC®M is d1 WIM
_y Review Workgroup, Champion has already begun the process
of identifying and implementing possible prevention and control measures which can be taken to
further reduce color discharges from the Trill. The permittee is directed to further evaluate trill
operation so as to fully identify opportunities for preventing and controlling measurable black
liquor leaks and spills (best management practices-BMPs). This evaluation will include gathering
more extensive and detailed data on sources of color within the Trull 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 sou ces 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 facitate 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. The permittee also is directed to thoroughly evaluate additional
measures to modify its process operations and controls to remove or reduce sewer generated
color.
ew
8) The permittee shall provide a report to the Division of Water Qu�tyO, oms he win
Workgroup and the NPDES Committee no later than June 1, 1998. This report will identify a
strategy and time line for implementing those color reduction measures is report it Paragraph E 7
until the target effluent limitations in Paragraph E 12 are met or all measures in Paragraph E 7
enti
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 E 10 are
not achieved by the color reduction measures specified in that paragraph.
ing
9) Four BMPs which have already been identified as having both a high potential OI%?Lift
color reduction and a high level of implement ability are: (a) installation of replacement digester
recirculation pumps and a spill collection sump; (b) installation of a pine courtyard Pashall flume
slide gate; (c) installation of weak black liquor tan aorta;, rucnt, arid; (d) correction of evaporate
set dernister clogging, installation of condensate instrumentation and sampling ports for the
evaporator set,and assurance of continued dry conveying of knot rejects. The permi=ee shall
fully implement all four of these BMPs by June 1, 1998.
Cob NA1%1M

PART ED
PAGE ; OF tr a
10) Beginning December I. 199S. the annual average disc'
h2_e of true color shall n ti: exceed
60,000 lbsidav and the monthly average true color loading sheii not exceed 69.000 l-siday.
However, if by October i. 1998, in accordance with the Settlement Agreement and *tee Revised
Color Variance, the Technologv Review Worigroup deterrmnes, and the \7PDES Com-n [tee
agrees, that there are overwhelrung technical, economic or oeerationai barriers to the oermittee's
ability to attain the above-stated color loading limits. the Tecnnoiogv Review Work�up 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 Com:,ittee anew
effective date for achieving annual average color loading limit of 60,000 lbs/day.Tn___I;.recommendations shall be based on what the Workgroup concludes Champion can reasonably be
expected to achieve, giving due consideration to the demonstrated discharge levels w_ich the mill
has, in fact, achieved and taking into account the evaluations conducted pursuant to Para_raph E 7
and the report submitted by the permittee pursuant to Paragraph E S. Based on the Workgroup's
recommendations, the NPDES Committee will determine the altemate interim limits to become
effective on December 1, 1998. as well as a new effective date for achieving an anntL:l 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. ®& - ft1
ft
11) The permittee shall begin implementation of that portion of the BFRTM 99. The
19
technolc�� which
involves the recycling of the Eo wage of the hardwood line by no later than J n 1.pernittee further shall provide an evaluation of that implementation as well as the po��19 for full
implementation of the BFRTM technology on the mill's hardwood line to the Division of Water
Quality, the Technology Review Workgroup and the NPDES Committee by DecemYr 1, 1999,
The evaluation will include data reflecting the color reduction benefit g-ained from the�ardal implementation and a projection of potential color reduction benefit to be o
implementation of the BFR technology on the hardwood line. �ameti from full
12) Based on the work that Champion and the Technology IL ID VA?
W n
done in the area of in-[Hill color reduction measures, it is anticipated that further cold_red have uctions,
beyond those to be obtained by the BFRTM on the pine line in combination with the -our BMPs
identified in Paragraph E 9, could be expected after implementation of the BMPs anc measures to
reduce and/or remove sewer generated color identified in Paragraph E 7, and partial 3FRTM
(e.g:,recycle of Eo filtrate) on the hardwood line. This combined package of in-mill, zolor
reduction measures (i.e., the four BMPs in Paragraph E 9, the additionaf BMPs and
sewer-generated color reduction measures identified in Paragraph E 7 as implemental pursuant to
Paragraph E 8, full implementation of BFR on the pine line, and partial BFR on the :`rdwood
line) shall hereinafter collectively be referred to as the Near-Term Package. It is furi:er
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 48,000-521:00 lbs/day.
C The permittee shall submit to the Division of Water Quality and the Technology Re%icw
Workgroup by January 1, 2001, a report on the feasibility of achieving a target annt, average
color loading limit within the range of 48,000-52,000 lbs/day based on full implem�ration of the
Near-Term Package. This report shall include all available data necessary to derive r.e lowest
achievable annual average and monthly color loading limits. By April 1, 2001, the T chnology
Review Workgroup shall recommend, considering the feasibility report submitted by:he permittee
and the demonstrated performance of the mill, the lowest achievable annual averag d monthly
color loading effluent limitations. The Workgroup evaluation and recommenr+ati^^ - -'_
submitted to the NPDES Committee and the other parties to the Settlement Agreemer_ If the V V recommended limits are within the target range, the limits shall become effective on Mav 1,2001,
by written notification from the Director of the North Carolina Division of Water Qua ity. If the
limits determined to be achievable by the Workgroup are not within the target range.:�:e Permit
shall be modified in accordance with North Carolina's permitting process to reflect hose limits.
The Workgroup's recommendation of limits under this Paragraph shall take into accoant
appropriate effluent variability.
MW Zool TVP*4 'T P- �u9

