NC0000272_Historical_File_2003thru2007_20070220

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rASHEVILLE
DBLUE �EB 2 1 2007
RIDGEPAPER PRODUCTS INC-
' - R QUALITY SECTION
REGIONAL OFFICE
February 20, 2007 ...
CERTIFIED-MAIL- —...------ -.. . -..._ .. .�,. A
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 3364
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Attn: Central Files
Re: NPDES NO. NC0000272
Best Management Practices 2006 Annual Report
Blue Ridge Paper Products, Inc.
Canton, NC
Please find attached two copies of the data summary of Best Management Practices (BMP)
daily monitoring for Blue Ridge Paper Product's Inc., Canton Mill. This submission is required
by Special Condition A.(6.) Best Management Practices, Section E4 and Section F1, of the
mill's NPDES Permit No. NC0000272.
As noted in the table below, BMP action levels were changed effective 1/1/2006 to reflect
improved color performance at the Canton mill. In addition, the BMP action levels were further
reduced in July 2006 to reflect the improvement in wastewater treatment plant influent color
levels seen from the acid sewer project. These changes are incorporated in the summary of
events below.
BMP Action Level Date Total Influent Color
January—June 2006
One day out-of-control level 19-Feb-06 120,098 Ibs/day
(TI > 82,740#/day) 29-Mar-06 85,460 Ibs/day
Two-day upper action level none none
(TI >72,960#/day)
Two-day lower action level none none
(TI > 63,180#/day)
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

February 20, 2007, Page 2
BMP Action Level Date Total Influent Color
July— December 2006
One day out-of-control level 06-Jul-06 181,636 Ibs/day
(TI > 72,514#/day) 07-Oct-06 74,363 Ibs/day
Two-day upper action level none none
(TI > 63,803 #/day)
Two-day lower action level 22-Aug-06 64,429 Ibs/day
(TI > 55,093#/day) 23-Aug-06 59,818 Ibs/day
09-Oct-06 61,376lbs/day
10-Oct-06 71,330lbs/day
04-Dec-06 62,158lbs/day
05-Dec-06 63,111lbs/day
06-Dec-06 70,276lbs/day
A table of the BMP Action Level exceedances and corresponding corrective actions is attached.
There were no action level exceedances that resulted in disruptions to the Wastewater
Treatment Plant.
Please call us if you have any questions or concerns regarding this information.
Sincerely,
XA r ---P,(2- S
J. Glenn Rogers Paul Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2874 828-646-6141
[e-mail] [e-mail]
Attachment: 2006 BMP Action Level Exceedances and Corrective Action
cc:
Mr. D. Keith Haynes (w/attachments)
Environmental Specialist
North Carolina Department of Environment
& Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Blue Ridge Paper Products Inc
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

February 20, 2007, Page 3
Internal Distribution:
C. File —Water
BMP Notebook
B. Williams
D. Brown
B. Shanahan
J. Clary
J. Pryately
Blue Ridge Paper Products Inc
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

2006 BMP Action Level Exceedances and Corresponding Corrective Actions
NPDES No. NC 0000272
Blue Ridge Paper Products, Inc.
Canton, NC
Dates Primary Influent Color BMP/Non-BMP Event and Corrective Action
During an unplanned outage of#11 Recovery Boiler the level at the waste treatment
plant's low lift was lower than the low lift 24-hour composite sampler's point of collection.
Therefore WTP operations personnel supplemented the composite with grab samples
during the time the water level was below the sampler's point of collection. This practice
led to an overestimated 24-hour composite primary influent color sample result. No
change was observed in secondary effluent color during this time period. Controls were
19-Feb-06 120,098 Non-BMP improved to maintain the appropriate level in the low lift.
During a transfer of black liquor a gasket on a gate valve in a crossover line failed. The
material escaped the containment via an open sump gate to#4 sewer. The conductivity
probe failed to detect high conductivity to alert operators of the presence of black liquor.
Operations personnel were monitoring the levels in the tanks involved in the transfer of
black liquor. It immediately became clear that there was a problem during the transfer and
an investigation followed. The conductivity probe was repaired and is on a regular
29-Mar-06 85,460 BMP preventative maintenance schedule.
During a routine maintenance outage of#11 Recovery Boiler, the line from the CRP slurry
tank to the torpedo tank became plugged with solids. This caused the CRP slurry tank to
overflow for approximately 15-20 minutes before it could be manually by-passed and
valved out. A contractor was called in to jet the plugged line and flow was restored. In the
future common practice will be to by-pass the slurry tank when CRP is down in order to
6-Jul-06 181,636 1 BMP prevent tank overflows.
BMP 2006 Report Data, BMP Summary Page 1 of 2 Printed 2/20/2007

Dilute wash water material from the west camp branch tank cleanout was intentionally
diverted to the mill sewer system. This intentional diversion was necessary to make the
tank suitable for the storage of green and white liquor in the future. Also contributing to
22-Aug-06 64,429 the elevated color was a packing leak in the hardwood blowtower agitator. The hardwood
23-Aug-06 59,818 BMP blowtower a itator was repaired.
An expansion joint on the 1st effect(West GB evaporators)failed and released black liquor
to the mill sewer system. A hot shut down was performed on the West GB evaporators
7-Oct-06 74,363 BMP and the expansion joint was repaired.
A gasket on the recirculation pump discharge valve ist effect(Swenson evaporators)failed
and released black liquor to the mill sewer system. In addition,the pine fiberline was
having filtrate balance problems,which contributed to high sewer generated color in the
WWTP.A hot shut down was performed on the Swenson evaporators and the valve was
09-Oct-06 61,376 repaired. Pine fiberline filtrate balance issues were resolved and returned to normal
10-Oct-06 71,330 BMP operation on 10/11.
7ve
sed from a drain valve on the hardwood blowtower. The drain valve had
04-Dec-06 62,158 ly left in the open position. The released material overwhelmed the sump
OS-Dec-06 63,111 urtyard and escaped to 28 sewer and the WWTP. The drain valve was
06-Dec-06 70,276 BMP ely u on discovery of the liquor release.
BMP 2006 Report Data, BMP Summary
Page 2 of 2 Printed 2/20/2007

�0F WArF9Q Michael F.Easley,Governor
`Q .G William G.Ross Jr,Secretary
co r North Carolina Department of Environment and Natural Resources
Alan W.Klimek,P.E.Director
Division,of Wattcr,Quality
March S, 2007 „ D
Mr. J. Glen Rogers D
Water Compliance Coordinator MAR 1 2 2007
Blue Ridge Paper Products
P.O. Box 4000
Canton, North Carolina WATER QUALITY SECTION
28716 ASHEVILLE REGIONAL OFFICE
Subject: Review of 2006 Monitoring Report for Dioxin in Fish Tissuer """"" "" y --w•
-Blue Ridge Paper Products
NPDES No. NC0000272
Dear Mr. Rogers:
The Division's Environmental Sciences Section has reviewed the Blue Ridge Paper
Products 2006 dioxin fish tissue monitoring results for Waterville Lake, resulting in the
removal of the fish advisory for carp along the Pigeon River.
The declining trend of TCDD concentrations in reservoir fish is certainly good news for
water quality in the Pigeon River. The 2006 results highlight this trend in Waterville Lake,
and justify the removal of carp from the Pigeon River fish advisory. However, in order to
maintain accordance with the existing DHHS protocol, we agree that sampling and dioxin
contamination analysis of carp from Waterville Lake (at station 4A or 4B)should continue
through 2007 and 2008.
Please feel free to contact Jeff DeBerardinis at 919-733-6946 with any questions or
comments.
Sin rely,
I
Chief, Environmental Sciences Section
cc: Mark Hale=ESS
(Roger-Edwards—ARO
Dr. Luanne Williams—NCDHHS
Susan Wilson—DWQ Permits
John Crutchfield—Progress Energy
Noy` Carolina
Jvatura/!�
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh,NC 27699.1621 Phone[phone]
Internet h2o.encstate.nc.us 4401 Reedy Creek Rd. Raleigh,NC 27607 FAX [phone]
An Equal Op podunitylAffirmative Aden Employer-50%Recycled110%Post Consumer Paper

h, � p •
6J
BLUE RIDGE JAN 2 3 2007
PAPER PRODUCTS INC.
January 22, 2007 CERTIFIED 1 IL WATER QUALITY SECTION
ASH _V _LE REGIONAL OFFICE
Return Recei t uese� .
7099 3220 Ob07 0371,:55Q4.. . ._�`:._`.'
D. Keith Haynes
Environmental Specialist
North Carolina Department of Environment
And Natural Resources
Division of Water Quality
2090 US Highway 70
Swannanoa, NC 28778
Subject: NPDES NC0000272
2006 Annual Average Color
Blue Ridge Paper Products, Inc.
Canton, NC
Dear Mr. Haynes -
This letter and attachment document the 2006 average annual color discharge from the Blue
Ridge Paper Products, Inc. mill in Canton, North Carolina. The average secondary effluent
color discharge for the calendar period 1 Jan 2006 through 31 Dec 2006 was 37,058 Ibs/day.
The attachment provides daily wastewater discharge flows and color from the mill during 2006.
Sincerely,
J. Glenn Rogers Paul S. Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2874 828-646-6141
[e-mail] [e-mail]
Attachment: Daily flow and color discharge for 2006
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

Keith Haynes, NC DENR DWQ
22 Jan 2007, Page 2
Distribution
C File- Water
L. Cooper
J. Pryately
B. Shanahan
D. Brown
J. Clary
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

2006 Discharge Color Data
NPDES Permit No.NC0000272
Blue Ridge Paper Products,Inc.
Canton,NC
Date Flow Color Date Flow Color Date Flow Color
an d lbs/daV mcid Ibs/da mad Ibs/da
1/1/2006 24.49 37,377 3/1/2006 24.7 31,106 5/1/2006 26.59 46,791
1/2/2006 26.94 30,556 3/2/2006 24.07 32,119 5/2/2006 27.32 53,317
1/3/2006 26.2 35,835 3/3/2006 25.74 29,410 5/3/2006 26.73 46,369
1/4/2006 25.05 25,697 3/4/2006 24.97 25,823 5/4/2006 26.9 39,036
1/5/2006 25.91 24,634 3/5/2006 25.81 29,705 5/5/2006 28.31 46,749
1/6/2006 25.84 42,670 3/6/2006 24.51 30,253 5/6/2006 27.4 32,221
1/7/2006 26.37 28,590 3/7/2006 24.52 27,812 5/7/2006 28.79 42.739
1/8/2006 26.68 31,597 3/8/2006 24.77 29,541 5/8/2006 27.18 39,443
1/9/2006 26.19 33,856 3/9/2006 26.2 29,280 5/9/2006 25.94 39,157
1/10/2006 26.27 41,408 3/10/2006 25.85 31,260 5/10/2006 26 37,730
1/11/2006 25.24 40,416 3/11/2006 25.92 32,858 5/11/2006 26.44 35,061
1/12/2006 24.79 45.071 3/12/2006 26.13 30,945 5/12/2006 25.9 43,633
1/13/2006 26.66 49,138 3/13/2006 25.8 31,845 5/13/2006 26.82 40,710
1/14/2006 26.14 46,000 3/14/2006 27.4 32,221 5/14/2006 27.3 41,666
1/15/2006 25.99 45,952 3/15/2006 27.41 29,947 5/15/2006 26.65 56,677
1/16/2006 27.43 46,668 3/16/2006 26.86 25,985 5/16/2006 23.85 42,765
1/17/2006 27.3 39,161 3/17/2006 24.31 23,518 5/17/2006 23.3 26,428
1/18/2006 25.94 32,018 3/18/2006 23.82 30,991 5/18/2006 22.67 23,444
1/19/2006 27.1 43,169 3/19/2006 24.67 34,154 5/19/2006 25.74 17.603
1/20/2006 24.85 36,890 3/20/2006 26.09 38,078 5/20/2006 28.82 22,353
1/21/2006 26.47 38,191 3/21/2006 25.59 33,294 5/21/2006 28.69 45,941
1/22/2006 25.65 30,805 3/22/2006 24.88 55,195 5/22/2006 28.04 56.826
1/23/2006 26.46 31,336 3/23/2006 27.71 41,598 5/23/2006 22.48 46,121
1/24/2006 25.82 45,006 3/24/2006 26.46 45,018 5/24/2006 25.43 43,478
1/25/2006 26.51 46,209 3/25/2006 27.42 39,333 5/25/2006 25.83 37,699
1/26/2006 25.09 42,687 3/26/2006 26.38 45,322 5/26/2006 26.91 39,275
1/27/2006 24.48 41,649 3/27/2006 26.18 42,358 5/27/2006 25.6 41,206
1/28/2006 26.15 40,129 3/28/2006 25.39 41,292 5/28/2006 27.14 42,327
1/29/2006 26.68 35,379 3/29/2006 24.73 43,725 5/29/2006 26.39 40,717
1/30/2006 26.95 35,063 3/30/2006 24.75 50,159 5/30/2006 26.09 33,074
1/31/2006 25.9 26,353 3/31/2006 25.87 37,757 5/31/2006 26.72 38,775
2/1/2006 25.1 26,167 4/1/2006 24.9 36,549 6/1/2006 26.35 31.645
2/2/2006 26.37 32,109 4/2/2006 25.71 34,307 6/2/2006 26.23 28,001
2/3/2006 26.17 32,302 4/3/2006 28.71 36,874 6/3/2006 25.63 35,056
2/4/2006 25.98 35,534 4/4/2006 26.17 33,175 6/4/2006 25.21 29,856
2/5/2006 25.6 33,734 4/5/2006 26.82 34,894 6/5/2006 25.95 43,285
2/6/2006 24.71 30,500 4/6/2006 27.68 45,247 6/6/2006 25.97 29,673
2/7/2006 24.67 33,743 4/7/2006 27.03 40,127 6/7/2006 25.66 23,326
2/8/2006 24.42 37,474 4/8/2006 27.97 40,356 6/8/2006 26.26 27,157
2/9/2006 24.26 44,108 4/9/2006 25.41 38,145 6/9/2006 24.73 32.793
2/10/2006 24.79 45,485 4/10/2006 25.59 44,391 6/10/2006 26.24 34,796
2/11/2006 25.93 35,899 4/11/2006 26.24 30,857 6/11/2006 26.99 36,241
2/12/2006 25.72 31,103 4/12/2006 26.83 36,473 6/12/2006 27.3 39,617
2/13/2006 24.8 34,748 4/13/2006 27.56 33,328 6/13/2006 26.73 32,993
2/14/2006 26.51 36,168 4/14/2006 26.14 28,123 6/14/2006 25.77 30,089
2/15/2006 24.85 33,989 4/15/2006 25.44 28,431 6/15/2006 25.89 30,229
2/16/2006 24.85 31,502 4/16/2006 25.5 30,624 6/16/2006 27.02 29,746
2/17/2006 24.08 31,731 4/17/2006 24.96 24,147 6/17/2006 27.02 35,830
2/18/2006 23.78 36,690 4/18/2006 25.5 29,561 6/18/2006 26.86 48,387
2/19/2006 25.12 39,805 4/19/2006 26.48 33,126 6/19/2006 25.85 35,357
2/20/2006 25.3 37,136 4/20/2006 25.95 30,732 6/20/2006 26.71 36,533
2/21/2006 28.44 36,290 4/21/2006 25.74 29,195 6/21/2006 26.37 30,130
2/22/2006 26.92 39,739 4/22/2006 28.06 41,656 6/22/2006 26.15 31,841
2/23/2006 26.37 40,686 4/23/2006 28.18 39,484 6/23/2006 27.14 29,652
2/24/2006 25.51 34,041 4/24/2006 25.96 44,600 6/24/2006 29.08 30,073
2/25/2006 25.1 38,517 4/25/2006 24.85 34,818 6/25/2006 29.1 27,424
2/26/2006 24.19 29,455 4/26/2006 27.76 37,969 6/26/2006 30.33 33,137
2/27/2006 25.17 37,785 4/27/2006 27.87 55,320 6/27/2006 28.51 29,008
2/28/2006 24.65 34,332 4/28/2006 27.16 34,204 6/28/2006 27.84 32,042
4/29/2006 29.22 58,974 6/29/2006 26.28 37,698
4/30/2006 26.92 35,922 6/30/2006 26.28 28,712
Subtotal Ibs 2,1 283 Subtotal Ibs 2,183,514 Subtotal Ibs 2,219,6581
2006colorcalc,2006 Daily Color data Paget of 2 Printed 1/19/2007

2006 Discharge Color Data,continued
NPDES Permit No.NC0000272
Date Flow Color Date Flow Color Date Flow Color
mad lbs/day an d Ibs/da mad Ibs/da
7/l/2006 26.93 27,176 9/l/2006 28.88 41,669 11/1/2006 24.29 41,123
7/2/2006 25.79 23,445 9/2/2006 26.94 33,028 11/2/2006 24.66 37,842
7/3/2006 26.34 33,391 9/3/2006 26.83 27,075 11/3/2006 24.99 30,846
7/4/2006 25.62 31,837 9/4/2006 27.58 33,122 11/4/2006 24.55 34,602
7/5/2006 27.54 39,046 9/5/2006 27.48 33,919 11/5/2006 25.43 35,206
7/6/2006 26.9 47,561 9/6/2006 26.5 38,677 11/6/2006 25.05 35,516
7/7/2006 26.5 101,223 9/7/2006 25.4 40,249 11/7/2006 26.09 28,287
7/8/2006 26.38 104,504 9/8/2006 26.23 44,627 11/8/2006 25.72 29,816
7/9/2006 25.7 48,656 9/9/2006 25.79 30.543 11/9/2006 24.92 28,681
7/10/2006 25 46,496 9/10/2006 26.37 38,707 11/10/2006 24.97 28,322
7/11/2006 25.67 42,389 9/11/2006 29.01 37,743 11/11/2006 25.81 27,768
7/12/2006 25.75 39,515 9/12/2006 23.84 37.180 11/12/2006 26.45 28,015
7/13/2006 24.52 48,670 9/13/2006 23.17 39,034 11/13/2006 28.34 36,635
7/14/2006 26.36 40,011 9/14/2006 24.52 33,946 11/14/2006 27.04 31,572
7/15/2006 25.1 28,469 9/15/2006 24.39 22,172 11/15/2006 28.55 33,811
7/16/2006 24.8 34,955 9/16/2006 23.73 20,385 11/16/2006 27.89 28,610
7/17/2006 25.25 40,011 9/17/2006 24.49 25,735 11/17/2006 26.48 32,685
7/18/2006 24.48 39,608 9/18/2006 24.88 38,180 11/18/2006 25.93 38,926
7/19/2006 25.14 30,192 9/19/2006 25.13 33,533 11/19/2006 26.6 32,833
7/20/2006 25.22 29,447 9/20/2006 24.65 22,203 11/20/2006 26.83 42,067
7/21/2006 26.53 29,649 9/21/2006 26.55 22,586 11/21/2006 26.65 25,115
7/22/2006 26.15 27,698 9/22/2006 27.06 38,817 11/22/2006 27.18 25,842
7/23/2006 24.78 24,593 9/23/2006 25.68 32,340 11/2312006 26.56 24,588
7/24/2006 25.62 27,136 9/24/2006 27.82 42,691 11/24/2006 26.81 31,751
7/25/2006 25.64 39.774 9/25/2006 24.35 30,868 11/25/2006 26.85 36,053
7/26/2006 24.8 33,920 9/26/2006 24.49 27,982 11/26/2006 27.12 46,141
7/27/2006 25.85 26,733 9/27/2006 24.29 29,576 11/27/2006 27.31 40,087
7/28/2006 25.73 34,549 9/28/2006 26.7 26,944 11/28/2006 28.23 44,733
7/29/2006 26.39 42,258 9/29/2006 24.55 29,893 11/29/2006 27.76 42,599
7/30/2006 24.89 43,592 9/30/2006 24.22 32,319 11/30/2006 28.42 30,576
7/31/2006 26.92 42,208 10/1/2006 24.31 33,453 12/1/2006 29.1 39,074
8/1/2006 27.3 37,795 10/2/2006 24.2 34,109 12/2/2006 27.18 30,829
8/2/2006 28.45 45,082 10/3/2006 24.87 33,601 12/3/2006 27 42,559
8/3/2006 26.22 36,081 10/4/2006 24.91 34,486 12/4/2006 27.13 44,122
8/4/2006 26.9 33,203 10/5/2006 25.69 32,781 12/5/2006 26.9 52,497
8/5/2006 27.86 29,741 10/6/2006 25.84 38,360 12/6/2006 27.04 57.731
8/6/2006 26.92 32,105 10/7/2006 25.23 47,555 12/7/2006 26.99 42,768
8/7/2006 27.76 36,811 10/8/2006 26.16 48.653 12/8/2006 26.44 47.410
8/8/2006 27.89 37,914 10/9/2006 25.03 50,100 12/9/2006 25.89 39.082
8/9/2006 25.59 35,214 10/10/2006 25.62 57,264 12/10/2006 25.76 35,233
8/10/2006 26.78 43,106 10/11/2006 26.11 38,543 12/11/2006 26.33 43,260
8/11/2006 28.2 67,264 10/12/2006 24.43 35,656 12/12/2006 26.2 47,198
8/12/2006 28.75 53,710 10/13/2006 24.2 30,476 12/13/2006 25.86 31,272
8/13/2006 26.36 42,649 10/14/2006 25.07 38,262 12/14/2006 24.77 33,053
8/14/2006 25.1 32.237 10/15/2006 25.25 40,011 12/15/2006 25.5 38,706
8/15/2006 27.75 43,510 10/16/2006 24.75 38,393 12/16/2006 25.38 26,247
8/16/2006 25.83 34,252 10/17/2006 26.98 44,103 12/17/2006 25.04 25,478
B11712006 25.34 36,138 10/18/2006 26.97 40,487 12/18/2006 25.79 26,671
8/18/2006 24.91 37,603 10/19/2006 27.52 45,903 12/19/2006 26.26 31,975
8/19/2006 28.34 42,780 10/20/2006 26.93 51,433 12/20/2006 25.63 34,628
8/20/2006 29.81 35,801 10/21/2006 26.77 46.885 12/21/2006 26.26 31,756
8/21/2006 27.32 37,595 10/22/2006 26.09 45.476 12/22/2006 26.02 30,381
8/22/2006 26.44 40,133 10/23/2006 25.73 45,707 12/23/2006 25.84 37,282
8/23/2006 26.85 40.307 10/24/2006 27.07 43,798 12/24/2006 25.64 39,560
8/24/2006 26.33 37,331 10/25/2006 23.34 35,817 12/25/2006 26.19 41,064
8/25/2006 25.81 29,705 10/26/2006 25.75 43,166 12/26/2006 25.86 36,017
8/26/2006 25.39 29,222 10/27/2006 26.4 58,567 12/27/2006 26.48 38,648
8/27/2006 26.12 46,182 10/28/2006 26.29 50,649 12/28/2006 26.38 28,821
8/28/2006 26.88 49,095 10/29/2006 26.3 48,913 12/29/2006 25.99 39,016
8/29/2006 28.03 36,001 10/30/2006 24.43 40,953 12/30/2006 26.58 47,439
8/30/2006 29.5 36,412 10/31/2006 24.28 42,929 12/3l/2006 28.5 44,686
8/31/2006 30.21 41,572
Subtotal Ibs 2.4 264 Subtotal Ibs 2 302 232 Subtotal Ibs 2.195.112
Total color discharge,Ibs 13,526,063 Days in 2006 365 Annual Average Color, Ibs/day 37,058
2006colorcalc,2006 Daily Color data Page2 of 2 Printed 1/19/2007

pF w/t TF9O Michael F.Easley,Governor
�
O (r William G.Ross Jr.,Secretary
� 'buid
r North Carolina Department of Environment and Natural Resources
"Alan.W.Klimek,P.E.Direcigr -
Division of Water Quality t
October 27, 2006 RJr
n f� 2� r1In LI I,', NOV — 6 2006 �l j
Mr. William G. Stamey, Town Manager I
Town of Canton I l-
w^7FR C'Jt,L'TY S^CT;CId
58 Park Street
Canton, North Carolina 28716-4324
h.. ...a .vaw -......... ....-«.. .... ,
SUBJECT: Town of Canton
Engineering Report
Influent Pump Station Flood Walls at
-Blue Ridge Paper Products WWTP — - —
STAG Project No. XP-96447306-00
Dear Mr. Stamey:
The Construction Grants and Loans Section of the Division of Water Quality has
completed its review of the town of Canton Engineering Report. The project consists of
construction of concrete floodwalls around the existing pump station at the wastewater treatment
plant, installing 3 plug valves and a 30" x 30" sluice gate, and related site work.
The subject town of Canton Engineering Report is hereby approved.
If you have any questions concerning this matter, please contact Mr. Larry Horton,P.E.
of our staff at [phone].
Sincerely,
-- - -- - — -- - - ?onstructi!onBowe,P.E.,Chief ---_--Grants and Loans Section
ZQC:dr
cc: McGill &Associates - Michael J. Waresak, P.E.
DWQ AshevilleReg not al'Office�
Daniel Blaisdell, P.E.
Larry Horton,P.E.
Zi-Qiang Chen, Ph.D.
PMB/DMU/STAG
Construction Grants and Loans Section One
1633 Mail Service Center Raleigh NC 27699-1633 NorthCarolina
Phone:[phone]/FAX:[phone]/Internet:www.nccgl.net /� [/
An Equal Opportunity/Affirmative Action Employer—50%Recycled/l0%Post Consumer Paper Natur( llU

F \NA
O�� RQG Michael F.Easley,Governor
65
William G.Ross Jr.,Secretary
r North Carolina Department of Environment and Natural Resources
`C Alan W.Klimek,P.E.Director
Division of Water Quality
October 3, 2006
198
Mr. John J. Pryately
Blue Ridge Paper Products Inc. WTP
P.O. Box 4000
Canton, NC 28716
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Mr. Pryately:
Enclosed is a report for the inspection performed on September 21, 2006 by Mr. Gary
Francies . No deficiencies or lettered comments and/or recommendations are cited in this
report, a response is not required. We appreciate the fine job you and your staff are doing. As
a certification requirement, your laboratory must continue to carry out the requirements set
forth in 15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from this
office. Thank you for your cooperation during the inspection. If you wish to obtain an electronic
copy of this report by email, or if you have questions or, need additional information please
contact us at 919-733-3908.
Sincerely,
Pat Donnelly
Branch Mane9er__
i
OCT
Enclosure L__
LAOORATORY SECTION
ASHEViILr HEGIO+;S,! ,I M o e cc: Gary Francies _._____ .Nnrthcarolina
Asheville Regional Office
North Carolina Division of Water Quality 1623 Mail Service Center Raleigh,NC 27699-1623 Phone[phone] Customer Servicc
Intemet www.dwglab.org Location:4405 Reedy Creek Rd Raleigh,NC 27607 Fax [phone]
An Equal Opportunity/Alfomative Action Employer—50%Recycled/70%Post Consumer Paper

On-Site Inspection Report
LABORATORY NAME:- Blue.Ridge Paper Products WWTP Lab
ADDRESS: P.O. Box 4000
Canton, NC 28716
CERTIFICATE NO: 198
DATE OF INSPECTION: 9/21/06
TYPE OF INSPECTION: Maintenance
EVALUATOR: Mr. Gary Francies
LOCAL PERSON(S) CONTACTED: Mr. John, Mr. Glenn Rogers, Ms. Lori Cooper, Mr. Harold Sweitzer
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
IL GENERAL COMMENTS:
The staff is congratulated for doing ..a good job of maintaining' the laboratory program. They are
commended for taking the initiative in requesting copies of check lists and new policy statements well
before the inspection to ensure any new policies were already in place. The laboratory is spacious and
well equipped. All equipment is well maintained. Since the last inspection a new refrigerator has been
obtained. Records are well kept and most data appeared accurate.
Ill. DEFICIENCIES, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
No deficiencies, comments, or recommendations were noted.
IV. PAPER TRAIL INVESTIGATION:
No paper trail was performed.
V. CONCLUSIONS:
No deficiencies, requirements, comments, or recommendations were noted during the inspection. No
response is required. The inspector would like to thank the staff for their assistance in the inspection
and data review process.
Report prepared by: Gary Francies Date: 9/29/06
OCT _ o 9602 '
i
LABORATORY SECTION
ASHEMIE REGIONA: OFF!U

�O pECE V,
s ICI g , D
NOTIFICATION REPORT FOR SPILI/REL�'SE JUN 2 2006
CANTON MILL
175 MAIN STREET P.O.BOX 4000 WATER QUALITY SECTION
C CANTON,NC 28716 1 L ASR VILLE REGIONAL OFFICE
Name of Chemical 40o mS►1f q� , JfOm kj%3bok "C� �u S:aTnn
Is Substance an Extremely Hazardous Substance ❑ YES NO
Caller's Name &Position: Mq &
Media into which release occurred: ❑ Air ® Water ❑ Land
S rMwnk�- PrAPe.e P�n�ON P�i,y C�ta f� gnus o��� �rh �Inat� Lr�
s�Pcft\uh�K out d 3
Quantity Released: (give reasonable estimate if known or that RQ may have exceeded,and will
call back as soon as possible--do not delay reporting) N -71 S8 goj`Inp,\ 45 & a\q l30
Date,start and stop of release : �/a I A f (-qA PM - -7- 4 Qt.
Cause and source of release : PIpcei%akrdfi it q
g010A some qurr,Qs \wte woeKL,Mg feu, coin NO+ Yee \JQ , Stl,'%e dn%'Qs LN
Sump OTT& �nnn Cn. - Ct 5iti �e ruo Jabul
Action taken to respond to release and status of actions : J q Py
tied- cleo,Ile� OUj- QZ - as well 0& suNday "N'o9,. P01; WpAe OLOV OL\+
iw� , srrou A-casH eu�? 04,1m h \aas also ALL+ .M glace 'k� meeeded, 'E061 of
— ,� warK�rlo� e�op� ec Y � sur~,Q leve ig- low , -
Other Notification:
National Response Center
Date: Time: Report No.
Petty Officer Name :
NCDEHNR-Asheville or NC Emergency Response-Raleigh
Date: 6 h4
t Time:: 7.4 ?T-
Contact: cdN� 6ea K2�{1A R1�1 \nPS pal (o �filo g--S,r A'M - Lt4 (`npsme
c�1ted lie�}L� bocY� N q:dSq"^ t s�>�e wi+�\ ti:fA. was 1d No S-dou
w f�l�eN Cf c 1 s`I?.eda� auk ceq,lle5}ed 0, cC�Y 0� 13fV\S �t7f M J0
Mri,

T
.. � r .�'�

Local Emergency Planning Committee
Date: fs Time
Contact:
Western North Carolina Regional Air Pollution Control Agency
Date: Time
Contact:
Whether any injuries occurred: ❑ YES NO
yes,provide detail:
Name and telephone number of person to contact for further information:
Action taken for clean-up:
Does release require written notification under Section 204 of Emerg ncy Planning and
Community Right to Know Act(Title III SARA): ❑ YES JN NO

Pce c
•; -`' 9q �ItuC EST 06_24_06.RPT =N
6 24 2006 1610 5.7 83 19.7 7.9 77 10.8 79.2 78.0 76.1 -1.24 630.2 0.00 27.40
6 24 2006 1615 6.6 69 14.4 8. 5 74 9.4 79.6 78.3 76.4 -1.34 635.6 0.00 27.40
6 24 2006 1620 8.1 78 11.2 11.4 76 4.4 79.9 78.5 77.0 -1.37 754.0 0.00 27.40
6 24 2006 1625 9.5 81 12.3 13.5 76 3.7 79.5 78.2 75.9 -1.34 467.0 0.00 27.40
6 24 2006 1630 9. 5 81 17.9 13.2 80 9.9 77.9 76.6 74.5 -1.35 542.3 0.00 27.40
6 24 2006 1635 9.5 84 17.4 15.2 81 7.6 78.4 76.9 74.2 -1.54 638.6 0.00 27.40
6 24 2006 1640 10.7 75 11.9 15.6 77 7.2 77.5 76.3 73.8 -1.20 546.9 0.00 27.39
6 24 2006 1645 11.5 78 13.6 16.1 80 7.9 75.6 74.7 72.6 -0.97 308.1 0.00 27.39
6 24 2006 1650 11.3 76 12.3 14.7 80 9.0 74.4 73.7 72.0 -0.71 173.9 0.00 27.39
6 24 2006 1655 9.4 70 16.5 14.3 75 6.2 73.6 73.1 71.6 -0.46 137.2 0.00 27.39
6 24 2006 1700 8.5 73 16.1 12.3 69 7.9 73.4 72.9 71.3 -0.50 117.4 0.00 27.39
6 24 2006 1705 8.2 77 14.3 11.6 77 6.5 72.8 72.4 71.2 -0.45 49.2 0.00 27.39
6 24 2006 1710 5.9 82 15.8 9.3 83 13.7 72.7 72.2 71.1 -0.44 27.3 0.00 27.39
6 24 2006 1715 6.7 78 17.4 10.2 77 9.0 72.5 72.1 70.8 -0.43 21.8 0.00 27.39
6 24 2006 1720 4.3 92 33.2 5.6 103 26.0 72.3 72.1 70.9 -0.16 10.0 0.00 27.40
6 24 2006 1725 6.0 209 55.2 8.8 206 64.9 73.1 74.5 70.6 1.37 4.2 0.06 27.41
6 24 2006 1730 13.4 277 15.3 18.9 264 12.3 70.0 68.9 67.1 -1.08 3.9 0.16 27.42
6 24 2006 1735 10.9 237 25.8 19.1 244 15.5 66.5 66.5 65.4 -0.02 4.6 0.31 27.44
6 24 2006 1740 9.2 281 29.2 14.2 276 20.5 65.0 64.9 64.1 -0.09 8.0 0.34 27.45
6 24 2006 1745 5.8 312 16.7 10.9 302 6.3 64.2 64.0 63.4 -0.16 14.6 0.17 27.44
6 24 2006 1750 4.9 321 20.7 6.4 312 13.8 63.8 63.6 63.2 -0.22 20.1 0.07 27.43
6 24 2006 1755 2.5 231 75.6 2.9 63 70.5 63.7 63.6 63.1 -0.09 24.2 0.04 27.43
6 24 2006 1800 3.6 127 39.7 6.0 84 26.8 63.6 63.6 63.1 -0-02 35.7 0.04 27.42
6 24 2006 1805 5.0 110 20.7 6.6 75 17.3 63.9 63.8 63.6 -0.14 64.7 0.02 27.42
6 24 2006 1810 4.1 127 17.6 7.8 92 9.4 64.2 63.8 63.2 -0.43 112.9 0.02 27.42
6 24 2006 1815 3.7 115 18..0 7.5 92 10.5 63.8 63.5 62.9 -0.25 118.9 0.02 27.42
6 24 2006 1820 4.6 158 16.9 5.9 110 20.8 64.1 63.8 62.9 -0.38 107.7 0.01 27.42
6 24 2006 1825 4.5 159 13.2 6.4 135 12.2 63.2 63. 5 62.7 0.34 109.4 0.01 27.42
6 24 2006 1830 3.9 162 15.8 5.5 131 14.5 64.7 64.1 63.2 -0.59 113.3 0.01 27.42
6 24 2006 1835 2.4 167 26.3 3.1 129 17.7 63.6 63.7 63.1 0.05 106.1 0.01 27.42
6 24 2006 1840 2.2 199 26.0 2.7 138 14.2 65.4 63.9 63.5 -1.55 84.1 0.00 27.42
6 24 2006 1845 2.2 188 28.0 2.6 144 19.3 64.2 64.0 63.5 -0.19 70.7 0.00 27.42
6 24 2006 1850 2.1 189 38.0 2.1 152 19.3 63.5 64.3 63.6 0.83 68.0 0.00 27.42
6 24 2006 1855 1.5 199 34.4 1.8 155 34.4 64.1 64.2 64.0 0.07 64.3 0.00 27.42
6 24 2006 1900 2.8 238 11.9 0.8 241 25.9 63.0 63.8 64.0 0.76 34.9 0.00 27.42
6 24 2006 1905 3.4 263 16.6 3.9 296 13.3 64.2 64.1 64.1 -0.09 17.6 0.00 27.42
6 24 2006 1910 4.1 246 12.4 4.7 281 5.1 64.0 64.3 64.0 0.39 10.0 0.00 27.43
6 24 2006 1915 3.1 277 23.1 4.2 301 17.6 65.8 63.8 64.1 -1.97 6.8 0.01 27.43
6 24 2006 1920 2.8 330 15.0 3.2 332 11.6 64.4 63.7 63.7 -0.62 5.6 0.01 27.44
6 24 2006 1925 2.6 273 22.8 3.6 353 17.2 63.1 64.0 64.1 0.96 4.6 0.01 27.44
6 24 2006 1930 2.0 253 24.4 2.5 319 24.3 63.4 63.9 64.0 0.42 3.4 0.02 27.44
6 24 2006 1935 2.6 291 22.8 4.1 323 14.0 63.6 63.4 63.5 -0.14 2.5 0.02 27.44
6 24 2006 1940 3.6 254 14.8 3.5 296 13.5 64.3 64.3 63.6 -0.06 0.8 0.01 27.44
6 24 2006 1945 2.8 228 21.6 2.1 299 43.4 64.0 63. 5 63.8 -0.47 0.0 0.01 27.44
6 24 2006 1950 2.1 187 28.3 1.5 150 47.5 61.0 63.0 63.4 1.93 0.0 0.01 27.44
6 24 2006 1955 2.7 143 13.7 3.6 128 9.8 62.0 63.6 63.4 1.55 0.0 0.00 27.44
6 24 2006 2000 2.6 155 17.4 4.4 136 9.2 64.7 64.2 63.5 -0.46 0.0 0.01 27.44
Page 6

`o�0F W ATFROG dllcn rc
act r.msicy,w ...oi William G.Ross Jr.,secretary
Cl) North Carolina Department of Environment and Natural Resources
1 - Alan W.Klimek,P.E.Director
O C Division of Water Quality
May 24, 2006 D � � � I
Mr. William G. Stamey,Town Manager MAY 3 0 200Town of Canton58 Park Street
Canton, North Carolina 28716-4324 ASHEVEL EGRiAL'TYEGONAL
SUBJECT: Town of Canton
Engineering Report
Influent Pump Station Flood Walls at
Blue Ridge Paper Products WWTP
STAG Project
Dear Mr. Stamey:
The Construction Grants and Loans Section has completed its technical review of the
subject town of Canton's Engineering Report of the Influent Pump Station Flood Walls at Blue
Ridge Paper Products WWTP. A copy of the comments resulting from this review is attached
for your reference. These comments are also being sent directly to your consulting engineer,
McGill &Associates, by copy of this letter. A revised Engineering Report that incorporates
responses to these comments should be submitted for our review and approval as soon as
possible. Providing thorough and complete responses to these review comments in a timely
manner is necessary to avoid delays of the project approval.
If you or your engineer have any questions or need assistance in resolving the
environmental assessment comments, please call Ms. Hannah Stallings at(919) 715-6209. If
you have any questions concerning technical review issues, please contact me at [phone].
Sincerely
K. Lawren Horton, III, P.E., Supervisor
Facilities valuation Unit
ZQC:dr
Attachments
cc: McGill &Associates - Michael J. Waresak, P.E.
DWQ Asheville Re Tonal Office
Daniel Blaisdell, P.E.
Zi-Qiang Chen, Ph.D.
Hannah Stallings
PMB/DMU/FEU/STAG
Construction Grants and Loans Section One
1633 Mail Service Center Raleigh NG 27699-1633 NorthCarolina
Phone:[phone]/FAX:[phone]Internet:www.nccgi.net a�R "
ura//y
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper f.�/�/ `

TOWN OF CANTON
Review Comments
Engineering Report of
Influent Pump Station Flood Walls
Wastewater Treatment Plant
STAG Project ,�q C
May 24,2006
NOTE: Please provide a response to all of the comments on a"comment for comment" basis.
Where appropriate, add or revise narrative in the text of the Engineering Report (ER)
that addresses the issues discussed in the comments. In addition, the comments and
responses-may be included as a part of the report (e.g. in an appendix).
I. General
1. The Table of Contents should also include the tables and figures that are in the report. A
descriptive title should be provided for each item, along with the page number where the
tables and/or figures are located in the report.
2. Please provide documentation that the town of Canton has, or is planning to complete an
agreement with Blue Ridge Paper Products concerning the town's use of the WWTP.
According the U.S. EPA Region IV's STAG project guidelines, the following two (2)
aspects of the agreement need to be included: 1) the town of Canton has the easement to
the flood walls; 2) the town conducts the maintenance of the flood walls in the WWTP
during the 20-year design period of time.
3. This information of the agreement mentioned in Item 2, in the form of a final agreement,
must be provided to Construction Grants & Loans (CG&L) before plans and
specifications are approved.
4. The owner and consulting engineer should be advised that after approval of the
Engineering Report, there are several construction project permits, approvals,
certifications, etc. that must be obtained before the project plans and specifications can be
approved and the project is advertised for bids. Therefore, it is strongly recommended
that preliminary work to obtain the following items, if applicable, begin as soon as
possible:
a. Sedimentation and Erosion Control Permit from the Division of Land Quality, or a
letter from them stating that no permit is required for this project.
b. 401 Water Quality Certification and Army Corps of Engineers' 404 Permit for all
stream crossings, or letters from the Army Corps of Engineers and from the Wetlands
401 Certification Unit stating that none is required for this project.
Page 1 of 2

1 ,
c. Section 10 Permit for aerial crossings of navigable waters, or a letter from the Corps
stating that none is required for this project.
d. A reasonable subsurface investigation that must be made available to the contractor.
If it is not included in the specifications, the specifications must advise where a copy
of the report can be observed. Typically, CG&L expects a boring about every
500 feet and at each road crossing for linework and at all major structures like pump
stations, aeration basins, and clarifiers.
II. Section B - Current Situation:
1. Pages 2 and 3: Please identify the age and condition of sewers system, associated pump
stations, and any important appurtenances.
2. Page 3: Please provide a general history of overflows and bypasses of the town's
wastewater system.
3. Page 8: Please provide an estimate of the current residential and commercial
wastewater flows in the town, if possible.
4. Page 8: Please confirm that the town and BRPP's total current wastewater flow is
26 MGD (BRPP) +0.8 MGD (Canton) = —27 MGD.
5. Please confirm that the proposed project design will comply with NCAC 21-1.0219 -
Minimum Design Requirements. (A copy of.0219 is attached for reference).
IH. Section F - Current User Charges and Financial Capability
Page 14: Please provide documentation to show that the$651,000 of the N.C. Hurricane
Recovery Act fund(grant) has been designated and reserved solely for the proposed
project.
IV. Section H - Proposed Proieet Description:
Please amend the following sentence on the bottom of page 16 so that it reads correctly:
"The locations of the flood walls have.been,closely-flood walls." _ — - --- — -- -- —
Page 2 of 2

�0 WATFRO _ Michael F.Easley,Governor
\� (r William G.Ross Jr.,Secretary
rNorth Camlina De arq chLoI:Envimnmen4aml' atuml Resources
c.k,P.E.Director
UDr rgro f Water Quality
MAY 1 6 2006 � U
May 12„2006
WATER DUALITY SECTION
GVILLE REGIONAL OFFICE
Mayor Patrick U. Smathers ASH
Town of Canton —
58 Park Street
Canton, North Carolina 28716-4324
SUBJECT: Review Comments
Town of Canton
Blue Ridge Paper Products WWTP
Construction of Flood Retaining Wall
STAG Project
Dear Mayor Smathers:
A review of the plans and specifications for the Blue Ridge Paper Products WWTP
influent pump station project has been completed by the Construction Grants and Loans Section
(CG&L). The comments resulting from this review are being transmitted directly to your
engineer for clarification and resolution; a copy is attached for your reference. Our goal is to
approve the plans and specifications as soon as possible. A thorough and timely response is
necessary in order to accomplish this goal.
Upon receipt of satisfactory responses from your engineer to our comments, the review of
the plan documents will be completed. If you have any questions concerning this matter, please
do not hesitate to contact Michelle McKay, E.I., State Project Review Engineer, at
[phone].
Sincerely, A
f1 � ��
Cecil Madden,Jr., P.E., Supervisor
Construction Grants and Loans Section
Design Management Unit
MM/dr
Attachment to all cc's
cc: Michael.J..W..aresak„P..E.,_McGill & Associates
EWQ_Asheville Regiottal Offie
Daniel Blaisdell, P.E.
Michelle McKay, E.I.
Cecil G. Madden, Jr., P.E.
Don Evans
STAG File
Construction Grants and Loans Section One
1633 Mail Service Center Raleigh NC 27699.1633 North Carolina
Phone:[phone]/FAX:[phone]/Internet:www.nccgl.nel
An Equal Opportunity/Af irmative Action Employer—50%Recycled/10%Post Consumer Paper Naturally

Construction Grants & Loans Section
Design Management Unit
Town of Canton
Blue Ridge Paper Products WWTP
Construction of Flood Retaining Wall
Review Comments
General Review
1. Provide a 401 Water Quality certification and a 404 permit associated with the proposed
project or provide letters from the agencies stating none is required.
2. Please confirm that the MOC Building, shown on sheet C1, will be removed prior to the
construction contract beginning.
3. Plans and specifications cannot be approved for funding prior to the approval of the
Engineering Report.
Review of Plans
1. Please show all property lines, construction easements, and permanent easements on the
plan drawings.
2. Please show all wetlands, watercourses and drainage features within 50 feet of the
proposed project.
3. What is the purpose of the proposed sluice gate in relation to the grit chamber?
4. Please show where the pilings will be located throughout the perimeter of the flood wall.
5. On sheet C2 the note under the Flood Gate Support detail states, "All flood gate supports,
bolts and plates not embedded in concrete is provided by others."There is also a note
pointing to this detail that states, "Flood gate support fitted in steel tubing embedded in
concrete(provided by others)."The notes on this sheet appear to be contradicting each
other. There are similar notes in the Flood Gate Wall Channel detail. It is also noted that
there is no specification for the flood gate equipment/hardware.
6. Confirm if piping located under the flood wall foundation will be adversely affected by
the flood wall.
7. Advise if piping and the granular fill surrounding it will serve as a conduit for
floodwaters to enter the area to be protected.
8. Confirm that a 10-foot driving head will not send flood waters under the flood wall.

