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Home My WebLink AboutNC0000272_NPDES_Draft_Permit 1� State of North Carolina e� Department of Environment IVA and Natural Resources Division of Water Quality L Michael F. Easley, Governor NCDENR William G. Ross, Jr., Secretary Gregory J. Thorpe, Acting Director August 3,2001 Mr. Robert Shanahan Vice President-Mill Manager Blue Ridge Paper Products P.O.Box 4000 Canton,North Carolina 28716 Subject: NPDES Draft Permit Permit No.NC0000272 Blue Ridge Paper Products Inc. Haywood County Dear Mr. Shanahan: Blue Ridge Paper Products Inc.applied for an NPDES permit renewal on February 26,2001. The Division of Water Quality's original schedule for conducting a public hearing prior to July 31,2001 was postponed in order to allow the EPA Tech Team and the Technology Review Workgroup the necessary time to incorporate the findings of a third party evaluation of the Canton Mill,sponsored by the Clean Water Fund of North Carolina,American Canoe Association,Western North Carolina Alliance,Dead Pigeon River Council,Appalachian Voices,Tennessee Environmental Council, Southern Appalachian Biodiversity Project,Dogwood Alliance and the National Forest Protection Council. The EPA Tech Team has completed their report and provided the Technology Review Workgroup with the`potential' color reductions available through the application of the identified process improvements. Based on this report,the Technology Review Workgroup developed the `regulatory' basis for additional color reductions in this permit cycle. Now that the EPA Tech Team and the Technology Review Workgroup's color recommendations are final,the Division of Water Quality has prepared this draft permit and scheduled a public hearing for September 6,2001 (additional details below). After issuing a"pre-draft"permit,the Division of Water Quality prepared this draft permit and is once again soliciting comments from the Environmental Protection Agency,the State of Tennessee, the City of Newport, Cocke County, and other concerned stakeholders. The Division reviewed and considered all comments received during the"pre-draft" comment period and modified the"pre-draft"permit and fact sheet accordingly. The modifications reflected in this draft permit include the following: The dioxin monitoring special condition has been modified. The dioxin monitoring special condition in the pre- draft permit allowed the permittee to split samples. If the analysis of either sample was below the minimum level,then the quality was considered zero for compliance purposes. The Division received concerns over this allowance and has modified the condition accordingly. The decision to split samples is at the discretion of the permittee, if samples are split,the permittee must report both values and compliance shall be judge on each sample independently. ➢ Dates that have passed have been deleted from the Best Management Practices Special Condition. Special Condition A. (8.)Requirements for Color Analysis and Compliance have been added. Based on the recommendations of the Technology Review Workgroup and the EPA Tech Team Report,the Division of Water Quality has developed the recommendations for additional color removal over the term of the permit. The color reductions contained in this condition represent a 19%to 29%reduction in the current permitted color load. After Blue Ridge Paper has implemented the process improvements necessary to achieve color reductions within the targeted range,Blue Ridge Paper will evaluate the feasibility of complying with North Carolina's 1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617-TELEPHONE 919-733-5083/FAX 919.733-0719 AN EQUAL OPPORTUNITY AFFIRMATNE ACRON EMPLOYER-50%RECYCLED/10%POST-CONSUMER PAPER VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES Permit Number: NC0000272 color standard. Then during permit renewal process in 2006,the Division of Water Quality and the NPDES Committee will evaluate what additional reduction,if any, are required in order to achieve compliance with North Carolina's color standard. Below are the Division's responses to comments received on the pre-draft permit. There were concerns over the language in the Best Management Practices Special Condition,these include: - Special Condition A. (6.) Section A. 1,the wording"to the maximum extent possible as determined by the mill. The language and conditions set forth in the Best Management Practices Special Condition were developed by the EPA as part of the new Effluent Guidelines for the Pulp and Paper Industry. After extensive research and gathering of public comment, the EPA stipulated an industry standard for Best Management Practices. The language contained in Special Condition A. (6.) is consistent with the industry standard as published in the Code of Federal Regulations. Since Blue Ridge Paper meets or exceeds the Best Management Practices standards,the Division does not feel that requiring a higher standard is justified at this time. - Special Condition A. (6.)Section E.3,the language"failure to take the actions required by Section E.2 as soon as practicable will be a permit violation". The comment was made that this language is unenforceable. In addition to the comment made for Special Condition A. (6.)Section E.3,it is the Division's understanding that the language in Section A.