PART III
PAGE ; OF l�r a
13) As the 1997 Revised Color Variance recognizes. [here .ouid still be some periods of time,
corresponding to periods of sower do es :a the river. Shen color at the Heoco gage might exceed
50 true color units. The perr.;mee shall d- eioo a contingency plan for rnitigarina the occurrence
and degree of these potenuai exceedances which correlates measures designed to achieve
mitigation with periods of lowest flow- with particular attention being given to periods of higher
recreational use in the river. 1n deveioping the plan. the perminee shall evaluate anv 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 conringenc}I plan shall
be submitted to the Division of Water Quality by December 1. 1998, for review by the
Technology Review Workgroup. The perminee shall work in good faith with the Workzroup 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 Comminee«ill 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. e.o m %*L 1m
14) By March 1, 1-001. the permittee will evaluate and report on end-of-pipe color reduction
technologies in conjunction with the Triennial Review o(N.C. Water Quality Standards. The
evaluation shall include an incremental color improvement analysis. This analysis will concentrate
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 must look
particularly at periods of low river flow. The report will identify specific economic and
implementation issues associated with the incremenaal improvement of color levels expected by
installing these technologies at the mill. The report will also project the expected additional color
reduction for each technology evaluated and the maximum color reduction possible using the
identified technology. The permittee shall provide this evaluation/report, together with an updated
report on the results of all ongoing and any additional planned color reduction activities, to the
Division of Water Quality, the Technology Review Workgroup and the NPDES Committee by
March 1, 2001. The Technology Review Workgrcup shall evaluate this combined report and
make recommendations to the NPDES Committee for further color reduction targets for inclusion
in the next NPDES permit. By June 1, 2001, the perrmittee will submit a report to the NPDES
Committee and N.C. DENR. Division of Water Quality, on the comparative evaluation of the
above collective efforts as pan of the Variance review process (Triennial Review of North
Carolina Water Quality Standards). Further, based on the continued development of color
discharge information from the reconfigured mill, the permittee will statistically evaluate its
monthly average color discharge, its annual average color discharge, and the performance of the
mill in relation to color discharged. This evaluation process shall be ongoing and the results of
the evaluation shall be reported to the NPDES Committee with the June 1, 2001. report. The
results of this evaluation process will be utilized by the Technology Review Workgroup to make
recommendations to the NPDES Committee for revisions to the 1997 permit and variance.
15) The pertnittee will not increase the mill's current pulp production capacity during the permit
term, unless this can be done in way that also reduces color loading. Even if this requirement is
met, increasing current pulp production capacity at this facility may require permit re'vision in
accordance with North Carolina's NPDES Permitting rules.
C�lip L 1 It