Review of Specifications
1. Provide a Bid Bond.
2. Provide a Change Order Form.
3. State Statute requires Dispute Resolution including mediation. Advise where this is found
in your specifications. A recommended format is available on our website at:
http://www.ncc lg net/fap/plans.html.
4. The Minority Business Forms provided were outdated or incomplete. Please use all of the
Minority Business Forms found on our website at: http://www.nccol.net/fap/plans.litml.
5. Please include the Minority Business Guide in the specifications. It can also be found on
our website.
6. Indicate in the specifications where the pilings will be located and what method will be
used for installation of the pilings.
Review of Soils Report
1. The Geotechnical Report provided states that the bottom of the walls foundation will be
at an elevation of 2587.5 feet and will be about five feet below ground level. The plans
indicate ground level is at approximately 2582 feet. Please make the appropriate
corrections.

F NNA7'E eq, Michael F.Easley,Governor '
oa0 RQG a. lliiawA,;RosdsaJ,r.,:Secretary,,
North Carolina Department of E0. re men and Natura�t odic §' ' r
h r is W. Ima P.E.Dir
>_ Diviin o ater Q ari s'
As�ewlle Reg%naYbff{Fk
SURFACE WATER PROTECTION
March 22, 2006
Derric Brown
Blue Ridge Paper Products Inc
PO Box 4000
Canton NC 28716
SUBJECT: Compliance Evaluation Inspection
Canton Mill
Permit No:. NC0000272
Haywood County
Dear Mr Brown:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for
the inspection, which I conducted at your facility on March 16, 2006. The facility was
found to be in Compliance with permit NC0000272.
Please refer to the enclosed inspection report for additional observations and
comments. If you or your staff, have any questions, please do not hesitate to call me at
296-4500.
Sincerely,
In')III
u z
Keith Hayn¢S
Environmental Specialist
Enclosure .
cc: John J Pryately, ORC
Central Files
%+Asheville Files--.-- o`�VCarolina
h!!Yl/l!f
2090 U.S.Highway 70.Swannanca,NC 28778 Telephone:[phone] Fax:[phone] Customer Service 1 877 623-6748

United States Environmental Protection Agency
EPA Washington,D.C.20460 Form Approved.
OMB No.2040-0057
Water Compliance inspection Report Approval expires 8-31-98
Section A: National Data System Coding(i.e., PCS)
Transaction Code NPDES ydmo/day Inspection Type Inspector Fac Type
1 Iul 2 I5I 31 NC0000272 I11 121 06/03/16 I17 18Ir1 19 cl 201 I
L� Remarks iJ LI
21IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 OA —Reserved-
67I 169 701 .LJ I 71 u 72 n 73 W 74 75I I I I I I I 180 .
Section B: Facility Data
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also Include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number)
Canton Mill 08:30 AM 06/03/16 05/06/01
175 Main se Exit TlmelDate Permit Expiration Date
Canton HC 28716 03:30 PM 06/03/16 06/11/30
Name(s)of Onsile Represerdative(s)Ttles(s)/Phone and Fax Number(s) Other Facility Data
John J Pryately/DRC/828-646-6720/
Paul Dickens///
Name,Address of Responsible Official(Title/Phone and Fax Number
Contacted
Derric Brown,PO Box 4000 Canton NC 28716//828-646-2318/
Yes
Section C: Areas Evaluated During Inspection(Check only those areas evaluated)
Flow Measurement Operations&Maintenance E Facility Site Review EfFluenttReceiving Waters
Section D: Summary of'Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Dale
xeith , Haynes ARC w4//828-296-4500/ J �1 0 r
r ` l�
Signature of Management O A Reviewer Agency/Office/Phone and Fax Numbers Date /
Roger C Edward ARO WQ//828-296-4500/ 3L,2 b(p
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

NPDES yr/mo/day Inspection Type i
3I NC0000272 I11 12I 06/03/16 I17 181CI
Section D: Summary of Finding/Comments(Attach additional)LC
of narrative and checklists as necessary)
The facility appeared to be properly maintained and well operated.
Page# 2

Permit: NC0000272 Owner-Facility: Canton Mill
Inspection Date: 03/16/2006 Inspection Type: Compliance Evaluation
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting? ■ ❑ ❑ ❑
Is flow meter calibrated annually? ■ ❑ ❑ ❑
Is the flow meter operational? ■ ❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter? ■ ❑ ❑ ❑
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
Does the facility analyze process control parameters,for ex:MLSS, MCRT, Settleable Solids,pH, DO, Sludge ■ ❑ ❑ ❑
Judge,and other that are applicable?
Comment:
Primary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? ❑ ■ ❑ ❑ '
Is the site free of excessive buildup of solids in center well of circular clarified ■ ❑ ❑ ❑
Are weirs level? ■ ❑ ❑ ❑
Is the site free of weir blockage? ■ ❑ ❑ Cl
Is the site free of evidence of short-circuiting? ■ ❑ ❑ ❑
Is scum removal adequate? ■ ❑ ❑ ❑
Is the site free of excessive floating sludge? ■ ❑ ❑ ❑
Is the drive unit operational? ■ ❑ ❑ ❑
Is the sludge blanket level acceptable? ❑ Cl ■ ❑
Is the sludge blanket level acceptable?(Approximately'/.of the sidewall depth) ❑ ❑ ■ ❑
Comment: The waste stream is normally black and odorous
Aeration Basins Yes No NA NE
Mode of operation Ext.Air
Type of aeration system
Is the basin free of dead spots? ■ ❑ ❑ ❑
Are surface aerators and mixers operational? ■ ❑ ❑ ❑
Are the diffusers operational? - ❑ ❑ ■ ❑
Is the foam the proper color for the treatment process? ■ ❑ ❑ ❑
Does the foam cover less than 25%of the basin's surface? ■ fl ❑ ❑
Page# 3

Permit: NC0000272 Owner-Facility: Canton Mill
Inspection Date: 03/1612006 Inspection Type: Compliance Evaluation
Aeration Basins _ Yes No NA NE
Is the DO level acceptable? ■ ❑ ❑ ❑
Is the DO level acceptable?(1.0 to 3.0 mg/I) ■ ❑ ❑ ❑
Comment: Due to the change in location of the waste stream from the acid sewer,
three of the four basins are now in use.
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? ■ ❑ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clariflel? ■ ❑ ❑ ❑
Are weirs level? ■ ❑ ❑ ❑
Is the site free of weir blockage? ■ ❑ ❑ ❑
Is the site free of evidence of short-circuiting? ■ ❑ ❑ ❑
Is scum removal adequate? ■ ❑ ❑ ❑
Is the site free of excessive floating sludge? ■ ❑ ❑ ❑
Is the drive unit operational? ■ ❑ ❑ ❑
Is the return rate acceptable(low turbulence)? ■ ❑ ❑ ❑
Is.the overflow clear of excessive solids/pin floc? ■ ❑ ❑ ❑
Is the sludge blanket level acceptable?(Approximately%of the sidewall depth) ■ ❑ ❑ ❑
Comment: Clarifier#6 is down for the winter; however, efflglnt from the#5 clarifier is
being pumped at a rate of 200,000 gallons per day, over to#6 during this process.
Page# 4

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross,Jr., Secretary....
Alan W. Klimek, P.E., Director
March 8,2006 I
Paul DickensBlue Ridge Paper Products, Inc. MAR 2 O 2006P.O. Box 4000
Canton, NC 28716 j
WATER QUALITY SECTIONSubject: RenewalHEwIRECIOrJeL OFFICE
NPDES Permit NC0000272
Canton Mill
Haywood County
Dear Permittee:
Your NPDES permit expires on November 30,2006. Federal (40 CFR 122.41)and North Carolina(15A NCAC
2H.0105(e))regulations require that permit renewal applications must be filed at least 180 days prior to expiration of
the current permit. If you have already mailed your renewal application,you may disregard this notice.
To satisfy this requirement,your renewal package must be sent to the Division postmarked no later than June
3,2006. Failure to request renewal by this date may result in a civil assessment of at least$500.00. Larger penalties
may be assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after November 30, 2006,the current permit must be renewed.
Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-215.1; unpermitted
discharges of wastewater may be assessed civil penalties of up to$25,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact me at the
telephone number or address listed below.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must
submit with the permit renewal application. If you have any questions, please contact me at the telephone number or
e-mail address listed below.
Sincerely,
-
Charles H.Weaver,Jr.
NPDES Unit
cc: Central Files
eville egrona ffig'{SorfacejW er ro ec ion
NPDES File
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 One
512 North Salisbury Street,Raleigh,North Carolina 27604 NorthCarolina
Phone: [phone],extension 5111 FAX [phone] [e-mail] naturally
An Equal Opportunity/Affirmative Action Employer-50%Recycled/10%Post Consumer Paper

NPDES Permit NC0000272
. Canton Mill
Haywood County
The following items are REQUIRED for all renewal packages:
o A cover letter requesting renewal of the permit and documenting any changes at the facility since
issuance of the last permit. Submit one signed original and two copies.
o The completed application form (copy attached), signed by the permittee or an Authorized
Representative. Submit one signed original and two copies.
o If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
the renewal package, written documentation must be provided showing the authority delegated to any
such Authorized Representative (see Part II.B.1l.b of the existing NPDES permit).
o A narrative description of the sludge management plan for the facility. Describe how sludge (or other
solids) generated during wastewater treatment are handled and disposed. If your facility has no such
plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed
original and two copies.
The following items must be submitted by any Municipal or Industrial facilities dischargiagg
process wastewater:
Industrial facilities classified as Primary Industries (see Appendices A-D to Title 40 of the Code of Federal
Regulations,Part 122) and ALL Municipal facilities with a permitted flow>_ 1.0 MGD must submit a
Priority Pollutant Analysis (PPA)in accordance with 40 CFR Part 122.21.
The above requirement does NOT apply to privately owned facilities treating 100%
domestic wastewater, or facilities which discharge non process wastewater (cooling
water, filter backwash, eta)
PLEASE NOTE:
Due to a change in fees effective January 1, 1999, there is no renewal fee required with your
application package.
Send the completed renewal package to:
Mrs. Carolyn Bryant
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

BLUE RIDGE
PAPER PRODUCTS INC. J MAR ] 1 M11A
March 29, 2004 MAR I LYVt
WATER QUALITY SECTION
North Carolina Department of Environment ASHEVILLE REGIONAL OFFICE
and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Attn: Central Files
Re: Best Management Practices 2003 Annual Report
Please find attached the data summary of Best Management Practices (BMP) daily
monitoring for Blue Ridge Paper Product's Inc., Canton Mill. This submission is required
by Special Condition A.(6.) Best Management Practices, Section E4 and Section F1, of
the mill's NPDES Permit No. NC0000272.
The Canton Mill's BMP Plan specifies that investigative action will be performed when
the Primary Influent Lower Action Level of 70,322 Ibs/day of True Color is exceeded for
two consecutive days. Investigative action was conducted for the five Lower Action
Level exceedances in 2003, listed below.
Date Primary Influent Color
10-Mar-03 76,138
11-Mar-03 71,852
15-Mar-03 75,535
16-Mar-03 72,862
17-Mar-03 71,786
29-Mar-03 83,509
30-Mar-03 73,795
31-Mar-03 80,407
01-Apr-03 76,453
02-Apr-03 89,936
06-May-03 73,630
07-May-03 74,328
29-Sep-03 82,961
30-Sep-03 72,447
The Canton Mill's BMP Plan specifies that investigative and corrective action will be
performed when the Primary Influent Upper Action Level of 78,609 Ibs/day of True Color
is exceeded for two consecutive days. Investigative and corrective actions were
conducted for the two Upper Action Level exceedances in 2003, listed below.
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

BMP 2003 Annual Report
Page 2
Date Primary Influent Color
27-Jan-03 146,106
28-Jan-03 99,510
06-Apr-03 146,214
07-Apr-03 156,040
The Canton Mill's BMP Plan specifies that immediate investigative and corrective action
will be performed when the Primary Influent Out-of-Control Level of 92,734 Ibs/day of
True Color is exceeded for one day. Investigative and corrective actions were
conducted for the 10 Out-of-Control Level exceedances in 2003, listed below.
Date Primary Influent Color
27-Jan-03 146,106 (also counted in Upper Action Level, above)
28-Jan-03 99,510 (also counted in Upper Action Level, above)
06-Apr-03 146,214 (also counted in Upper Action Level, above)
07-Apr-03 156,040 (also counted in Upper Action Level, above)
13-Apr-03 127,561
28-Apr-03 148,118
24-May-03 121,118
12-Jun-03 101,511
12-Aug-03 176,230
03-Oct-03 118,309
A table of the BMP Action Level exceedances and corresponding corrective actions is
attached.
Please call Paul Dickens [phone] or me at [phone] if you have any
questions or concerns regarding this information.
Sincerely,
Axf/ven� 5
Michael Koerschner, P.E. Paul Dickens, P.E.
Environmental Engineer Environmental Manager
Xc: Keith Haynes
Forrest Westall

''')03 - PRIMARY INFLUENT COLOR
APri Inf Pri Inf Pri Inf Pri Inf Pri Inf Pri Inf ; Pri Inf
Color Color Color Color Color Color Color
June "Ib/day' July "lb/day" August "lb/day" September "lb/day" October "Ib/day" November "Ib/day" December "Ib/day"
6/1/03 55338 7/1103 55644 8/1103 56315 9/110 40881 10/1/03 35257 11/1103 48333 1211/03 40824
612/03 46478 7/2/03 67880 8/2103 55701 9/2/03 34941 10/2103 63677 11/2/03 44193 12/2/03 58568
6/3103 39437 713/03 65173 8/3/03 66159 9/3/03 56227 1013/03 118309 11/3/03 59109 1213/03 62513
614/03 45013 7/4/03 52923 8/4/03 53135 9/4103 65237 10/4/03 42936 11/4/03 43239 12/4103 45916
6/5/03 55266 7/5103 54973 8/5/03 53323 9/5/03 51884 10/5/03 52630 11/5103 66578 12/5103 59811
6/6103 45664 7/6/03 64809 8/6103 39905 9/6/03 35695 10/6/03 59601 11/6103 34254 1216/03 42908
6/7103 78838 717/03 63572 8/7/03 50545 9/7/03 49798 10/7/03 39489 11M03 35725 1217103 42109
618/03 49647 7/8/03 43393 8/8103 36558 9/8/03 51724 10/8/03 22821 11/8/03 27074 1218103 56898
619/03 56032 719/03 33313 8/9/03 42298 9/9103 47119 10/9/03 54463 11/9/03 36930 12/9103 52718
6/10103 53644 7/10103 35235 8110/03 38401 9/10103 55953 10/10/03 55377 11/10/03 27647 12/10/03 37490
6/11/03 35721 7/11103 69210 8111/03 43528 9/11/03 41400 10/11/03 36714 11/11/03 49283 12/11/03 29355
6/12/03 101511 7/12J03 72783 8/12/03 176230 9/12/03 36400 10/12/03 54002 11/12/03 50747 12/12/03 32450
/13103 57205 6/13103 26502 7/13/03 64794 8/13/03 32333 9113/03 46576 10/13/03 54908 11/13/03 41353 12/13/03 23798
/14/03 56311 6/14/03 39058 7/14/03 63388 8114/03 37012 9/14/03 52159 10/14/03 64448 11/14/03 50497 12/14/03 43562
5/15/03 34667 6/15103 59774 7/15/03 58551 8115/03 33040 9/15/03 30794 10/16/03 69848 11/15/03 30483 12/15/03 36566
5/16/03 28200 6/16/03 45362 7/16/03 62239 8/16103 38159 9/16/03 60548 10/16/03 52979 11/16/03 57663 12/16/03 41847
5 5/17/03 58351 6/17/03 47298 7/17/03 43155 8/17/03 59340 9/17/03 62903 10/17/03 W07 11/17/03 45089 12/17/03 47105
/83 5/18/03 39124 6118/03 57054 7118/03 81565 8/18103 62970 9/18/03 61858 10/18/03 40307 11/18/03 48812 12/18/03 50844
/147 5/19103 46687 6/19/03 77673 7119/03 69085 8119/03 60800 9119/03 54391 10/19/03 43679 11/19/03 48853 12/19/03 47038
288 5/20/03 45979 6/20/03 62118 7120/03 77602 8/20/03 54531 9/20/03 67836 10/20/03 62187 11/20/03 55523 12120/03 48440
3207 5/21/03 41770 6/21/03 36623 7121/03 41376 8/21/03 56467 9/21/03 42701 10/21/03 39996 11/21/03 46359 12/21/03 53777
67389 5/22/03 52573 6/22/03 64529 7/22/03 46742 8/22103 51968 9122/03 53834 10/22103 29175 11/22/03 58775 12/22/03 40016
58477 5/23/03 54328 6/23/03 53042 7/23/03 61094 8/23/03 37753 9/23103 54979 10/23/03 38677 11/23/03 34793 12/23/03 35655
59499 5/24/03 121118 6/24/03 49413 7/24/03 59667 8/24/03 42747 9/24/03 43439 10/24/03 51879 11/24/03 53243 12124/03 37243
73965 5/25/03 64661 6125/03 60383 7/25/03 42111 8/25/03 65712 9/25/03 51752 10/25/03 52853 11/25/03 88707 12/25/03 58786
59384 5/26/03 71267 6/26/03 48909 7/26/03 52M 8126/03 44211 9/26/03 54106 10/26/03 60309 11/26/03 59696 12/26/03 48748
/3 67533 5/27/03 44641 6/27/03 52658 7/27/03 47404 8/27/03 72875 9/27/03 52563 10/27/03 64519 11/27/03 56691 12/27/03 57986
/03 148118 5/28/03 54662 6/28/03 56176 7/28/03 41062 8128/03 58507 9128/03 51465 10/28103 59728 11/28/03 53898 12128/03 32145
d/03 65650 5/29/03 43453 6/29/03 45572 7/29/03 40768 8/29/03 53900 9/29/03 82961 10/29/03 38302 11/29/03 46702 12/29/03 32983
�30103 63243 5/30103 59257 6/30103 55983 7/30/03 45239 8/30/03 47811 9/30103 72447 10/30/03 38296 11/30/03 61847 12130/03 32201
�� 5/31/03 49327 7/31/03 46128 8131/03 48997 1011/03 10/31/03 52310 1211/03 12/31/03 31688

2003 BMP Action Level Exceedances and Corresponding Corrective Actions
Dates Primary Influent Color BMP/Non-BMP Corrective Action
A broken coupling in the Pine MC pump caused stock to back up and overflow from the
Pine Surge Tank. The overflow was not detected because the operator did not receive a
27-Jan-03 146,106 high level alarm. It was later determined that the level transmitter had frozen. The broken
28-Jan-03 99,510 BMP coupling and the level transmitter were both replaced.
The Pine Secondary Knotter plugged and liquor flushed to the sewer. The Knotter was
10-Mar-03 76,138 BMP and Non- unplugged and the problem was corrected. Color from the Pine Bleach plant and
11-Mar-03 71,852 BMP carryover in the evaporators also contributed to these elevated color days.
15-Mar-03 75,535 Recovery area had to clean out East Unoxidized Storage tank. A temporary dam was
16-Mar-03 72,862 built to contain the tank material while it was being hauled to the landfill. Some of the
17-Mar-03 71,786 BMP material leached into the sewer over the three day period causing elevated color.
29-Mar-03 83,509
30-Mar-03 73,795
31-Mar-03 80,407
01-Apr-03 76,453 There were no BMP events during this period. Color was elevated due to Sewer
02-Apr-03 89,936 Non-BMP Generated Color and poor MRP Closure on March 30th and March 31st, and April 2nd.
These elevated colors resulted from a Cold Mill Outage shutdown where many tanks and
lines were emptied and cleaned for required maintenance. A Cold Mill Outage occurs
06-Apr-03 146,214 once every 6-7 years and much of the material was caught in the offline, spare primary
07-Apr-03 1 156,040 BMP clarifier.All tanks were"run down"to the lowest levels possible prior to emptying.
During start-up from the Cold Mill outage, the Hardwood Fiberline experienced losses that
are typically recovered by piping to the Pine Blow Tower. However, the Pine Fiberline
started up late and was not able to receive the material. Due to the extensive nature of
the Cold Mill Outage, there was not sufficient space available in the offline, spare primary
13-Apr-03 127,661 1 BMP 1clarifier on this day.

A valve failure on one of the Evaporator Effects caused large amounts of carryover into
the normally clean combined condensate. This condensate was being used on the Pine
Quaternary Screen Rejects which is normally sewered. The problem was corrected by
28-Apr-03 148,118 BMP replacing the valve in the Evaporator Effect.
06-May-03 73,630 There were no BMP events during this period. Again, color was elevated due to Sewer
07-May-03 74,328 Non-BMP Generated Color.
This elevated color resulted from problems with the Pine Eo washer that caused
increased amounts of Eo bleach plant filtrate to be sewered.Also, during a scheduled
maintenance outage, the 3rd Cyclone wash from#10 Recovery Boiler was collected in the
Non-BMP and offline, spare clarifier and later fed into the system at a rate that was not disruptive to the
24-May-03 121,118 BMP Wastewater Treatment Plant.
Washing out the Chloride Removal Process caused elevated Primary Influent Color.
There were no detrimental impacts on the Wastewater Treatment plant from this
12-Jun-03 101,511 BMP maintenance procedure.
The Recovery area's Pump Tank was plugged, therefore the liquor feed to the cyclones
was jumpered around the storage pumps that normally feed the cyclones. During a
scheduled maintenance outage, the Recovery Boiler's level control valve was accidentally
in automatic so,when the level in the cyclones dropped due to the cyclone wash, liquor
from the jumpered line went into the cyclone and to the sewer with the wash material.
12-Aug-03 176,230 BMP Discussions were held with all crews to ensure the proper procedure was understood.
This elevated color resulted from a Semi-annual Outage that involved maintenance on
29-Sep-03 82,961 both Fiberlines. Due to the extended nature of this outage, not all material could be
30-Sep-03 72,447 recovered. There was no detrimental impact on the Wastewater Treatment Plant.
This elevated color also resulted from the extended Semi-annual Outage. To increase
recovery capacity in the mill the Boilout Tank was diverted to the offline, spare clarifier
3-Oct-03 118,309 BMP and later fed into the Wastewater Treatment Plant system at a slow, non-disruptive rate.

BLUE RIDGE
PAPER PRODUCTS INC.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220.0007,6013
19 January 2006 _
[SCE VE
Mr. Roger C. Edwards D
Regional Supervisor JAN 2 3 2006
Surface Water Protection
North Carolina Department of Environment
and Natural Resources WATER QUALITY SECTION
Division of Water Quality ASHEVIL-LE REGIONAL OFFICE
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Subject: Notice of Violation NOV-2005-L-0561
NPDES NC0000272
Blue Ridge Paper Products Inc
Canton Mill
Haywood County
Dear Mr. Edwards:
Blue Ridge Paper Products Inc. received the subject Notice of Violation (NOV) dated 12 Jan
2006. The NOV concerns maximum day BOD5 excursions on 21 & 22 Oct 2005. These
excursions were reported to Mr. Keith Haynes of your office by telephone and e-mail on 27 Oct
2005 as soon as we received and confirmed the daily wastewater analytical results. Mr. Haynes
inspected the Canton Mill wastewater treatment facilities on 31 Oct 2005.
On 1 Nov 2005, Blue Ridge Paper submitted a written report documenting the 18 Oct 2005 mill
steam and power failure and related treatment process upsets that caused the daily BOD5
excursions as well as corrective actions taken by the Canton Mill. A copy of this report is
attached. Prior to knowledge of the BOD excursions, Blue Ridge Paper had advised your-office
by e-mail about the unplanned mill outage, mill restart and related process issues.
The BOD5 excursions on 21 &22 Oct 2005 were just above the daily maximum limit. Blue
Ridge Paper completed October 2005 with monthly average BOD5 within limits as follows:
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Roger C Edwards, NC DENR ARO DWQ
19 Jan 2006, Page 2
October 2005 SE BOD5 Average=3173 lbs/day Monthly Limit= 3205 lbs/day
Daily and monthly average secondary effluent BOD5 during November and December 2005
were well within permit limits.
Blue Ridge Paper Products properly responded to the 18 Oct 2005 unplanned mill outage and
related treatment process upsets. We minimized the impact of these events and completed the
month within permit limits. The two daily BOD5 excursions in October 2005 were a single,
special-cause event. Subsequent daily and monthly wastewater treatment performance was well
within permit limits.
Please contact us if you need additional information.
Sincerely,
Paul S. Dickens John J. Pryately
Manager, Environmental Affairs Wastewater Supervisor and Operator in Charge
828-646-6141 828-646-6720
[e-mail] pr}[e-mail]
Attachment: 1 Nov 2005 BOD5 Excursion Report
Blue Ridge Paper Products Inc. -Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Roger C Edwards, NC DENR ARO DWQ
19 Jan 2006, Page 3
Distribution:
C. File—Water
Regulatory File- Water
Bob Shanahan
Bob Williams
Jay Clary
Michael Ferguson
Lori Cooper
Glenn Rogers
Randy Medford
Billy Clarke—Roberts & Stevens
Blue Ridge Paper Products Inc. - Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

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

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

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

aoF wArF90 Michael F.Easley,Governor
William G.Ross Jr.,Secretary
\0 G North Carolina Department of Environment and Natural Resources
0 r Alan W.Klimek,P.E.Director
_{ Division of Water Quality
� Y
Asheville Regional Office
SURFACE WATER PROTECTI
January 12, 2006 D
CERTIFIED MAIL JAN 17, 2006
RETURN RECEIPT REQUESTED 7005 0390 00013552 8770
BLUE RIDGE PAPER PRODUCTS INC
Blue Ridge Paper Products Inc BHS DEPARTMENT
PO Box 4000
Canton NC 28716
Subject: NOTICE OF VIOLATION
NOV-2005-LV-0561
Permit No. NC0000272
Canton Mill
Haywood County
Dear Mr. Brown:
A review of Canton Mill's monitoring report for October 2005 showed the following
violations:
Parameter Date Limit Value Reported Limit Type
Value
BOD, 5-Day (20 Deg. C) 10/21/05 10,897 11,498 Ibs/day Daily
Ibs/day Maximum
Exceeded
BOD, 5-Day (20 Deg. C) 10/22/05 10,897 11,673 Ibs/day Daily
Ibs/day Maximum
Exceeded
Remedial actions should be taken to correct this problem. The Division of Water Quality may pursue
enforcement action for this and any additional violations of State law.
To prevent further action, carefully review these violations and deficiencies and respond in writing to
this office within 15 working day of receipt of this letter. You should address the causes of non-
compliance and all actions taken to prevent the recurrence of similar situations. If you should have
any questions, please do not hesitate to contact Keith Haynes at 296-4500.
Sincerely,
R ger C. Edwards, Regional Supervisor
9 P
Surface Water Protection
Enclosure
cc: WQ Central Files
2090 U.S.Highway 70, Swannanoa,N.C. 28778 8281296-4500(Telephone) 8281299-7043(Fax) Customer Service 877-623-6748 No�thCarolina
'A ..t..,.,.//.i

�C�W QT 90 lichael F. 5s1E1,Governor
liliam G. ossJr,Secretary
r pg�"o—"tea
\0 0 North Carolina Dep�hment oflwironmenrand MIResources
an W.Klimek,P.E.Director
--I Division of Water Quality
O . Y
Asheville Regional Office
SURFACE WATER PROTECTION
January 12, 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7005 0390 00013552 8770
Blue Ridge Paper Products Inc
PO Box 4000
Canton NC 28716
Subject: NOTICE OF VIOLATION
NOV-2005-LV-0561
Permit No. NC0000272
Canton Mill
Haywood County
Dear Mr. Brown:
A review of Canton Mill's monitoring report for October 2005 showed the following
violations:
Parameter Date Limit Value Reported Limit Type
Value
BOD, 5-Day (20 Deg. C) 10/21/05 10,897 11,498 Ibs/day Daily
Ibs/day Maximum
Exceeded
BOD, 5-Day (20 Deg. C) 10/22/05 10,897 11,673 Ibs/day Daily
Ibs/day Maximum
Exceeded
Remedial actions should be taken to correct this problem. The Division of Water Quality may pursue
enforcement action for this and any additional violations of State law.
To prevent further action, carefully review these violations and deficiencies and respond in writing to
this office within 15 working day of receipt of this letter. You should address the causes of non-
compliance and all actions taken to prevent the recurrence of similar situations. If you should have
any questions, please do not hesitate to contact Keith Haynes at 296-4500.
Sincerely,
R ger C. Edwards, Regional Supervisor
9 P
Surface Water Protection
Enclosure
cc: WQ Central Files
2090 U.S.Highway 70, Swannanoa,N.C. 28778 828/296-4500(Telephone) 828/299-7043(Fax) Customer Service 877-623-6748 NorsthCarol;na

eBLUE RIDGE D
PAPER PRODUCTS INC.
J AN 17 2006
Certified Mall WATER QUALITY SECTION .
Return Receipt Request d ASHEVILLE REGIONAL OFFICE
12 January 2006 7099 3220 0007 0371 5975- > t
Mr. Alan Klimek
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617 _
Subject: Extensions to Permit Required Reports
NPDES Permit No. NC0000272
Blue Ridge Paper Products Inc.
Canton, North Carolina
Dear Mr. Klimek:
Blue Ridge Paper Products requests an extension to the March 1, 2006 due date of the Color
Variance report required in Part I, Condition A.(8.),Paragraph 10 of NPDES Permit No.
NC0000272. In addition, Blue Ridge requests an extension to the May 1,2006 due date of the
316a Balanced and Indigenous Species Study required by Part I, Condition A.(13.) of NPDES
Permit No. NC0000272. Blue Ridge requests that both reports be submitted with the NPDES
permit renewal application due on May 31, 2006.
Due to high flow conditions in the Pigeon River this past summer, the field work for the 316a
Study was delayed. As a result, the schedule for the 316a Study is approximately six weeks
behind schedule. Blue Ridge will require the information in the final version of the 316a Study
to complete the Color Variance report as well as the permit renewal application. Therefore, Blue
Ridge requests a May 31, 2006 due date for the Color Variance and 316a Study reports.
Please contact us if you have any questions.
Sincerely,
J. Glenn Rogers Paul S. Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2874 828-646-6141
[e-mail] [e-mail]
Blue Ridge Paper Products -Environmental Group
175 Main Street o PO Box 4000
Canton, North Carolina 28716 D 828-646-2000
Raising Your Expectations

..yi
N VA

Mr. Alan W. Klimek, NC DENR DWQ
12 January 2006, Page 2
cc: CRoger Edwards
Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Susan Wilson
Environmental Supervisor _
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Sergei Chemikov
Environmental Engineer
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
D. Keith Haynes
Environmental Specialist
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Internal Distribution:
C. File Water
Engr File
B. Shanahan
M. Ferguson
D. Brown
B. Williams
J. Clary
J. Pryately
Blue Ridge Paper Products -Environmental Group
175 Main Street m PO Box 4000
Canton, North Carolina 28716 0 828-646-2000
Raising Your Expectations

� D
e , BLUE RIDGE JAN 17 2006
PAPER PRODUCTS INC.
,.
WATER QUALITY SECTION!
Certified Mall ASHEVILLE REGIONAL OFFICE
Return Receipt Requested
12 January 2006 7099 3220 0007 0371 5979' '
I
i
Mr. Alan Klimek
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Extensions to Permit Required Reports
NPDES Permit No. NC0000272
Blue Ridge Paper Products Inc.
Canton, North Carolina
Dear Mr. Klimek:
Blue Ridge Paper Products requests an extension to the March 1, 2006 due date of the Color
Variance report required in Part I, Condition A.(8.), Paragraph 10 of NPDES Permit No.
NC0000272. In addition, Blue Ridge requests an extension to the May 1, 2006 due date of the
316a Balanced and Indigenous Species Study required by Part I, Condition A.(13.) of NPDES
Permit No. NC0000272. Blue Ridge requests that both reports be submitted with the NPDES
permit renewal application due on May 31, 2006.
Due to high flow conditions in the Pigeon River this past summer, the field work for the 316a
Study was delayed. As a result, the schedule for the 316a Study is approximately six weeks
behind schedule. Blue Ridge will require the information in the final version of the 316a Study
to complete the Color Variance report as well as the permit renewal application. Therefore, Blue
Ridge requests a May 31, 2006 due date for the Color Variance and 316a Study reports.
Please contact us if you have any questions.
Sincerely,
J. Glenn Rogers Paul S. Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2874 828-646-6141
[e-mail] [e-mail]
Blue Ridge Paper Products -Environmental Group
175 Main Street D PO Box 4000
Canton, North Carolina 28716 o 828-646-2000
Raising Your Expectations

Mr. Alan W. Klimek, NC DENR DWQ
12 January 2006, Page 2
cc: Roger Edwards
Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Susan Wilson
Environmental Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Sergei Chernikov
Environmental Engineer
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
D_ . Keith, dynes
nvironmental Specialist
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70 - -
Swannanoa, North Carolina 28778
Internal Distribution:
C. File Water
Engr File
B. Shanahan
M. Ferguson
D. Brown
B. Williams
J. Clary
J. Pryately
Blue Ridge Paper Products -Environmental Group
175 Main Street o PO Box 4000
Canton, North Carolina 28716 0 828-646-2000
Raising Your Expectations

BLUE RIDGE �LJJ
PAPER PRODUCTS INC. DEC — 8 2005
December 5, 2005 WATER QUALITY SECTION
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5924
Mr. D. Keith Haynes
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: NPDES NO. NC0000272
Certification in Lieu of Monitoring for Chloroform— Process Parameter Exceedance
Blue Ridge Paper Products, Inc.
Canton, NC
In accordance with NPDES Permit No. NC0000272 and 40 CFR 430.02(f)(6)(i)(A), Blue Ridge
Paper Products is hereby notifying the Division of Water Quality (DWQ) of a process parameter
exceedance on the hardwood fiberline that occurred on November 9, 2005. As approved by the
DWQ on August 16, 2005 Blue Ridge monitors certain process parameters (pH of the first C102
bleaching stage, kappa factor of the first CI02 bleaching stage, and total bleach line CI02
application rate) for its certification in lieu of monitoring for chloroform. In this case, the maximum
allowable pH value of the 1"t CI02 stage for the hardwood fiberline was exceeded on November 9,
2005 (see Attachment 1).
In accordance with 40 CFR 430.02(f)(6)(i)(B), Blue Ridge Paper Products is demonstrating
compliance with the applicable chloroform standard by submitting the results of one sample taken
from the hardwood fiberline effluent on November 14, 2005 (see Attachment II). Given that the
results of the sample are well below permitted limits, Blue Ridge has resumed process monitoring
in lieu of monitoring for chloroform as allowed for by NPDES Permit No. NC0000272.
Blue Ridge has remained well below permitted limits for daily maximum and monthly average
chloroform limitations required by NPDES permit No. NC0000272 and remains committed to
continuous improvement in effluent quality. If you have any questions please don't hesitate to call.
Sincerely,
X4
J. Glenn Rogers John J. Pryately
Water Compliance Coordinator Wastewater Supervisor & Operator in Charge
828-646-2874 828-646-6720
[e-mail] [e-mail]
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

5 December 2005, Page 2
Attachment I: Process Parameter Tracking Sheet
Attachment II: Results Of Chloroform Testing
Internal Distribution:
C. File—Water
B. Shanahan
J. Clary
P. Dickens
D. Brown
C. Dowdle
L. Cooper
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

ATTACHMENT I: PROCESS PARAMETER TRACKING SHEET

O O O <A <m3 y
iz, m1�^ J N �
N N N a �
R3 t3 N N N
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mn m ma m mn m t�
F = F = F = o t=e
d m d m d m W N N N N N N N N N N N N N N N N N N N N N N N N N N N N N y d
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ATTACHMENT If: RESULTS OF CHLOROFORM TESTING

Pace Analytical Services, Inc. Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100 2225 Riverside Drive
Huntersville, NC 28078 Asheville, NC 28804
Ph -704.875.909 Phone.,828.25. 8aceAnalytical Fax [phone] Fax.,828.2524618 www.pacelabs.com
I
November 28. 2005
Mr. John Pryately
Blue Ridge'Paper Products, Inc
175 Main St.
Canton, NC 28716
RE: Lab Project Number: 92107508
Client Project ID: Chloroforms
Dear Mr. Pryately:
Enclosed are the analytical results for sample(s) received by the laboratory on November 15. 2005. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Si ncepply,
orr' Patton
[e-mail]
Project Manager
Enclosures
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 NC Wastewater 12
NC Drinking Water 37712 This report shall not be reproduced,except in full, NC Drinking Water 37706
Sc 99030 without the written consent of Pace Analytical Services, Inc. SC 99006
FL NELAP E87648 `E °,f FL NELAP E87627

Pace Analytical Services, Inc. Pace Analytical Services,Inc.
9800 Kincey Avenue, Suite 100 2225 Riverside Drive
Nuntersville, NC28078 Asheville,NC28804
aceAnalytical® Phone:[phone] Phone.[phone]
Fax:[phone] Fax:[phone]
www.pacelabs.conr
I Lab Project Number: 92107508
Client Project ID: Chloroforms
Lab Sample No: 926342429 Project Sample Number: 92107508-001 Date Collected: 11/14/05 22:20
Client Sample ID: HWD D1 (COMP) Matrix: Water Date Received: 11/15/05 12:22
Parameters Results Units Report Limit Analyzed By CAS No. Qual RegLmt
GUMS Volatiles
Volatile GUMS by 624 Method: EPA 624
Chloroform 11. ug/l 5.0 11/22/05 13:52 DLK 67-66-3
Toluene-d8 (S) 99 X 11/22/05 13:52 DLK 2037-26-5
4-Bromofluorobenzene (S) 86 X 11/22/05 13:52 DLK 460-00-4 1
Dibromofluoromethane (S) 117 X 11/22/05 13:52 DLK 1868-53-7
Date: 11/28/05 Page: 1 of 6
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 NC Wastewater 12
NC Drinking Water 37712 This report shall not be reproduced,except in full, NC Drinking Water 37706
SC 99030 without the written consent of Pace Analytical Services, Inc. SC 99006
FL NELAP E87648 �n
' FL NELAP E87627
'. A/�.f

Pace Analytical Services, Inc. Pace Analytical Services,Inc.
9800 Kincey Avenue, Suite 100 2225 Riverside Drive
Huntersville, NC 28078 Asheville,NC 28604
aceAnalytical® Phone:[phone] Phone:[phone]
Fax:[phone] Fax:[phone]
www.paceiahs.com
I Lab Project Number: 92107508
Client Project ID: Chloroforms
Lab Sample No: 926342452 Project Sample Number: 92107508-002 Date Collected: 11/14/05 22:25
Client Sample ID: HWD E0 (COMP) Matrix: Water Date Received: 11/15/05 12:22
Parameters Results Units Report Limit Analyzed By CAS No. Qual ReaLmt
GUMS Volatiles
Volatile GUMS by 624 Method: EPA 624
Chloroform ND ug/l 5.0 11/22/05 14:12 DLK 67-66-3
Toluene-d8 (S) 101 X 11/22/05 14:12 DLK 2037-26-5
4-Bromofluorobenzene (S) 83 % 11/22/05 14:12 DLK 460-00.4
Dibromofluoromethane (S) 0 % 11/22/05 14:12 DLK 1868-53-7 1.2
I
Date: 11/28/05 Page: 2 of 6
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 NC Wastewater 12
NC Drinking Water 37712 This report shall not be reproduced,except in full, NC Drinking Water 37706
without the written consent of Pace Analytical Services, Inc.
Sc 99030 Sc 99006
FL NELAP E87648 j� jam" FL NELAP E87627
/Y'YPlaf�'-

Bleach Filtrate Chloroform Calculations
Date: 11/14/2005
HW D-1 HW Eo HW Total Pine D-1 Pine Eo Pine D-2 Pine Total
Flow in mgd 1.782682 0.444152 2.226834
Concentration in mg/l 0.011 0.005
8.34 8.34
Lbs/day 0.1635 0.0185 0.1821

OF wA rFq
_Michael F.Easley,Governor
O OG E Willia�Ross k;Secretary
j [ North Carolin Department of ,ico met i.and Natural Resources
Alan W.Klimek,P.E.Director
'4 -'➢ Division of Water Quality
SURFACE WATER PROTECTION
December 5, 2005
Mr. Derric Brown
Blue Ridge Paper Products Inc .
Post Office Box 4000
Canton, North Carolina 28716
Subject : Acceptance of Groundwater
From Mountain Environmental Site
NPDES Permit No. N00000272
Haywood County
Dear Mr. Brown:
This Office does not foresee a problem with your wastewater treatment
plant accepting groundwater from a site being handled by Mountain
Environmental Group. It is suggested that you maintain a record of all loads
received including the date of the load and the number of gallons in each
load.
If you have any questions concerning this matter or if you require
additional information, please do not hesitate to contact me at 251-6208 .
Sincerely,
D. Keith Haynes
Environmental Specialist
xc: Mountain Environmental Group
N""o��1,,Carolina
✓vrrlura!ly
North Carolina Division of Water Quality 2090 U.S.Highway 70 Swannanoa,NC 28778 Phone [phone] Internet h2o.encstate.nc.us ( ) Customer Service
FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Reeycled110%Post Consumer Paper

F WH1F ivel muley,Governor O .
y William G.Ross 3n,Secretary
> r North Carolina Department of Environment and Natural Resources
—i
O Y Alan W.Klimek,P.E.Director
Division of Water Quality
Date: October 17, 2005
Derric Brown OCT 2 0 2605 D
1329 Howell Mill Road
Waynesville, NC 28786
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
Subject: Notice of Incomplete Discharge Monitoring Report
Dear Permittee:
The purpose of this letter is to call your attention to problems with the recent submittal of the Discharge
Monitoring Report(DMR)from your facility. As you may know,the data recorded on your DMR is keyed
into the Division's database. Our data entry staff has informed me of problems with your recent DMR
submittal. Until these problems have been corrected, your DMR will be considered incomplete. Please
see the attached form along with a copy of the problem DMR for details regarding the DMR's deficiency.
Incomplete or illegible DMRs affect our staff's ability to provide a timely and effective evaluation of DMR
submittals. Please be aware that until the Division receives a corrected DMR, you may be considered
noncompliant with your NPDES permit and 15A NCAC 02B .0506, and you may be subject to further
enforcement action. Please take the necessary steps to correct the problems and submit two copies of the
amended DMR within fifteen (15)days of the date of this letter to the following address:
Attention: Michele Phillips
Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Future DMR submittals with the same or similar problems will be unacceptable. If you have any questions
about the proper completion of DMRs,please contact Michele Phillips at 919-733-5083 Ext. 225. Thank
you for your assistance in this matter.
Sincerely,
Alan W. Klimek,P.E.
cc: . OA'sheville Regional"Office
Central Files
NorihCarolina
JVaturatty
N.C.Division of Water Quality 1617 Mail Service Center Raleigh,North Carolina 27699-1617 Phone: [phone] Customer Service
Internet: htlix/Vo.enr.state.nc.us 512 N.Salisbury St. Raleigh,NC 27604 Fax: (919)733-D719 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer

If&ke of Neomplete Discharge Monitoring Report
Permit Numbers`U O U
Facility:
County. � l
DMR Month and Year lit -s
The Division of Water Quality deems the aforementioned DMR as incomplete due to the
following remon(s): (Please see the highlighted areas on the attached DAM for details.)
❑ The written values are illegLble.
❑ The Average,Maximum,and/or the Mmimum data points have been omitted.
❑ The tints of Measure have been omitted or are incorrect
❑ The DMR Parameter Codes have been omitted.
Other.
"►s� ncor(ya� r+sh6t,.4c4 be 3 qL 2.1 Also 444h Ir�chlora,�honol
5 `? + 3 8 00
l� � � Ghlo ho be 321n�� w

C NATFR Michael F.Easley,Governor
r'y P ss,
North Carolina Department of Envir en an aural Rgprces.
O ,. Y visio fyl�i#ter Qual ,
SURFACE WATER PROTECTION
November 4, 2005
Paul Dickens
Blue Ridge Paper Products Inc
PO Box 4000
Canton NC 28716
SUBJECT: Compliance Evaluation Inspection
Blue Ridge Paper Canton Mill
Permit No: NC0000272
Haywood County
Dear Mr. Dickens:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for
the inspection, which I conducted at your facility on October 31, 2005. The facility was
found to be in Compliance with permit NC0000272.
Please refer to the enclosed inspection report for additional observations and
comments. The assistance provided by Glenn Rogers and John Pryately, during the
inspection, was greatly appreciated. If you or your staff, have any questions, please do
not hesitate to call me at 828-296-4500.
Sincer ly,
Keith Hayn s
Environmental Specialist
Enclosure
cc: John J Pryately, ORC
Central Files
As evii e Fi1
N$o°�` Carolina
JvultlPll��J�
2090 U.S.Highway 70,Swannanoa, NC 28778 Telephone:'[phone] Fax: [phone] Customer Service 1 877 623-6748

United States Environmental Protection Agency
EPA Washington,D.C.20460 Form Approved.
OMB No.2040-0057
Water Compliance inspection Report Approval expires 8-31-98
Section A: National Data System Coding(i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I NI 2 I CI 31 NC0000272 111 121 05/10/31 117 181 rI 19I-I 20I I
J L
z,llllllllllllllll Remarks
L
lllllllllllllllllllllllllllllll6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA -------Reserved----
67I 169 701 4I 711 1 721 NI 73IL I LI 174 75I I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number)
Canton Mill
12:30 PI.1 05/10/31 05/08/01
175 train st Exit Time/Date Permit Expiration Date
Canton tic 28716 03:30 PM 05/10/31 06/11/30
Name(s)of Onsite Representative(s)Tlles(s)/Phone and Fax Number(s) Other Facility Data
///
John J Pryately/ORC.r828-646-6720/
Name,Address of Responsible Official/Title/Phone and Fax Number
Paul Dickens,PO Box 4000 Canton NC 28716//828-646-6141/ Contacted
NO
Section C: Areas Evaluated During Inspection(Check only those areas evaluated)
Permit E Flow Measurement 0 Operations&Maintenance E Self-Monitoring Program
Facility Site Review E Effluent/Receiving Waters
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Dale
Keith Haynes 14 P.RO WQ//828-296-4500 Ext.4660/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Dale
11
Boger C Edwards Plfg / ll
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.

NPDES yr/mo/day Inspection Type 1
3I NC0000272 I11 12I 05/10/31 I17 18ICI
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
The facility appeared to be eery well maintained and properly operated.

Permit: NC0000272 Owner-Facility: Canton Mill
Inspection Date: 10/31/2005 Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? ■ n n n
Is the facility as described in the permit? ■ n n n
Are there any special conditions for the permit? ■ n n n
Is access to the plant site restricted to the general public? ■ n ❑ n
Is the inspector granted access to all areas for inspection? ■ n n n
Comment:
Operations& Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ n n
Does the facility analyze process control parameters,for ex: MLSS,MCRT,Settleable Solids, pH,DO,Sludge ■ n n n
Judge,and other that are applicable?
Comment:
Pump Station-Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures? n n ■ n
Is the wet well free of excessive grease? n nl ■ n
Are all pumps present? ■ n n n
Are all pumps operable? ■ n n n
Are Float controls operable? ■ n n n
Is SCADA,telemetry available and operational? n n ■ n
Is audible and visual alarm available and operational? n n ■ fl
Comment:One of two variable speed and one of the two constant speed pumps were in operation.
Bar Screens Yes No NA NE
Type of bar screen
a.Manual n
b.Mechanical ■
Are the bars adequately screening debris? - ■ n n n
Is the screen free of excessive debris? ■ n n n
Is disposal of screening in compliance? ■ n n n
Is the unit in good condition? ■ n n n
Comment:One of the two screens is operated alternately.
Grit Removal Yes No NA NE
Type of grit removal
a.Manual n
b.Mechanical ■
Is the grit free of excessive organic matter? ■ ❑ ❑ fl
Is the grit free of excessive odor? ■ n n n
Is disposal of grit in compliance? ■ n n n
Comment:
Primary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? n ■ El
Is the site free of excessive buildup of solids in center well of circular clarifier? ■ n p n
Are weirs level? ■ n n n
Is the site free of weir blockage? ■ n n n

/
Permit: NC0000272 Owner-Facility: Canton Mill
Inspection Date: 10/31/2005 Inspection Type: Compliance Evaluation
Primary Clarifier Yes No NA NE
Is the site free of evidence of short-circuiting? ■ n n n
Is scum removal adequate? ■ n n n
Is the site free of excessive floating sludge? ■ n n n
Is the drive unit operational? ■ n n n.
Is the sludge blanket level acceptable? n ❑ ■ n
Is the sludge blanket level acceptable?(Approximately'/.of the sidewall depth) n n n ■
Comment:The influent is sometimes black and is odorous
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? ■ n n n
Is the site free of excessive buildup of solids in center well of circular clarifier? ■ n n n
Are weirs level? ■ n.n n
Is the site free of weir blockage? n ■ n n
Is the site free of evidence of short-circuiting? ■ n n n
Is scum removal adequate? ■ n n n
Is the site free of excessive floating sludge? ■ n n n
Is the drive unit operational? ■ n n n
Is the return rate acceptable(low turbulence)? ■ n n n
Is the overflow clear of excessive solids/pin floc? ■ n n n
Is the sludge blanket level acceptable?(Approximately%of the sidewall depth) ■ n n n
Comment:Some weir blockage was noted due to scum. This was not excessive,but should be watched.
Aeration Basins Yes No NA NE
Made of operation Ext.Air
Type of aeration system' Surface
Is the basin free of dead spots? ■ 0 n n
Are surface aerators and mixers operational? ■ n n n
Are the diffusers operational? n ❑ ■ n
Is the foam the proper color for the treatment process? ■ n n n
Does the foam cover less than 25%of the basin's surface? ■ n n n
Is the DO level acceptable? ■ n n n
Is the DO level acceptable?(1.0 to 3.0 mg/l) ■ n n n
Comment:Two of the four basins are used as"digesters".
Standby Power Yes No NA NE
Is automatically activated standby power available? ■ n n n
Is the generator tested by interrupting primary power source? n n ■ n
Is the generator tested under load? n n ■ n
Was generator tested&operational during the inspection? n n ■ n
Do the generator(s)have adequate capacity to operate the entire wastewater site? ■ n n ❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power? ■ n n n
Is the generator fuel level monitored? ■ n n n
Comment:
Flow Measurement-Influent Yes No NA NE
Is flow meter used for reporting? 0 ■ 00

Permit: NC0000272 Owner-Facility: Canton Mill
Inspection Date: 10/31/2005 Inspection Type: Compliance Evaluation
Flow Measurement-Influent Yes No NA NE
Is flow meter calibrated annually? ■ n n ❑
Is the flow meter operational? ■ n n n
(If units are separated)Does the chart recorder match the flow meter? ■ n El
Comment:
Flow Measurement-Effluent Yes No NA NE
Is flow meter used for reporting?- ■ n n
Is flow meter calibrated annually? ■
Is the flow meter operational? ■ n ❑ n
(If units are separated)Does the chart recorder match the flow meter? ■ n n n
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ■ ❑ n El
Is sample collected below all treatment units? ■ n n
Is proper volume collected? ■ n n n
Is the tubing clean? ■ n n n
Is proper temperature set for sample storage(kept at 1.0 to 4.4 degrees Celsius)? ■ ❑ n n
Is the facility sampling performed as required by the permit(frequency,sampling type representative)? ■ n n n
Comment:
Effluent Pike Yes No NA NE
Is right of way to the outfall properly maintained? ■ n -❑ n
Are the receiving water free of foam other than trace amounts and other debris? ■ n n n
If effluent (diffuser pipes are required) are they operating properly? ■ n n n
Comment:

\O��F W A Michael F.Easley,Governor
CO
y William G.Ross Jr.,Secretary
> r North Carolina Department of Environment and Natural Resources
1
O _ Y Alan W.Klimek,P.E.Director
Division of Water Quality
Date: November 7,2005
Derric Brown
1329 Howell Mill Road
Waynesville, NC 28786
Subject: Notice of Incomplete Discharge Monitoring Report NC0000272
Dear Permittee:
The purpose of this letter is to call your attention to problems with the recent submittal of the Discharge
Monitoring Report(DMR) from your facility. As you may know, the data recorded on your DMR is keyed
into the Division's database. Our data entry staff has informed me of problems with your recent DMR
submittal. Until these problems have been corrected,your DMR will be considered incomplete. Please
see the attached form along with a copy of the problem DMR for details regarding the DMR's deficiency.
Incomplete or illegible DMRs affect our staff's ability to provide a timely and effective evaluation of DMR
submittals. Please be aware that until the Division receives a corrected DMR,you may be considered
noncompliant with your NPDES permit and 15A NCAC 02B .0506, and yolf may be subject to further
enforcement action. Please take the necessary steps to correct the problems and submit two copies of the
amended DMR within fifteen (15)days of the date of this letter to the following address:
Attention: Michele Phillips
Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Future DMR submittals with the same or similar problems will be unacceptable. If you have any questions
about the proper completion of DMRs,please contact Michele Phillips at 919-733-5083 Ext. 534. Thank
you for your assistance in this matter.
Sincerely,
�„`_ Yw'MSN;fAV'1:.�'F`-'.••_•'aPyvh 4.:•Rw'.Y;3.S fIv
�G L(/GZf%6(/ri `f '£ •.:.:a . �.:= pp:
Alan W.Klimek,P.E. D D
NOV - 8120,05
cc: Ash evil le:Re`gionalOfice
Central Files WATER QUALITY SECTION
AS4EVILLE REGIONAL OFFICE
�Q�rthCarolina H
N.C.Division of Water Quality 1617 Mail Service Center Raleigh,North Carolina 27699-1617 Phone: (91 33-1015' Customer Service o
Internet http91h2o.enr.state.nc.us 512 N.Salisbury St. Raleigh,NC 27604 Fax: [phone] 1-877-623-6748
An Equal Opportun'Ay/AKrmative Action Employer

gotiee of Incomplete Discharge Monitoring Report
Permit Number. �l f
f
Facility-
County. m I) -_
DMR Month and Year:
The Division of Water Quality deems the aforementioned DMR as incomplete due to the
following reason(s): (Please see the highlighted areas on the attached DMR for details.)
❑ The written values are illegible.
❑ The Average,Maximum,and/or the Minimum data points have been omitted.
The Units of Measure have been omitted are incorrect f2 TrQ p, _LOej—
Taa�V ( i rt f� YV1QQ�i l�? L ►X' •�pfrun ft be�
❑ The DMR Parameter Codes have been omitted.
.�.! Other•.' ii LO
d-e -Q(1
�TL We C 4— c-(Ar-e�,/ 6 Od-e Shol" ham.

lJ I I
BLUE RIDGE OCT 1 8 2005 �J
PAPER PRODUCTS INC.
October 12, 2005 I�A"' vi F ' - e
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5801
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Mr. D. Keith Haynes
2090 U.S. Highway 70
Swannanoa, NC 28778
Re: NPDES NO. NC0000272
Certification in Lieu of Monitoring for Chloroform — Process Parameter Exceedance
Blue Ridge Paper Products, Inc.
Canton, NC
In accordance with NPDES Permit No. NC0000272 and 40 CFR 430.02(f)(6)(i)(A), Blue Ridge
Paper Products is hereby notifying the Division of Water Quality (DWQ) of a process parameter
exceedance on the hardwood fiberline that occurred on September 18, 2005. As approved by the
DWQ on August 16, 2005 Blue Ridge monitors certain process parameters (pH of the first C102
bleaching stage, kappa factor of the first C102 bleaching stage, and total bleach line C102
application rate) for its certification in lieu of monitoring for chloroform. In this case, the maximum
allowable pH value of the 1st C102 stage for the hardwood fiberline was exceeded on September
18, 2005 (see Attachment 1).
In accordance with 40 CFR 430.02(f)(6)(i)(B), Blue Ridge Paper Products is demonstrating
compliance with the applicable chloroform standard by submitting the results of one sample taken
from the hardwood fiberline effluent on September 19, 2005 (see Attachment 11). Given that the
results of the sample are well below permitted limits, Blue Ridge has resumed process monitoring
in lieu of monitoring for chloroform as allowed for by NPDES Permit No. NC0000272.
Blue Ridge has remained well below permitted limits for daily maximum and monthly average
chloroform limitations required by NPDES permit No. NC0000272 and remains committed to
continuous improvement in effluent quality. If you have any questions please don't hesitate to call
me at 828-646-2874.
Sincerely, /
Glenn Rogers Paul Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2874 828-646-6141
rogergablueridgepaper.com dickepC@_blueridgepaper.com
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

12 October 2005, Page 2
Attachment [: Process Parameter Tracking Sheet
Attachment II: Results Of Chloroform Testing
Internal Distribution:
C. File—Water
B. Williams
B. Shanahan
J. Clary
J. Pryately
D. Brown
C. Dowdle
L. Cooper
Environmental Group
175 Main Street • PC Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

ATTACHMENT I: PROCESS PARAMETER TRACKING SHEET

•Today a iba02005"For questions about excursions,contact Chad Dowdle Ph:2858 P8:444 302 or pulp foreman on
radio Channel 1A or 2445
Pine Data Total C102 Application Hardwood Data Total C102 Application
1st C102 Stage pH Kappa Factor Rate(lbs/ADT) 1st C102 stage pH Kappa Factor Rate(lbsIADT)
9/l/2005 2.60 0.24 51.88 3.06 0.24 25.41
9/2/2005 2.72 0.25 52.88 3.04 0.23 25.08
9/3/2005 2.84 0.22 47.39 3.36 0.23 24.11
9/4/2005 2.74 0.30 60.56 3.43 0.25 26.10
9/5/2005 2.74 0.28 55.24 3.19 0.23 24.58
9/6/2005 2.68 0.26 54.76 3.17 0.23 24.33
9/7/2005 2.63 0.26 55.92 3.05 0.23 26.57
9/8/2005 2.62 0.27 55.32 3.14 0.24 27.75
9/9/2005 2.73 0.25 53.17 3.26 0.23 26.28
9/10/2005 2.71 0.27 57.30 3.22 0.23 26.60
9/11/2005 2.93 0.24 52.57 3.25 0.24 27.59
9/12/2005 2.83 0.25 54.95 2.92 0.27 29.36
9/13/20051 2.93 0.23 1 51.04 3.03 0.24 28.25
9/14/2005 2.76 0.24 55.75 3.33 0.21 26.52
9/15/2005 2.54 0.27 56.40 3.37 0.16 22.68
9/16/2005 2.61 0.27 56.36 3.44 0.19 25.42
9/17/2005 2.59 0.25 55.62 3.21 0.20 25.44
9/18/2005 2.59 0.25 51.97 3.80 0.17 26.53
9/19/2005 2.62 0.22 49.38 3.45 0.18 27.09
9/20/2005 2.60 0.24 54.89 3.32 0.18 26.66
9/21/2005 2.62 0.21 47.52 3.33 0.17 23.01
9/22/2005 2.63 0.21 47.72 3.36 0.17 23.45
9/23/2005 2.63 0.22 47.45 3.30 0.17 22.55
9/24/2005 2.63 0.22 53.15 3.40 0.17 23.43
9/25/2005 2.57 0.22 49.61 3.44 0.16 21.67
9/26/2005 2.59 0.23 47.82 3.41 0.17 21.54
9/27/2005 2.60 0.24 50.67 3.21 0.18 21.78
9/28/2005 2.50 0.25 51.41 3.34 0.17 21.40
9/29/2005 2.45 0.25 55.51 3.35 0.17 22.82
Maximum Demonstrated
alues 3.19 0.330 75.5 3.79 0.418 43.9
Max.Mchadly Value(If
exceeds Demonstrated
alue) 3.80
Date of Exceedance Fiberline Parameter Exceeded Exception Response
Began sampling 9/19/2005 for chloroform testing
Hardwood ;r rat Stage pH 17 Instrument Malfunctions
.Pine r Kappa Factor r Startup/Shut Down (-
Total C102 s No Exception rJ
Data Archive Error s
Dale of Exceedance Fiberline Parameter Exceeded Exception Response
Hardwood s tat Stage pH r Instrument Malfunction r-
Pine r Kappa.Factor r Startup/Shut Down r
Total C102 r No Exception r
Data Archive Error r
Date of Exceedance Fiberline Parameter Exceeded Exception Response
Hardwood r tat Stage pH r Instrument Malfunctions
Pine r Kappa Factor r Startup/Shut Down r
Total C102 r No Exception r
Data Archive Error r

ATTACHMENT II: RESULTS OF CHLOROFORM TESTING

Pace Analytical Services, Inc. Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100 2225 Riverside Drive
Huntersville,NC28078 Asheville, NC28804
aceAnalytical0 Phone:704.875.909 Phne:828.25 .7178
Fax:[phone] Fax.,828.252.4818
www.pacelabs.com
October 04. 2005
Mr. John Pryately
Blue Ridge Paper Products, Inc
175 Main St.
Canton, NC 28716
RE: Lab Project Number: 92103532
Client Project ID: Chloroforms 9/20
Dear Mr. Pryately:
Enclosed are the analytical results for sample(s) received by the laboratory on September 20, 2005. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
I Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Sincer y,
frr �_on
[e-mail]
Project Manager
Enclosures
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 NC Wastewater 12
NC Drinking Water 37712 This report shall not be reproduced, except in full, NC Drinking Water 37706
without the written consent of Pace Analytical Services, Inc.
Sc 99030 . .«o Sc 99006
FL NELAP E87648 ea° - FL NELAP E87627

Pace Analytical Services, Inc. Pace Analytical Services, Inc.
' 9800 Kincey Avenue, Suite 100 2225 Riverside Drive
Huntersville,NG28078 Asheville, NC28804
WaceAnalXicalPhone:704.875.909 Phone.,828.252.. 8
Fax:[phone] Fax.,828.2524818
www.pacelabs.com
Lab Project Number: 92103532
` Client Project ID: Chloroforms 9/20
Lab Sample No: 926116542 Project Sample Number: 92103532-001 Date Collected: 09/19/05 07:20
Client Sample ID: HARDWOOD 01 COMPOSITE 9/19 Matrix: Water Date Received: 09/20/05 11:31
Parameters Results Units Report Limit Analyzed By CAS No. Qual RegLmt
GUMS Volatiles
Volatile GUMS by 624 Method: EPA 624
,Chloroform 11. ug/l 5.0 10/02/05 10:33 DLK 67-66-3
Toluene-d8 (S) 96 % 10/02/05 10.33 DLK 2037-26-5
4-Bromofluorobenzene (S) 95 % 10/02/05 10:33 DLK 460-00-4 1
Dibromofluoromethane (S) 114 X 10/02/05 10:33 DLK 1868-53-7
1
Date: 10/04/05 Page: 1 of 6
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced,except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC 99030 SC 99006
FL NELAP E87648 "" FL NELAP E87627

Pace Analytical Services, Inc. Pace Analytical Services,Inc.
9800 Kincey Avenue, Suite 100 2225 Riverside Drive
Huntersvi/le,NO 28078 Asheville, NC 28804
Ph :704.875.909 Phone:828.252.. 6
1!;a'ceAna1XJlca16 Fax:[phone] Fax:[phone] www.pacelabs.com
I Lab Project Number: 92103532
Client Project ID: Chloroforms 9/20
Lab Sample No: 926116559 Project Sample Number: 92103532-002 Date Collected: 09/19/05 07:25
Client Sample ID: HARDWOOD EO COMPOSITE 9/19 Matrix: Water Date Received: 09/20/05 11:31
Parameters Results Units Report Limit Analyzed By CAS No. Quall RegLmt
GUMS Volatiles
Volatile GUMS by 624 Method: EPA 624
Chloroform 8.2 ug/l 5.0 10/02/05 10:53 OLK 67-66-3
Toluene-dB (S) 98 x 10/02/05 10:53 DLK 2037-26-5
4-Bromofluorobenzene (S) 96 % 10/02/05 10:53 DLK 460-00-4 1
Dibromofluoromethane (S) 0 x 10/02/05 10:53 DLK 1868-53-7 2
Date: 10/04/05 Page: 2 of 6
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced,except in full, NO Wastewater 12
NO Drinking Water 37712 NO Drinking Water 37706
SC 99030 without the written consent of Pace Analytical Services, Inc. SC 99006
FL NELAP E87648r"" FL NELAP E87627

Bleach Filtrate Chloroform Calculations
Date: 9/19/2005
HW D-1 HW Eo HW Total Pine D-1 Pine Eo Pine D-2 Pine Total
Flow in mgd 1.66386 0.392087 2.055947
Concentration in mg/I 0.011 0.0082
8.34 8.34
Lbs/day 0.1526 0.0268 0"1795

oECE ED .
BLUE RIDGE SEP 2 2 2005
PAPER PRODUCTS INC.
WATER QUALITY SECTION
September 20, 2005 ASHEVILLE REGIONAL OFFICE
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5092
Mr. Keith Haynes
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
Division of Water Quality
2090 US Highway 70
Swannanoa,North Carolina 28778
Follow-up to August 19, 2005 Written Report
Subject: Release of Stormwater Normally Managed as Wastewater
Blue Ridge Paper Canton Mill
Dear Mr. Haynes:
There have been three flash floods on Mingus Branch since June 2005, each resulting in release
of chip pile Stormwater to the river. The mill has now completed repair to the following parts of
Mingus Branch in response to the September, 2004 floods: inlet of the underground conveyance,
adjacent to the warehouse and 100 feet of underground piping underneath the hardwood chip
pile. The hardwood sump pumps controls have also been added to the new wastewater treatment
plant's DCS system with alarms set at 60% of the sump capacity. This returns the pre-flood
controls and alarm for that system.
As part of the Mingus Branch repairs, the mill also dye traced and confirmed segregation of the
chip pile and Mingus Branch storm drain system.
This BMP corrective action has restored Mingus Branch to its normal carrying capacity.
Problems with Mingus Branch flow, which was a direct result of floods during hurricane's Ivan
and Francis, have been resolved.
If you have questions or would like to see the repairs and new controls, please contact us at one
of the following numbers.
Blue Ridge Paper Products -Environmental Group
175 Main Street• PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Keith Haynes,NC-DENR
Sincerely, !�
Louie J stus T`Paul S. Dickens
Senior Environmental Engineer Manager, Environmental Affairs
828-646-2874 828-646-6141
cc:
C-File Water
Stormwater Pollution Prevention Plan
J. Giauque
J. Pryatley
M. Elmore
B. Williams
Blue Ridge Paper Products Inc. -Environmental Group
175 Main Street• PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

OF wATF9 Michael F.Easley
`CCU pG pp Governor
William G.Ross,Jr.,Secretary
NCDENR
Y Alan W.Klimek,P.E.,Director
Division of Water Quality
August 16, 2005
Mr. Paul Dickens, Manager
Environmental Affairs
Blue Ridge Paper Products, Inc.
175 Main Street, P.O. Box 4000
Canton, North Carolina 28716
Subject: NPDES Permit Modification
'Permit NC0000272
Blue Ridge Paper Products, Inc.
Haywood County
Dear Mr. Dickens:
The Division of Water Quality has reviewed your request for modification of the subject
pennit. Your request for certification in lieu of monitoring for chloroform has been approved in
accordance with 40 CFR 430.02 (f).
Please find enclosed two revised Effluent Limitations and Monitoring Requirements pages
for outfalls 002 and 003. These pages should be inserted into your permit. The old pages may
then be discarded. Please carefully review footnotes #4 and #6 for both effluent pages. All
other terms and conditions contained in the original permit remain unchanged and in full
effect. This permit modification is issued pursuant to the requirements of North Carolina
General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and
the U. S. Environmental Protection Agency.
If any parts, measurement frequencies or sampling requirements contained in this permit
modification are unacceptable to you, you have the right to an adjudicatory hearing upon
written request within thirty(30) days following receipt of this letter. This request must be a
written petition conforming to Chapter 150B of the North Carolina General Statutes, filed with
the Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina
27611-7447. Unless such demand is made, this decision shall be final and binding.
If you have any questions concerning this permit modification, please contact Sergei
Chernikov at telephone number(919) 733-5083, extension 594.
Sincerely,
VL!, Aian Mimek. P.E. - --
cc. Central Files
NPDES Files
Asheville Regional Office;Surface Water Protection
Roosevelt Childress, EPA
N.C.Division of Water Quality I NPDES Unit Phone:[phone]
1617 Mail Service Center,Raleigh,NC 27699-1617 fax:[phone]
Internet:h2o.enr.s1ate.nc.us DENR Customer Service Center.1800 623.7748

Permit Number: NC0000272
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
outfall(s) 002 (EZt),shall be limited and monitored by the Permittee as specified below and in A.(7.)
Effluent Guideline Sampling Plan Special Condition:
14- 71-
,p-;,,i�w EfflllCnt ,� y rs; .�L1IIllt5 �_ ". Monitoring Requirements £s' .
Characteristics "> _ r e 4^ �l
is s +. Monthly Daily' I)ady ; •Measurement Sample xSample
__f .7..,, 4 _ _g_ � _- g ,4 _Y» }x_.�3'p : •Location':=,;
Flo _ Weekly Calculated EZ
Chloroform 5.15lb/day 8.601b/day Suspended Grab EZ
2,3,7,8 Tetrachloro- < 10 pg/L Monthly Composite Er
dibenzo- -dioxin(TCDD)
2,3,7,8 Tetrachloro- 31.9 pg/L Monthly Composite Er
dibenzo- -furan(TCDF
Trichlorosyringol < 2.5 µW Monthly Composite EZ
3,4,5-Trichlorocatechol < 5.0 µg/L Monthly Composite EZ
3,4,6-Trichlorocatechol < 5.0 µg/L Monthly Composite EZ
3,4,5-Trichloroguaiacol < 2.5 µg/I. Monthly Composite Ez
3,4,6-Trichloroguaiacol < 2.5 pg/L Monthly Composite EZ
4,5,6-Trichloroguaiacol < 2.5 pg/L Monthly Composite E2
2,4,5-Trichlorophenol < 2.5 µg/L Monthly Composite Ez
2,4,6-Trichlorophenol < 2.5 µg/L Monthly Composite Ea
Tetrachlorocatechol P2.5pg/LL
Monthly Composite EZ
Tetrachloroguaiacol pg/L' Monthly Composite EZ
2,3,4,6-Tetrachlorophenol Monthly Composite EZ
Pentachlorophenol Monthly Composite Ez
pH of the fastC'02 3.19Weekly Grab E2
bleaching stage6
Kappa factor of the first 0.33 Weekly Calculated Ez
C102 bleaching stageb
Total bleach line C102 75.52 Weekly Calculated Ez
application rate(lb/ADT)6
Footnotes:
1. Sample Location:E2—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from C10Z bleaching stage D-100 and from tap installed on filtrate pump from C102
bleaching stage D-2)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E.). See A.(7.)Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters as prepared by the pennittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently;refer to A. (7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or flow
meters,and report total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestrearn.

Permit Number: NC0000272
4. Per 40 CFR 430.02(f)chloroform monitoring is suspended due to the submission of"Certification in lieu of
monitoring".If conditions of certification are violated and chloroform sampling is performed,then for
compliance purposes,the permittee must report the total chloroform mass loading based on addition of separate
acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels(ML)specified in 40 CFR 430.01.
6. If limit is exceeded the permittee will be in violation unless:
a) DWQ is notified within 30 days of the exceedence,and
b) Compliance with the chloroform limit is demonstrated by taking one sample to monitor bleach plant
effluent for chloroform within 7 days of exceeding the value.If the sample demonstrates compliance,
process monitoring will resume in lieu of monitoring for chloroform.
Compliance with the chloroform effluent limit can be demonstrated by either sampling each fiberline for
chloroform or by monitoring process parameters.
In order to continue exemption from the chloroform monitoring requirements the pemdttee must meet conditions
specified in 40 CFR 430.02(f)(6)(2).Periods of start-up,shutdown,or instrumental malfunction will not be
considered for the purposes of demonstrating compliance.
Definitions:
lb/day—Pounds per day µg/L—Micrograms per liter
pg/L—Picograms per liter ADT—air dried ton of pulp product

Permit Number: NC0000272
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
outfall(s) 003 (E31),shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
iEftltientCliaractenstics Llmits: iVlonitoln�Reguirements3 :
n x :a ' r: Monthly t ^Dady a Measurement Sampleflype i Sample'.
�"� � „ ,:•' '- , "�� �rAvera a Avera a � ,'zFre uenc M - �+'" ''''
-g __ y., q. y - -� �, .... .. �I:ocation'=
FlOW2Weekly Calculated E3
Chloroforrn 7.14lb/day 11.931b/day Suspended Grab E3
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E3
dioxin(TCDD)
2,3,7,8 Tetrachloro-dibenzo- 31.9 pg/L Monthly Composite E3
furan(TCDF)
Trichlorosyringol 02.5gW Monthly Corriposite E3
3,4,5-Trichlorocatechol Monthly Composite E3
3,4,6-Trichlorocatechol Monthly Composite E3
3,4,5-Trichloroguaiacol Monthly Composite E3
3,4,6-Trichloroguaiacol Monthly Composite E3
4,5,6-Trichloroguaiacol Monthly Composite E3
2,4,5-Trichlorophenol < 2.5 µgV Monthly Composite E3
2,4,6-Trichlorophenol < 2.5 µg/L Monthly Composite E3
Tetrachlorocatechol < 5.0 Pg1L1 Monthly Composite E3
Tetrachloroguaiacol < 5.0 µgV Monthly Composite E3
2,3,4,6-Tetrachlorophenol < 2.5 µg/I Monthly Composite E3
Pentachlorophenol < 5.0 µgJL Monthly Composite E3
pH of the fast CIOZ bleaching 3.79 Weekly Grab E3
stages
Kappa factor of the first CF02 0.42 Weekly Calculated E3
bleaching stage
Total bleach line C102 43.93 Weekly Calculated E3
application rate(lb/ADT)e
Footnotes:
1. Sample Location:E3—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100)and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage E.).See A.(7.)Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters, as prepared by the permittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or by flow
meter,and report total bleach plant flow(acid+alkaline wastestrearns)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period fromboth the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.