,
PART �
PAGE 6 OF 14 Cl
F. OTHER REQUIRENIENTS RELATED TO COLOR N[INLMIZATIOti. THE i997 REVISED
COLOR S UA..\CE AND THE 1997 SEt t E\!E\T AGREENIE\T
1 t By March 1. 1998 the permmaee xiil submit a status re-Pon to the Division Quality and
the NPDES Committee on the anaiyses prepared for other zrmiuins agencies concerning the
effects of the BFRTNI technology on air emissions. �-
COM PIJ'
21 The NPDES Permit shall be subject to reopening in order to modify [he color reouirements
based upon the following and in association with the required triennial reviews:
a. Any breakthrough in color removal technologies. Such breakthroughs shall be brought to
the NPDES Committee for consideration, by the permittee and the bivision of Water
Quality, as soon as they are discovered.
b. An acceptable statistical analysis of effluent color discharge data demonstrarin2
significantly better color removal performance than that currently prescribed in the
variance and permit.
c. 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.
3)Transfer of this NPDES permit will not proceed until any successor-in-interest to the current
owner has agreed to accept the provisions of the 1997 Settlement Agreement and requested of and
received from the NPDES Committee a transfer of the 1997 Revised Color Variance. COMNgA
4)The Canton Mill already meets or exceeds the technology requirements of the EPA Pulp and
Paper Cluster Rule for limits on dioxin. This permit requires that the Canton Mill continue to
meet those requirements. All other requirements of the Cluster Rule, including any monitoring
requirements, will apply to the permittee in accordance with time frames established oursuant to
the Rule.
9,41ANGO WO !ND/(TS/VDr/s s'PEZt 6s ST-0)
PGftNn/1-D M2 1,YUM S12 OF a000

o p.
EAST TENNESSEE
Fly collection shows
Pigeon River 01
B► Morgan S"" Scientists'report signs of lessening pollution fi
ner
News-Seitmd staff venter
Ii9RTFORD, Tenn. — From the T>ermessee vaUa, Andy, ale fines- David Imo nney, aquatic biologist for off not related to the mill. P
egoatic insects �m�aig to the bottom of see Department a Envuunment and TWRA, said Wednesdays untied sampla!8 In Past Ycere+ the �n River has w
the rocks to the fi9h lriding in the Pao1s, Conservation and ORNL—takes place at on the Pigeon River shows increasrs m tteen dewed of snails and mussels,which a
the Pigeon ]liver is skmly recovering two fixed sites located eight miles apart the aquatic insect population aver last need clean high�nality water Last year h
fiUm its long history of PODUhon, seen- on the Tennessee side of the Pigeon River summer biologist stocked the river uith common
fists said Wednesday. between Hartford and Newport. `Generally, if you've got the food river snails and spiney ricer snails, and if b
While the river may be in better As a point of refererim the aaentists source, you've gut fish," MdSinney said these make it, plans we to do the same s
shape than it was a decat?e ago,they said also survey the little Rive; which has "Were seeing subtle improvements, Par- with freshwater mussels r
there is still mnsidersbie room for im- physical characteristics 9imi18r m the Pi- ocularly in the less pollution tolerant Charlie Saylor, TVA fishenes biologist, e
provenient goon bat is more pristine. species like stone flies and caddis flies." spent Wednesday in the rivers rifle and
'The zn'w seems healthier as reflected This week's sampling of the Piggeeoon McEIn ney said fish samples taken on shoal auras to collect samples of the L
by the fish community" said Marshall River comes seven months ai er the Envi- the Pigeon River a decade ago yielded rivers smaller fish species By noon, his
Adams senior scientist with Oak Ridge ronmental Protection Agency issued only 12 to 14 species of fish, and most of crew had collected an assortment of q
Natianal lsbarataryc "We've seen same Champion International anew permit them had adapted to living in polluted darters, including a-Swannanoah darter, o
a never before found in the Pi-
but but the river still has a way to regm the maipanys Canton, N.C., water. species t
tom' miII to reduce its color disdiarge by He said that in the past few years the goon River
This is the loth year Tennessee natu- percent by 2001. The new permit also =pec�es must on the Pigeon's upper sum- Sayler characterized the rivers im-
ral resources mid water quality officials moves the point for monitoting pollution clog site has incma9ed to mind 35 pmvement as gradual, with slight annual e
have if
fish and aquatic insects upstream into North Carolina, closer to different spa - still about 10 species messes in densities and varieties of n
ham the River to serve as indica- the paper mi1L short of what the river might have if h�s gone from real low to medium,"
tars of its emlogical health As a fast step, the permit calls on unpolluted v
Th e surveys—conducted by the Ten- Champion to make significant color re- McKinney said the water quality also The Pigeon River in Tennessee still m
nessee Wildlife Resources Agency, the ductions in its discharge by Decembez is affected by urban and agricultural run• carries a consumption advisory from s
. - : . :1 Y._/a:y.3.u :Ct^:::a•'. -[i:F_�:r"� -Jv�2i. ".:n - .e'Y!_: �'irn �l. - TS.__- .:lf
v.
I�{
I