Permit Number: NCOOOO272
4. Per 40 CFR 430.02(f)chloroform monitoring is suspended due to the submission of"Certification in lieu of
monitoring".If conditions of certification are violated and chloroform sampling is performed,then for
compliance purposes,the permittee must report the total chloroform mass loading based on addition of separate
acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels(ML)specified in 40 CFR 430.01.
6. If limit is exceeded the permittee will be in violation unless:
c) DWQ is notified within 30 days of the exceedence,and
d) Compliance with the chloroform limit is demonstrated by taking one sample to monitor bleach plant
effluent for chloroform within 7 days of exceeding the value.If the sample demonstrates compliance,
process monitoring will resume in lieu of monitoring for chloroform
Compliance with the chloroform effluent limit can be demonstrated by either sampling each frberline for
chloroform or by monitoring process parameters.
In order to continue exemption from the chloroform monitoring requirements the permittee must meet conditions
specified in 40 CFR 430.02(1)(6)(2).Periods of start-up,shutdown,or instrumental malfunction will not be
considered for the purposes of demonstrating compliance
Definitions:
lb/day—Pounds per day µg/L—Micrograms per liter
pg/L—Picograms per liter ADT—air dried ton of pulp product

bF WA Michael F.Easley
�O Q pw Governor
vj. ©NA William G.Ross,Jr.,Secretary
NCDENR North Carolina Department of Environment and Natural Resources
1
O < Alan W.Rlimek,P.E.,Director
` Division of Water Quality
l l !
July 14, 2005 I I
Mr. Paul Dickens, Manager
Environmental Affairs
Blue Ridge Paper Products, Inc. urreFCTION
175 Main Street, P.O. Box 4000 I _-?. ,t• r, ;;�, ..O�
Canton, North Carolina 28716 -
Subject: NPDES Permit Modification
Permit NC0000272
Blue Ridge Paper Products, Inc.
Haywood County
Dear Mr. Dickens:
The Division of Water Quality has reviewed your request for modification of the subject
permit. Your request for certification in lieu of monitoring for chloroform has been approved in
accordance with 40 CFR 430.02 (f).
Please find enclosed two revised Effluent Limitations and Monitoring Requirements pages
for outfalls 002 and 003. These pages should be inserted into your permit. The old pages may
then be discarded. Please carefully review footnotes #4 and #6 for both effluent pages. All
other terms and conditions contained in the original permit remain unchanged and in full
effect. This permit modification is issued pursuant to the requirements of North Carolina
General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and
the U. S. Environmental Protection Agency.
If any parts, measurement frequencies or sampling requirements contained in this permit
modification are unacceptable to you, you have the right to an adjudicatory hearing upon
written request within thirty (30) days following receipt of this letter. This request must be a
written petition conforming to Chapter 150B of the North Carolina General Statutes, filed with
the Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina
27611-7447. Unless such demand is made, this decision shall be final and binding.
If you have any questions concerning this permit modification, please contact Sergei
Chernikov at telephone number [phone], extension 594.
Sincerely,
an Klimek, P.E.�YII/l ApnJ
cc. Central Files
NPDES Files
Asheville Regfohal Office, Surface Water Protection
Roosevelt Childress, EPA
N.C.Division of Water Quality/NPDES Unit Phone:[phone]
1617 Mail Service Center,Raleigh,NC 27699-1617 fax:[phone]
Internet:h2o.enr.state.nc.us DENR Customer Service Center.,1800 623-7748

Permit Number: NC0000272
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
outfall(s)002(E2%shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sam ling Plan Special Condition
`�3e, .1.�r Effluent ,y ', Limits u� ' MOn1tOrIIIROQIDremClltS��y ,
tjnararteristlC3
Monthly Dail Daily s y Measurement Sample Samp�e i
3 n � ,
K'4 Average: Average Maximum Frequency: Typg
,. ' :'L'acahonc;a
Flo Weekly Calculated F�
Chloroform 5.151b/day 8.60lb/day Suspended Grab E2
Tetrachloro- < 10 pg/L Monthly Composite E2
dibenzo- -dioxin(TCDD)
2,3,7,8 Teuachloro- 31.9 pg/L Monthly Composite E2
dibenzo- -furan(TCDF)
Trichlorosyringol < 2.5 µg/L Monthly Composite E2
3,4,5-Trichlorocatechol < 5.0 µg/L Monthly Composite E2
3,4,6-Trichlorocatechol < 5.0 µg/L Monthly Composite E2
3,4,5-Trichloroguaiacol < 2.5 µg/I Monthly Composite E2
3,4,6-Trichloroguaiacol < 2.5 µg/L Monthly Composite E2
4,5,6-Trichloroguaiacol < 2.5 µg/L Monthly Composite E2
2,4,5-Trichlorophenol < 2.5 jig/LT Monthly Composite E2
2,4,6-Trichlorophenol < 2.5 µg/L Monthly Composite E2
Tetrachlorocatechol < 5.0 µg/L Monthly Composite E2
Tetrachloroguaiacol < 5.0 µg/L Monthly Composite E2
2,3,4,6-Tetrachlorophenol < 2.5 µg/L Monthly Composite E2
Pentachlorophenol < 5.0 µg/L Monthly Composite E2
pH of the first C102 3.19 Weekly Grab F2
bleaching stage6
Kappa factor of the first 0.33 Weekly Calculated Ez
C102 bleaching stage6
Total bleach line C102 75.52 Weekly Calculated E2
application rate(lb/ADT)6
Footnotes:
1. Sample Location:E2—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100 and from tap installed on filtrate pump from C102
bleaching stage D-2)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E.).See A.(7.)Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters as prepared by the pennittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or flow,
meters,and report total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.

Permit Number: NC0000272
4. Per 40 CFR 430.02(f)chloroform monitoring is suspended due to the submission of"Certification in lieu of
monitoring'.If conditions of certification are violated and chloroform sampling is performed,then for
compliance purposes,the permittee must report the total chloroform mass loading based on addition of separate
acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels(ML)specified in 40 CFR 430.01.
6. If limit is exceeded the permittee will be in violation unless:
a) DWQ is notified within 30 days of the exceedence, and
b) Compliance with the chloroform limit is demonstrated for a duration of 30 days with the weekly sampling
frequency(4 samples).If 4 samples demonstrate compliance,process monitoring will resume in lieu of
monitoring for chloroform.--- -' -
In order to continue exemption from the chloroform monitoring requirements the permittee must meet conditions
specified in 40 CFR 430.02(f)(6)(2).Periods of start-up,shutdown,or instrumental malfunction will not be
considered for the purposes of demonstrating compliance.
- Definitions: - -- - -
lb/day-Pounds per day µg/L-Micrograms per liter
pg/L-Picograms per liter ADT-air dried ton of pulp product

Permit Number: NC0000272
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration, the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
outfall(s) 003(E3r),shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
"Effluen't.Chazacterist cs Liriuts Monitorine Reguirements2..
~Monthly Datly Measurement Sample Type `, Sample. '
Average Average , .'.Frequency , _ .Locations
Flow Weekly Calculated E3
Chloroform 7.14lb/day 11.93lb/day Suspended Grab E3
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E3
dioxin(TCDD)
2,3,7,8 Tetrachloro-dibenzo- 31.9 pg/L Monthly Composite E3
furan(TCDF)
Trichlorosyringol < 2.5 µW Monthly Composite E3
3,4,5-Trichlorocatechol < 5.0 µg/L Monthly Composite E3
3,4,6-Trichlorocatechol < 5.0 µg/L Monthly Composite E3
3,4,5-Trichloroguaiacol < 2.5 µg/L Monthly Composite E3
3,4,6-Trichloroguaiacol < 2.5 µW Monthly Composite E3
4,5,6-Trichloroguaiacol < 2.5 µgV Monthly Composite E3
2,4,5-Trichlorophenol < 2.5 µg/L Monthly Composite E3
2,4,6-Trichlorophenol < 2.5 µg/L Monthly Composite E3
Tetrachlorocatechol < 5.0 µW Monthly Composite E3
Tenachloroguaiacol < 5.0 µg/L Monthly Composite E3
2,3,4,6-Tetrachlorophenol < 2.5 µg/L' Monthly Composite E3
Pentachlorophenol < 5.0 µW Monthly Composite E3
pH of the first C102 bleaching 3.79 Weekly Grab E3
stage
Kappa factor of the first C102 0.29 Weekly Calculated E3
bleaching stage
Total bleach line C102 43.93 Weekly, Calculated E3
application rate(lb/ADT)6
Footnotes:
1. Sample Location:E3—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100)and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage E.).See A.(7.)Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001) or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters,as prepared by the permittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently;refer to A. (7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or by flow
meter,and report total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.

Permit Number: NCOOOO272
4. Per 40 CFR 430.02 (0 chloroform monitoring is suspended due to the submission of"Certification in lieu of
monitoring".If conditions of certification are violated and chloroform sampling is performed, then for
compliance purposes,the permittee must report the total chloroform mass loading based on addition of separate
acid and alkaline chloroform mass loadings.
5: Limits are based on Minimum Levels (NE)specified in 40 CFR 430.0E" - — - -
6. If limit is exceeded the permittee will be in violation unless:
c) DWQ is notified within 30 days of the exceedence,and
d) Compliance with the chloroform limit is demonstrated for a duration of 30 days with the weekly sampling
frequency(4 samples).If 4 samples demonstrate compliance,a process monitoring will resume in lieu of
monitoring for chloroform.
In order to continue exemption from the chloroform monitoring requirements the permittee must meet conditions
specified in 40 CFR 430.02(f)(6)(2).Periods of start-up, shutdown, or instrumental malfunction will not be
considered for the purposes of demonstrating compliance
Definitions:
lb/day—Pounds per day µg/L—Micrograms per liter
pg/L—Picograms per liter ADT—air dried ton of pulp product

f-- 'p'�# ri; t--y+
of warFq = u � MicItael'F.Easley,Governor
o ) L. 1.
William G.Ross Jr.,Secretary
r North Carolina Department of Environment and Natural Resources
Alan W.Klimek,P.E.Director
n Division of Water Quality
September 8, 2005
Mr. Paul Dickens, Manager
Environmental Affairs
Blue Ridge Paper Products
Post Office Box 4000
Canton,North Carolina 28716
Subject: Influent Monitoring Change for New Acid Sewer
Blue Ridge Paper Products
NPDES Permit No.NC0000272
Haywood County
Dear Mr. Dickens:
This Office is in receipt of your letter dated September 2, 2005 in which you request
approval to make a change in the influent monitoring location for the acid sewer. It is our
understanding that this request is necessary due to the installation of a new acid sewer force
main.
After review of your letter, Surface Water staff of the ARO agrees with the request that
the influent monitoring site be switched to reflect the change in the point of discharge of the new
acid sewer line into the wastewater treatment plant. It also appears that the proposed method for
calculating the total influent load is satisfactory. We are also hopeful that the project will help
reduce effluent color by reducing sewer-generated color.
If you have any questions regarding this matter,please do not hesitate to contact Keith
Haynes or me at 296-4500.
Sincerely,
Roger C. Edwards,
Regional Water Quality Supervisor
Cc: John Pryately
Sergei Chemikov
N�` Carolina
Vo Carollin
North Carolina Division of Water Quality 2090 U.S.Highway 70 Swannanoa,NC 28778 Phone(828)296A500 Customer Service
Internet h2o.enr.slate.nc.us FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

BLUE RIDGE JUN 2 0 2005 D
PAPER PRODUCTS INC
June 17, 2005 WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
f
CERTIFIED MAIL
RETURN RECEIPT REQUESTED _
7099 3220 0007 0371 3593
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Mr. Paul Rawls
Surface Water Protection Chief
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES NO. NC0000272
Request for Certification in Lieu of Monitoring for Chloroform "
Blue Ridge Paper Products, Inc.
Canton, NC
In accordance with NPDES permit No. NC0000272 and 40 CFR 430.02(f), Blue Ridge Paper
Products (Blue Ridge) is submitting this certification in lieu of monitoring for chloroform and
requesting NPDES Permit monitoring modifications to the Effluent Guidelines requirements for
chloroform. The NPDES permit references this certification in Section A.7 Effluent Guidelines
Sampling Plan Special Condition. In addition, this request shall not trigger re-opening of the
permit as allowed for in 15A NCAC 21-1.0114(b)(1).
In accordance with 40 CFR 430.02(f)(2)(i), Attachment I provides 174 pine and hardwood
fiberline chloroform measurements taken over a consecutive 41 month period which
demonstrate compliance with the applicable standard for chloroform. As shown below in Tables
1 and 2 all of these measurements are well below the applicable standard.
Table 1
Pine Fiberline Chloroform Data December 2001 - Ma 2005
Chloroform Data Standard %Standard
Chloroform Maximum
Monthly Average(lb/day) 1.05 5.15 20.36%
Chloroform Maximum
Dail (lb/day) 1.35 8.60 15.66%
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

17 June 2005, Page 2
Table 2
Hardwood Fiberline Chloroform Data December 2001 - May 2005
Chloroform Data Standard I %Standard
Chloroform Maximum
Monthly Average(lb/day) 0.75 7.14 10.53%
Chloroform Maximum
Dail Ib/da 1.29 11.93 10.82%
In addition, Blue Ridge hereby certifies that it will maintain records in accordance with 40 CFR
430.02(f)(2)(ii) for each fiberline. Attachment I provides this data along with the established
daily maximum values. In accordance with 430.02(f)(2)(iii) and (iv) Blue Ridge certifies that
there was no direct chlorine containing compound, including elemental chlorine and
hypochlorite, used as bleaching agents during the sample collection period used to make the
demonstration required under 430.02(f)(2)(i).
Based upon vendor-supplied data the chlorine content of the chlorine dioxide used on the
bleach lines does not exceed 0.2gm/I. Attachment II is an EPA letter clarifying that, under this
rule, vendor data can be used instead of making actual measurements to demonstrate that the
chlorine content parameter was not exceeded during the initial demonstration period. Blue
Ridge requests that this letter and the vendor supplied data satisfy the requirements of 40 CFR
430.02(f)(2)(ii)(B) and 40 CFR 430.02(f)(4)(ii).
Blue Ridge will meet the requirements of 40 CFR 430.02(f)(3) if process or operating conditions
are changed in a manner that exceeds the values recorded under paragraph (f)(2)(ii) for that
process or operating condition. In accordance with paragraph (f)(4), for each fiberline Blue
Ridge will include in its monthly Discharge Monitoring Report (DMR) data the daily average
value of: 1) pH of the first chlorine dioxide bleaching stage; 2) the kappa factor of the first
chlorine dioxide bleaching stage; and 3) the total bleach line chlorine dioxide application rate.
These records will be maintained daily except when there are brief periods of downtime such as
equipment start-up, shutdown, or instrumentation malfunction. However, periods of start-up,
shutdown, or instrumentation malfunction will not be considered for the purposes of
demonstrating compliance. The data required by 40 CFR 430.02 is critical to fiberline
operations and any periods not monitored will be brief and infrequent. In line with current
sampling requirements, monitoring will be initiated if records of the required parameters are not
generated for a period greater than 7 consecutive days.
Blue Ridge will notify NCDENR in writing within 30 days if, for any reason, it fails to maintain
process and operating conditions at values equal to or less than the maximum value recorded
under 430.02(f)(2)(ii) or 430.02(f)(3)(ii) for each such condition. In accordance with 40 CFR
430.02(f)(6)(i)(B), once a value is exceeded, Blue Ridge proposes to demonstrate compliance
with the applicable chloroform standard by taking one sample to monitor the bleach plant
effluent for chloroform within 7 days of exceeding the value and will include the results in the 30-
day letter for re-certification. After one sample demonstrates compliance, process monitoring
will resume in lieu of monitoring for chloroform.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

17 June 2005, Page 3
In summary, Blue Ridge has remained well below permitted limits for daily maximum and
monthly average chloroform limitations required by NPDES permit No. NC0000272. Based
upon this information and the attached data, Blue Ridge submits this certification in lieu of
monitoring for chloroform in accordance with 40 CFR 430.02(f) and its NPDES permit No.
NC0000272 and requests modification of the Permit chloroform monitoring requirements.
Sincerely,
Glenn Rogers Paul Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2874 828-646-6141
[e-mail] [e-mail]
Attachment: Demonstration period - Chloroform monitoring and process data
Attachment: EPA letter regarding vendor certification
cc:
Mr. D. Keith Haynes (w/attachments)
Environmental Specialist
North Carolina Department of Environment
& Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Internal Distribution:
C. File—Water
B. Williams
B. Shanahan
J. Clary
J. Pryately
D. Brown
C. Dowdle
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

Attachment I

Attachment 1
Pine Chloroform and Parameter Maximums
Daily Averages(Pine)
Pine Chloroform 1st Pine CIO,Stage Pine Total CIO,
Date (Ib/day) PH Kappa Factor pb/ADT)
12/3/2001 0.40 2.45 0.23 65.77
12/10/2001 1.35 2.48 0.26 75.52
12/17/2001 0.23 2.51 0.24 51.17
12/24/2001 0.37
12/31/2001 0.48
1/7/2002 1.02 2.55 0.25 65.21
1/16/2002 1.34 2.74 0.24 61.67
1/21/2002 0.96 2.39 0.25 71.65
1/28/2002 0.87 2.63 0.24 55.98
2/4/2002 0.97 2.29 0.25 65.55
2/11/2002 0.67 2.34 0.23 54.63
2/18/2002 0.59 2.50 0.24 54.28
2/25/2002 0.41 2.49 0.22 52.75
3/4/2002 0.52 2.61 0.26 72.17
3/11/2002 0.59 2.53 0.24 70.32
3/18/2002 0.45 2.53 0.23 63.45
3/25/2002 0.35 2.45 0.23 56.13
4/l/2002 0.23 2.19 0.24 55.37
4/8/2002 0.31 2.43 0.23 54.21
4/19/2002 0.23 2.51 0.23 54.72
4/22/2002 0.29 2.77 0.25 55.46
4/29/2002 0.12 2.65 0.23 54.34
5/6/2002 0.12 2.02 0.22 45.61
5/13/2002 0.40 2.50 0.22 54.36
5/20/2002 0.57 2.02 0.24 56.40
5/31/2002 0.37 2.75 0.25 51.71
6/3/2002 0.35 3.04 0.26 66.38
6/10/2002 0.52 2.05 0.22 48.75
6/21/2002 0.66 2.57 0.28 61.25
6/24/2002 0.48 2.35 0.28 55.56
7/1/2002 0.72 2.73 0.24 55.54
7/8/2002 0.92 2.24 0.25 66.41
7/15/2002 0.82 2.43 0.24 60.09
7/22/2002 0.82 2.26 0.24 55.92
7/29/2002 0.51 2.12 0.25 56.06
8/5/2002 0.16 2.29 0.24 53.44
8/12/2002 0.08 2.24 0.25 62.63
8/19/2002 0.53 2.37 0.23 52.45
8/26/2002 0.72 2.55 0.23 53.87
9/2/2002 0.74 2.57 0.26 67.83
9/15/2002 1.15 2.39 0.24 48.69
9/16/2002 0.88 2.38 0.23 53.96
9/23/2002 0.23 2.43 0.23 57.09
9/30/2002 0.68 2.27 0.24 47.71
PI Data Archive system doom/unavailable
Fbertme down/abnormal operations
Mill flooded/operations down t

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Attachment I
Pine Chloroform and Parameter Maximums
Daily Averages(Pine)
Pine Chloroform 1st Pine CIO,Stage Pine Total CIO,
Date pb/day) pH Kappa Factor pb/ADT)
3/7/2005 0.39 2.24 0.28 60.08
3/14/2005 0.53 2.35 0.21 54.13
3/21/2005 0.40 2.45 0.23 53.86
3/28/2005 0.40 2.36 0.23 52.65
4/4/2005 2.58 0.32 61.66
4/11/2005 0.57 2.25 0.24 49.34
4/18/2005 0.40 2.59 0.22 49.34
4/25/2005 0.33 2.47 0.23 52.61
6/2/2005 0.15 2.30 0.25 54.63
Maximum Process Values 3.19 0.33 75.52
Table 1
Pine Fiberline Chloroform Data December 2001 -May 2005
Chloroform Data Standard %Standard
Chloroform Maximum Monthly
Average 1.05 5.15 20.36%
Chloroform Maximum
Daily 1.35 8.60 15.66%
Pi Data Archive system dawn/unavailable
Fiberline down/abnormal operations
Mill flooded/operations dawn 5

Attachment I
Hardwood Chloroform and Parameter Maximums
Daily Averages(Hardwood)
Hardwood 1st Hardwood CIO, Hardwood Total
Date Chloroform pb/day) Stage pH Kappa Factor CIO,(Ib/ADT)
12/3/2001 0.39 3.32 0.19 37.57
12/10/2001 0.41 3.11 0.26 42.18
12/17/2001 0.20 2.64 0.25 38.57
12/24/2001 0.19 '
12/31/2001 0.29
V7/2002 0.23 2.79 0.22 33.43
1/15/2002 0.22 2.83 0.20 35.63
1/21/2002 0.17 2.81 0.19 35.86
1/28/2002 0.24 2.77 0.26 42.63
2/4/2002 0.22 2.65 0.29 41.07
2/11/2002 0.24 2.73 0.27 41.67
2/18/2002 0.45 3.08 0.28 39.77
2/25/2002 0.51 3.02 0.22 39.05
3/4/2002 0.40 3.06 0.19 35.89
3/11/2002 0.91 3.12 0.22 37.06
3/18/2002 0.41 3.20 0.21 35.57
3/25/2002 1.29 3.47 0.22 34.60
4/1/2002 0.76 3.49 0.18 32.67
4/8/2002 0.60 3.37 0.19 32.22
4/19/2002 0.56 3.30 0.23 38.46
4/22/2002 0.89 3.61 0.22 35.86
4/29/2002 0.55 3.29 0.24 36.62
5/6/2002 0.52 3.32 0.20 29.56
5/13/2002 0.57 3.43 0.23 36.68
6/20/2002 1.01 2.28 0.01 4.57
5/31/2002 0.54 3.30 0.19 31.68
6/3/2002 0.52 3.49 0.18 33.72
6/10/2002 0.28 3.41 0.16 32.49
6/21/2002 0.33 3.44 0.15 36.21
6/24/2002 0.25 3.12 0.12 27.57
7/1/2002 0.34 3.51 0.16 33.24
7/8/2002 0.15 2.98 0.21 34.45
7/15/2002 0.50 3.36 0.23 35.48
7/22/2002 0.67 3.56 0.19 34.71
7/29/2002 0.74 3.51 0.17 33.13
8/5/2002 0.31 3.30 0.19 29.54
8/12/2002 0.38 3.34 0.19 33.36
8/19/2002 0.69 3.47 0.22 36.58
8/26/2002 0.15 3.33 0.22 36.03
9/2/2002 0.60 3.21 0.23 38.71
9/15/2002 0.39 3.29 0.13 19.67
9/16/2002 0.39 3.18 0.17 32.10
9/23/2002 0.45 3.20 0.22 36.54
9/30/2002 0.41 3.20 0.18 33.81
Pi Data Archive system dawn/unavailable
Flbedine dawn/abnormal operations
Mill flooded/operations dawn 6

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Attachment I
Hardwood Chloroform and Parameter Maximums
Daily Averages(Hardwood)
Hardwood 1st Hardwood 002 Hardwood Total
Date Chloroform(Ib/day) Stage pH Kappa Factor C1O2(Ib/ADT)
5/10/2004 0.46 3.05 0.20 32.43
5/17/2004 0.17 3.07 0.22 29.57
5/28/2004 0.22 3.33 0.22 29.21
5/31/2004 0.35 3.19 0.28 36.52
6/7/2004 0.27 3.27 0.21 32.95
6/14/2004 0.47 3.47 0.22 34.78
6/21/2004 0.32 3.02 0.25 29.92
6/28/2004 0.14 2.95 0.25 31.87
7/5/2004 0.16 3.21 0.20 27.47
7/12/2004 0.17 3.18 0.22 30.93
7/19/2004 0.23 3.18 0.24 29.69
7/26/2004 0.14 2.98 0.22 27.59
8/2/2004 0.22 3.43 0.16 29.20
8/9/2004 0.10 2.87 0.24 28.89
8/16/2004 0.08 3.01 0.23 29.38
8/23/2004 0.09 3.17 0.24 33.43
8/30/2004 0.11 3.24 0.24 33.46
9/6/2004 0.11 2.91 0.25 34.58
9/13/2004 "' "' - -
9/20/2004
9/27/2004 - "` - -
10/6/2004 0.06 3.15 0.21 30.37
10/11/2004 0.13 3.28 0.21 29.22
10/18/2004 0.12 3.36 0.21 33.56
10/25/2004 0.10 3.12 0.23 32.67
11/1/2004 0.27 3.44 0.18 29.97
11/8/2004 0.08 2.96 0.20 27.65
11/15/2004 0.15 3.37 0.19 26.20
11/22/2004 0.10 3.14 0.22 28.75
11/29/2004 0.14 3.49 0.19 29.04
12/6/2004 0.19 3.03 0.18 29.22
12/13/2004 0.06 2.99 0.20 27.90
12/20/2004 0.08 2.93 0.24 31.61
12/27/2004 0.07 3.12 0.15 28.04
1/3/2005 0.08 3.15 0.18 27.24
1/10/2005 0.10 3.20 0.17 25.31
1/17/2005 0.15 3.41 0.18 25.07
1/24/2005 0.11 3.45 0.18 27.47
1/31/2005 0.12 3.15 0.21 30.76
2/7/2005 0.08 2.96 0.21 29.55
2/14/2005 0.09 3.07 0.21 29.43
2/21/2005 0.11 3.18 0.25 32.70
2/28/2005 0.14 3.30 0.21 29.26
Pi Data Archive system down/unavailable
"Fiberline down/abnormal operations
Mill flooded/operations down 9

Attachment I
Hardwood Chloroform and Parameter Maximums
Daily Averages(Hardwood)
Hardwood 1st Hardwood C102 Hardwood Total
Date Chloroform(lb/day) Stage pH Kappa Factor CIOs(Ib/ADT)
3/7/2005 0.27 3.25 0.18 29.47
3/14/2005 0.16 3.20 0.20 27.53
3/21/2005 0.13 3.21 0.20 28.52
3/28/2005 0.24 3.13 0.24 25.38
4/4/2005 0.13 3.62 0.16 22.84
4/11/2005 0.18 3.39 0.16 21.84
4/18/2005 0.18 3.56 0.19 22.96
4/25/2005 0.27 3.41 0.19 25.66
5/2/2005 0.22 3.49 0.21 23.67
Maximum Process Values 3.79 0.29 43.93
Table 2
Hardwood Fiberline Chloroform Data December 2001 -May 2005
Chloroform Data Standard %Standard
Chloroform Maximum Monthly
Average 0.75 7.14 10.53%
Chloroform Maximum
Daily 1.29 11.93 10.82%
Pi Data Archive system down/unavailable
"Fibedine down/abnormal operations
Mill flooded/operations down 10

Attachment II

41.oa inn ZuZ qua Zeta AP&rA 10002/003
x A G UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Y WASHINGTON, D.C. 20460
C PRDT�
5 2V OFFICE OF
WATER
Mr. Jerry Schwartz
Senior Director,Water Quality Programs
American Forest &Paper Association
1111 Nineteenth Street,NW,Suite 800
Washington,DC 20036
Dear Mr. Schwartz,
Thank you for your letter,dated December 13,2002, concerning the certification
amendment to the Pulp and Paper effluent guidelines(Cluster Rules). This amendment allows
bleached papergiade kraft mills to discontinue monitoring for chloroform in their bleach plant
wastestreams after demonstrating compliance with the chloroform effluent limitations,given
certain data requirements and operational conditions. This amendment was promulgated on
September 19,2002 at 40 CFR 430.02(f).
Your inquiry seeks clarification on the ability of a certifying mill to rely on vendor-
supplied data and information when reporting the chlorine content of the chlorine dioxide used
on its bleach lines. You posited your understanding of our intention that once a mill met the
certification requirements, the mill should not be expected to monitor for chlorine content,unless
operational changes occurred that would be expected to change chlorine content. You observed
that many mills do not have the ability to perform this analysis on-site. You further noted that a
mill's reliance on vendor-supplied data when reporting chlorine content was not addressed by
EPA in the rule language.
The Agency understands that chlorine content analysis requires a wet-chemistry
procedure that most mills do not perform on-site on a routine basis. Upon considering currently
available information on chlorine dioxide generators being used by the vast majority of mills
across the industry for compliance with the Cluster Rules,EPA believes that normal operation of
such generators is not likely to produce large amounts of chlorine(typically less than 1 percent).
Therefore, the Agency concludes that routine chlorine content monitoring would not be likely to
provide additional useful information regarding the potential for generating chloroform. As a
result,EPA believes that it is generally acceptable for a certifying mill to use vendor-supplied
data when routinely reporting the chloride content of its chlorine dioxide solution. The only
exception would be when operational changes may be expected to change that solution. Such
operational circumstances could include,but may not be limited to,changing the chemistry of
generating chlorine dioxide.
Internet Address(URL). hftp:l/www.epa.9oV
ReeyelodIR"yclable.Pnntsd with Vegetable Oil Based Inks on Recycled Paper(Minunum 301A Poseansumer(
i
05/09/03 FRI 07:57 ITX/RX NO 6374]

.. .....w ......, .. <o< rvu cY<u nrere 19003/003
2
If you have any questions, please feel free to call meat(202)566-1021. You also may
call Ahmar Siddiqui at(202) 566-1044 or contact him via e-mail at siddiqui.ahmarnu enaeov.
Sincerely,
Donald F.Anderson
Acting Chief,Chemical Engineering Branch
Engineering and Analysis Division(4303T)
cc: Ahmar Siddiqui
Betsy Bicknell,ERG
05/09/03 FRI 07:57 [TX/RX NO 63741

BLUE RIDGE D E E v
PAPER PRODUCTS INC. '
APR — 4 2005
31 March 2005
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
Mr. D. Keith Haynes
Environmental Scientist
North Carolina Department of Environment
and Natural Resources
Water Quality Division
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Subject: Permanent Flood Repairs for Power Reliability
NPDES No. NC 0000272
Blue Ridge Paper Products Inc.
Haywood County
Canton, North Carolina
Dear Keith—
This letter is to advise you that Blue Ridge Paper will be relocating power feeds at our
wastewater treatment plant during the April semi-annual outage next week. Specifically, we will
raise and replace the automatic power transfer switch that was submerged during the floods of
September 2004. Blue Ridge Paper had repaired the flooded switch and restored dual feed
power capability after the September floods. This project is a permanent relocation and
replacement of the automatic power transfer switch. The new location is above the high water
level of the September 2004 floods.
The power relocation work is scheduled for Tuesday, Wednesday and Thursday April 5—7,
2005. During this period our influent wastewater pumps will operate on mill power only. We
have rented portable hydraulic pumps as an emergency backup. The work is being done during
the April semi-annual outage when total mill wastewater flow is reduced.
Please contact me if you have questions concerning the power relocation work.
-e- S
Paul S. Dickens
Manager, Environmental Affairs
828-646-6141
dickei)@blueridgepaper.com
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 1681
19 Nov 2004 FASHEVILLE
� pp E
Forrest R. Westall, PE VWater Quality Regional Supervisor 2
North Carolina Department of Environment
and Natural ResourcesDivision of Water ualit LITY SECTION
Q yGIONAL OFFICE
2090 US Highway 70
Swannanoa, NC 28778
Subject: NPDES NC 0000272
October 2004 Discharge Monitoring Report
Blue Ridge Paper Products, Inc.
Canton,NC
Dear Forrest:
This letter accompanies the October 2004 discharge monitoring report(DMR) and documents
monthly average excursions for color and BOD that resulted from the unexpected process and
wastewater treatment upset that occurred during mill restart following back-to-back floods in
September 2004.
Mill Restart and Wastewater Excursions
As you are aware, the Blue Ridge Paper Products mill in Canton, NC was hit by the remnants of
three hurricanes (Frances, Ivan and Jeanne) and by back-to-back historic floods during the month
of September 2004. Our wastewater plant and significant parts of the mill were flooded twice.
Wastewater treatment operations were down for a total of 9 days during September 2004. Mill
operations were down for 3 weeks.
The floods caused an unplanned, extended cold shutdown of the mill. Restart of the pulping and
recovery processes at the mill occurred between 9/27 and 10/4/2004. During restart, there were
several unexpected process upsets that led to high effluent color on 10/1. There was a biological
wastewater treatment upset during the first week of October 2004 that led to elevated effluent
BODs. We notified DENR of these upsets events by telephone and e-mail and submitted follow-
up written reports on 10/1, 10/3, 10/19 and 11/10.
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
19 Nov 2004, Page 2
The monthly average effluent true color for October 2004 was 59,539 lbs/day. The permit limit
maximum monthly average color is 52,000 lbs/day. The elevated monthly average color result
was due to high effluent color on 10/1. Average color for the 30-day period from 10/2 thru
10/31 was 44,168 lbs/day. The average color for the 3-week period from 10/8 thru 10/31 was
39,934 lbs/day. This compares well with the pre-flood color performance of the mill. The
average effluent color for the period January thru August 2004 was 39,737 lbs/day.
The monthly average secondary effluent BOD for October 2004 was 4039 lbs/day. The permit
limit monthly average BOD is 32051bs/day. The elevated monthly average BOD result was due
to the wastewater treatment upset and elevated effluent BODs that occurred during the first week
of October. There was a maximum day effluent BOD excursion on 10/4. The 10/4 BOD result
was 23,0361bs/day. The maximum day BOD permit limit is 10,8971bs/day.
The wastewater plant quickly recovered from upset conditions. The average BOD for the 3-week
period from 10/8 thru 10/31 was 2127 Ibs/day. This is within the normal range of pre-flood
BOD performance for the mill.
Blue Ridge Paper completed a chronic toxicity test on the wastewater effluent during the week of
10/18. The sample was split with DENR. The toxicity test results were good and passed at all
waste concentrations.
The performance of the Blue Ridge Paper wastewater treatment plant during mill restart
following the September floods is typical of activated sludge plants that experience a step change
in organic loading. The secondary treatment system went from essentially no organic load to the
normal mill organic loading. It takes one to two weeks for the activated sludge mass to increase
to match increased organic loading. The volatile-to-total solids ratio in the aeration basins
during September 2004 prior to mill restart was lower than during normal mill operations. This
is indicative of the low organic loading.
The Ivan flood on 9/17 washed out the lower aeration basins at the Blue Ridge Paper wastewater
treatment plant. We trucked in activated sludge from the City of Waynesville wastewater plant
during the last two weeks of September to rebuild sludge mass prior to mill restart. We also
limited sludge wasting until mid-October when BOD treatment performance and the volatile-to-
total solids ratio in the activated sludge returned to normal range. The fact that the period of
elevated effluent BODs was limited to one week demonstrates that our strategy for restarting
wastewater treatment following the September flood outages was successful.
Summary
Blue Ridge Paper has made good progress on recovery from the September 2004 floods. Our
mill operations and wastewater treatment performance have returned to normal. The period of
wastewater treatment upset associated with mill restart was limited to one week.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
19 Nov 2004, Page 3
We truly appreciate your help and that of Keith Haynes with flood recovery efforts.
Sincerely-
1 S
00
Paul S. Dickens John J. Pryately
Manager,Environmental Affairs Waste Treatment and Lab Supervisor
828-646-6141 Operator in Responsible Charge
dickeR@blueridgei)ai)er.com 828-646-2480
[e-mail]
Enclosure: October 2004 Discharge Monitoring Report
Distribution—copy attached to each DMR
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

Effluent n 9 7 w1
NPDES No.: NC 0000272 Discharge No.: 001 Month: October Y ar: 2004
Facility Name: Blue Ride Paper Products Inc. Class:IV F lCounty: Ha ood
Operator in Responsible Charge(ORC): John J.P atel Grade: IV Ph 6ga 6t6�672 ,,,, CE
Certified Laboratories: (1)Blue Ride Paper Prod.#198;(2) Pace #40,#12, 3 Simalabs International 002ASHEVIL
Check Box if ORC Has Changed Person(s)Collecting Samples: Operators on Duty-
Mail ORIG'L+1 CUPY to:
Attn:Central Files
DN.of Environmental Mgt. X i
DEHNR nature of erator in Re ponsib a Charge) Date
P.O.Box 29535 BY THIS SIGNATURE,I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE
Raleigh,NC 27626-0535 TO THE BEST OF MY KNOWLEDGE.
50050 00010 00400 00400 1 00310 00610 00530 31505 1 00300 00600
d
E rn LL
° 2
9
m e= ie N v Z
`o o 0
00 E U N o
0 o LL r m aF-
HRS YIN MGD °C Std Units Std Units lb./day mg/L IbJday p/100m1 mg L mg/L
1 0700 =-,24,,- -Y 27.550. - 34;2 7.6•" -,7.5" 9420 ` A,�0572i�r 27572t.i". .__ _2 0700 24 N 26.920 33.3 7.5 7.3 10552 18410 6.053 0700 -24` N 27:03t) '° - -a75 : „'7.2,_ . :• 10144 ,12850 ,_4 0700 24 Y 25.110 35.5 7.6 7.4 23036 14659 7.245 0700 24, ` ' Y ' . -'23 540: : 31;5 7.7;:r 7 5 _ 9424 _-10994 ; ' '._6 0700 24 Y 22.460 34.6 7.6 7.5 8804 11239 230 9.037. 0700' _24 . ;.Y„ .`,--23 800 ""3" ,7.6'� 1 v 7 5`: '= 27,79'• =i67.49 ,,,, ,'- ' 7:9R ' + 3.30"1.
8 0700 24 Y 23.880 34.0 7.7 7.1 996 0.210 6373 9.78
9 07001 24. N 24.530` `i 34:4 7.64 �, 7:2,r;,' 2864�<':0:100 .' `:5524 9,34:
10 0700 24 N 25.910 35.3 7.5 7.3 3241 < 0.100 7563 8.35
1.1 0700 -=24 _ -Y 26.990 34:5 7 5" 7:3'.;„ , 2696 <i0100 .;5617 ) '` 8-
12 0700 24 Y 27.100 35.9 7.6 7.4 2260 < 0.100 5424 6 8.22
13 0700'-', '24`. .Y F25:390,• -M °7:6; . r -.5;� -,2118:;t<10:500 "3812 f',k.,i ,. 8.12_s:
14 0700 24 Y 25.690 35.1 77 7.6 1286 < 0.100 4285 8.34
15 07W - -24-,,- Y''' '.'24.690' -.33:1 7.6 ;'' , a7,:5; 1853 <>01,00 4324 797 ': ti1 i
.�
16 0700 24 N 24.570 33.8 7.7 7.5 1025 < 0.100 2664 7.51
17" 0700° e' 24 N -. 25.370; 32:5 7 Q".°` -.-7 T .;,` 1058., <;'0100 „2751 9.07
18 0700 24 Y 25.400 33.8 7.7 7.6 1271 < 0.100 2330 8.35
19 0700 '. ''24: Y ='26 650 ,=-35:1 „7 8 ' 7 5 '_`i_.1334_'. <0100;: 2223 =9r;_Y _-7 1;
20 0700 24 Y 24.880 35.5 7.7 7.6 1660 0.170 2075 9.53
21 -0700 ;'24`__. , Y__. : 251560 ', 36:4 7,,6 7.8.a_ 2984_- -<�10100 s 2984 13:97
22 0700 24 1 Y 23.900 35.6 7.9 7.5 1 1993 < 0.100 3389 12.92
23 �0700. • :24_ N.•. §,25A40 . :35.8 T l 7,6_'- I> 4403 #-k74M00 _',r_3564 r F 1314;,-
24 0700 24 N 24.520 35.4 7.7 7.5 2863 1 0.140 4294 13.27:
25'„l.0700 24:`•, .: ,Y' -23 000 .,.34i9 , .,7:8 7 6,` 2i,10 0 200. ;si 4028 , <2"- 12!82
26 0700 24 Y 22.850 34.9 7.7 7.6 1435 0.440 5527 11.84.
'27, ^0700. . ` 24 Y _ 24030.; '34 6 7.9r;'' 7787 i 3231 'A f00+,1 75010 .7777-'AM".:i
28 1 0700 24 Y 25.110 35.4 7.6 7.5 3501 0.220 5864 9.26 .
29 0700 .. 24i' 'Y --- 231930T• ,35i6 7.8. 7,4,-; ,1537., ;10MTJ0 =:3792 k_-, 7.49 :,.
30 0700 24 N 25.040 35.3 7.8 7.7 1424 0.120 4386 7.37.
31._07,00 _.: 24;' ' `N,,'. '251000: i`=35i5 7 8:_'t 7 7, s N1908 ti0 100., ?7 23-;. 7 _.,
Average 25.016 34.8 4039 0.16 6615 13 9.12: 3.30
Maximum," 1 27,:550' %38.5 7 9'n„ ,;7 7`_ f_23036 1 F10' "27572_;ra 230': s 13.97.
Minimum 22.460 31.5 7.5 7.1 996 0.10 2075 :2 6.05 3.30
C0m L7Gr""ab' G aG,. _G",;r G ''_ _C '.•.:C F ;eC.. , G,' _G�
Monthly Limit 29.9 9 6 J 3,205 12,549 I 200 6

Facility Status:(Please check one of the following)
All monitoring data and sampling frequencies meet permit monitoring requirements. 0
Compliant
All monitoring data and sampling frequencies do NOT meet permit monitoring requirements. =X
Noncompliant
If the facility is noncompliant,please comment on corrective actions being taken in respect to equipment,
operation,maintenance,etc.and a time table for improvements to be made.
See Attached Letter.
°I certity,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 submitted 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!
Robert Shanahan
Permittee(Please print or type)
r
Signature of Permittee•• ate
P.O.Box C-10 Canton,NC 28716 828-646-2840 Permit Expires Nov.30,2006
Parameter Codes
00010 Temperature 00556 Oil&Grease 00951 Total Fluoride 01067 Nickel 50060 Total
00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual
00080 Color(Pt-Co) 00610 Ammonia Nitrogen 01092 Zinc Chlorine
00082 Color(ADMI) 00625 Total Kjeldahl 01027 Cadmium 01105 Aluminum
00095 Conductivity Nitrogen 01147 Total Selenium 71880 Formaldehyde
00300 Dissolved Oxygen 00630 NitratesINihites 01032 Hexavalent Chromium 31614 Fecal Coliform 71900 Mercury
00310 BOD5 01034 Chromium 32730 Total Phenolics 81551 Xylehe
00340 COD 00665 Total Phosphorus 34235 Benzene
00400 pH 00720 Cyanide 01037 Total Cobalt 34481 Toluene
00500 Total Solids 00745 Total Sulfide 01042 Capper 38260 MBAs
00530 Tot.Suspended 00927 Total Magnesium 39516 PCBs
Residue 00929 Total Sodium 01045 Total Iron 50050 Flow
00545 Settleable Matter 00940 Total Chloride 01051 Lead
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at(919)733-5083,extension 581 or 534.
The monthly average for fecal corAorm is to be reported as a GEOMETRIC mean. Use only units designated In the reporting
facility's permit for reporting data.
ORC must visit facility and document visitation of facility as required per 15A NCAC BA.0202(b)(5)(B).
•'If signed by other than the penniltee,delegation of signatory authority must be on file with the State per 15A NCAC 2B.0506(b).

NPDES No.: NC 0000272 Discharge No.: 001 Month: October Year: 2004
Facility Name: Blue Ride Paper Products Inc. County: Haywood
ORC: JohnJ. Pryately
Person(s)Collecting Samples: Operators on Du
EFFLUENT CON'T
00665 00030 00340 00095 00080 00082 03594
2
0
0
a o
N N 0 j n 7
mE 0 v
O V U 0 U U O
Q
HRS 1 1 mg/L lb/day 1 1 mg/L umhos/cm mg/L mg/L I I Ib/day
1 0700 520652 ' : "_ ,,' 2790 2266 3415'` 234.4
2 0700 139647 2796 622 1320 224.5
3 0700 67403.E " +2254 299 736
4 0700 58636.9 1894 280 540 205.2
5 0700 37301:5 - 200 •_1968.: 190", 305 174.7
6 0700 26973.6 1932 144 838 191.1
7 0700 _ 0.59 135728.61 140 _ _1838 180' , . 523 2025.
8 0700 35848.7 2074 180 436 199•P
9,_ 070D' _._._ . 25367.9; ' __ - 2128 ' 124 e 434 212:8
10 0700 45162.7 2264 209 390 192.3
11 0001 i" '56619:3'; , 2250 . 257= '' ; 37.5 209:0
12 0700 37744.3 150 2053 167 390 212.5
13 0700 391742 218E 185' `. 842'' . 213:9 _
14 0700 40708.4 2319 190 323 195.0
15 _6700 3521'1.4 2365 171 "315' 181:2
16 0700 42007.3 2743 205 300 209.0
17 0700 40412:9 `2.56- .. _191 ='` 274_ 190.4
18 0700 44697.4 2713 21l 270 218.2
19 0700 40451:5 2453 "182•' .`%233
20 0700 51044.8 140 2321 246 326 219.9
21 0700 45831.6., 2 2369' 21-5 ` 208;9_
22 0700 1 35280.71 2158 177 298 199.3
23 0700- 42772:2 -2024 204 . ' 457 21TI
24 0700 32310.5 2319 158 384 180.0
25 0700 39898.6: _ j40- 2118 208' 367 182.2
26 0700 42878 2758 225 332 192.5
. ..
27 0700 48699.7 ..: =- ,2540 ,. 243'' ',' 413 176:4
28 0700 41464.6 2183 198 424 230.4
29 0700 ` 31732.E 177:6
30 0700 1 31533.91 2180 151 312 186.0
31 0700' 3252E 12328, 156' 344' 20242' ,
Average 0.59 59539 154 2297 277 522 202.3
Maximum . 0.59 520652 200' 2796_ :2266:•
Minimum 0.59 25367.9 140 1838 124 233 174.7
Comp(C)/Grab.(G) C �,.C... n' ,. -: _ .'G;� .:. C • .777 -
Monthly Limit 1556.9

NPDES No.: NC 0000272 IDIscharge No.: 001 Month: October Year: 2004
Facility Name: Blue Ridge Paper Products Inc. I County:Haywood
ORC:John J. Pryately
Person(s)Collecting Samples:Operators on Duty
Effluent Chronic Toxicity
THP3B
Y
� U
U —
o H
N V
O 9 O
o cti
HRS NOEL
2
5
6
7_
8 - -
9,
' 1
10
11
12
13
14
16
17 '
18 -
20
21
22 11:00 100
24
25 -
26 -
27' .. h.
IT
28
•P9
30
• .. is
Avera a 100
Maximum' 100
Minimum 100
Comp(C)/Grab'(G) C
f4 Y
Monthly Limit >=90

Pace Analytical Services,Inc.
ace Analytical® 2225 Riverside N d 28804
Asheville,NC 28804
Phone.[phone]
ffiuent Aquatic Toggify Apo Form/Phase II Chronic Ceriodaphnia Fax:[phone]
Facility Blue Ridge Paper Products NPDES#:NC 0000272 Pipe# County Haywood
Laboratory Pa ormi Test PACE Analytical Services,Inc, Comments:
ZIA
Si turaef0 bring nsi me ionaW iLa Suoe or
Test Stang a End oats Start Time End Tme
Sample Information Sample 1 S'mple Control 10\20104 m(2no4 15:25 12:00
Collection Start DateU24.75hr
21\04 JMInformation•
Start Renewt Renew2 Start Renew? Renev2
Grab Treatment too % 100 % 100 % Control Control Control
Composite(Duration) 4hr pH Initial 8.0 8.1 7.7 7.3 7.5 7.5
.Hardness(mg/L) 31 pH Final 7.9 7.9 8.0 7.4 7.6 7.7
Spec.Cord.(µmhos/cm) 2380 2050 147 D.O.Initial 7.8 7.5 7.7 8.0 7.6 7.5
Chlorine(mg/L) <0.1 <0.1 D.O. Final 7.7 7.6 7.5 7.8 7.5 7.3
Sample Temp.at Receipt 2.6 C 1 2.5 C 11111111111111 Temp.Initial 25.3 24.9 25.6 24.7 1 5.5 24.8
Temp.Final 243 24.9 25.0 24.8 1 24.9 25.0
Organism# Chronic Test Results
1 2 3 4 5 6 7 8 9 10 11 12 mean Final Control Mortality % 0
Control #Young 22 27 8 1 31 26 21 1 26 22 31 1 28 NA NA 24.2 % Control with 3rd Brood 90
Adult
(L)ive(D)ead L L L L L L L LL I L I L I NA NA Control Reproduction CV 27.7
1 2 . 3 4 5 6 7 8 9 10 11 12 mean 48 Hour Mortality
w
#Young
Efflu4e5nt% � 28 21 29 29 25 22 28 24 24 23 NA NA 25.3 0 0 10 0 0 10
Adult %Red ••
(L)ive(D)ead L L L L L L L L L L NA NA 0.0 Significant? No
Final Mortality Significant R no coot.
1. 2 3 4 5 6 7 8 9 10 mean % x
#Young Reproduction Analysis:Effl 75 t% 21 29 27 26 25 23 27 24 25 30 25.7
Adult %Red
(L)Ive(D)ead L L L I L I L I L I L I L L L 0.0 Reproduction LOEC= >100 % : NOEC= 100%
1 2 3 4 5 6 7 8 9 10 mean Method: Steel's Many One Rank
#Young
Effluent% 29 26 23 1 31 1 26 23 1 28 25 26 23 26.0 Normal Distrito? Yes Method: Kolmogorov D
Adult %Red
90 tL)ive(D)ead L L L L L L L L L L 0.0 Statistic: 0.889 Critical: 1.035
1 2 3 4 5 6 7 8 9 10 mean Non-Parametric Analvsis of applicable):
Efflu� #Young 23 30 27 21 23 27 23 17 25 22 23.8 Method:
Adult %Red
95 (L)ivo(plead L L L L L L L L L L 7.7 E#luent% Rank Sum Critical Sum
1 2 3 4 5 6 7 8 9 10 mean 45 106.5 75.0
Effluent% #Young 22 21 25 26 24 24 20 24 23 22 23.1 75 106.5 75.0
Adult %Red
100 (L)ive(D)ead L L I L L I L L L I L L L 4.5 90 110.5 75.0
95 97.5 75.0
MAIL ATT:Environmental Sciences Branch Should use highest test 100 88.5 75.0
Div.of Water Quality concentration or highest
TO: N.C.DENR concentration with D.C. mg/L Overall Analysis:
Result=PASS/FAIL or
1621 Mail Service Center •• vs Reduction from control 0 Test LOEC= >1 % ; NOEC= 100.0
_ Chronic Value 0 % ;
Raleigh,NC 27699-1621 Reproduction Mean
REPORT OF LABORATORY ANALYSIS
Asheville Certification IN This report shall not be reproduced,except in full, Charlotte Certification IDs
NC Wastewater 40 without the written consent of Pace Analytical Services,Inc. NC Wastewater 12
NC Drinking Water 37712 NC Drinking Water 37706
SC Environmental 99030 % SC 99006
n n,n nn rmn•n "/rrw1�rr° - -. ... ------

NPDES No.: NC 0000272 Discharge No.:001 Month: Oct. Year: 2004
Facility Name: Blue Ride Paper Products Inc. County: Haywood
ORC':John J.Pryately
Person(s)Collecting Samples:Operators on Du
Quarterly Effluent Testing
01092 01027 01147 01077
Y
V
O
U
E E
N �
E 'E
m E c m d 2
O U fn to
HR& ugn ugn ug/I - ugn
1 5
2
3 i` 5 ° ..... s ;
+
- w
6
a
10
u
12
13
r
�y
14
s
16
'17 _ :F i_ h3c.'J 4, 7
18 -
19
20 23:00 10 <1 <5 <2
1
22
23
x ..
24
71
26
,2Z 41 1F a,
26
29
- -
.a
30 _ --
315, 1A,
Average 10 <1 <5 <2
Maxlmuro, 10 <1
Minimum 10 <1 <5 <2
Comp,(C)/Grab((3)` C C il;L> C; . . 77
M ... s.._._:
Limit 10.6 ug/I

NPDES No.: NC 0000272 Discharge No.:002 Month: Oct. Year: 2004
Facility Name: Blue Ridge Paper Products Inc. Coun : Haywood
ORC:John J. Pryately
Person(s)Collecting Samples:Operators on Duty
Pine Bleach Plant Effluent
34316 84103 38691 73054 73037 51024 34041 51022 73089 1346211 38700 73050 73047 77770 39032
0
0 0 t
_ •� 7 � L L O U O C
O p LL O O O O O O O O
Q Q C O 2 O O O O itl N t
T U V U U C U UO O d O
U FU FU y c
N O c0 m O L ~ .0
V LQ 11 N
Q r ll U t+J m .0 < N ItCIF
d.
HRS mgd Ib/day pg/I pg/I ugA ug/I ugA ugA ugA ug/I ugA ugA ugA ugA ugA ug/I
2
3 .
4
5 u _a
6 23:00 0.686 0.132
7 ,
8
9 . .
10
11 23:00 0.597 '0.192 "<10: <10; "_z2.1 ;<4.3 ;r<4.3. ', <21.- <2.1; ,"<21'_ <2.V <2.1' <4.3, '<4.3 -<2.1 , r<4:3 .
12
,13 _
14
15
16
17 ;
18 23:00 0.425 0.175
19 t'
20
'21 ..
22
23 .
24
25 23:00 �0.418 _0.24 ; , R
5 `S'n 0Y
26
27
28 =
29 x w
30
Average 0.185 <10 <10 <2.1 <4,3 <4.3 <2,1 <2.1 <2.1 <2.1 <2.1 <4.3 <4,3 .<2.1 <4.3
Maximum •,' - 0:24 <10 .,<10,. .'<2a <4.3. 'r;<4.3' '<2.1, .<2.1, ;<2'1 :<2:1:' '<2.1,; .<4.2 : <4.3=,.<2:1 , <43.
Minimum 0.132 <10 <10 <2.1 <4.3 <4.3 <2.1 <2.1 <2.1 <2.1 <2.1 <4.3 <4.3 <2.1 <4.3
Comp(C)/Grab(G)'y ` C C,rl C`_'"_C C °s C . '.C' C . :rC° C'; _C`s� ';:;C C_
<5.0 <2.5 <5.0
Limit 5.15 <10 31.9 <2.5 <5.0 <5.0 <2.5 <2.5 <2.5 <2.5 <2.5 <5.0

NPDES No.: NC 0000272 Discharge No.:003 Month: Oct. Year: 2004
Facility Name: Blue Ride Paper Products Inc. [County: Haywood
ORC:John J. Pryately
Person(s)Collecting Samples:Operators on Duty
Hardwood Bleach Plant Effluent
34316 84103, 30691 1 73054 73037 51024 34041 51022 1 73089 134621 3B700 73050 .73047. 77770 39032
p p 8 o s
V O V V V O O d a 0 d'
y
U c F vT! lO tUp > p>q O> L L O O O
UO O O O O. O
N O m' O O • O O O r O O O
m N o E ? O1� r N •O 10 L !O l0 L h L f0 `v v aC
9 FT
HRS mgd lb/day pg/l pgA _ug4 ugll ugA ugA- ugA ug4 ugA ugA ugA ugA. . -ugA - ug/1
2
3
4
6 23:00 1.345 0.063
. 7
8
y l
10
11, 23i00"=;M2t093 0:127 ' <10=', <�l0 <21, :<4:3-ti*�43 'F2:9 Pk2.j z2.ls • <2;1'% <2:1 ': <43 <4:3 <21 5k3'y;
12-43 6�
14
15 _ �_ �_ iv�` J` ♦ _' k .. 1. � r•�.e1 i � ...t ti�'� I�1 �_ �. x e A4"I<
16
17
18 23:00 1.917 0.116
20
21
22
23
24
­25 23100. <1,'469 ;0:098 .1 ' a '' �,' x 4 x
-'�� =r;
26
27
J k. ,
28
.29
30
31
Average 0.101 <10 <10 <2.1 <4.3 <4.3 <2.1 <2.1 <2.1 <2.1 <2.1 <4.3 <4.3 °<2.1 <4.3
Maximum''k "_ ., , 0:127' .;<i0> ,<1Q,,::t21 , -t4:3' ;<4.3.< <2-1 t <21„ tiro`<21> <21: -<21 ,•<430 ..<43
Minimum 0.063 <10 I <10 1 <2.1 <4.3 <4.3 <2.1 <2.1 <2.1 <2.1 <2.1 <4.3 <4.3 <2.1 <4.3
Comp(C)%Grab,(G). ;'-C C'd `r , C..` C Cz _ C.. ,_:G _;C . .x C ' . C 's C `rw 5
Limit 7.14 <10 31.9 <2.5 <5.0 <5.0 <2.5 <2.5 <2:5 72.5 <2.5 <5.0 <5.0 :<2,5 <5.0

Influent
NPDES No.: NC 0000272 Influent to WWTP Month: October Year; 2004 .
Facility Name: Blue Ride Paper Products Inc. County: Haywood
00310 00530 00080 00082
U U d
O � p N N W
N r
m E p A '�` w `o 6
O U m m 0
HRS HRS mg/L mg/L mg/L mg/L
1 ,.4 24 - 9600;-'. `1500 ��,267".. .
2 830 24 1 710.0 1600 296 2484
3 830.. 24_,• 1200:0,_ aA$70 244
4 730 24 660.0 470 256 2411
5 . �-.&o 24;.;.:
6 810 24 1 310.0 940 165 2433
-7,1 24.- ' . 320.0' , 920 ,. ?156. 1365 r` .. -',
8 820 24 300.0 820 147 2324
9 ,_820, 24 250 0
s7
10 825 24 250.0 540 264 1364
11 730n ..= 24 ._ .230.0 ;140. "318 :1135 =
12 740 24 340.0 340 258 1286
13 635 . ,. 24 300.0,
14 700 24 210.0 350 239 1 1051
'15` '745,, `=24 2806,` 380 ° `"�:,371 = �1'330 _ _
16 1020 24 320.0 1 490 329 1679
17. 700r "24 300.0•t "740 . _255 -2420; "
18 830 24 420.0 580 306 2128
19 '$59t_ _ 24, ; 420.0, 47C . 2464 1875�_
20 800 24 290.0 870 180 2480
21,, -745; 24 550.0'a; BYO, -1,91 � 1
22 815 24 440.0 470 226 1834
.23 " 83V 24_ 390 0 7,80 1'64' ,,1999;� , "p �` "- '•` . .._ k.
- n :
24 845 24 330.0 290 169 2047
25 .700 w 24-_'. 540 0 - ';370 s, . '.262,
26 815 24 276.2 540 331 1423
27 '730. "I"
28 700 . 24 1 296.4 190 173 984
29 , 820; . N-'- 321.7 430 259 2239;'
_ "-
30 845 24 410.4 870 179 2146
31 340 442.6.` . 600 .. .1248e.. '<2543'` ,s ..t wa•'r' rt,
Average 411.5 607 243 1906
Monthl .Maz 1200 0' i'600z:' ' 37,1 3620e�1 r r7777„,`fr, u
Monthly Min. 210.0 140 147 805
Sample,Type I C �wC.�_ .0 �rC,.x

NPDES No.: NC 0000272 Receiving Stream Month: October Year: 2004
Facility Name: Blue Ride Paper Products Inc. lCoun : Haywood
Stream: Pigeon River-UP
Location:Canton (River Mile -64.5
UPSTREAM
50050 00010 00300 31505 00080 00082 00095
Y d O
O
U m 0 € ¢
m
o
5 m 30 H `o `o o'
E LL r O LL o 0 0
U U U
HRS MGD °C mg/L H/100ml mg/L mg/L umhos/cm
1 925- 5920 1450 „8:64 32,70'
2 900 447.3 14.40 8.67 35.20
3 900' 440.8 . 16.00 _ 7:95 "- 31:00` `
4 645 394.9 13.50 9.33 32.70
5 '920, 359.4: 12.60 0.,15
6 1140 329.6 14.20 8.90 240 15 32 36.60
7 .840= - 30118 . 13.30; 9:38 Z--" • '36.608 905 276.0 12.30 8.7637.80
9 000 ' -260 5 13.60 : ': 8:8238:9010 905 248.2 13.70 8.8140.50
11 850 234:6 15.30 8180 _12 1010 224.3 15.00 9.02 30044.50
13 ' 615: :243:0• 15.60, i8.54 i19 "' 4760'
14 800 208.1 14.90 8.53 < 10 23 46.50
15 830<, ,` 194.5_ 12:70 ' '`` 9:41_ T y'42.40 ,
16 1105 175.2 11.80 9.42 44.40
17 815:` ' '165.5 .'11 90 9:07 %; , - ; 46:00
18 910 182.9 11.20 9.52 48.20
_19 1206.8,_ 1360 _6.69
20 830 192.6 13.20 8.58 < 10 17 32.00
21 ;'835 ' 176:4' -.'14.50 ' ' ' 9:53 = <�i0 - 18 3200--
22 900 168.0 15.20 8.77 34.60
23 . 930 - 161,6 , _ 1510. >' 8;62
24 945 159.0 14.90 8.71 35.70
25 _M .,152 5.' 14.56 8.92 ,170'
26 900 146.7 13.70 . 8.79 33.00
27 815.1" -144.1 '13 6D 8.71 11 24, >v 32 0,
-
28 730 142.8 15.90 8.14 12 29 36.40
29 900 190.T 1550" _•.: 'Z:94 „"'f 34.30,' .e ?
30 920 152.5 14.90 8.38 33.50
31 905' 140.9=- 15 20I,, 795 33.10
Average 239.1 14.1 1 8.72 280 11 24 37,41
Monthly Maz:: ' ,'592:08::`.1600 ' "_''' ' 9;53 r500i3" _1,5 A 32,
Monthly Min. 140.9 1 11.20 1 6.69 170 < 10 16 31.00

NPDES No.: NC 0000272 IDISCHARGE N0: Month: October Year: 2004
Facility Name: Blue Ride Paper Products Inc. Count : Haywood
Stream: Pigeon River-DN1
Location: Fiberville River Mile 62.9
DOWNSTREAM
00010 00010 00300 00300 00095 00090 000e2
UO {a O
m
U U a m F G
Al
N O. f m ttl fA (A
m m E zry 0 O 'm `o `o
p E ~ Om 0 O U U U
HRS °C °C I mg/L mg/L 1 umhos/c mg/L mg/L
1 9"40. 14 80 v 0.30. "9.42. Ak 129 _
2 915 15.10 0.70 9.24 9.24 174
3, T91'5 - t:, `15.60
4 830 15.30 1.80 9.16 9.16 147
5 '905 .14:90, 2 10
6 1050 14.40 0.20 9.03 9.03 151 14 67
7 855. , .,- _ .'14.00.• 0.70: n9:54- ..9.54.+
8 1 915 13.80 1.50 9.35 935 190
9 9];5 '8.78 $:78 .. 222
10 915 15.20 1.50 9.17 9.17 218
11 '905 16.50 229 -t`? ,z
12 1025 16.60 1.60 9.30 9.30 241
13 830` y 16:10' r0.60. "9'12 ? 9;12 " ° . ': ,208„
14 815 15.80 0.90 9.36 9.36 256 18 39
15 800 _r_ 14.30 '1,60f ,922- '+922 264, 1
16 1050 14.70 2.90 9.42 9.42 400
17 839 `. ._, ,
1280. ''I; 090: 1 01 , 11;b'i -; ,`405..
18 920 14.30 3.10 8.81 8.81 434
16,30 ' 2 70 "8i45 . .8i45' 379` '=_'"
20 840 15.70 2.50 9.59 9.59 312 21 40
21 845 17 20`� !2 70. 10 84_ ,`348 ,_ `24 :_5i '
22 845 18.20 3.00 8.49 8.49 326
:23 •900 ; 18 00` =: 2 90 :841 , 8':4'10+ NL. 3009a t; 4
24 915 17.60 2.70 8.38 8.38 332
25 730 17 30: s2 80; + 851„ ;8:51, 287. " `
�. ,
26 845 16.60 2.90 8.41 8.41 385
27. ,800 1670 '_'310;,. 8.44 8:44 j.k. i 370-, ""26k 66 >"
28 745 17.70 1.80 8.59 8.59 339 1 24 71
17.60: #27;
30 910 18.00 3.10 8.07 8.07 31 91:5 _18 10^ 2 90-- `8 64 8.64 ; _ r 4 .
Average 15.95 1.87 9.05 9.05 273 20 55
Monttl'.'[4ax 18 20. "3 10 6
Monthly Min. 12.80 70.40 8.07 8.07 98 14 36
Montfily_Uvilf, 13'9 --5, ,4 3 f t "'• ""

NPDES NO: NC 0000272 IDISCHARGE NO: MONTH: October YEAR: 2004
FACILITY NAME: Blue Ride Paper Products Inc. COUNTY: Haywood
STREAM: Pigeon River-DN2 STREAM: Pigeon River-DN5 .
LOCATION: Above Clyde (River Mile 57.7) LOCATION: Hepco (River Mile 42.6)
Downstream Downstream
00010 00300 00300 50050 00010 00300 00000 WOOD
m m m
m rn y a m o
x !- Q
m E U ate`' h-i o 0 5 E U o m e+ m d
F- LL nm d ¢ m w
N O N d U r�ii O
w N H m 0 U O O p
HRS °C mg4 mg4 HRS MGD °C mgA mgA mg4
1 1000!'t45.70- 8.90 .8.88' ;`* .''_ ., :1286z ?`
f .
2 930 15.70 8.50 8.47 1014.7
3 935, 100 8.30 ',8.28 975:9
4 900 15.70 8.34 8.30 885.5
5 940 e' .14,30, 8.85 8,81s
6 850 15.30 8.50 8.48 930 743.3 14.80 9.50 10 59
_7; ' 910_:' ,16:60 , 8.06 .8.02 945 ,;691:fi' r1500'. 888
8 935 14.60 1 8.71 8.68 652.8
9 '930'' '15.40' !8.04` 8.03' 625.fi
t
10 930 15.80 8.39 8.36 608.8
11 . 920'. 1710', .,8.22 _ 821,_ 586i9• ", 4''
12 1040 16.95 8.68 8.67 568.1
13 '`845' 16.85 ', 8.41' .-8.40 915„601,1; , 1710";905w', ,,14s,
14 830 16.00 8.74 8.73 830 557.1 13 35
15 815 15 20 _8 66 865_ 534r5 „y ';
16 1120 13.50 9.44 9.43 506.7
17 . 845" '12.40: .10591 '10.58 4854=, - "
18 935 13.70 6.40 6.36 485.4
19 . 1005;.'.15.50. `'6 61. %6.52,
20 855 15.50 8.83 8.79 920 570.7 14.80 9.22 20 85
21 -905 16.90` 9.22 , ;9;';f9 e .; 930--, 5028 = 14S^ 34
22 915 17.30 9.07 9.06 480.2
23 -915 17.10; * 896 8.95 ::';
24 930 17.10 8.82 8.81 457.6
25 800:,`.16.90 _.'8 95
26 915 16.40 8.66 8.64 435.6
27, 830i; 16.20 '861 8,60 ,`; ' 850 43]7', 15.8'0', -929 ,'ll ,t'8% X33:. "-
28 800 17.60 7.67 7.65 820 427.2 19 34
29 . .930,; _17 50'.
30 940 17.20 7.99 7.94 402.7
31 930'_ 17.40' _Z 93 7:91f1
Average 15.99 8.49 8.47 606.0 15.50 9.19 15 46
MonPN Max�ri urn. 17.60 't10.59 1'Ot58 , ,1288 2 417.10' '9 50 •20', „ 85 -
Morally Minimum 12.40 6.40 6.36 367.1 14.80 8.88 10 33
77

NPDES NO: NC 0000272 DISCHARGE NO: MONTH: October YEAR: 2004
FACILITY NAME:Blue Ride Paper Products Inc. COUNTY: Haywood
STREAM: Pigeon River-DN6 STREAM: Pigeon River-BC
LOCATION: Above Big Creek (River Mile 26) LOCATION: Mouth Big Creek (River Mile -26)
Downstream Downstream
00000 00082 0000o 00002
m m U m o� m rn E U m a m rn
:e E ¢m am ni- n'-
O F o y m N v H o N m N m
HRS mg/I mgfl HRS mg4 mgA
3 k ma e ^.-
4
5 e a
6 1000 ' 25 85 a 1005 < 10 _. < 10
7 1030' ,21 ,: ` 71 _ 1035 <;10 " < 10 8
10
12 —
;13 945 . 13, 36 ;950 < 10�µ t`C"10
_ .
14 1 945 1 12 21 950 < 10 < 10
15 ;,
Ile
16
17 a,.
18
r;t g ka 6wr n g-
20 945 15 56 1 1 950 < 10 < 10 -
21 ; 955-• ` 14 47 t, ;, „ 1000 <;10 `< 10 *..,:. s7`sra
22
24
25
26
27 9251 '_-03 1 ` .37
a
28 855 1 13 36 850 < 10 < 10
29
w r 4:' � _ r _ � ..sa 2
30 :
,.._
averaeo 16 49 < 10 < 10
v 25 85 a x {
`ManN MBxmwm' — - - .A'`" �'- <J10� n10' L•�' tf r ".':�:
MonthHMmiMM 12 21 < 10 < 10
Monthly MmO ii _ :s x�a1 a r _ ♦ r
PD-Powerhouse Down

NPDES NO: NC 0000272 DISCHARGE No: MONTH: October YEARN 2004
FACILITY NAME: Blue Ride Paper Products Inc. COUNTY: Haywood
STREAM: Pigeon River-:DN7 STREAM:
LOCATION: 1.40 Bridge (River Mile 24.7) LOCATION:
Downstream Downstream
00010 00300 00090 NOV
�e m
i3 v � 6 0j u
m m n O c> o
m E E
N� ~
U
2 Q N n o
e ' � o U`o m a
O ZI
0 U U w
HRS- °C mgA mg/I mgq mgll HRS
_
2 _
r..R'
4
3i
6 1015 16.2 8.87 22 77 —
7 -,1045' :16.0 9.47 20; B8 `
8
10
d x
12
13r. ' 1005. 16.7 'r8:22+ Ut,,13 '_ 32'`'''
14 1015 1 14 30
16
17 r
19
20 1005 15.3 8.80' 12 47
21 .1,010"' ,; 13. . •34;- ; 15
22
I
r ••a. p .Y S_ "x ly•• a A 4.• f _: Flkr 5 T•' .fir'-S .[Ys T..nV�'$'
24
26
27 .1015'` 16:1 - 8 32'h 14 ^' •34; . s µ,14 rt
28 905 14 35
29 nh i +4r:f' r •'..� 1:.a 9 3 F.n.x f .4 _ t'.^rv+' .. } Y,_hs'r:
30
31
.mge 16.1 8.74 15 45 -17
pt*Maximum'._ ; 16.7 + , e_ 9.471 .+ 22 77, "� d ' > `>-t r 't'
Momh? mWmum 15.3 8.22 " 12 30

NPDES No,: NC 0000272 Discharge No.: 001 Month: October Year: 2004
Facility Name: Blue Ridge Paper Products Inc. I County:Haywood
ORC:John J.Pryately
Persons Collecting Samples:Operators on Du
QA / QC DATA SPECIFICATIONS
0
0
U O
d
O O
U m
v c
a, m
m �
m U
oI m `o
mg/L
2
- ft
4
6
7
8
t
9 dr t'
10
11
12
13 :, „
14
16 _..
17 ;t
18
19 h4 tf ,k
20 —
21
3 � C.
22
23 0
24
25. �g
26
`27
28 x
29
77 ,
30
31
e 4i

W ATF
Michael F.Easley,Governor
�0 G William G.Ross Jr.,Secretary
h r North Carolina Department of Environment and Natural Resources
1 �
p -'C Alan W.Klimek,P.E.Director
Division of Water Quality
November 10, 2004
Mr.Paul Dickens, Manager
Environmental Affairs
Blue Ridge Paper Products
PO Box 4000
Canton,North Carolina 28778
Subject: CRP Color Report
Extension Request
Blue Ridge Paper—Canton Mill
NPDES Permit No.NC0000272
Haywood County
Dear Mr. Dickens:
The Division of Water Quality staff have reviewed your request for an extension of the Part I, Condition
A.(8).9 stipulation of the subject NPDES permit. This condition requires that Blue Ridge Paper Products
evaluate color reduction technologies associated with the Chloride Removal Process waste stream with a report
of the findings submitted to the Division of Water Quality by December 1, 2004. This stipulation also requires
that the DWQ's recommendation on the report be submitted to the NPDES Committee by February 1, 2005.
Due to the back-to-back flooding events occurring at the mill in September 2004, the Division is willing
to extend the due date of the subject report until April 1,2005. It should be noted that this date extension does
not change any other compliance date requirements of the Permit.
If you have any questions concerning this matter,please do not hesitate to contact Mr. Forrest Westall or
Mr. Keith Haynes of our Asheville Regional Office at 828-296-4500.
Sincerely,
Alan W. Klimek, P.E. D E a pp E
xc: Dave Goodrich NOV 1 2 2004
�ARO�
Don Anderson WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
N"0o�`ttCarolina
dVaturn!!�
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 Phone[phone] Customer Service
Internal.h2o.encstate.nc.us 512 N.Salisbury St. Raleigh,NC 27604 FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

BLUE RIDGE
PAPER PRODUCTS INC.
10 November 2004 CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 1667
Forrest R. Westall, PE
Water Quality Regional Supervisor
North Carolina Department of Environment to
And Natural Resources D U D
Division of Water Quality
2090 US Highway 70 NOV 1 2 2004
Swannanoa, NC 28778
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
Subject: NPDES NC0000272
October 2004 Monthly Average BOD Excursion
Wastewater Treatment Plant Recovery from Floods
Blue Ridge Paper Products, Inc.
Canton,NC
Dear Forrest,
This is the 5-day written report required to notify your office of an excursion.. We previously
notified your office of a maximum day BOD excursion that occurred on 10/4/04. The monthly
secondary effluent average BOD for October 2004 was 4039 lbs/day. The permit monthly
average BOD limit is 3205 ibs/day. Paul Dickens of Blue Ridge Paper notified Keith Haynes via
telephone on 11/9 concerning the October BOD result.
The elevated monthly BOD for October was a result of the unexpected process and wastewater
treatment upset that occurred during restart of the Blue Ridge Paper Products mill following the
September 2004 floods. The upset led to an elevated color discharge between 9/29 and 10/2 and
to elevated effluent BOD concentrations during the first week of October. We notified Keith
Haynes via telephone and with follow-up written reports concerning these events. The treatment
plant quickly recovered from upset conditions. Color and effluent BOD performance since the
first week of October have been good. The secondary effluent average BOD for the 21-day
period from 10/8 thru 10/31 was 2127 lbs/day.
During the week of 10/18 we completed the effluent toxicity test that was lost in September 2004
due to the floods. The toxicity sample was split with DENR. The results were good and passed
at all waste concentrations.
175 Main Street • PO Box 4000.
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

Forrest Westall, NC'DENR DWQ
10 Nov 2004, Page 2
Blue Ridge Paper is making great progress towards restoring our on-site wastewater lab that was
destroyed in the September floods. We resumed running BOD samples in our own lab on 10/26.
BOD data for the last week of October 2004 is the average between our in-house results and
results from PACE labs.
We greatly appreciate DENR's help and understanding with the flood recovery efforts.
Sincerely,
John J. Pryately Paul S. Dickens
Operator in Responsible Charge Manager,Environmental Affairs
828-646-2480 828-646-6141
pryatj @blueridgepaper.com dicket)@blueridgepaDer.com
JJP/PSD/s
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

BLUE RIDGE MAR — 2 2005 D PAPER PRODUCTS INC.
March 1, 2005 WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 1872
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Attn: Central Files
Re: NPDES NO. NC0000272
Best Management Practices 2004 Annual Report
Blue Ridge Paper Products, Inc.
Canton, NC
Please find attached two copies of the data summary of Best Management Practices (BMP)
daily monitoring for Blue Ridge Paper Product's Inc., Canton Mill. This submission is required
by Special Condition A.(6.) Best Management Practices, Section E4 and Section F1, of the
mill's NPDES Permit No. NC0000272.
The Canton Mill's BMP Plan specifies that investigative action will be performed when the
Primary Influent Lower Action Level of 70,322 Ibs/day of True Color is exceeded for two
consecutive days. Investigative action was conducted for the eight Lower Action Level
exceedances in 2004, listed below.
Date Primary Influent Color
16-May-04 86,817
17-May-04 96,151
18-May-04 91,197
09-July-04 79,766
10-July-04 74,131
11-July-04 80,382
29-Aug-04 115,384
30-Aug-04 77,596
05-Sep-04 72,923
06-Sep-04 78,218
07-Sep-04 73,124
15-Sep-04 70,446
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

01 Mar 2005, Page 2
16-Sep-04 70,883
23-Sep-04 102,125
24-Sep-04 107,500
29-Sep-04 163,509
30-Sep-04 194,320
24-Dec-04 86,131
25-Dec-04 73,097
The Canton Mill's BMP Plan specifies that investigative and corrective action will be performed
when the Primary Influent Upper Action Level of 78,609 Ibs/day of True Color is exceeded for
two consecutive days. Investigative and corrective actions were conducted for the three Upper
Action Level exceedances in 2004, listed below.
Date Primary Influent Color
16-May-04 86,817
17-May-04 96,151
18-May-04 91,197
23-Sep-04 102,125
24-Sep-04 107,500
29-Sep-04 163,509
30-Sep-04 194,320
The Canton Mill's BMP Plan specifies that immediate investigative and corrective action will be
performed when the Primary Influent Out-of-Control Level of 92,734 Ibs/day of True Color is
exceeded for one day. Investigative and corrective actions were conducted for the nine Out-of-
Control Level exceedances in 2004, listed below.
Date Primary Influent Color
14-Jan-04 112,818
14-Mar-04 146,684
22-Mar-04 107,786
17-May-04 96,151 (also counted in Upper Action Level, above)
29-Aug-04 115,384
23-Sep-04 102,125 (also counted in Upper Action Level, above)
24-Sep-04 107,500 (also counted in Upper Action Level, above)
29-Sep-04 163,509 (also counted in Upper Action Level, above)
30-Sep-04 194,320 (also counted in Upper Action Level, above)
A table of the BMP Action Level exceedances and corresponding corrective actions is attached.
Environmental Group
175 Main'Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

01 Mar 2005,Page 3
Please call us if you have any questions or concerns regarding this information.
Sincerely,
AL-5F�
Glenn Rogers Paul Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2874 828-646-6141
rogerci@blueridgei)aper.com [e-mail]
Attachment: 2004 BMP Action Level Exceedances and Corrective Action
cc:
CMr:D`Keith_Rgl ynes (w/attachments)
Environ' mental Specialist
North Carolina Department of Environment
& Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Internal Distribution:
C. File—Water
BMP Notebook
B. Williams
B. Shanahan
S. Single
J. Pryately
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

2004 BMP Action Level Exceedances and Corresponding Corrective Actions
NPDES No. NC 0000272
Blue Ridge Paper Products, Inc.
Canton, NC
Dates Primary Influent Color BMP/Non-BMP Corrective Action
During a scheduled maintenance outage,the excess Cyclone wash from #11 Recovery
Boiler was collected in the off line, spare clarifier and later fed into the system at a rate that
14-Jan-04 112,818 BMP was not disruptive to the Wastewater Treatment Plant.
A char fouling of boiler tubes led to high top end temperatures and an unplanned
shutdown of#11 Recovery Boiler. A recover boiler wash was required. Wash water was
diverted to the spare clarifier and treated with polyamine. BMP procedures were followed.
However, drain valve on spare clarifier had leak. Some high color material collected for
14-Mar-04 146;684 BMP treatment was lost back into influent lift station.
As the pine blow tower was being emptied during a scheduled maintenance outage, it was
discovered that the sump pumps servicing the area were plugged with fiber thus
preventing them from pumping the black liquor to collection tanks. The sumps were
washed with water and began to function again. Event was reviewed with operators with
22-Mar-04 107,786 BMP instructions to field verify operation of spill collection pumps during outages.
This elevated color resulted from a planned outage that involved maintenance on the Pine
16-May-04 86,817 Fiberline and#10 Recovery Boiler. Due to the extended nature of this outage, not all
17-May-04 96,151 material could be recovered. There was no detrimental impact on the Wastewater
18-May-04 91,197 BMP Treatment Plant.
Color event following successful 10-week outage of the Hardwood'Fiberline and #11
Recovery Boiler. An unintentional diversion of black liquor occurred as a result of the
09-July-04 79,766 failure of pumps to start when controls were switched from manual to automatic after
10-July-04 74,131 Non-BMP and completing planned maintenance activities. The pump control logic was fixed, and there
11-Jul -04 80,382 BMP was no detrimental impact on the Wastewater Treatment Plant.
BMP 2004 Report Data, BMP Summary Page 1 of 2 Printed 3/1/2005

A process upset occurred on the Pine fiberline during restart after an unplanned outage.A
brownstock collection pump failed to start and divert weak liquor to spill containment.
29-Aug-04 115,384 Non-BMP and Operators relied on control displays and did not field verify proper operation of pump.
30-Aug-04 77,596 BMP Root cause of event was reviewed with supervisors and operators.
05-Sep-04
06-Sep-04 72,923 74,131 There were no BMP events during this period. Color was elevated due to Sewer
07-Sep-04 80,382 Non-BMP Generated Color from the bleach plant effluent.
Restart of No. 10 Recovery Furnace on oil to complete cyclone wash in preparation for mill
15-Sep-04 70,446 restart after Frances flood outage of wastewater treatment 9/7 -9/11. The wash tank was
16-Sep-04 70,883 BMP full therefore diluted cyclone rinse was intentionally diverted to wastewater treatment.
Preparation for mill restart after Ivan flood outage of wastewater treatment 9/17-9/21.
Slow drained brownstock spill tanks and evaporator boilout tank to provide load to
23-Sep-04 102,125 wastewater treatment plant to rebuild biosolids inventory. Monitored 2-hr color loadings to
24-Sep-04 107,500 BMP mill to insure no adverse impact on treatment.
Elevated color due to the unexpected process and wastewater treatment upsets during
pulp mill startup following the Sept 2004 floods. Weak liquor intentionally diverted to
sewer after process failure filled all available storage tanks. Control system malfunction
resulted in heavy black liquor spill to sewer. No. 1 Clarifier was damaged by Ivan flood
29-Sep-04 163,509 and was not available for spill diversion. These were events during non-standard
30-Sep-04 194,320 BMP operating conditions. Detailed BMP documentation for post-flood mill restart is on file.
24-Dec-04 86,131 There were no BMP events during this period. Sewer generated color related to washing
25-Dec-04 73,097 Non-BMP problems in Pine bleach plant. Excess EO and D1 filtrates balance were sewered.
BMP 2004 Report Data, BMP Summary Page 2 of 2 Printed 3/1/2005