Thursday, M 9, 1M8
mend
i officials against eating carp, cat-
nil redbreast sunfish
y1or said the pools of the Pigeon
usually provides decent catch r"
fish. Whats laces he
are snail fish that would indicate
ly spawns in recent years
terms of game fish species,
fists an Wednesday Ibund crapine,
mouth ham, spitted ham,rock bass,
cast sunfish, and sauger, Other spa
etted out of the deep pools included
A shad, redhorse, buffalo, northern
icker and drum.
-Idor said that as the, Pigecn's water
,v imprm-es, so should its diversity
I species.
P nom Wednesday crews had oollec-
darters —up from the
Z sues
but short of the
or so species the river at the upper
Loring station should hold.
he improvements are noticeable,but
ill have a w;kv to go," Saylor said.
I Sarnwm cm be m=hEd trV"w at 423-
t2 w wffmnsmQkrCW&=m
-'MM

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ATTACHMENT II
NOTE: The legal boundaries of the
�� i F1 :/ i' ��i' r `',\n' C I •fi ' , J ••�✓ o`� (' ' O V facility are shown on Attachment III.
2600
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Bemap ad han USGS 7.5 minute seres9uedn9le(1 24,000
)------
/ v - ' iC Calm,NC(1990).BLUE RIDGE PAPER PRODUCTS,INC.
y \\\
IIAYWOOD COUNTY
CANTON
/ ' e�,Irx`che' � ,� •F `�.%� ���' �s �' /`�`wi .NC MILL
71
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E �J /' '-( ti : 2 ; �; i :I� \ d 1 n r � JJ S I �����' `: ,��'1 ✓ NPDES Permit No.NC0000272
-
/ b7X) 1 � 'a
�i. S • �1 _ - t. � 1�-i�.� b \ •I . a l- � �::\\1 C'\� ��/. Itr 1 r--..-._.' .. r

,, / //ice , , / �� '�►� �►
��� �/� �•

1 2 3 4 1 5 6 7 8 9 101 11 1 12 1 13
K BY-PASS WASTE MIXED LIQUOR K
NUTRIENT FEED
H2SOq PH NTRO) NH40H H3PO4 i r ------ ---------
AB OR AERATION
i DIGESTER i BASIN
i 2.3 MG 3.4 MG i
POLYMER ADDITION
AB OR i
54.82 i DZG3SMGR A NAGIN N i FOR TSS CONTROL
3.4 MG
I `---------- ----------�
IT
i I
INTERMITTENT ADDITION AERATION BASIN
PRIMARY EFFLUENT i OF CACO 20 SURFACE AERATORS
i
0 INJECTION- INTERMITTENT
2 SULFIDE CONTROL
i
•4
CLARIFIER
200' DIAMETER 11 . 48 .
DEWATERED 12' DEEP
CLARIFIER SLUDGE 2.B2 MILLION
G 15.5 200' DIAMETER i i GALLONS
14. 75' DEEP i i G
3.47 MILLION ��
GALLONS i J
�04 RECYCLE—SLUDGE coLL
I �--- 23. 92 ------- — {�
F FOUR i
PRIMARY r F
____ ____ ARUS-PRESSES W
0.6 BELT PRESSES w
.5 �
IL
min i � 200LADIAMETER 11.48 W
02 i i 12' DEEP }
E FLOW 2.82 MILLION ¢
CLARIFIER i E
15.5 200' DIAMETER SPLITTING i GALLONS o
14. 75' DEEP i STATION i o
3. 47 ALLONS ON i w
i Lo N OXYGEN i En
D m D
CONTRO ��� •6 2FT.
REAERATION `��. 150'CLARIFIER
FLUME
•1 �.� CASCADE 14: DEEP
C CLARIFIER �' 1.85 MILLION 6.22
125' DIAMETER �' LOW `� GALLONS C
I1' DEEP LIFT �w GRIT FINAL
1.01 MILLION PUMPS m� CHAMBER EFFLUENT
GALLONS c�
• i
NORMALLY 8FT. FLUME
B SPILL
FOR FLOW COMPLIANCE
COMPLIANCE B
COLYR IOIM bif MMIN TITLE
CITY WWTP - FLOW DIAGRAM
NOTE� Y"
WASTEWATER 29. 0 SE0W9R BLUE RIDGE PAPER PRODUCTS
1 . ALL FLOWS AT DESIGN RATES IN M60 Nis PETMIT NO.
A x u oaam ua uwm. mr u n A
NC0000272
�. wrtemm Dare -ea-e�
MILL OMYINO NUR
F-107A-526
1 2 3 4 1 5 1 9 7 9 4 101 11 12 12