BLUE RIDGE MAR - 9 2005 D
PAPER PR INC.
March 1, 2005 WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 1872
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Attn: Central Files
Re: NPDES NO. NC0000272
Best Management Practices 2004 Annual Report
Blue Ridge Paper Products, Inc.
Canton, NC
Please find attached two copies of the data summary of Best Management Practices (BMP)
daily monitoring for Blue Ridge Paper Product's Inc., Canton Mill. This submission is required
by Special Condition A.(6.) Best Management Practices, Section E4 and Section F1, of the
mill's NPDES Permit No. NC0000272.
The Canton Mill's BMP Plan specifies that investigative action will be performed when the
Primary Influent Lower Action Level of 70,322 Ibs/day of True Color is exceeded for two
consecutive days. Investigative action was conducted for the eight Lower Action Level
exceedances in 2004, listed below.
Date Primary Influent Color
16-May-04 86,817
17-May-04 96,151
18-May-04 91,197
09-July-04 79,766
10-July-04 74,131
11-July-04 80,382
29-Aug-04 115,384
30-Aug-04 77,596
05-Sep-04 72,923
06-Sep-04 78,218
07-Sep-04 73,124
15-Sep-04 70,446
_Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

01 Mar 2005, Page 2
16-Sep-04 70,883
23-Sep-04 102,125
24-Sep-04 107,500
29-Sep-04 163,509
30-Sep-04 194,320
24-Dec-04 86,131
25-Dec-04 73,097
The Canton Mill's BMP Plan specifies that investigative and corrective action will be performed
when the Primary Influent Upper Action Level of 78,609 Ibs/day of True Color is exceeded for
two consecutive days. Investigative and corrective actions were conducted for the three Upper
Action Level exceedances in 2004, listed below.
Date Primary Influent Color
16-May-04 86,817
17-May-04 96,151
18-May-04 91,197
23-Sep-04 102,125
24-Sep-04 107,500
29-Sep-04 163,509
30-Sep-04 194,320
The Canton Mill's BMP Plan specifies that immediate investigative and corrective action will be
performed when the Primary Influent Out-of-Control Level of 92,734 Ibs/day of True Color is
exceeded for one day. Investigative and corrective actions were conducted for the nine Out-of-
Control Level exceedances in 2004, listed below.
Date Primary Influent Color
14-Jan-04 112,818
14-Mar-04 146,684
22-Mar-04 107,786
17-May-04 96,151 (also counted in Upper Action Level, above)
29-Aug-04 115,384
23-Sep-04 102,125 (also counted in Upper Action Level, above)
24-Sep-04 107,500 (also counted in Upper Action Level, above)
29-Sep-04 163,509 (also counted in Upper Action Level, above)
30-Sep-04 194,320 (also counted in Upper Action Level, above)
A table of the BMP Action Level exceedances and corresponding corrective actions is attached.
' �
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

01 Mar 2005, Page 3
Please call us if you have any questions or concerns regarding this information.
Sincerely,
Glenn Rogers Paul Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2874 828-646-6141
rogerg @ blueridgegaoer.com dickep@blueridqel)al)er.com
Attachment: 2004 BMP Action Level Exceedances and Corrective Action
cc:
Mr. D. Keith Haynes (w/attachments)
Environmental Specialist
North Carolina Department of Environment
& Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Internal Distribution:
C. File—Water
BMP Notebook
B. Williams
B. Shanahan
S. Single
J. Pryately
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

2004 BMP Action Level Exceedances and Corresponding Corrective Actions
NPDES No. NC 0000272
Blue Ridge Paper Products, Inc.
Canton, NC
Dates Primary Influent Color BMP/Non-BMP Corrective Action
During a scheduled maintenance outage,the excess Cyclone wash from #11 Recovery
Boiler was collected in the offline, spare clarifier and later fed into the system at a rate that
14-Jan-04 112,818 BMP was not disruptive to the Wastewater Treatment Plant.
A char fouling of boiler tubes led to high top end temperatures and an unplanned
_ shutdown of#11 Recovery Boiler. A recover boiler wash was required. Wash water was
diverted to the spare clarifier and treated with polyamine. BMP procedures were followed.
However, drain valve on spare clarifier had leak. Some high color material collected for
14-Ma'-04 146,684 BMP treatment was lost back into influent lift station.
f6 As the pine blow tower was being emptied during a scheduled maintenance outage, it was
discovered that the sump pumps servicing the area were plugged with fiber thus
preventing them from pumping the black liquor to collection tanks. The sumps were
washed with water and began to function again. Event was reviewed with operators with
22-Mar-04 107,786 BMP instructions to field verify operation of spill collection pumps during outages.
This elevated color resulted from a planned outage that involved maintenance on the Pine
16-May-04 86,817 Fiberline and#10 Recovery Boiler. Due to the extended nature of this outage, not all
17-May-04 96,151 material could be recovered. There was no detrimental impact on the Wastewater
18-May-04 91,197 BMP Treatment Plant.
Color event following successful 10-week outage of the Hardwood Fiberline and#11
Recovery Boiler. An unintentional diversion of black liquor occurred as a result of the
09-July-04 79,766 failure of pumps to start when controls were switched from manual to automatic after
10-July-04 74,131 Non-BMP and completing planned maintenance activities. The pump control logic was fixed, and there
11-Jul -04 80,382 BMP was no detrimental impact on the Wastewater Treatment Plant.
BMP 2004 Report Data, BMP Summary Page 1 of 2 Printed 3/1/2005

MAR -7 05

A process upset occurred on the Pine fiberline during restart after an unplanned outage. A
brownstock collection pump failed to start and divert weak liquor to spill containment.
29-Aug-04 115,384 Nan-BMP and Operators relied on control displays and did not field verify proper operation of pump.
30-Aug-04 77,596 BMP Root cause of event was reviewed with supervisors and operators.
05-Sep-04
06-Sep-04 72,923 74,131 There were no BMP events during this period. Color was elevated due to Sewer
07-Sep-04 80,382 Non-BMP Generated Color from the bleach plant effluent.
Restart of No. 10 Recovery Furnace on oil to complete cyclone wash in preparation for mill
15-Sep-04 70,446 restart after Frances flood outage of wastewater treatment 9/7-9/11. The wash tank was
16-Sep=04 70,883 BMP full therefore diluted cyclone rinse was intentionally diverted to wastewater treatment.
L -
;� Preparation for mill restart after Ivan flood outage of wastewater treatment 9/17-9/21.
Slow drained brownstock spill tanks and evaporator boilout tank to provide load to
23-Sep-04 102,125 wastewater treatment plant to rebuild biosolids inventory. Monitored 2-hr color loadings to
24-Se -04 107,500 BMP mill to insure no adverse impact on treatment.
Elevated color due to the unexpected process and wastewater treatment upsets during
pulp mill startup following the Sept 2004 floods. Weak liquor intentionally diverted to
sewer after process failure filled all available storage tanks. Control system malfunction
resulted in heavy black liquor spill to sewer. No. 1 Clarifier was damaged by Ivan flood
29-Sep-04 163,509 and was not available for spill diversion. These were events during non-standard
30-Sep-04 194,320 BMP operating conditions. Detailed BMP documentation for post-flood mill restart is on file.
24-Dec-04 86,131 There were no BMP events during this period. Sewer generated color related to washing
25-Dec-04 73,097 Non-BMP problems in Pine bleach plant. Excess EO and D1 filtrates balance were sewered.
BMP 2004 Report Data, BMP Summary Page 2 of 2 Printed 3/1/2005

BLUE RIDGE
PAPER PRODUCTS INC. APR - 1 2005 i L/ ;
Certified Mail
Return Recei GRe este VATER QUALITY SECTION
7099 3220 0007 19119 ASHEVILLE REGIONAL OFFICE
31 March 2005
Mr. Alan W. Klimek,P.E.
Director
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617�Mail Service Center
Raleigh, NC 27699-1617
Subject: Chloride Removal Process - Color Reduction Technology Assessment
NPDES Permit No. NC0000272
Blue Ridge Paper Products Inc.
Canton,North Carolina
Dear Mr. Klimek:
Enclosed are two (2) copies of the subject report in accordance with Part I, Condition A.8.1 of
the NPDES permit. The original submittal date for the report was December 1, 2004. The
Division of Water Quality extended the due date to April 1, 2005 due to the floods of September
2004 that impacted the Blue Ridge Paper Canton Mill. A copy of the extension letter is attached.
The report documents evaluation of technologies for removal of color from the Chloride
Removal Process (CRP) purge stream. The report includes specific technologies identified in
the NPDES permit as well as other technologies identified by Blue Ridge Paper.
At this time, Blue Ridge Paper has not identified any technologies that are technically,
economically or operationally feasible for color reduction in the CRP purge stream.
Please contact us if you have any questions.
Sincerely,
?a �w
you
Paul S.Dickens Robert V. Williams
Manager, Environmental Affairs Director, Regulatory Affairs
828-646-6141 828-646-2033
dickep@bluerid¢epaper.com [e-mail]
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Alan W. Klimek, NC DENR DWQ
31 March 2005, Page 2
Attachment: 10 Nov 2004 Letter from Alan Klimek, NC DENR DWQ
Enclosure: CRP Color Reduction Technology Assessment Report(2 copies)
cc: (w/encl): Dave A. Goodrich
Environmental Supervisor
Point Source Branch
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
D. Keith Haynes
Environmental Specialist
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Don Anderson
US Environmental Protection Agency
Office of Water
Office of Science and Technology (4301 T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Internal Distribution:
C. File Water
Engr File_CRP Color Studies
B. Shanahan
S. Single
M. Ferguson
K. Hennessy
D. Brown
P. Geoghegan
R. Medford
C. Dowdle
D. Brown
J. Pryately
L. Cooper
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

V� NA r'FR Michael F.Easley,Governor
William G.Ross Jr.,Secretary
pj North Carolina Department of Environment and Natural Resources
Alan W.Klimek,P.E.Director
- Division of Water Quality
November 10, 2004 IRIE C V� E
Mr.Paul Dickens,Manager D .
NOV �15 2004
Environmental Affairs
Blue Ridge Paper Products
PO Box 4000 BLUE RIDGE PAPER PRODUCTS INC
BHS DEPARTMENT
Canton,North Carolina 28778
Subject: CRP Color Report
Extension Request
Blue Ridge Paper—Canton Mill
NPDES Permit No.NC0000272
Haywood County
Dear Mr.Dickens:
The Division of Water Quality staff have reviewed your request for an extension of the Part I, Condition
A.(8).9 stipulation of the subject NPDES permit. This condition requires that Blue Ridge Paper Products
evaluate color reduction technologies associated with the Chloride Removal Process waste stream with a report
of the findings submitted to the Division of Water Quality by December 1, 2004. This stipulation also requires
that the DWQ's recommendation on the report be submitted to the NPDES Committee by February 1,2005.
Due to the back-to-back flooding events occurring at the mill in September 2004,the Division is willing
to extend the due date of the subject report until April 1, 2005. It should be noted that this date extension does
not change any other compliance date requirements of the Permit.
If you have any questions concerning this matter,please do not hesitate to contact Ivor.Forrest Westall or
Mr.Keith Haynes of our Asheville Regional Office at 828-296-4500. j
Sincerely, r&�k
Alan W.Klimek,P.E.
xc: Dave Goodrich
ARO
Don Anderson
Wcalltcarolina
)vatura11
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 Phone[phone] Customer Service
Intemet h2o.enr.state.nc.us 512 N.Salisbury St. Raleigh,NC 27604 FAX [phone] 1-877-6236748

E
APR - 1 2005
BLUE RIDGE ASWATER HEVILLE REGIONAL OFFICE
PAPER PRODUCTS INC.
Blue Ridge Paper Products Inc.
Canton Mill, Canton, North Carolina
Chloride Removal Process (CRP)
Color Reduction Technology Assessment
March 2005

March 2005 CRP Color Reduction Technology Report
Page ii
Executive Summary
This report outlines investigations on Chloride Removal Process (CRP) color reduction
technologies that Blue Ridge Paper Products Inc. has conducted to meet the requirements of the
2001 NPDES Permit. Specifically, the report reviews extensive efforts by Blue Ridge Paper to
evaluate and identify a viable color reduction technology for the CRP purge stream. The
investigations included literature reviews, vendor contacts, bench scale tests and field trials. In
addition to the four specific technologies identified in the permit, Blue Ridge Paper looked at
several additional technologies for removing color in the CRP purge stream. The table following
this summary outlines the technologies reviewed and the results.
It is essential in understanding the difficulty of treating the CRP wastewater to recognize that the
CRP purge is a resultant waste flow from a complex system that treats what is, in a typical pulp
mill, a "sewered" wastewater(that is, a discharge to the mill's wastewater treatment system).
The CRP along with the Minerals Removal Process (MRP) at the Blue Ridge Paper Canton Mill
forms the BFRm or"Bleached Filtrate Recovery" process. The BFR process allows the mill to
recycle a large portion of its "pine line"pulp bleaching wastewaters. In a typical pulp mill these
wash waters,which contain"color"from the processed wood pulp, are sent directly to the
wastewater treatment system. Much of the color in the wash waters from a typical pulp mill ends
up in the mill's treated discharge. At Blue Ridge Paper, BFR allows the mill to `reuse" these
wash waters and reduce the total color going to the treatment system. The CRP purge stream by
its very nature is a very concentrated, high chlorides material. A summary of CRP purge stream
characteristics is as follows:
Average CRP purge stream characteristics
Average flow 10 gpm (15,000 gpd)
Total inorganic carbon(TIC, as.carbonate) 30,500 mg/L
Total organic carbon(TOC) 6260 mg/L
Absorbable organic halides (AOX) 17.4 mg/L
Sodium(Na) 110,000 mg/L
Potassium(K) 22,200 mg/L
Conductivity 133,000 mmhos/cm
Chemical Oxygen Demand (COD) 19,100 mg/L
Sulfate (SO4-) 203,000 mg/L
Chloride(Cl-) 26,800 mg/L
Color(true filtered) 41,000 mg/L at 465 nm
pH 10.1
Total suspended solids 4020 mg/L
Total solids 33.5 percent
Total dissolved salts 360,000 mg/L
Temperature at discharge to mill sewer 165 degs F
This is clearly a very"difficult to treat" wastewater. In fact, as noted in many of the trials
documented in this report,just physically handling the CRP purge stream(pumping and placing
March 2005 CRP Report Final,doc

March 2005 CRP Color Reduction Technology Report
Page iii
the wastewater in tanks for treatment)proved challenging. Often the purge stream would "plug"
lines or crystallize as the temperature of the liquid dropped. These characteristics, and the
overall "treatability" issues associated with this wastewater,resulted in the EPA Technology
Review Workgroup (TRW) concluding that CRP treatment had a reduced potential for further
color reduction. The many trials, tests and evaluations outlined in this report confirm that
conclusion.
Investigations of technologies for CRP purge stream color reduction have failed to identify any
viable technology or combination of technologies that meet the NPDES Permit's test of
"technical, economic and operational feasibility." Blue Ridge Paper takes very seriously the
need to further reduce color in the Canton Mill's wastewater discharge and is fully prepared to
continue those efforts. The company took a very comprehensive look at treating the CRP purge
stream and evaluated not only the technologies identified in the permit condition, but many
more. At this juncture, Blue Ridge Paper cannot recommend implementation of any of the tested
technologies. The search for an effective CRP management strategy should continue, and the
company is committed to doing that in conjunction with mill-wide color reduction efforts.
Summary Table
The following table is a summary of the color removal technology assessment for the CRP purge
stream. The table lists both permit-specified and other technologies evaluated.
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 1
Introduction
Purpose
This report outlines investigations on CRP color reduction technologies that Blue Ridge Paper
Products Inc. has conducted to meet the requirements of the 2001 NPDES Permit. The original
due date for the report was December 1, 2004. However, Blue Ridge Paper and the Town of
Canton, North Carolina experienced back-to-back historic floods during September 2004. The
floods disrupted completion of CRP color investigation work. The Blue Ridge Paper Canton
Mill was down for 3 weeks during September 2004 because of the flooding. Work to fully
restore wastewater treatment operations and wastewater laboratory capability took the balance of
2004 to complete. In October 2004, Blue Ridge Paper requested an extension of the due date for
the CRP color reduction technologies report until April 1, 2005. The Division of Water Quality
(DWQ) of the North Carolina Department of Environment and Natural Resources (DENR)
approved the extension request on November 10, 2004.
Permit Requirement
The requirement of the 2001 NPDES permit for this study is specified in Section A.(8.),
Paragraph 9:
"By December 1, 2004*, the permittee shall evaluate color reduction technologies
associated with the Chloride Removal Process (CRP) wastestream. The CRP analysis
shall concentrate on the technical, economic and operational feasibility of implementing
the applicable technologies on all or a portion of the purge stream. The report shall
identify specific economic and implementation issues associated with the improvements.
The report shall also project the expected additional color redaction for each technology
evaluated and maximum color reduction possible using the identified technologies.
Though not limited to the following, the report shall include an analysis of the land
application of the high chloride wastewater, commercial incineration,
coagulant/precipitation technologies, and solidification for land disposal. The Division
of Water Quality (in consultation with the Technology Review Workgroup)shall evaluate
the feasibility of implementing identified technologies for further color reduction and
shall submit to the NDPES committee by February 1, 2005** the DWQ's
recommendations regarding color reductions associated with the treatment of the CRP
wastestream.
If during the course of this evaluation, Blue Ridge Paper identifies a technical, economic,
and operationally feasible color reduction technology that can be implemented for
treatment of the CRP wastestream, the permitte may request that the Technology Review
Workgroup review this technology for implementation at the Canton mill. If the
Technology Review Workgroup concurs that the identified technology is suitable for the
Canton mill and that the color reductions achievable are adequate, the mill's obligation
to research additional technologies will be waived after formal notification from Blue
Ridge Paper that the identified technology will be installed and placed into operation.
This notification shall include language indicating the permittee's commitment to the
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 2
implementation of the technology, along with a schedule for implementation. The
Division of Water Quality will notify the permittee in writing that the proposed
implementation schedule is acceptable."
* Due date was extended to April 1, 2005 due to September 2004 floods; see
10 Nov 2004 letter from Alan Klimek,NC DENR DWQ
** Since the submission date was extended by four months, the DWQ's submission
to the NPDES committee extends by four months to June 1,2005.
CRP Process Overview
The Bleach Filtrate Recycling (BFRTm) process is a pollution prevention technology unique to
Blue Ridge Paper Products' Canton Mill. It was originally implemented as a full-scale trial
demonstration project in 1995. Today, it has been converted to an integral part of the operations
at the Canton Mill. The BFR process is an important element of Blue Ridge Paper's
management of wastewater effluent color.
Recycling the bleaching filtrates has not been successful in the past at other mills because some
of the waste minerals, such as sodium, potassium, calcium, manganese, and magnesium, as well
as chlorides, interfere with the operation of the pulping,bleaching, and recovery operations.
Wherever these materials accumulate in the processes, they can impair process operation and
cause excessive corrosion damage to the process equipment. Another difficulty in recycling
bleaching wastes is that the dissolved lignin component can consume additional amounts of
bleaching chemicals, increasing bleaching cost and causing quality problems with final bleached
pulp and paper products. c
The basic concept of BFRm is to recycle the bleaching filtrates through the pulp-washing system
in the same manner that pulping and oxygen delignification filtrates are recycled. Wood
minerals and salts produced in the bleaching process are removed at strategic locations in the
bleach plant and in the chemical recovery process. This allows the bleached kraft pulp mill to
reduce discharge of colored effluents to mill sewers, reduce water usage in pulp bleaching and
washing operations, and reduce other chemical discharges from the mill.
The BFRTm process at Blue Ridge Paper recycles filtrates from the pine bleach plant only. There
are two distinct components of bleach filtrate recycling: the Minerals Removal Process (MRP),
associated with the pine bleach plant, and the Chloride Removal Process (CRP), associated with
the chemical recovery area. The MRP removes the calcium, magnesium, manganese, and other
hard water elements from the bleaching waste. The CRP removes the sodium chloride and
potassium from the recycled chemicals before they enter the recovery furnaces.
The Chloride Removal Process (CRP)treats a portion of the chemical ash (produced by burning
the lignin waste in the recovery furnaces) removing chloride and potassium. This ash, which is
later converted into active cooking chemicals, is where the chloride and potassium compounds
accumulate. A schematic diagram of the CRP process is presented in the following figure.
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 3
35
44
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March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 4
In the chemical recovery cycle, reclaimed spent cooking chemicals and lignin waste,known as
black liquor, are concentrated by an evaporation process. The concentrated black liquor is
burned as a fuel in the recovery furnaces to generate steam and electric power. The lignin and
other organic wood wastes burn off in the recovery furnaces. The ash, or smelt, remaining after
combustion contains the spent cooking chemicals, primarily sodium sulfate and sodium
carbonate. The smelt is removed from the bottom of the furnaces and dissolved in water to form
green liquor. The green liquor is chemically activated in the causticizing area. The reactivated
cooking chemical,known as white liquor, is sent to the pulp mill to be reused for cooking pulp.
Some of the ash that is produced in burning black liquor is carried out of the recovery furnace by
the flue gases produced by combustion. The Canton Mill has direct contact cyclone evaporators
on the recovery furnaces. These cyclones contact the flue gas with the incoming black liquor to
evaporate water from the liquor before combustion. Some of the lignin and other color material
from black liquor in the cyclones may also be carried out of the recovery furnace with fly ash.
This fly ash must be removed from the recovery furnace flue gas before the gases are exhausted
to the atmosphere. The flue gases pass through large wet-bottom, electrostatic precipitators that
remove fly ash from the gases.
Because of bleach filtrate recycling, the weak black liquor received by the chemical recovery
area from brown stock washing contains a higher percentage of sodium chloride salt than it
would in the conventional pulp bleaching process without filtrate recycling. The higher salt
content must be removed from the process to prevent corrosion of the recovery furnace
evaporator and boiler tubes and disruption of the recovery process.
The CRP takes advantage of the greater solubility of sodium chloride and potassium compared to
sodium sulfate. In a conventional chemical recovery process, fly ash from the electrostatic
precipitators is returned directly to black liquor to recover salts. In the CRP, fly ash from the
precipitators is dissolved in water instead of black liquor in the bottom of the precipitators. The
flow from the precipitators, now a salt solution instead of black liquor, is directed to a series of
three CRP evaporators instead of directly into the recovery furnaces.
The salt solution is introduced into the CRP evaporators with steam to evaporate a portion of the
water in the salt solution. Upon completion of the third evaporation stage, enough water has
been evaporated from the solution to cause the sodium sulfate to precipitate as salt crystals. The
sodium chloride and potassium remain in solution. A portion of the salt cake and salt solution is
continually pumped from the final evaporator stage to a filter system, which separates the
crystallized sodium sulfate "salt cake" from the liquid salt solution.
The sodium sulfate salt cake from CRP is mixed with heavy black liquor and returned to the
recovery furnace for chemical recovery. A portion of the salt solution containing concentrated
sodium chloride and potassium is also returned, and a portion is "purged" to control the
concentration and buildup of chloride and potassium in the chemical recovery and pulp cooking
liquors. The CRP purge stream is primarily salty water, but also contains a significant
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 5
concentration of color bodies. The CRP purge stream is the focus of the NPDES permit
requirement and of this report.
The technical feasibility of permit-specified technologies depends in large part on the chemical
composition and physical properties of the CRP purge stream. Average characteristics of the
CRP purge based on long-term monitoring by Blue Ridge Paper are listed below. The
temperature of the purge stream at the point of discharge to the mill sewer is about 74 degrees
Celsius (165 deg Fahrenheit). The design purge flow rate is 10 gpm or about 15,000 gallons per
day. This volume is 0.06 percent of the mill's average daily wastewater flow of 25 mgd. The
primary control method for chlorides and potassium in the chemical recovery cycle is to vary
CRP purge rate. As a result, the daily CRP purge stream flow can vary from the target of 10
gpm.
The CRP purge stream is best described as brine. Samples of the purge stream will crystallize at
varying temperature depending on salt concentration. Sometimes the sample will remain in
liquid form when cooled to room temperature and at other times the sample will crystallize after
it has cooled several degrees. Crystallized samples will re-liquefy when subjected to shear. The
CRP purge stream is diluted as it is added to the mill sewer to prevent crystallization and
plugging. The mill experiences occasional operating problems with plugging in the CRP process
from crystallization.
Average CRP purge stream characteristics
Average flow 10 gpm (15,000 gpd)
Total inorganic carbon(TIC, as carbonate) 30,500 mg/L
Total organic carbon(TOC) 6260 mg/L
Absorbable organic halides (AOX) 17.4 mg/L
Sodium(Na) 110,000 mg/L
Potassium(K) 22,200 mg/L
Conductivity 133,000 nunhos/cm
Chemical Oxygen Demand (COD) 19,100 mg/L
Sulfate (SO4=) 203,000 mg/L
Chloride(Cl") 26,800 mg/L
Color(true filtered) 41,000 mg/L at 465 nm
PH 10.1
Total suspended solids 4020 mg/L
Total solids 33.5 percent
Total dissolved salts 360,000 mg/L
Temperature at discharge to mill sewer 165 degs F
The potential contribution of the CRP purge stream to primary influent and secondary effluent
color was documented in the 2001 Color Removal Technology Removal Assessment Report:
Primary influent color attributed to CRP purge stream — 5000 lbs/day
Secondary effluent color attributed to CRP purge stream <23001bs/day (estimated)
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 6
The daily CRP purge stream flow rate can vary from 0 to 15 gpm (0 to 21,600 gpd) depending on
operating conditions and maintenance activities. The color contributions above are annual
average values based on the design CRP purge stream rate of 10 gpm(15,000 gpd). The
secondary effluent color attributed to the CRP purge stream is based on removal efficiency of
black liquor color in the Canton Mill's activated sludge treatment system. Color in the CRP
purge stream originates from black liquor in the recovery furnaces and is assumed to behave
similarly to black liquor wastewater treatment.
The average secondary effluent discharge for the Blue Ridge Paper Canton mill in 2004 was
41,463 lbs/day. The 23001bs/day contribution to secondary effluent color from the CRP purge
stream is 5.6 percent of the 2004 average color and is approximately 1/4 of the standard deviation
of the 2004 secondary effluent color. The small contribution of the CRP purge stream to
secondary effluent color creates problems confirming the effectiveness of technologies to
remove color in the CRP purge stream. It may not be possible to statistically confirm that
reductions in CRP purge stream color result in equivalent reductions in secondary effluent color.
Permit Specified Technologies
The 2001 NPDES permit specifies that Blue Ridge Paper evaluate the technical, economic and
operational feasibility of several specific technologies for treatment of the CRP purge stream
including land application, commercial incineration, coagulation/precipitation and solidification
for land disposal.
Land Application
Land application refers to the use of liquid wastewaters at agronomic rates for irrigation,
treatment and to recover beneficial nutrients. Microbes in the irrigated soil and vegetation
provide treatment. The liquid wastewater can be applied to forage grasses, food crops or
woodlands. Land application avoids direct discharge of wastewater to streams. The land-
applied wastewater moves through the soil and vegetation system, is "taken up'°,to a limited
degree by vegetation, is absorbed and "filtered"by the soil, is acted upon by microorganisms
present in the soil, and evaporates to some degree during periods of low humidity and sunlight.
The remaining "treated" water from land application is then indirectly discharged to streams
through surface runoff and groundwater. Treated municipal wastewater and some treated and
even untreated industrial wastewaters have been successfully land applied for many years.
Factors limiting the land application of wastewater are evaporation, accumulation of metals and
other pollutants in soils and vegetation, and the sensitivity of the irrigated vegetation to salts. Of
these factors, salt content is the limiting factor applicable to potential land application of the CRP
purge stream.
Blue Ridge Paper researched general design criteria for land application of wastewater. Principle
sources were Metcalf and Eddy, Wastewater Engineering, Third Edition and several state
agricultural extension service publications on the Web related to land application of organic
wastes. To be suitable for irrigation without restriction, wastewaters should have a chloride
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 7
content of less than 100 mg/L. Wastewaters with chloride contents greater than 350 mg/L are
not suited for land application to due vegetative effects and changes to the percolation
characteristics of the soil. Similarly, the conductivity of wastewaters for land application should
be less than 35,000 mmhos/cm and the total dissolved salt concentration should be less than 2000
mg/L. With a chloride content of 26,800 mg/L, a conductivity of 133,000 mmhos/cm and a total
dissolved salts content of 360,000 mg/L, the CRP purge steam cannot be land applied without
significant dilution.
Based on chloride content, the CRP purge would have to be diluted by a ratio of at least 270:1 to
be land applied at agronomic rates without restriction. With dilution water, the daily volume for
land application would be 4,050,000 gallons per day. At an irrigation rate of 48 inches.per year
(typical for southeastern forests under wastewater irrigation), a total of 1135 acres of suitable
land would be required. A 24-inch diameter pipeline to irrigation site would be required.
Assuming land was available, the design flow rate for transfer pumps, irrigation pumps and land
application equipment would be a minimum of 2800 gallons per minute. Land application
systems also require wet weather storage typically sized to hold 30 to 60 days of wastewater
production. A reservoir of 120 to 240 million gallons storage capacity would be required.
Conclusion of Land Application
Because of chloride salt content and associated technical and logistical issues, land application is
not a feasible technology for treatment and disposal of the CRP purge stream.
Commercial Incineration
Commercial incineration refers to off-site shipment of industrial waste for incineration in lime
kilns or dedicated waste incinerators. There are three reasons to incinerate an industrial waste:
• Off-set fuel use by recovering the heat content of the waste
• Destroy organic components in the waste
• Thermally recover valuable components of the waste.
The CRP purge stream originates from recovery furnace fly ash. It has essentially no heat value.
It has no constituents at concentrations economically attractive for recovery. The high chloride
content makes the purge stream very corrosive under combustion conditions. Incineration is not
an appropriate technology for the CRP purge stream.
To verify that incineration was not a viable option, Blue Ridge Paper requested a waste approval
and quote from Onyx Environmental for incineration disposal of the CRP purge stream. Onyx is
a commercial hazardous waste transportation and disposal company who matches industrial
wastes with appropriate recovery, recycling or disposal options based on technical, regulatory
and economic considerations. Onyx, in their own evaluation, confirmed that incineration is not a
technically appropriate or economically viable disposal option for the CRP purge stream. The
high chloride content and zero heat value of the purge stream would require blending with a
large volume of other more suitable waste before incineration. Quoted cost in December 2004
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 8
for commercial incineration disposal of the CRP purge stream is $0.46 per lb of liquid CRP
purge excluding transportation. The quote for off-site transportation to the incineration facility
in a 5000-gallon tanker is $3635 per load including tanker cleaning, rental and fuel surcharges.
Based on the Onyx Environmental quote, 15,000 gallons per day of CRP purge and 5000 gallons
per tanker load, the annual estimated cost for commercial incineration disposal of the CRP purge
stream is:
Incineration: 15,000 gpd x 8.5 lbs /gallon x $0.46/lb x 360 days /year = $21,114,000
Transportation: 3 loads/day x $3635/load x 360 days/year = $3,925,800
Total annual cost in excess of$25 million.
Off-site hauling of the CRP purge stream will require a truck loading facility and heated storage
tank. The estimated capital cost of a truck loading and storage facility for the CRP purge stream
is in excess of$150,000.
Conclusion on Commercial Incineration
Based on both physical and chemical characteristics and on commercial quotes, incineration of
the CRP purge stream is not an economically or operationally feasible technology.
Coagulation/Precipitation
Coagulation and precipitation is a method of removing color bodies from wastewater by adding a
flocculating chemical. The flocculating chemical works in one of two ways:
• change the zeta potential (electrostatic charge) of the color body particles allowing the
particles to agglomerate into larger particles that will settle out.
• form a large chemical precipitant floc that "sweeps"the color body particles out of
solution as the floe settles.
Any coagulation and precipitation technology for color removal generates sludge that requires
disposal as a solid waste. Sweep floc precipitation generates large volumes of sludge relative to
the volume of color body particles removed.
The 2001 Color Removal Technology Assessment Report examined secondary effluent color
removal by sweep floe coagulation and precipitation with alum and with lime. These chemicals
worked on the relatively dilute secondary effluent color. However,because of the volume of
secondary effluent flow, coagulation and precipitation technology was capital intensive with high
operating costs for chemicals and sludge disposal. The 2001 report concluded that this
technology was not appropriate for secondary effluent color removal.
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The focus of this report is color removal treatment of the concentrated CRP purge stream. Color
in the CRP purge stream originates from lignin in the black liquor ash. Coagulation and
precipitation of color in the CRP purge stream is removal of dissolved lignin in the liquid CRP
purge stream. The high dissolved salt content and high alkalinity of the CRP purge can interfere
with coagulation chemicals and the formation of floc.
RMT Study
Blue Ridge Paper retained RMT Consultants to perform bench scale screening trials of different
chemical coagulations for treatment of the concentrated CRP purge stream. The coagulants
tested were lime, aluminum salts, iron salts and polyamine. The RMT bench scale tests were
completed during January 2005.
The color removal target for the RMT study was 85%. That is, coagulation technologies were
not considered technically viable unless they could achieve an 85% or greater removal of color
from the concentrated CRP purge stream. The basis of 85%removal is effect on secondary
effluent color. A large reduction in CRP color will be necessary to see any corresponding
reduction in secondary effluent color. The 85% target equates to a potential 20001bs/day
removal of secondary effluent color attributed to the CRP purge stream.
None of the coagulation chemicals tried—lime, alum, ferric sulfate and polyamine—met the
85% color removal goal. Lime and alum are not technically feasible coagulants for the
concentrated CRP stream. Massive doses of chemical are required to achieve any color
reduction and the resulting sludge did not settle. Highest color removal by chemical coagulation
and precipitation was 77%. This was achieved with a combination of ferric sulfate and
polyamine. However, to obtain a floc, settling and color removal, the concentrated CRP purge
stream must first be acidified to neutral pH. Polyamine addition alone after pH adjustment
achieved only 66% color removal. Polyamine treatment of the concentrated CRP purge stream is
not desirable because the high doses required can potentially cause problems with wastewater
effluent toxicity.
During the bench scale trials, RMT collected 5-gallon grab samples of the CRP purge stream for
testing over a period of two days. RMT noted a large variability in the color concentration and
physical characteristics of these grab samples. The CRP color concentration in grab samples
doubled between the first and second day of testing. RMT also observed an increase in CRP
color during the day as the buckets of CRP sample sat in the lab between tests. Because of this
variability, chemical dose process control for coagulation/precipitation of the CRP purge may
be difficult. Color removal effectiveness in a full-scale system would vary. There is no
indication that color removal by coagulation/precipitation of the CRP purge stream will result
in an equivalent reduction of secondary effluent color.
RMT prepared chemical cost estimates for acidification of the concentrated CRP purge stream
followed by chemical coagulation and precipitation with ferric sulfate and polyamine. The
estimate assumes the design purge rate of 10 gpm. Chemical prices are based on commercial
quotes for bulk quantities.
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Projected annual chemical costs are:
Acid $175,000
Ferric Sulfate $ 28,000
Polyamine 77,000
Total chemicals $280,000
The RMT study did not include capital equipment or sludge disposal costs. Blue Ridge Paper
developed these cost estimates using EPA cost curves and other sources. The capital cost is in
excess of more than$1.7 million. This does not include the cost of special materials that may be
required to handle the high chloride content of the CRP purge stream. Estimated sludge
generation is 6.1 tons per ton of color removed. The sludge disposal cost estimate is in excess of
$90,000 per year.
Conclusion on Coagulation/Precipitation
Coagulation/precipitation is an infeasible technology for the CRP purge stream. The large
quantities of chemicals required and large sludge volume relative to color removed, makes the
use of this technology unrealistic. There is no indication that color removal by coagulation/
precipitation of the CRP purge stream will result in an equivalent reduction of secondary effluent
color. The use of polyarnme may have adverse effects on secondary effluent toxicity.
Based on these factors, coagulation/precipitation of color in the CRP purge stream is not a
technically, economically or operationally feasible technology.
Solidification for Land Disposal
Solidification for land disposal refers to treating liquid waste materials with various pozzolanic
materials and/or heat to form a solid (non-liquid) waste suitable for burial in a commercial
landfill or dedicated land disposal site.
VOPAK
Vopak Industrial Services is a provider of off-site non-hazardous waste treatment and disposal,
located in Mauldin, South Carolina. VOPAK evaluated the CRP purge stream in 2002 for
solidification and landfill disposal. Disposal through VOPAK would consist of using 5,000
gallon tankers to transport the CRP purge to the treatment facility, eliminating 100% of the CRP
color from Blue Ridge Paper's wastewater. At 5,000 gallons per tanker, at least 3 tankers per
day, seven days per week, and 52 weeks per year, would be required. The cost for this disposal
would be$2.6 million- $2.7 million per year. This estimate does not include any of the capital
costs, nor operating costs that Blue Ridge would incur in implementing this technology.
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Onyx Environmental
To verify that off-site solidification and landfill disposal was not a viable option, Blue Ridge
Paper requested a waste approval and quote from Onyx Environmental for off-site solidification
and landfill disposal of the CRP purge stream. Onyx is a commercial hazardous waste
transportation and disposal company who matches industrial wastes with appropriate recovery,
recycling or disposal options based on technical,regulatory and economic considerations. Onyx
confirmed that solidification is not a technically appropriate or economically viable disposal
option for the CRP purge stream. Quoted cost in December 2004 for commercial solidification
and landfill disposal of the CRP purge stream is $115 per ton of liquid CRP purge excluding
transportation. The quote for off-site transportation to the land disposal facility in Mauldin,
South Carolina in a 5000-gallon tanker is $855 per load including tanker cleaning, rental and fuel
surcharges.
Based on the Onyx Environmental quote, 15,000 gallons per day of CRP purge and 5000 gallons
per tanker load, the annual estimated cost for commercial off-site solidification and landfill
disposal of the CRP purge stream is:
Solidification: 15,000 gpd x 8.5 lbs/gallon x 1 ton/20001bs x $115/ton x 360 days/year
_ $2,639,250
Transportation: 3 loads/day x $855/load x 360 days/year = $923,400
Total annual cost in excess of$3.6 million.
Off-site hauling of the CRP purge stream will require a truck loading facility and heated storage
tank. The estimated capital cost of a truck loading and storage facility for the CRP purge stream
is in excess of$150,000
Evaporation
As part of the 2001 Color Removal Technology Assessment, Blue Ridge Paper evaluated the
feasibility and cost of treating the CRP purge stream through crystallization(i.e., solidification)
and disposal at the landfill. Basically, this technology would add one additional crystalizer,
tanks, pumps, and a plate-and-frame filter press to the CRP process. The current brine purge
stream would be further concentrated to form a crystalline solid, which would be sent to the
landfill. This would remove the entire CRP stream form the WTP influent.
The estimated capital cost for this crystallization system was $11,151,000 in January 2001. The
annual operating cost associated with the system was estimated to be$2,137,000 per year. These
estimates indicate that crystallization would not be a cost-effective option for treatment of the
CRP stream. Additional details of this process and cost estimates were included in the 2001
Color Removal Technology Assessment Report.
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Conclusion on Solidification
Blue Ridge Paper investigated commercially available technologies and services for
solidification and landfill disposal of the CRP purge stream. These have the advantage of
completely removing CRP purge stream color from the mill wastewater plant. However,none of
the solidification options are economically or operationally feasible for treating color in the CRP
purge stream.
Other Technologies — Bleaching/Oxidation
Bleaching involves use of oxidants to destroy lignin and related color bodies in wastewater.
Bleaching has the potential advantage of removing color without generating a sludge that
requires landfill disposal. At a conceptual level, bleaching appeared to be a promising
technology for cost-effective treatment of the CRP purge stream. Blue Ridge Paper investigated
bleaching of the CRP purge stream with a series of bench and field trial tests.
Ozonation
Laboratory tests were conducted during the summer of 2003 on samples of the CRP purge
stream. In the laboratory, pilot-scale batch reactors were able to achieve between 68% to 92%
decolorization of the CRP purge stream at ozone dose rates of 2.8 to 6.8 grams/liter. The
reaction time was 3 hours. A byproduct of ozone treatment of the CRP purge was foam. It is
important to note that the lab reactor foamed over during the pilot scale trial of ozone
dechlorization of CRP wastewater. The foaming was so severe it was concluded that treatment
of the concentrated CRP purge stream was not technically feasible. Dilution was necessary for
successful treatment, which significantly increases the size and operating cost of the treatment
equipment required.
Preliminary engineering estimates were prepared based on laboratory pilot-scale trials for a CRP
purge treatment system that mixed and diluted the CRP purge with other wastewaters from the
Canton Mill. The estimated capital cost was in excess of$2.7 million USD. Estimated operating
costs including power and oxygen were in excess of$2 million USD per year.
The laboratory tests represent high rate ozone treatment, which requires a liquid oxygen ozone
generator and a moderately pressurized reaction vessel with off-gas controls. The ozone
generator controls and safety systems are complex. Foaming that occurs when treating the
concentrated CRP purge stream with high rate ozone makes this technology infeasible for full-
scale application.
Clozone(Ozone and Chlorine Dioxide)—2002/2003
Blue Ridge Paper investigated bleaching technology during fall of 2002 and winter of 2003. A
proprietary package system was offered for point-of-use generation of moderate quantities of
chlorine dioxide(002) and ozone for bleaching and decolorization of colored materials. The
name of the proprietary chlorine dioxide process is "TST" and the application of the ozone
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technology"Clozone". The raw materials associated with the"TST" technology are sodium
chlorate,hydrogen peroxide, and sulfuric acid. The"Clozone" technology is proprietary only in
the point of application of the ozone. Ozone in the system is generated with electricity from
ambient air.
A bench-scale study of Clozone treatment of the CRP purge stream was performed in December
of 2002 with favorable results. A four-day field trial of the TST/Clozone process was then
conducted in February 2003. The field trial had two goals:
• Determine effectiveness of Clozone for CRP purge stream bleaching at design purge
rates.
• Determine optimum C1O2 and Ozone concentrations for extended field trials.
The field trial equipment included a 1000-gallon plastic tank for mixing and reacting Clozone
with the CRP purge stream. The Clozone mix water flow rate was 40 gpm and the CRP purge
rate was 10 gpm. Detention time in the mixing tank was approximately 20 minutes. The field
trial involved a series of 2-hr continuous flow bleaching tests at different C1O2 and ozone mass
dose rates and mixing tank concentrations. Bleaching chemical dose rates and concentrations
would be adjusted and allowed to run for 2 hours to reach steady state conditions in the mixing
tank. Color samples were then collected from the mixing tank influent and effluent. The trial
was therefore a series of short duration tests. There was no attempt to relate color reductions in
the CRP purge stream to secondary effluent color.
The technology removed color from the CRP purge stream by an average of 93% over the 4-day
trial. However, bleaching effectiveness was inconsistent. The dose rate of C1O2 ranged from
750 mg/L to 1700 m/L and ozone input ranged from 0 to 90 lbs/day. Some two-hr trials
involved chlorine dioxide alone without ozone. The color removal without ozone averaged 89
percent. Foaming and overflow of mix tank was observed during the trial and became a
problem. Off gassing of C1O2 from the mixing tank at C1O2 concentrations above 1200 mg/L in
the Clozone mix water was also encountered.
Operating and Clozone equipment cost estimates were provided based on the 4-day field trial.
The estimated operating cost, including chemicals and electricity, is $615,000 per year. The
quoted purchase price of the Clozone generator was $370,000. A complete Clozone equipment
installation for CRP bleaching would require a mixing tank, chemical storage tanks, CRP
transfer equipment, an off-gas scrubber and process controls. The estimated capital cost is in
excess of$1.8 million USD.
The Clozone trial indicated that chlorine dioxide alone could be effective for color reduction of
the CRP purge stream. The extra complexity, safety issues and cost of Clozone compared to
C1O2 alone are not technically or operationally justified. Clozone is an infeasible technology
for color reduction in CRP purge stream.
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C1O2 Bleaching Trial-2004
Blue Ridge Paper investigated an additional bleaching technology that involved only the use of
C1O2. A 30-day trial of CRP bleaching with C1O2 was conducted. The trial had two goals:
• Determine optimum dose rates of C1O2 for CRP purge stream bleaching at design purge
rates.
• Run full-scale CRP bleaching for a 30-day period to establish a relationship between
color reductions in the CRP purge stream and reduction in secondary effluent color.
The 30-day trial was planned to start in July 2004. However, a series of problems with
equipment, chemical contamination, and safety issues prevented any extended CRP bleaching
runs during July. The trial resumed in early August and ran for several 1 to 2 day periods
between failures of the C1O2 generator. Analysis of color samples during early August showed
little, if any, effective bleaching of the CRP.
Changes were made to improve efficiency of the C1O2 generator and a 4—day continuous CRP
bleaching trial was completed in mid-August. Color removal in the CRP purge stream during
this 4-day period was 75 to 90 percent. This was the longest continuous successful run, but it
was not long enough to see any color effect on the mill's secondary effluent. Variability in the
CRP purge stream and problems with the C1O2 generator caused unreliable bleaching
effectiveness.
Because of reliability problems with the C1O2 generator, Blue Ridge Paper shut down the trial in
late August 2004 and made arrangements with another vendor to provide C1O2 equipment. The
CRP bleaching trial was to resume in late September following the scheduled semi-annual mill
outage in the middle of that month. Unfortunately, back-to-back historic floods hit the Blue
Ridge Paper Canton Mill during September 2004. The flood disruptions required postponing
restart of CRP bleaching trials until December 2004.
Blue Ridge CRP Bleaching Trial—2004/2005
Blue Ridge Paper rented another C1O2 generator and set up an extended bleaching trial using the
mix tank from the earlier field trials. The trial started in December 2004 and was run entirely by
Blue Ridge Paper personnel. The trial was suspended during the Christmas holiday and resumed
in January 2005. The Blue Ridge CRP Bleaching Trial had several goals:
• Understand the process variables and dynamics involved in CRP bleaching with C1O2.
• Develop a process for possible full-scale application.
• Run full-scale CRP bleaching for an extended period to establish a relationship between
color reductions in the CRP purge stream and reduction in secondary effluent color.
It took most of December and the first half of January 2005 to tune the C1O2 generator and dose
rate to obtain consistent bleaching. A static mixer was added to the inlet of the mixing tank to
improve contact of C1O2 with the CRP purge stream. There were some problems with foaming
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and overflow of the mix tank. Off gassing of C1O2 was controlled by limiting C1O2
concentration in the mix water to 1.7 g(L or less. Variability in the CRP purge stream caused hit
and miss bleaching effectiveness. The CRP bleaching process was not easy to control. A 1 to 4
dilution of the concentrated CRP purge stream with mix water was necessary for effective
bleaching and to avoid handling problems with plugging of CRP transfer lines and equipment.
CRP transfer lines had to be frequently flushed.
The C1O2 generator was reliable and allowed a 20-day extended CRP bleaching run from
January 24 until February 12, 2005. Color reduction in the CRP purge stream during the Blue
Ridge CRP Bleaching Trial ranged from 39% to 82%. The color reduction was strongly
influenced by CRP purge rate and the capacity of the generator. At a steady CRP purge rate of 8
gpm, the color reduction averaged 79%.
Color in the 5B sewer was monitored during the Blue Ridge CRP Bleaching Trial. The CRP
purge stream mixes with the 5B sewer prior to wastewater treatment. Color reduction in the 5B
sewer averaged 45% and was statistically significant. However, there was no corresponding
statistically significant reduction in secondary effluent color during the Blue Ridge CRP
Bleaching trial:
Conclusion on CRP Bleaching Technology
Bleaching of the CRP purge stream for color proved difficult to control in extended field trials.
Bleaching effectiveness was unreliable due to variability in the CRP purge stream. None of the
CRP bleaching trials achieved a consistent color removal. Color removal at time during
extended trials was 50% or less. There is no indication that color reduction in the CRP purge
stream from C1O2 bleaching resulted in an equivalent reduction in secondary effluent color.
Based on field trials and C1O2 from the existing bulk C1O2 system at the Blue Ridge Paper
Canton Mill, the annual chemical cost for CRP bleaching would be$145,000 per year. The
estimated capital cost including mix tank, C1O2 transfer piping, an off-gas scrubber and controls
is in excess of$1.2 million.
Although-initially promising, bleaching proved to be an infeasible technology for the CRP purge
stream. Based on full-scale field trials, the level of effort and quantity of chemical necessary to
sustain a C1O2 bleaching effect on the CRP purge stream do not render any significant reduction
in secondary effluent color. Bleaching is not a technically, economically or operationally
feasible technology for color reduction in the CRP purge stream.
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Other Technologies - CRP on Lime Precoat Filter
During summer of 2004, Blue Ridge Paper conducted a bench scale test of filtering the CRP
purge stream through lime mud from the precoat filter. This idea to use lime mud as a filter
media for the CRP purge originated from a process supervisor in the Recovery area of the mill.
This process, if successful, would largely remove the CRP purge stream from the mill sewers.
Only filtrate would be sewered. The CRP purge solids including color would be hauled to the
mill's landfill facility for disposal.
Results from the lab experiment for CRP filtering though lime mud looked promising. A short
duration trial of the idea was scheduled to take place in September 2004. Unfortunately, the
Canton Mill was hit by back-to-back historic floods during September. The CRP on lime precoat
filter trial was postponed until 2005 following completion of CRP bleaching trial work.
Three 4-hour and one 36-hour trials of CRP filtering through lime mud on the lime precoat filter
were conducted in February and March 2005. The full CRP purge stream at an average rate of
10 gpm was applied to the No. 6 precoat filter during each trial. Lime mud and filtrate samples
were collected and analyzed for color removal and dissolved salts. Color reduction results for
the CRP purge stream were mixed. Average color removal was 77 percent, but ranged from 34
to 94 percent. Because the CRP on Lime Precoat Filter trials were short duration, there was no
attempt to relate color reductions in the CRP purge stream to secondary effluent color.
Conclusion of CRP on Lime Precoat Filter
Based on field trial results to date, the idea to filter CRP through lime mud is an unproven
technology for color reduction. Several equipment and technical issues remain to be quantified
including:
• effect of high chlorides in the CRP purge on lime mud precoat filter equipment
• storage of CRP during periods when the No. 6 lime precoat filter is down (about 20% of
mill operating time)
• release of CRP color from lime mud in the landfill and possible return of this color to the
mill wastewater plant in landfill leachate.
The technical, economic and operational feasibility of treating the CRP purge stream on the lime
precoat filter is undetermined. More trial work is needed to reach a definite conclusion.
Other Technologies — Proprietary Third Party
Blue Ridge Paper Products contacted various waste treatment technology vendors to investigate
options for color treatment of the CRP purge stream. These are discussed below. Some of the
vendors conducted bench scale tests. Others used information on the physical and chemical
characteristics of the CRP purge stream to make an evaluation of technical and economic
viability.
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March 2005 CRP Color Reduction Technology Report
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None of the proprietary technologies evaluated are technically, economically or operationally
feasible for color removal from the CRP purge stream.
Wet Air Oxidation and PACT- 2002
Blue Ridge Paper investigated a patented wet air oxidation and powered activated carbon
treatment or PACT technology. This technology is typically used on high strength organic waste
streams. In this technology, powered activated carbon- or PAC- is added to the waste stream to
absorb waste constituents of concern. The PAC is then settled and regenerated in a wet air
oxidation unit. During regeneration, organics absorbed on the PAC are destroyed or broken
apart so they can be more easily removed in subsequent biological wastewater treatment steps.
The wet air oxidation technology can be directly applied to concentrated waste streams. In this
application, PAC is not used. Organics in the high strength liquid waste are directly oxidized.
It seemed that the technology might be applicable for the removal and oxidation of color
constituents in the CRP purge stream. However, there were no existing similar treatment
installations for comparison and the ability to conduct bench scale tests was non-existent. The
wet air oxidation technology involves moderately high temperatures and pressures (600 deg F at
100 psig), which would add additional thermal load to the Blue Ridge Paper wastewater
discharge. The technology is also capital equipment intensive. Preliminary equipment cost
estimates for a CRP purge stream treatment system ranged from$1.7 to$2.9 million and
operating cost estimates were on the order of$1000 per day.
To refine preliminary cost estimates and determine if the technology would actually work, a
series of rather expensive field trials were proposed. One significant concern,besides cost of
trials, was the corrosive effect of high chlorides in the CRP purge stream on pilot scale
equipment. Blue Ridge Paper decided that it was better to direct such field trial expenditures
towards CRP bleaching and other technologies.
High Temperature Peroxide Oxidation- 2002
Blue Ridge Paper evaluated the use of extreme temperature and pressure with hydrogen peroxide
to decolorize the CRP purge stream. Samples were sent for bench scale testing. No color
reduction was observed. It was then proposed to perform an additional laboratory trial using
evaporation enhancements to the technology. However, a fee$25,000 for the additional work
was required. Again, there weren't any existing similar treatment installations for comparison
and there was no indication that the second fee-trial would be successful. Based on the
preliminary results and commercial trial costs, Blue Ridge Paper decided to suspend further
investigation of this technology.
Filter Papers - 2002
Filter papers have been used in machining and other industries to separate solids and other
contaminates from process fluids and wastes. The spent filter paper and captured solids are then
processed for material recovery or shipped to a landfill for disposal. The filter paper process can
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March 2005 CRP Color Reduction Technology Report
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be continuous or batch. Blue Ridge Paper evaluated a proprietary technology using treated paper
to remove color from the CRP purge stream. The treated paper coagulates and filters solids
including color bodies from the waste.
Bench-scale tests of the filter paper were run at the Canton mill. The filter paper removed
approximately 90% of the color from the CRP purge stream. There were no pilot or full-scale
operations using this technology for color removal. The equipment required for a full-scale
system for the CRP purge stream is not well defined.
A budgetary quote of$1 to 2 million per year for filter paper to treat the CRP purge stream was
provided. Capital cost of equipment was not estimated. In addition, the filter paper technology
would generate 2.25 tons/day, or an additional 820 tons/year of waste paper requiring landfill
disposal. Although this technology did initially appear promising, the costs for the treated paper,
as well as costs for additional equipment and waste disposal prevent this technology from being
economically viable. It was determined that the filter paper technology was not a commercially
competitive option for Blue Ridge Paper. A field trial was not pursued for this technology.
Proprietary Oxidation Technology- 2002
Blue Ridge Paper evaluated a proprietary oxidation technology that could possibly destroy lignin
compounds and color in the CRP purge stream. Blue Ridge Paper provided CRP purge stream
samples for bench scale testing. The bench scale work was not effective for color removal and
Blue Ridge Paper was informed that the CRP purge stream was not a feasible application for this
technology.
Ultra/Nano Filtration—2002
Several manufacturers of ultra/nano filtration equipment were contacted concerning color
removal from the CRP purge stream. When these companies received detailed information on
the characteristics of the CRP purge stream—especially the very high dissolved salt content—
they expressed serious reservations about the viability of ultra/nano filtration for this
application. The technical issue was salt plugging of the filter membranes. None of the
companies offered to do bench scale tests or field trials. Ultra/nano filtration is not a feasible
technology for the CRP purge stream.
Summary/ Conclusions
Blue Ridge Paper Products Inc. has and continues to evaluate every possible methodology
available for the effective treatment of the CRP purge stream. This report illustrates a concerted
effort to deal with this color source and to evaluate many possible alternatives. As specific
details conceming the use of each technology have been examined in more"real world"
application terms, significant problems have arisen. These issues are hugely important from a
logistics, technology, performance and overall effectiveness standpoint. A technology that
doesn't work in a real, full-scale application for the significant reduction of color provides no
benefits to the water quality. Continued improvement in secondary effluent color is the overall
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March 2005 CRP Color Reduction Technology Report
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' objective of Blue Ridge Paper, those interested in these issues, and the NPDES Permit for the
mill.
In the testing of the potential technologies for color reduction in the CRP purge stream, even in
cases where a significant color reduction was indicated(still not near the 85 % goal), no
statistically significant reduction in the mill's secondary effluent could be demonstrated. The
character and pollutant content of the CRP waste stream represents an already concentrated
"waste" from an extensive, in-mill effort to reduce color. The purge stream is the wastewater of
a wastewater treatment process. By its very nature it carries the pollution that was removed from
another wastewater stream so that stream can now be recycled. The ability to "further"treat
such a concentrated stream and remove its impact from the overall mill discharge is a .
challenging and almost overwhelming engineering problem. The day-to-day variation in mill
effluent color is greater than the contribution of color from the CRP purge stream. The actual
amount of color related to the CRP purge discharge results in only about 2000 lbs/day in the
secondary effluent. At 42,000 lbs./day of color in the discharge, this represents only about 5 %
of the loading. While the Canton Mill has essentially reduced its color discharge by over 90 %
from the late 1980s, the CRP purge stream is a difficult color source to manage and additionally
reduce.
The overall objective of meeting NPDES permit requirements regarding CRP color can be
illustrated by the following sentence in the permit condition: "The CRP analysis shall
concentrate on the technical, economic and operational feasibility of implementing the
applicable technologies on all or a portion of the purge stream." Blue Ridge Paper takes very
seriously the need to further reduce color in the Canton Mill wastewater discharge and has taken
a very comprehensive look at not only the technologies identified in the permit condition, but
many more. At this juncture, Blue Ridge Paper cannot recommend the implementation of any of
the evaluated technologies. The search for an effective CRP management strategy should
continue, and the company is committed to doing that in conjunction with mill-wide color
reduction efforts.
Blue Ridge Paper has diligently placed into operational use all of the applicable technologies
identified by the TRW (Technology Review Workgroup) during the 2001 permit renewal process
that were_identified as "highest certainty" steps and those that were appropriate and identified as
"reasonable certainty" steps. The CRP treatment consideration was identified by the TRW as
having reduced potential for application as compared to the"highest certainty" and "reasonable
certainty" items and is referred to in TRW reporting and the permit as "technologies for further
color reduction." The NPDES permit specifically identifies color treatment of the CRP purge
stream as a "lowest certainty" method for additional effluent color reduction.
Initial consideration of this waste stream identified a number of possible treatment approaches.
The trials summarized in this report and used to evaluate potential treatment approaches have
frankly raised many questions, eliminated several technologies from reasonable consideration
and have failed to identify any one or combination of technologies that can be implemented at
this time. As Blue Ridge Paper continues to evaluate technical approaches to the CRP purge
stream, the company remains committed to finding ways to further reduce color overall in the
mill effluent and to meet all the conditions of the NPDES Permit.
March 2005 CRP Report Final.doc

APO - 1 2005
WATBLUE RIDGE
A REVEL EO REGIONAL OFUALITY FICE
PAPER PRODUCTS INC.
Blue Ridge Paper Products Inc. .
Canton Mill, Canton, North Carolina
Chloride Removal Process (CRP)
Color Reduction Technology Assessment
March 2005

March 2005 CRP Color Reduction Technology Report
Page ii
Executive Summary
This report outlines investigations on Chloride Removal Process (CRP) color reduction
technologies that Blue Ridge Paper Products Inc. has conducted to meet the requirements of the
2001 NPDES Permit. Specifically, the report reviews extensive efforts by Blue Ridge Paper to
evaluate and identify a viable color reduction technology for the CRP purge stream. The
investigations included literature reviews, vendor contacts,bench scale tests and field trials. In
addition to the four specific technologies identified in the permit, Blue Ridge Paper looked at
several additional technologies for removing color in the CRP purge stream. The table following
this summary outlines the technologies reviewed and the results.
It is essential in understanding the difficulty of treating the CRP wastewater to recognize that the
CRP purge is a resultant waste flow from a complex system that treats what is, in a typical pulp
mill, a"sewered" wastewater(that is, a discharge to the mill's wastewater treatment system).
The CRP alongwith the Minerals Removal Process (MRP) at the Blue Ridge Paper Canton Mill
forms the BFR along_with
"Bleached Filtrate Recovery" process. The BFR process allows the mill to
recycle a large portion of its "pine line"pulp bleaching wastewaters. In a typical pulp mill these
wash waters, which contain"color" from the processed wood pulp, are sent directly to the
wastewater treatment system. Much of the color in the wash waters from a typical pulp mill ends
up in the mill's treated discharge. At Blue Ridge Paper,BFR allows the mill to "reuse" these
wash waters and reduce the total color going to the treatment system. The CRP purge stream by
its very nature is a very concentrated, high chlorides material. A summary of CRP purge stream
characteristics is as follows:
Average CRP puree stream characteristics
Average flow 10 gpm (15,000 gpd)
Total inorganic carbon(TIC, as carbonate) 30,500 mg/L
Total organic carbon(TOC) 6260 mg/L
Absorbable organic halides (AOX) 17.4 mg/L
Sodium (Na) 110,000 mg/L
Potassium (K) 22,200 mg/L
Conductivity 133,000 mmhos/cm
Chemical Oxygen Demand(COD) 19,100 mg/L
Sulfate(SO4-) 203,000 mg/L
Chloride (Cl-) 26,800 mg/L
Color(true filtered) 41,000 mg/L at 465 nm
pH 10.1
Total suspended solids 4020 mg/L
Total solids 33.5 percent
Total dissolved salts 360,000 mg/L
Temperature at discharge to mill sewer 165 degs F
This is clearly a very "difficult to treat" wastewater. In fact, as noted in many of the trials
documented in this report,just physically handling the CRP purge stream(pumping and placing
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the wastewater in tanks for treatment) proved challenging. Often the purge stream would "plug"
lines or crystallize as the temperature of the liquid dropped. These characteristics, and the
overall "treatability" issues associated with this wastewater,resulted in the EPA Technology
Review Workgroup (TRW) concluding that CRP treatment had a reduced potential for further
color reduction. The many trials, tests and evaluations outlined in this report confirm that
conclusion.
Investigations of technologies for CRP purge stream color reduction have failed to identify any
viable technology or combination of technologies that meet the NPDES Permit's test of
"technical, economic and operational feasibility." Blue Ridge Paper takes very seriously the
need to further reduce color in the Canton Mill's wastewater discharge and is fully prepared to
continue those efforts. The company took a very comprehensive look at treating the CRP purge
stream and evaluated not only the technologies identified in the permit condition, but many
more. At this juncture, Blue Ridge Paper cannot recommend implementation of any of the tested
technologies. The search for an effective CRP management strategy should continue, and the
company is committed to doing that in conjunction with mill-wide color reduction efforts.
Summary Table
The following table is a summary of the color removal technology assessment for the CRP purge
stream. The table lists both permit-specified and other technologies evaluated.
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Table of Contents
ExecutiveSummary........................................................................................................................ii
...
Summary Table..............................................................................................................................iu
Introduction..................................................................................................................................... 1
Purpose........................................................................................................................................ 1
PermitRequirement.................................................................................................................... 1
CRPProcess Overview...................................................................................................................2
Average CRP purge stream characteristics................................................................................. 5
PermitSpecified Technologies ....................................................................................................... 6
LandApplication........................................................................................................................ 6
Conclusionon Land Application............................................................................................7
Commercial Incineration............................................................................................................7
Conclusion on Commercial Incineration................................................................................ 8
Coagulation/Precipitation........................................................................................................... 8
RMTStudy..............................................................................................................................9
Conclusion on Coagulation/Precipitation........................................................................... 10
Solidification for Land Disposal............................................................................................... 10
VOPAK................................................................................................................................. 10
OnyxEnvironmental............................................................................................................. 11
Evaporation........................................................................................................................... 11
Conclusionon Solidification................................................................................................. 12
Other Technologies —Bleaching/Oxidation.................................................................................. 12
Ozonation.............................................................................................................................. 12
Clozone(Ozone and Chlorine Dioxide)—2002/2003 ........................................................ 12
- C102 Bleaching Trial-2004................................................................................................. 14
Blue Ridge CRP Bleaching Trial—2004/2005................................................................... 14
Conclusion on CRP Bleaching Technology ......................................................................... 15
Other Technologies - CRP on Lime Precoat Filter....................................................................... 16
Conclusion............................................................................................................................ 16
Other Technologies —Proprietary Third Party.............................................................................. 16
WetAir Oxidation and PACT-2002................................................................................... 17
High Temperature Peroxide Oxidation- 2002...................................................................... 17
FilterPapers - 2002............................................................................................................... 17
Proprietary Oxidation Technology- 2002............................................................................ 18
Ultra/Nano Filtration—2002............................................................................................... 18
Summary/Conclusions................................................................................................................ 18
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Introduction
Purpose
This report outlines investigations on CRP color reduction technologies that Blue Ridge Paper
Products Inc. has conducted to meet the requirements of the 2001 NPDES Permit. The original
due date for the report was December 1, 2004. However, Blue Ridge Paper and the Town of
Canton, North Carolina experienced back-to-back historic floods during September 2004. The
floods disrupted completion of CRP color investigation work. The Blue Ridge Paper Canton
Mill was down for 3 weeks during September 2004 because of the flooding. Work to fully
restore wastewater treatment operations and wastewater laboratory capability took the balance of
2004 to complete. In October 2004, Blue Ridge Paper requested an extension of the due date for
the CRP color reduction technologies report until April 1, 2005. The Division of Water Quality
(DWQ) of the North Carolina Department of Environment and Natural Resources (DENR)
approved the extension request on November 10, 2004.
Permit Requirement
The requirement of the 2001 NPDES permit for this study is specified in Section A.(8.),
Paragraph 9:
"By December 1, 2004*, the permittee shall evaluate color reduction technologies
associated with the Chloride Removal Process (CRP)wastestream. The CRP analysis
shall concentrate on the technical, economic and operational feasibility of implementing
the applicable technologies on all or a portion of the purge stream. The report shall
identify specific economic and implementation issues associated with the improvements.
The report shall also project the expected additional color reduction for each technology
evaluated and maximum color reduction possible using the identified technologies.
Though not limited to the following, the report shall include an analysis of the land
application of the high chloride wastewater, commercial incineration,
coagulant/precipitation technologies, and solidification for land disposal. The Division
of Water Quality (in consultation with the Technology Review Workgroup) shall evaluate
the feasibility of implementing identified technologies for further color reduction and
shall submit to the NDPES committee by February 1, 2005**the DWQ's
recommendations regarding color reductions associated with the treatment of the CRP
wastestream.
If during the course of this evaluation, Blue Ridge Paper identifies a technical, economic,
and operationally feasible color reduction technology that can be implemented for
treatment of the CRP wastestream, the permitte may request that the Technology Review
Workgroup review this technology for implementation at the Canton mill. If the
Technology Review Workgroup concurs that the identified technology is suitable for the
Canton mill and that the color reductions achievable are adequate, the mill's obligation
to research additional technologies will be waived after formal notification from Blue
Ridge Paper that the identified technology will be installed and placed into operation.
This notification shall include language indicating the permittee's commitment to the
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implementation of the technology, along with a schedule for implementation. The
Division of Water Quality will notify the permittee in writing that the proposed
implementation schedule is acceptable."
* Due date was extended to April 1,2005 due to September 2004 floods; see
10 Nov 2004 letter from Alan Klimek,NC DENR DWQ
**Since the submission date was extended by four months, the DWQ's submission
to the NPDES committee extends by four months to June 1, 2005.
CRP Process Overview
The Bleach Filtrate Recycling(BFRm)process is a pollution prevention technology unique to
Blue Ridge Paper Products' Canton Mill. It was originally implemented as a full-scale trial
demonstration project in 1995. Today, it has been converted to an integral part of the operations
at the Canton Mill. The BFR process is an important element of Blue Ridge Paper's
management of wastewater effluent color.
Recycling the bleaching filtrates has not been successful in the past at other mills because some
of the waste minerals, such as sodium, potassium, calcium, manganese, and magnesium, as well
as chlorides, interfere with the operation of the pulping, bleaching, and recovery operations.
Wherever these materials accumulate in the processes, they can impair process operation and
cause excessive corrosion damage to the process equipment. Another difficulty in recycling
bleaching wastes is that the dissolved lignin component can consume additional amounts of
bleaching chemicals, increasing bleaching cost and causing quality problems with final bleached
pulp and paper products.
The basic concept of BFRTM is to recycle the bleaching filtrates through the pulp-washing system
in the same manner that pulping and oxygen delignification filtrates are recycled. Wood
minerals and salts produced in the bleaching process are removed at strategic locations in the
bleach plant and in the chemical recovery process. This allows the bleached kraft pulp mill to
reduce discharge of colored effluents to mill sewers, reduce water usage in pulp bleaching and
washing operations, and reduce other chemical discharges from the mill.
The BFRTm process at Blue Ridge Paper recycles filtrates from the pine bleach plant only. There
are two distinct components of bleach filtrate recycling: the Minerals Removal Process (MRP),
associated with the pine bleach plant, and the Chloride Removal Process (CRP), associated with
the chemical recovery area. The MRP removes the calcium, magnesium, manganese, and other
hard water elements from the bleaching waste. The CRP removes the sodium chloride and
potassium from the recycled chemicals before they enter the recovery furnaces.
The Chloride Removal Process (CRP) treats a portion of the chemical ash (produced by burning
the lignin waste in the recovery furnaces) removing chloride and potassium. This ash, which is
later converted into active cooking chemicals, is where the chloride and potassium compounds
accumulate. A schematic diagram of the CRP process is presented in the following figure.
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In the chemical recovery cycle, reclaimed spent cooking chemicals and lignin waste,known as
black liquor, are concentrated by an evaporation process. The concentrated black liquor is
burned as a fuel in the recovery furnaces to generate steam and electric power. The lignin and
other organic wood wastes bum off in the recovery furnaces. The ash, or smelt, remaining after
combustion contains the spent cooking chemicals, primarily sodium sulfate and sodium
carbonate. The smelt is removed from the bottom of the furnaces and dissolved in water to form
green liquor. The green liquor is chemically activated in the causticizing area. The reactivated
cooking chemical,known as white liquor, is sent to the pulp mill to be reused for cooking pulp.
Some of the ash that is produced in burning black liquor is carried out of the recovery furnace by
the flue gases produced by combustion. The Canton Mill has direct contact cyclone evaporators
on the recovery furnaces. These cyclones contact the flue gas with the incoming black liquor to
evaporate water from the liquor before combustion. Some of the lignin and other color material
from black liquor in the cyclones may also be carried out of the recovery furnace with fly ash.
This fly ash must be removed from the recovery furnace flue gas before the gases are exhausted
to the atmosphere. The flue gases pass through large wet-bottom, electrostatic precipitators that
remove fly ash from the gases.
Because of bleach filtrate recycling, the weak black liquor received by the chemical recovery
area from brown stock washing contains a higher percentage of sodium chloride salt than it
would in the conventional pulp bleaching process without filtrate recycling. The higher salt
content must be removed from the process to prevent corrosion of the recovery furnace
evaporator and boiler tubes and disruption of the recovery process.
The CRP takes advantage of the greater solubility of sodium chloride and potassium compared to
sodium sulfate. In a conventional chemical recovery process, fly ash from the electrostatic
precipitators is returned directly to black liquor to recover salts. In the CRP, fly ash from the
precipitators is dissolved in water instead of black liquor in the bottom of the precipitators. The
flow from the precipitators, now a salt solution instead of black liquor, is directed to a series of
three CRP evaporators instead of directly into the recovery furnaces.
The salt solution is introduced into the CRP evaporators with steam to evaporate a portion of the
water in the salt solution. Upon completion of the third evaporation stage, enough water has
been evaporated from the solution to cause the sodium sulfate to precipitate as salt crystals. The
sodium chloride and potassium remain in solution. A portion of the salt cake and salt solution is
continually pumped from the final evaporator stage to a filter system, which separates the
crystallized sodium sulfate "salt cake" from the liquid salt solution.
The sodium sulfate salt cake from CRP is mixed with heavy black liquor and returned to the
recovery furnace for chemical recovery. A portion of the salt solution containing concentrated
sodium chloride and potassium is also returned, and a portion is "purged" to control the
concentration and buildup of chloride and potassium in the chemical recovery and pulp cooking
liquors. The CRP purge stream is primarily salty water, but also contains a significant
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concentration of color bodies. The CRP purge stream is the focus of the NPDES permit
requirement and of this report.
The technical feasibility of permit-specified technologies depends in large part on the chemical
composition and physical properties of the CRP purge stream. Average characteristics of the
CRP purge based on long-term monitoring by Blue Ridge Paper are listed below. The
temperature of the purge stream at the point of discharge to the mill sewer is about 74 degrees
Celsius (165 deg Fahrenheit). The design purge flow rate is 10 gpm or about 15,000 gallons per
day. This volume is 0.06 percent of the mill's average daily wastewater flow of 25 mgd. The
primary control method for chlorides and potassium in the chemical recovery cycle is to vary
CRP purge rate. As a result, the daily CRP purge stream flow can vary from the target of 10
gpm.
The CRP purge stream is best described as brine. Samples of the purge stream will crystallize at
varying temperature depending on salt concentration. Sometimes the sample will remain in
liquid form when cooled to room temperature and at other times the sample will crystallize after
it has cooled several degrees. Crystallized samples will re-liquefy when subjected to shear. The
CRP purge stream is diluted as it is added to the mill sewer to prevent crystallization and
plugging. The mill experiences occasional operating problems with plugging in the CRP process
from crystallization.
Average CRP purge stream characteristics
Average flow 10 gpm (15,000 gpd)
Total inorganic carbon (TIC, as carbonate) 30,500 mg/L
Total organic carbon(TOC) 6260 mg/L
Absorbable organic halides (AOX) 17.4 mg/L
Sodium(Na) 110,000 mg/L
Potassium(K) 22,200 mg/L
Conductivity 133,000 mmhos/cm
Chemical Oxygen Demand (COD) 19,100 mg/L
Sulfate (SO4=) 203,000 mg/L
Chloride(Cl-) 26,800 mg/L
Color(true filtered) 41,000 mg/L at 465 nm
pH 10.1
Total suspended solids 4020 mg/L
Total solids 33.5 percent
Total dissolved salts 360,000 mg/L
Temperature at discharge to mill sewer 165 degs F
The potential contribution of the CRP purge stream to primary influent and secondary effluent
color was documented in the 2001 Color Removal Technology Removal Assessment Report:
Primary influent color attributed to CRP purge stream — 5000 lbs/day
Secondary effluent color attributed to CRP purge stream <23001bs/day (estimated)
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The daily CRP purge stream flow rate can vary from 0 to 15 gpm(0 to 21,600 gpd) depending on
operating conditions and maintenance activities. The color contributions above are annual
average values based on the design CRP purge stream rate of 10 gpm(15,000 gpd). The
secondary effluent color attributed to the CRP purge stream is based on removal efficiency of
black liquor color in the Canton Mill's activated sludge treatment system. Color in the CRP
purge stream originates from black liquor in the recovery furnaces and is assumed to behave
similarly to black liquor wastewater treatment.
The average secondary effluent discharge for the Blue Ridge Paper Canton mill in 2004 was
41,463 lbs/day. The 2300 lbs/day contribution to secondary effluent color from the CRP purge
stream is 5.6 percent of the 2004 average color and is approximately 1/of the standard deviation
of the 2004 secondary effluent color. The small contribution of the CRP purge stream to
secondary effluent color creates problems confirming the effectiveness of technologies to
remove color in the CRP purge stream. It may not be possible to statistically confirm that
reductions in CRP purge stream color result in equivalent reductions in secondary effluent color.
Permit Specified Technologies
The 2001 NPDES permit specifies that Blue Ridge Paper evaluate the technical, economic and
operational feasibility of several specific technologies for treatment of the CRP purge stream
including land application, commercial incineration, coagulation/precipitation and solidification
for land disposal.
Land Application
Land application refers to the use of liquid wastewaters at agronomic rates for irrigation,
treatment and to recover beneficial nutrients. Microbes in the irrigated soil and vegetation
provide treatment. The liquid wastewater can be applied to forage grasses, food crops or
woodlands. Land application avoids direct discharge of wastewater to streams. The land-
applied wastewater moves through the soil and vegetation system, is "taken up" to a limited
degree by vegetation, is absorbed and "filtered"by the soil, is acted upon by microorganisms
present in the soil, and evaporates to some degree during periods of low humidity and sunlight.
The remaining "treated" water from land application is then indirectly discharged to streams
through surface runoff and groundwater. Treated municipal wastewater and some treated and
even untreated industrial wastewaters have been successfully land applied for many years.
Factors limiting the land application of wastewater are evaporation, accumulation of metals and
other pollutants in soils and vegetation, and the sensitivity of the irrigated vegetation to salts. Of
these factors, salt content is the limiting factor applicable to potential land application of the CRP
purge stream.
Blue Ridge Paper researched general design criteria for land application of wastewater. Principle
sources were Metcalf and Eddy, Wastewater Engineering, Third Edition and several state
agricultural extension service publications on the Web related to land application of organic
wastes. To be suitable for irrigation without restriction, wastewaters should have a chloride
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content of less than 100 mg/L. Wastewaters with chloride contents greater than 350 mg/L are
not suited for land application to due vegetative effects and changes to the percolation
characteristics of the soil. Similarly, the conductivity of wastewaters for land application should
be less than 35,000 mmhos/cm and the total dissolved salt concentration should be less than 2000
mg/L. With a chloride content of 26,800 mg/L, a conductivity of 133,000 mmhos/cm and a total
dissolved salts content of 360,000 mg/L, the CRP purge steam cannot be land applied without
significant dilution.
Based on chloride content, the CRP purge would have to be diluted by a ratio of at least 270:1 to
be land applied at agronomic rates without restriction. With dilution water, the daily volume for
land application would be 4,050,000 gallons per day. At an irrigation rate of 48 inches.per year
(typical for southeastern forests under wastewater irrigation), a total of 1135 acres of suitable
land would be required. A 24-inch diameter pipeline to irrigation site would be required.
Assuming land was available, the design flow rate for transfer pumps, irrigation pumps and land
application equipment would be a minimum of 2800 gallons per minute. Land application
systems also require wet weather storage typically sized to hold 30 to 60 days of wastewater
production. A reservoir of 120 to 240 million gallons storage capacity would be required.
Conclusion of Land Application
Because of chloride salt content and associated technical and logistical issues, land application is
not a feasible technology for treatment and disposal of the CRP purge stream.
Commercial Incineration
Commercial incineration refers to off-site shipment of industrial waste for incineration in lime
kilns or dedicated waste incinerators. There are three reasons to incinerate an industrial waste:
• Off-set fuel use by recovering the heat content of the waste
• Destroy organic components in the waste
• Thermally recover valuable components of the waste.
The CRP purge stream originates from recovery furnace fly ash. It has essentially no heat value.
It has no constituents at concentrations economically attractive for recovery. The high chloride
content makes the purge stream very corrosive under combustion conditions. Incineration is not
an appropriate technology for the CRP purge stream.
To verify that incineration was not a viable option, Blue Ridge Paper requested a waste approval
and quote from Onyx Environmental for incineration disposal of the CRP purge stream. Onyx is
a commercial hazardous waste transportation and disposal company who matches industrial
wastes with appropriate recovery, recycling or disposal options based on technical,regulatory
and economic considerations. Onyx, in their own evaluation, confirmed that incineration is not a
technically appropriate or economically viable disposal option for the CRP purge stream. The
high chloride content and zero heat value of the purge stream would require blending with a
large volume of other more suitable waste before incineration. Quoted cost in December 2004
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for commercial incineration disposal of the CRP purge stream is $0.46 per lb of liquid CRP
purge excluding transportation. The quote for off-site transportation to the incineration facility
in a 5000-gallon tanker is $3635 per load including tanker cleaning, rental and fuel surcharges.
Based on the Onyx Environmental quote, 15,000 gallons per day of CRP purge and 5000 gallons
per tanker load, the annual estimated cost for commercial incineration disposal of the CRP purge
stream is:
Incineration: 15,000 gpd x 8.5 lbs/gallon x $0.46/lb x 360 days /year = $21,114,000
Transportation: 3 loads/day x $3635/load x 360 days/year = $3,925,800
Total annual cost in excess of$25 million.
Off-site hauling of the CRP purge stream will require a truck loading facility and heated storage
tank. The estimated capital cost of a truck loading and storage facility for the CRP purge stream
is in excess of$150,000.
Conclusion on Commercial Incineration
Based on both physical and chemical characteristics and on commercial quotes, incineration of
the CRP purge stream is not an economically or operationally feasible technology.
Coagulation/Precipitation
Coagulation and precipitation is a method of removing color bodies from wastewater by adding a
flocculating chemical. The flocculating chemical works in one of two ways:
• change the zeta potential (electrostatic charge) of the color body particles allowing the
particles to agglomerate into larger particles that will settle out.
• form a large chemical precipitant floc that"sweeps" the color body particles out of
solution as the floc settles.
Any coagulation and precipitation technology for color removal generates sludge that requires
disposal as a solid waste. Sweep floc precipitation generates large volumes of sludge relative to
the volume of color body particles removed.
The 2001 Color Removal Technology Assessment Report examined secondary effluent color
removal by sweep floc coagulation and precipitation with alum and with lime. These chemicals
worked on the relatively dilute secondary effluent color. However,because of the volume of
secondary effluent flow, coagulation and precipitation technology was capital intensive with high
operating costs for chemicals and sludge disposal. The 2001 report concluded that this
technology was not appropriate for secondary effluent color removal.
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The focus of this report is color removal treatment of the concentrated CRP purge stream. Color
in the CRP purge stream originates from lignin in the black liquor ash. Coagulation and
precipitation of color in the CRP purge stream is removal of dissolved lignin in the liquid CRP
purge stream. The high dissolved salt content and high alkalinity of the CRP purge can interfere
with coagulation chemicals and the formation of floc.
RMT Study
Blue Ridge Paper retained RMT Consultants to perform bench scale screening trials of different
chemical coagulations for treatment of the concentrated CRP purge stream. The coagulants
tested were lime, aluminum salts, iron salts and polyamine. The RMT bench scale tests were
completed during January 2005.
The color removal target for the RMT study was 85%. That is, coagulation technologies were
not considered technically viable unless they could achieve an 85% or greater removal of color
from the concentrated CRP purge stream. The basis of 85% removal is effect on secondary
effluent color. A large reduction in CRP color will be necessary to see any corresponding
reduction in secondary effluent color. The 85% target equates to a potential 2000 lbs/day
removal of secondary effluent color attributed to the CRP purge stream.
None of the coagulation chemicals tried—lime, alum, ferric sulfate and polyamine—met the
85% color removal goal. Lime and alum are not technically feasible coagulants for the
concentrated CRP stream. Massive doses of chemical are required to achieve any color
reduction and the resulting sludge did not settle. Highest color removal by chemical coagulation
and precipitation was 77%. This was achieved with a combination of ferric sulfate and
polyamine. However, to obtain a floc, settling and color removal, the concentrated CRP purge
stream must first be acidified to neutral pH. Polyamine addition alone after pH adjustment
achieved only 66% color removal. Polyamine treatment of the concentrated CRP purge stream is
not desirable because the high doses required can potentially cause problems with wastewater
effluent toxicity.
During the bench scale trials, RMT collected 5-gallon grab samples of the CRP purge stream for
testing over a period of two days. RMT noted a large variability in the color concentration and
physical characteristics of these grab samples. The CRP color concentration in grab samples
doubled between the first and second day of testing. RMT also observed an increase in CRP
color during the day as the buckets of CRP sample sat in the lab between tests. Because of this
variability, chemical dose process control for coagulation/precipitation of the CRP purge may
be difficult. Color removal effectiveness in a full-scale system would vary. There is no
indication that color removal by coagulation/precipitation of the CRP purge stream will result
in an equivalent reduction of secondary effluent color.
RMT prepared chemical cost estimates for acidification of the concentrated CRP purge stream
followed by chemical coagulation and precipitation with ferric sulfate and polyamine. The
estimate assumes the design purge rate of 10 gpm. Chemical prices are based on commercial
quotes for bulk quantities.
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Projected annual chemical costs are:
Acid $175,000
Ferric Sulfate $ 28,000
Polyamine 77,000
Total chemicals $280,000
The RMT study did not include capital equipment or sludge disposal costs. Blue Ridge Paper
developed these cost estimates using EPA cost curves and other sources. The capital cost is in
excess of more than $1.7 million. This does not include the cost of special materials that may be
required to handle the high chloride content of the CRP purge stream. Estimated sludge
generation is 6.1 tons per ton of color removed. The sludge disposal cost estimate is in excess of
$90,000 per year.
Conclusion on Coagulation/Precipitation
Coagulation/precipitation is an infeasible technology for the CRP purge stream. The large
quantities of chemicals required and large sludge volume relative to color removed, makes the
use of this technology unrealistic. There is no indication that color removal by coagulation/
precipitation of the CRP purge stream will result in an equivalent reduction of secondary effluent
color. The use of polyamine may have adverse effects on secondary effluent toxicity.
Based on these factors, coagulation/precipitation of color in the CRP purge stream is not a
technically, economically or operationally feasible technology.
Solidification for Land Disposal
Solidification for land disposal refers to treating liquid waste materials with various pozzolanic
materials and/or heat to form a solid (non-liquid) waste suitable for burial in a commercial
landfill or dedicated land disposal site.
VOPAK
Vopak Industrial Services is a provider of off-site non-hazardous waste treatment and disposal,
located in Mauldin, South Carolina. VOPAK evaluated the CRP purge stream in 2002 for
solidification and landfill disposal. Disposal through VOPAK would consist of using 5,000
gallon tankers to transport the CRP purge to the treatment facility, eliminating 100% of the CRP
color from Blue Ridge Paper's wastewater. At 5,000 gallons per tanker, at least 3 tankers per
day, seven days per week, and 52 weeks per year, would be required. The cost for this disposal
would be$2.6 million- $2.7 million pez year. This estimate does not include any of the capital
costs,nor operating costs that Blue Ridge would incur in implementing this technology.
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Onyx Environmental
To verify that off-site solidification and landfill disposal was not a viable option, Blue Ridge
Paper requested a waste approval and quote from Onyx Environmental for off-site solidification
and landfill disposal of the CRP purge stream. Onyx is a commercial hazardous waste
transportation and disposal company who matches industrial wastes with appropriate recovery,
recycling or disposal options based on technical, regulatory and economic considerations. Onyx
confirmed that solidification is not a technically appropriate or economically viable disposal
option for the CRP purge stream. Quoted cost in December 2004 for commercial solidification
and landfill disposal of the CRP purge stream is $115 per ton of liquid CRP purge excluding
transportation. The quote for off-site transportation to the land disposal facility in Mauldin,
South Carolina in a 5000-gallon tanker is $855 per load including tanker cleaning, rental and fuel
surcharges.
Based on the Onyx Environmental quote, 15,000 gallons per day of CRP purge and 5000 gallons
per tanker load, the annual estimated cost for commercial off-site solidification and landfill
disposal of the CRP purge stream is:
Solidification: 15,000 gpd x 8.51bs/gallon x 1 ton/20001bs x $115/ton x 360 days/year
_ $2,639,250
Transportation: 3 loads/day x $855/load x 360 days/year = $923,400
Total annual cost in excess of$3.6 million.
Off-site hauling of the CRP purge stream will require a truck loading facility and heated storage
tank. The estimated capital cost of a truck loading and storage facility for the CRP purge stream
is in excess of$150,000
Evavoration
As part of the 2001 Color Removal Technology Assessment, Blue Ridge Paper evaluated the
feasibility and cost of treating the CRP purge stream through crystallization(i.e., solidification)
and disposal at the landfill. Basically, this technology would add one additional crystalizer,
tanks, pumps, and a plate-and-frame filter press to the CRP process. The current brine purge
stream would be further concentrated to form a crystalline solid, which would be sent to the
landfill. This would remove the entire CRP stream form the WTP influent.
The estimated capital cost for this crystallization system was $11,151,000 in January 2001. The
annual operating cost associated with the system was estimated to be$2,137,000 per year. These
estimates indicate that crystallization would not be a cost-effective option for treatment of the
CRP stream. Additional details of this process and cost estimates were included in the 2001
Color Removal Technology Assessment Report.
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Conclusion on Solidification
Blue Ridge Paper investigated commercially available technologies and services for
solidification and landfill disposal of the CRP purge stream. These have the advantage of
completely removing CRP purge stream color from the mill wastewater plant. However, none of
the solidification options are economically or operationally feasible for treating color in the CRP
purge stream.
Other Technologies — Bleaching/Oxidation
Bleaching involves use of oxidants to destroy lignin and related color bodies in wastewater.
Bleaching has the potential advantage of removing color without generating a sludge that
requires landfill disposal. At a conceptual level, bleaching appeared to be a promising
technology for cost-effective treatment of the CRP purge stream. Blue Ridge Paper investigated
bleaching of the CRP purge stream with a series of bench and field trial tests.
Ozonation
Laboratory tests were conducted during the summer of 2003 on samples of the CRP purge
stream. In the laboratory,pilot-scale batch reactors were able to achieve between 68% to 92%
decolorization of the CRP purge stream at ozone dose rates of 2.8 to 6.8 grams/liter. The
reaction time was 3 hours. A byproduct of ozone treatment of the CRP purge was foam. It is
important to note that the lab reactor foamed over during the pilot scale trial of ozone
dechlorization of CRP wastewater. The foaming was so severe it was concluded that treatment
of the concentrated CRP purge stream was not technically feasible. Dilution was necessary for
successful treatment, which significantly increases the size and operating cost of the treatment
equipment required.
Preliminary engineering estimates were prepared based on laboratory pilot-scale trials for a CRP
purge treatment system that mixed and diluted the CRP purge with other wastewaters from the
Canton Mill. The estimated capital cost was in excess of$2.7 million USD. Estimated operating
costs including power and oxygen were in excess of$2 million USD per year.
The laboratory tests represent high rate ozone treatment, which requires a liquid oxygen ozone
generator and a moderately pressurized reaction vessel with off-gas controls. The ozone
generator controls and safety systems are complex. Foaming that occurs when treating the
concentrated CRP purge stream with high rate ozone makes this technology infeasible for full-
scale application.
Clozone(Ozone and Chlorine Dioxide)—2002/2003
Blue Ridge Paper investigated bleaching technology during fall of 2002 and winter of 2003. A
proprietary package system was offered for point-of-use generation of moderate quantities of
chlorine dioxide(C102) and ozone for bleaching and decolorization of colored materials. The
name of the proprietary chlorine dioxide process is "TST" and the application of the ozone
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March 2005 CRP Color Reduction Technology Report
Page 13
technology"Clozone". The raw materials associated with the "TST" technology are sodium
chlorate,hydrogen peroxide, and sulfuric acid. The"Clozone"technology is proprietary only in
the point of application of the ozone. Ozone in the system is generated with electricity from
ambient air.
A bench-scale study of Clozone treatment of the CRP purge stream was performed in December
of 2002 with favorable results. A four-day field trial of the TST/Clozone process was then
conducted in February 2003. The field trial had two goals:
• Determine effectiveness of Clozone for CRP purge stream bleaching at design purge
rates.
• Determine optimum C1O2 and Ozone concentrations for extended field trials.
The field trial equipment included a 1000-gallon plastic tank for mixing and reacting Clozone
with the CRP purge stream. The Clozone mix water flow rate was 40 gpm and the CRP purge
rate was 10 gpm. Detention time in the mixing tank was approximately 20 minutes. The field
trial involved a series of 2-hr continuous flow bleaching tests at different C1O2 and ozone mass
dose rates and mixing tank concentrations. Bleaching chemical dose rates and concentrations
would be adjusted and allowed to run for 2 hours to reach steady state conditions in the mixing
tank. Color samples were then collected from the mixing tank influent and effluent. The trial
was therefore a series of short duration tests. There was no attempt to relate color reductions in
the CRP purge stream to secondary effluent color.
The technology removed color from the CRP purge stream by an average of 93% over the 4-day
trial. However, bleaching effectiveness was inconsistent. The dose rate of C1O2 ranged from
750 mg/L to 1700 m/L and ozone input ranged from 0 to 90 lbs/day. Some two-hr trials
involved chlorine dioxide alone without ozone. The color removal without ozone averaged 89
percent. Foaming and overflow of mix tank was observed during the trial and became a
problem. Off gassing of C1O2 from the mixing tank at C1O2 concentrations above 1200 mg/L in
the Clozone mix water was also encountered.
Operating and Clozone equipment cost estimates were provided based on the 4-day field trial.
The estimated operating cost, including chemicals and electricity, is $615,000 per year. The
quoted purchase price of the Clozone generator was $370,000. A complete Clozone equipment
installation for CRP bleaching would require a mixing tank, chemical storage tanks, CRP
transfer equipment, an off-gas scrubber and process controls. The estimated capital cost is in
excess of$1.8 million USD.
The Clozone trial indicated that chlorine dioxide alone could be effective for color reduction of
the CRP purge stream. The extra complexity, safety issues and cost of Clozone compared to
C1O2 alone are not technically or operationally justified. Clozone is an infeasible technology
for color reduction in CRP purge stream.
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 14
C1O2 Bleaching Trial - 2004
Blue Ridge Paper investigated an additional bleaching technology that involved only the use of
C1O2. A 30-day trial of CRP bleaching with C1O2 was conducted. The trial had two goals:
• Determine optimum dose rates of C1O2 for CRP purge stream bleaching at design purge
rates.
• Run full-scale CRP bleaching for a 30-day period to establish a relationship between
color reductions in the CRP purge stream and reduction in secondary effluent color.
The 30-day trial was planned to start in July 2004. However, a series of problems with
equipment, chemical contamination, and safety issues prevented any extended CRP bleaching
runs during July. The trial resumed in early August and ran for several 1 to 2 day periods
between failures of the C1O2 generator. Analysis of color samples during early August showed
little, if any, effective bleaching of the CRP.
Changes were made to improve efficiency of the C1O2 generator and a 4—day continuous CRP
bleaching trial was completed in mid-August. Color removal in the CRP purge stream during
this 4-day period was 75 to 90 percent. This was the longest continuous successful run, but it
was not long enough to see any color effect on the mill's secondary effluent. Variability in the
CRP purge stream and problems with the C1O2 generator caused unreliable bleaching
effectiveness.
Because of reliability problems with the C1O2 generator, Blue Ridge Paper shut down the trial in
late August 2004 and made arrangements with another vendor to provide C1O2 equipment. The
CRP bleaching trial was to resume in late September following the scheduled semi-annual mill
outage in the middle of that month. Unfortunately, back-to-back historic floods hit the Blue
Ridge Paper Canton Mill during September 2004. The flood disruptions required postponing
restart of CRP bleaching trials until December 2004.
Blue Ridge CRP Bleaching Trial—2004/2005
Blue Ridge Paper rented another C1O2 generator and set up an extended bleaching trial using the
mix tank from the earlier field trials. The trial started in December 2004 and was run entirely by
Blue Ridge Paper personnel. The trial was suspended during the Christmas holiday and resumed
in January 2005. The Blue Ridge CRP Bleaching Trial had several goals:
• Understand the process variables and dynamics involved in CRP bleaching with C1O2.
• Develop a process for possible full-scale application.
• Run full-scale CRP bleaching for an extended period to establish a relationship between
color reductions in the CRP purge stream and reduction in secondary effluent color.
It took most of December and the fast half of January 2005 to tune the C1O2 generator and dose
rate to obtain consistent bleaching. A static mixer was added to the inlet of the mixing tank to
improve contact of C1O2 with the CRP purge stream. There were some problems with foaming
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March 2005 CRP Color Reduction Technology Report
Page 15
and overflow of the mix tank. Off gassing of C1O2 was controlled by limiting C1O2
concentration in the mix water to 1.7 g/L or less. Variability in the CRP purge stream caused hit
and miss bleaching effectiveness. The CRP bleaching process was not easy to control. A 1 to 4
dilution of the concentrated CRP purge stream with mix water was necessary for effective
bleaching and to avoid handling problems with plugging of CRP transfer lines and equipment.
CRP transfer lines had to be frequently flushed.
The C1O2 generator was reliable and allowed a 20-day extended CRP bleaching run from
January 24 until February 12, 2005. Color reduction in the CRP purge stream during the Blue
Ridge CRP Bleaching Trial ranged from 39% to 82%. The color reduction was strongly
influenced by CRP purge rate and the capacity of the generator. At a steady CRP purge rate of 8
gpm, the color reduction averaged 79%.
Color in the 5B sewer was monitored during the Blue Ridge CRP Bleaching Trial. The CRP
purge stream mixes with the 5B sewer prior to wastewater treatment. Color reduction in the 5B
sewer averaged 45% and was statistically significant. However, there was no corresponding
statistically significant reduction in secondary effluent color during the Blue Ridge CRP
Bleaching trial.
Conclusion on CRP Bleaching Technology
Bleaching of the CRP purge stream for color proved difficult to control in extended field trials.
Bleaching effectiveness was unreliable due to variability in the CRP purge stream. None of the
CRP bleaching trials achieved a consistent color removal. Color removal at time during
extended trials was 50% or less. There is no indication that color reduction in the CRP purge
stream from C1O2 bleaching resulted in an equivalent reduction in secondary effluent color.
Based on field trials and C1O2 from the existing bulk C1O2 system at the Blue Ridge Paper
Canton Mill, the annual chemical cost for CRP bleaching would be$145,000 per year. The
estimated capital cost including mix tank, C1O2 transfer piping, an off-gas scrubber and controls
is in excess of$1.2 million.
Although-initially promising, bleaching proved to be an infeasible technology for the CRP purge
stream. Based on full-scale field trials, the level of effort and quantity of chemical necessary to
sustain a C1O2 bleaching effect on the CRP purge stream do not render any significant reduction
in secondary effluent color. Bleaching is not a technically, economically or operationally
feasible technology for color reduction in the CRP purge stream.
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March 2005 CRP Color Reduction Technology Report
Page 16
Other Technologies - CRP on Lime Precoat Filter
During summer of 2004, Blue Ridge Paper conducted a bench scale test of filtering the CRP
purge stream through lime mud from the precoat filter. This idea to use lime mud as a filter
media for the CRP purge originated from a process supervisor in the Recovery area of the mill.
This process, if successful, would largely remove the CRP purge stream from the mill sewers.
Only filtrate would be sewered. The CRP purge solids including color would be hauled to the
mill's landfill facility for disposal.
Results from the lab experiment for CRP filtering though lime mud looked promising. A short
duration trial of the idea was scheduled to take place in September 2004. Unfortunately, the
Canton Mill was hit by back-to-back historic floods during September. The CRP on lime precoat
filter trial was postponed until 2005 following completion of CRP bleaching trial work.
Three 4-hour and one 36-hour trials of CRP filtering through lime mud on the lime precoat filter
were conducted in February and March 2005. The full CRP purge stream at an average rate of
10 gpm was applied to the No. 6 precoat filter during each trial. Lune mud and filtrate samples
were collected and analyzed for color removal and dissolved salts. Color reduction results for
the CRP purge stream were mixed. Average color removal was 77 percent, but ranged from 34
to 94 percent. Because the CRP on Lime Precoat Filter trials were short duration, there was no
attempt to relate color reductions in the CRP purge stream to secondary effluent color.
Conclusion of CRP on Lime Precoat Filter
Based on field trial results to date, the idea to filter CRP through lime mud is an unproven
technology for color reduction. Several equipment and technical issues remain to be quantified
including:
• effect of high chlorides in the CRP purge on lime mud precoat filter equipment
• storage of CRP during periods when the No. 6 lime precoat filter is down(about 20% of
mill operating time)
• release of CRP color from lime mud in the landfill and possible return of this color to the
mill wastewater plant in landfill leachate.
The technical, economic and operational feasibility of treating the CRP purge stream on the lime
precoat filter is undetermined. More trial work is needed to reach a definite conclusion.
Other Technologies —Proprietary Third Party
Blue Ridge Paper Products contacted various waste treatment technology vendors to investigate
options for color treatment of the CRP purge stream. These are discussed below. Some of the
vendors conducted bench scale tests. Others used information on the physical and chemical
characteristics of the CRP purge stream to make an evaluation of technical and economic
viability.
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March 2005 CRP Color Reduction Technology Report
Page 17
None of the proprietary technologies evaluated are technically, economically or operationally
feasible for color removal from the CRP purge stream.
Wet Air Oxidation and PACT-2002
Blue Ridge Paper investigated a patented wet air oxidation and powered activated carbon
treatment or PACT technology. This technology is typically used on high strength organic waste
streams. In this technology, powered activated carbon- or PAC- is added to the waste stream to
absorb waste constituents of concern. The PAC is then settled and regenerated in a wet air
oxidation unit. During regeneration, organics absorbed on the PAC are destroyed or broken
apart so they can be more easily removed in subsequent biological wastewater treatment steps.
The wet air oxidation technology can be directly applied to concentrated waste streams. In this
application, PAC is not used. Organics in the high strength liquid waste are directly oxidized.
It seemed that the technology might be applicable for the removal and oxidation of color
constituents in the CRP purge stream. However, there were no existing similar treatment
installations for comparison and the ability to conduct bench scale tests was non-existent. The
wet air oxidation technology involves moderately high temperatures and pressures (600 deg F at
100 psig), which would add additional thermal load to the Blue Ridge Paper wastewater
discharge. The technology is also capital equipment intensive. Preliminary equipment cost
estimates for a CRP purge stream treatment system ranged from$1.7 to $2.9 million and
operating cost estimates were on the order of$1000 per day.
To refine preliminary cost estimates and determine if the technology would actually work, a
series of rather expensive field trials were proposed. One significant concern, besides cost of
trials, was the corrosive effect of high chlorides in the CRP purge stream on pilot scale
equipment. Blue Ridge Paper decided that it was better to direct such field trial expenditures
towards CRP bleaching and other technologies.
High Temperature Peroxide Oxidation-2002
Blue Ridge Paper evaluated the use of extreme temperature and pressure with hydrogen peroxide
to decolorize the CRP purge stream. Samples were sent for bench scale testing. No color
reduction was observed. It was then proposed to perform an additional laboratory trial using
evaporation enhancements to the technology. However, a fee$25,000 for the additional work
was required. Again, there weren't any existing similar treatment installations for comparison
and there was no indication that the second fee-trial would be successful. Based on the
preliminary results and commercial trial costs, Blue Ridge Paper decided to suspend further
investigation of this technology.
Filter Papers - 2002
Filter papers have been used in machining and other industries to separate solids and other
contaminates from process fluids and wastes. The spent filter paper and captured solids are then
processed for material recovery or shipped to a landfill for disposal. The filter paper process can
March 2005 CRP Report Final.doc

March 2005 CRP Color Reduction Technology Report
Page 18
be continuous or batch. Blue Ridge Paper evaluated a proprietary technology using treated paper
to remove color from the CRP purge stream. The treated paper coagulates and filters solids
including color bodies from the waste.
Bench-scale tests of the filter paper were run at the Canton mill. The filter paper removed
approximately 90% of the color from the CRP purge stream. There were no pilot or full-scale
operations using this technology for color removal. The equipment required for a full-scale
system for the CRP purge stream is not well defined.
A budgetary quote of$1 to 2 million per year for filter paper to treat the CRP purge stream was
provided. Capital cost of equipment was not estimated. In addition, the filter paper technology
would generate 2.25 tons/day, or an additional 820 tons/year of waste paper requiring landfill
disposal. Although this technology did initially appear promising, the costs for the treated paper,
as well as costs for additional equipment and waste disposal prevent this technology from being
economically viable. It was determined that the filter paper technology was not a commercially
competitive option for Blue Ridge Paper. A field trial was not pursued for this technology.
Proprietary Oxidation Technology-2002
Blue Ridge Paper evaluated a proprietary oxidation technology that could possibly destroy lignin
compounds and color in the CRP purge stream. Blue Ridge Paper provided CRP purge stream
samples for bench scale testing. The bench scale work was not effective for color removal and
Blue Ridge Paper was informed that the CRP purge stream was not a feasible application for this
technology.
Ultra/Nano Filtration—2002
Several manufacturers of ultra/nano filtration equipment were contacted concerning color
removal from the CRP purge stream. When these companies received detailed information on
the characteristics of the CRP purge stream—especially the very high dissolved salt content—
they expressed serious reservations about the viability of ultra/nano filtration for this
application. The technical issue was salt plugging of the filter membranes. None of the
companies offered to do bench scale tests or field trials. Ultra/nano filtration is not a feasible
technology for the CRP purge stream.
Summary/ Conclusions
Blue Ridge Paper Products Inc. has and continues to evaluate every possible methodology
available for the effective treatment of the CRP purge stream. This report illustrates a concerted
effort to deal with this color source and to evaluate many possible alternatives. As specific
details concerning the use of each technology have been examined in more "real world"
application terms, significant problems have arisen. These issues are hugely important from a
logistics, technology, performance and overall effectiveness standpoint. A technology that
doesn't work in a real, full-scale application for the significant reduction of color provides no
benefits to the water quality. Continued improvement in secondary effluent color is the overall
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March 2005 CRP Color Reduction Technology Report
Page 19
objective of Blue Ridge Paper, those interested in these issues, and the NPDES Permit for the
Mill.
In the testing of the potential technologies for color reduction in the CRP purge stream, even in
cases where a significant color reduction was indicated (still not near the 85 % goal), no
statistically significant reduction in the mill's secondary effluent could be demonstrated. The
character and pollutant content of the CRP waste stream represents an already concentrated
"waste" from an extensive, in-mill effort to reduce color. The purge stream is the wastewater of
a wastewater treatment process. By its very nature it carries the pollution that was removed from
another wastewater stream so that stream can now be recycled. The ability to "further"treat
such a concentrated stream and remove its impact from the overall mill discharge is a .
challenging and almost overwhelming engineering problem. The day-to-day variation in mill
effluent color is greater than the contribution of color from the CRP purge stream. The actual
amount of color related to the CRP purge discharge results in only about 2000 lbs/day in the
secondary effluent. At 42,000 lbs./day of color in the discharge, this represents only about 5 %
of the loading. While the Canton Mill has essentially reduced its color discharge by over 90 %
from the late 1980s, the CRP purge stream is a difficult color source to manage and additionally
reduce.
The overall objective of meeting NPDES permit requirements regarding CRP color can be
illustrated by the following sentence in the permit condition: "The CRP analysis shall
concentrate on the technical, economic and operational feasibility of implementing the
applicable technologies on all or a portion of the purge stream." Blue Ridge Paper takes very
seriously the need to further reduce color in the Canton Mill wastewater discharge and has taken
a very comprehensive look at not only the technologies identified in the permit condition, but
many more. At this juncture, Blue Ridge Paper cannot recommend the implementation of any of
the evaluated technologies. The search for an effective CRP management strategy should
continue, and the company is committed to doing that in conjunction with mill-wide color
reduction efforts.
Blue Ridge Paper has diligently placed into operational use all of the applicable technologies
identified by the TRW (Technology Review Workgroup) during the 2001 permit renewal process
that wereddentifted as "highest certainty" steps and those that were appropriate and identified as
"reasonable certainty" steps. The CRP treatment consideration was identified by the TRW as
having reduced potential for application as compared to the"highest certainty" and "reasonable
certainty" items and is referred to in TRW reporting and the permit as "technologies for further
color reduction." The NPDES permit specifically identifies color treatment of the CRP purge
stream as a "lowest certainty"method for additional effluent color reduction.
Initial consideration of this waste stream identified a number of possible treatment approaches.
The trials summarized in this report and used to evaluate potential treatment approaches have
frankly raised many questions, eliminated several technologies from reasonable consideration
and have failed to identify any one or combination of technologies that can be implemented at
this time. As Blue Ridge Paper continues to evaluate technical approaches to the CRP purge
stream, the company remains committed to finding ways to further reduce color overall in the
mill effluent and to meet all the conditions of the NPDES Permit.
March 2005 CRP Report Final.doc

o � C � o � � �
BLUE RIDGE
PAPER PRODUCTS INC:
MAR - 1 2005
28 Feb 2005
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
Certified ar
Return Receipt Requested
7099 3220 0007 0371 1858
Mr. D. Keith Haynes
Environmental Specialist
North Carolina Department of Environment
and Natural Resources
Asheville Region Office
Division of Water Quality
2090 US Highway 70
Swannanoa, North Carolina 28778
Subject: NPDES No.NC0000272
2005 Study Plan— Canton Mill Thermal Assessment
Blue Ridge Paper Products, Inc.
Canton, North Carolina
Dear Mr. Haynes—
Enclosed is the subject plan required under Part I, Condition A.13 of the NPDES permit for the
Blue Ridge Paper Products mill in Canton, North Carolina.
Blue Ridge Paper is required to submit a thermal variance report under Section 316a,of the Clean
Water Act as part of the May 2006 application to renew the NPDES permit for the Canton Mill.
We have selected a team lead by Dr. Larry Wilson of the University of Tennessee, Department
of Forestry, Wildlife and Fisheries to complete fieldwork and prepare the 316a Thermal Variance
Report.
Dr. Wilson and the University of Tennessee are key members of the Pigeon River Restoration
Project. The focus of this project is re-introduction of non-game species to the Pigeon River
following the substantial improvements in water quality associated with the Canton Mill
modernization in the 1990s. Re-introductions in the Tennessee portion of the Pigeon River
began,in 2001 and were expanded to North Carolina portions of the river in 2004. The
restoration project is cooperative effort between state and Federal water quality and wildlife
agencies in Tennessee and North Carolina. The project receives funding support from both
public and private sources including Blue Ridge Paper. General information on the Pigeon 3�
River Restoration Project is also enclosed.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

Ms. Coleen Sullins, NC DENR DWQ
28 Feb 2005, Page 2
Dr. Wilson and Blue Ridge Paper met with Mr. Bryn Tracy of the DENR DWQ Biological
Assessment Unit on January 19, 2005 in Knoxville, Tennessee. The purpose of this meeting was
to discuss the scope of the 2005 study and proposed changes from previous studies in 1995 and
2000. We greatly appreciate Mr. Tracy's input to development of the 2005 Study plan.
Please contact us if you have questions regarding this submittal. The project team will meet in
Knoxville, Tennessee on March 11, 2005 to develop fieldwork schedules and sampling method
training for the University field crews.
Sincerely- ,
Paul S. Dickens Bob Williams
Manager, Environmental Affairs Director, Regulatory Affairs
828-646-6141 828-646-2033
dickei)@blueridgei)ai)er.com [e-mail]
Enclosures: 2005 Study Plan- Canton Mill Thermal Assessments
Information on Pigeon River Restoration Project
cc: w/enclosures:
NC Division of Water Quality(2 copies)
Central Files
1617 Mail Service Center
Raleigh, North Carolina 27669-1617
Ms. Coleen H. Sullins
Deputy Director
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh,North Carolina 27669-1617
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising.Your Expectations

Ms. Coleen Sullins, NC DENR DWQ
28 Feb 2005, Page 3
Mr. Bryn H. Tracy
Environmental Biologist
Biological Assessment Unit
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27669-1617
Mr. Jonathan Burr
TDEC—Water Pollution Control
Knoxville EAC
2700 Middlebrook Pike
State Plaza Building, Suite 200
Knoxville, Tennessee 37921
Dr. J. Larry Wilson
Dept of Forestry, Wildlife and Fisheris
Institute of Agriculture
The University of Tennessee
274 Ellington Plant Sciences Bldg
Knoxville, Tennessee 37996-4563
Internal Distribution
C. File—Water
Engr File—Water
Bob Williams
Glenn Rogers
Derric Brown
Bob Shanahan
Steve Single
John Pryately
Lori Cooper
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

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

2005 Study Plan-Canton Mill Thermal Assessment
Page 2
Task 1- Conduct Biological Surveys to Support a Continuation of the Mill's Thermal Variance
During July and August 2005,UTK Nvill survey fish and macro-invertebrates at the following 13 stations on
the Pigeon River in North Carolina(I1 stations) and Tennessee(2 stations).River mile refers to distance
upstream of the confluence of the Pigeon River with the French Broad River in Tennessee.
River Mile Location
64.5 Upstream of mill
63 Fiberville
61 D.O. augmentation station
59 Upstream of Clyde
55.5 Downstream of Clyde
54.5 Downstream of Waynesville WWTP
52.3 Old Rt 209
48.2 Ferguson Bridge
42.6 New Hepco Bridge
Trib Richland Creek
Trib Jonathan Creek
24.7 Waterville(TN)
19.3 Groundhog Creek-Bluffton(IN)
These data will be augmented(where applicable)with spring and fall fish and invertebrate data compiled from
Pigeon River samples that have been,and will continue to be,collected as part of an on-going Pigeon River
Restoration Project since 2001. Collection procedures to be used at each location will follow methodologies
established and presently used by TVA,TWRA,'IDEC,and EPA;specific protocols include TVA 2004 (fish
sampling),TVA 2002 (benthic sampling),and Barbour et al. 1999 (benthic sampling). Collection techniques
will also be consistent with NCDENR sampling guidelines (NCDENR 2001,2003) and are comparable to
those used during previous thermal assessment data collections (EA-EST,Inc. 1995,2000,2001a,2001b).
The 2005 study will be restricted to fish,macro-invertebrates,and habitat evaluation and will include
measurement of routinely-collected field physical/chemical parameters (i.e., temperature,DO,conductivity,
and water transparency [Secchi depth (visual) and/or turbidity levels (meter)]. Field data will be summarized
and used to assess the biological communities at selected sites and may include various comparative
descriptors such as species richness and composition,indicator species,trophic function,abundance and
condition,and reproductive function.These categories, and specifically the individual parameters (metrics),
are often used to determine index of biotic integrity(IBI) scores;however,care must be taken to ensure the
protocols used are designed for the specific stream/river sampled.
Task 2-Representative Important Species
Based on collections from Task 1,representative important species (RIS)will be identified to represent a
range of thermal tolerances,trophic levels,and recreational importance. It is important to note that as a
human-activity impacted river,not all species present in reference watersheds or historically found in the
Pigeon River may be collected during the 2005 thermal variance study.The RIS determination will be based
on life history characteristics of native fish presently inhabiting the Pigeon River and from historically
documented records.Native species of recreational importance include smallmouth bass,largemouth bass,
rock bass,and channel catfish.Targeted trophic level groupings (and example species)include herbivores
(stoneroller,),insectivores (river chub,mottled sculpin,bluegill,northern hogsucker,black redhorse),and
piscivores (smallmouth and largemouth bass,rock bass, channel catfish)(Barbour et al. 1999).Based on the
EPA protocols,most of the above species are listed as `tolerant'to `intermediate tolerance' (depending on
region of the country) based on thermal variations while a few(northern hogsucker,black redhorse,mottled
sculpin,river chub) are generally considered thermally sensitive,i.e., intolerant'.

2005 Study Plan-Canton Mill Thermal Assessment
Page 3
Task 3 -Update the Previously Developed Temperature Model and Low Flow Statistics
A temperature model has previously been developed for the discharge of the Blue Ridge Paper Products
(BRPP) Canton Mill to the Pigeon River(EA Engr 2001a). Model calibration-was based upon data collected
by mill personnel for the 6-year period 1994 to 1999.Additional verification of the diel temperature range was
provided by the deployment of continuously recording thermographs at Pigeon River locations during July
2000.As part of the year 2005 316(a)Temperature Variance Study,the temperature model will be further
verified by making comparisons between model predictions and more recent temperature data collected by
mill personnel and deployed thermographs.
Pigeon River temperature data collected by mill personnel since 1999 include daily values at Canton,
Fiberville,and Clyde,and weekly values at Hepco.Additional temperature data will be obtained by six
thermographs which will be deployed for a 4-6-week period during July and August 2005.The thermographs
will be deployed during the first biological survey and retrieved during the second survey.They will be
deployed in the river at six specific locations: Canton (upstream of mill discharge),mill discharge,Fiberville,
Clyde,Richland Creek,and Crabtree Creek.
The model calculates at an hourly time step using hourly meteorological data for surface heat exchange.
Hourly air temperature,wind speed,and solar radiation data are available from the mill.The surface heat
exchange calculation also requires relative humidity,which will be obtained from the NOAA station at
Asheville.The model is executed using the reported discharge temperature and flow data at the mill and using
the USGS river flow data at Canton and Hepco.
The Pigeon River temperature model will be executed for the duration of the summer 2005 thermograph
deployment period,and for an extended period corresponding to the collection of river data by mill
personnel.A standard error of estimate between predicted and observed temperatures will be calculated and
compared to previous values determined during the original model calibration/verification.The model
calibration will be adjusted if deemed appropriate.
The re-verified Pigeon River temperature model will be used in support of the thermal variance study.Year-
long model run outputs can be summarized as daily/weekly mean temperatures or other intervals of interest
as a function of season.Worst-case mill discharge or receiving water conditions can also be presented.
Low flow frequency statistics including the 30Q2 and 7Q10 will be updated as part of the study.The USGS
Canton and Hepco station data will be obtained for the historical period of record.The frequency statistics
will be generated using a log Pearson program that has previously been verified against flow statistics
generated by the USGS.The program allows multiple daily averaging periods and yearly return intervals to be
used. Comparisons can also be made between the historical period of record and more recent periods to
demonstrate changes in the runoff characteristics of the watershed.
Task 4-Prepare a 316(a) Demonstration Report
Based on the data collected during Task 1, the results of the temperature model(Task 3),an updated review
of the thermal tolerance literature,and any other applicable data (e.g.,NC DENR data,Progress Energy
data),UTK will prepare an updated 316(a) Demonstration Report(i.e., "Balanced Indigenous"Report).This
report will address the central question posed by Q316(a) of the Clean Water Act,i.e.,does the thermal
discharge in question allow for the maintenance or establishment of a balanced indigenous population (BIP)
(community) of aquatic organisms?

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

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on River Restoration Project Page 2 of 3
Pigeon River Topography
The headwaters of the Pigeon River are located at Sam Knob on Black Mountain, at an elevation of
approximately 6130 feet. Sam Knob is 30 miles southwest of Asheville, North Carolina. The river flows from
Sam Knob north to Canton, North Carolina. Blue Ridge Paper Products, Inc. is located on the river in Canton.
The Pigeon River flows through the papermill at Canton and then along Interstate 40 for approximately 25 river
miles to Waterville and the Progress Energy Hydroelectric Dam.
From Canton to Waterville, the elevation changes from 2580 to 2258 feet. A small bypass channel curves
around the dam and runs 12.5 river miles before merging with the water being released from the dam aquaducts
at the Tennessee State Line. The Pigeon River then flows 4.5 river miles to Hartford, Tennessee. The elevation
at Hartford is about 1260 feet. This 160 foot drop in river elevation produces class III and IV rapids.
Progress Energy and the 12 Hartford white-water rafting companies work together to plan recreational water
releases from the Waterville Dam for rafting. After passing through Hartford, the Pigeon flows through Denton
(1800 ft) and Newport (1040 ft),Tennessee. The Pigeon empties into the French Broad River at an elevation of
about 1000 feet. Due to these elevational changes, the Pigeon River is divided into two regions or ecoregions; a
high gradient stream from Sam Knob to around Denton, Tennessee and a low gradient stream from Newport,
Tennessee to the French Broad River.
A Brief History of the Pigeon River
A papermill was established in Canton, North Carolina on the Pigeon River in the early 1900's. The mill has
been operated in that locality for about 100 years. After 1983, Champion Paper began to upgrade the papermill
to reduce emissions going into the river. Blue Ridge Paper Products, Inc. bought out Champion and completed
the upgrades in equipment and the reductions in emissions based on EPA criteria. Blue Ridge Paper is an
employee-owned and operated facility and has spent millions of dollars to upgrade the papermill. This
corporation continues researching methods to increase efficiency and reduce any adverse impacts on the Pigeon
River.
UTK Fisheries began working with Blue Ridge Paper in 2001. A plan was launched to reintroduce native non-
game fish species into the Pigeon near Newport, Tennessee. The Tennessee Department of Environment and
Conservation (TDEC),Water Pollution Control Division provided advice and assistance in collecting and
relocating fish into the Pigeon River. In early 2004, the fish reintroduction project was expanded into North
Carolina with the aid of the North Carolina Wildlife Resources Commission.
Native Fish Reintroduction
After 1993, the Pigeon River water quality and water clarity improved. Larger, native fish species were then
able to recolonize the Pigeon River from its tributaries. The river was surveyed yearly for fish species by TVA,
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o m River Restoration Project Page 3 of 3
TWRA and TDEC-WPC. These organizations realized that several of the smaller native fish species had not
returned to the Pigeon. In 2001, in conjunction with UTK Fisheries, US Fish&Wildlife Service, USGS and
Blue Ridge Paper, these Tennessee state agencies put together a list of native, non-game fish species missing
from the Pigeon River.
The first species of fish to be collected and relocated were the Bluebreast Darter, Blueside Darter and Guilt
Darter. And in 2002, additional species were added; Stargazing Minnow and Smoky Madtom(small catfish). In
2003, the Stripetail Darter and the non-parasitic American Brook Lamprey and Mountain Brook Lamprey were
also collected for relocation into the Pigeon River.
In 2004, with financial support from Blue Ridge Paper Products, the Pigeon River Restoration Project was
expanded to include the Upper Pigeon River in North Carolina. The project team met in March 2004 and invited
the North Carolina Wildlife Resources Commission to participate. An additional list of missing fish from North
Carolina's half of the Pigeon River was assembled. Efforts to relocate Saffron Shiners, Mirror Shiners, Silver
Shiners and Telescope Shiners began soon after this meeting. UTK Fisheries and TDEC-WPC headed up the
collection efforts. NCWRC assisted in the collections and relocations of these shiners to the Pigeon River a few
miles downstream from the papermill.
Native Freshwater Mussel & Snail Reintroductions
Native freshwater snails (1996) and mussels (2000) were reintroduced into the Pigeon River near Newport,
Tennessee. From 2000-2004, about 20,000 individuals from 3 snail genera were released; lo, Pleurocera,
Leptoxis. The latter two genera are reproducing and spreading downstream in the Pigeon. Also during the past
few years, around 200 individuals from 9 different mussel species have been reintroduced. The common names
for these 9 species are the Elktoe, Threeridge,Purple Pimpleback, Spike, Wavyrayed Lampmussel, Plain
Pocketbook, Kidneyshell, Pimpleback and Creeper. The life cycle of the mussel requires a host fish species to
carry the free-living mussel larvae. Studies need to be conducted to determine if mussel reproduction is
occuring and whether or not the Gilt Darter or any darter present in the Pigeon is a successful host species for
any or all of the mussel species.
©2004 University of Tennessee, Dept. of Forestry, Wildlife &Fisheries
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