(6.)E.3 "failure to take the actions required by Section E.2 as soon as practicable will be a permit violation", is a 'good faith' condition and that any gross violations of this condition are enforceable. - Monthly reporting of'action' level exceedence was recommended. In addition,to the comment made for Special Condition A. (6) Section E.3,please refer to the Best Management Practices Special Condition Paragraph E. This condition requires that Blue Ridge Paper submit an annual report to the Division of Water Quality that summarizes Best Management Practices monitoring and action levels. The longer time frame (annual as opposed to monthly)associated with the annual submittal required in Special Condition A. (7.)provides the Division with a more representative analysis of operations at the mill and is better suited for analysis and conclusions. Therefore, the Division feels that annual reporting is appropriate. Comments were made regarding the daily maximum BOD5 limit proposed in the pre-draft permit. The Division's review of the instream dissolved oxygen data indicates that the limits and conditions in the permit are protecting the dissolved oxygen standard in the River. Additionally,the Division's model predicts and actual data supports that the lowest dissolved oxygen concentrations occur at river mile 57.7,which is above Hepco. The Division received comments regarding the need for nutrient limits in permits above the lake. The Division has no evidence that nutrients are a concern in this watershed. Additionally,Blue Ridge Paper's nutrient loading is relatively low,however,nutrient monitoring will continue as a condition for this permit in order to assess Blue Ridge Paper's nutrient loading to the River. The Division received comments regarding the removal of the monitoring station at river mile 53.5. Blue Ridge Paper currently is monitoring color,temperature,and dissolved oxygen at river mile 53.5. Temperature and dissolved oxygen monitoring at this point is required according to the NPDES permit issued to the City of 'Waynesville. Since Waynesville is already required to monitor this station, it is the Division's recommendation that additional monitoring of temperature and dissolved oxygen by Blue Ridge Paper is not appropriate. The color monitoring at this station was originally implemented in order to assess the impacts from Clyde's,the Waynesville and Richland Creek. With the removal of Clyde's discharge,the Division feels that the continued monitoring of color at river mile 62.9(Fiberville)and river mile 42.6(Hepco)is sufficient. D The Division received a request to require dioxin isomer monitoring of the octachlorinated dioxin isomers at the internal outfalls,sludge and landfill leachate. The Division also received opposing comments suggesting that the dioxin and furan monitoring proposed in the pre-draft unnecessary. During the previous permit cycle,Blue Ridge Paper was required to monitor 15 isomers of dioxin and furans. Based on a review of this data and the Permit Number: NCO0OO272 public comments received,the Division recommends continued monitoring of 2,3,7,8,TCDD and 2,3,7,8 TCDF on the effluent, sludge,landfill leachate, and the influent to the wastewater treatment plant. Please review the draft permit and fact sheet carefully and submit comments to DENR—D WQ NPDES Unit. This draft permit should not be interpreted as the Division and NPDES Committee's final decision. A 30-day public comment period follows the release of this draft permit and will close at the discretion of the hearing officer and will be announced at the beginning of the public hearing to be held on September 6,2001. The details on where and when the hearing will be held is listed below: Public Hearing on regarding the Blue Ridge Paper Products Canton Mill's NPDES discharge will be held: September 6,2001 @ 7:00 pm at the Tuscola High School Auditorium 564 Tuscola School Road Waynesville,North Carolina Haywood County If you have any questions concerning the draft permit for your facility,please call me at(919)733-5083, extension 508. Sincerely, Michael S. Myers, EI NPDES Unit cc: Central Files NPDES Files Aquatic Toxicology Unit Marion Dee;hake — North Carolina Environmental Management Commission, NPDES Committee Jerry Wilde— Dead Pigeon River Council 402 W. Broadway Newport, Tennessee 37821 Forrest Westall - Asheville Regional Office/Water Quality Section Dan Oakley — North Carolina Attorney General, Environmental Division Keith Haynes -Asheville Regional Office/Water Quality Section Rob Lang — Compliance and Enforcement Unit Diane Reid— Classification and Standards Unit Roosevelt Childress Jr. — Environmental Protection Agency, Region IV Karrie-Jo Shell —Environmental Protection Agency, Region IV Don Anderson— Environmental Protection Agency, Headquarters Mark Perez —Environmental Protection Agency, Headquarters Justin P. Wilson— Deputy to the Governor Tennessee State Capital, Suite G10 Nashville, Tennessee 37243 Paul Davis —Tennessee Division of Water Pollution Control 6th Floor, L&C Annex 401 Church Street Nashville, TN 37243-1534 Charles Lewis Moore — County Executive Cocke County 360 Main Street, East Newport, Tennessee 37821 David Jenkins—American Canoe Association 7432 Alban Station Boulevard,Suite B-232 Springfield,Virginia 22150-2311 Permit Number: NCO000272 Hope Taylor- Clean Water Fund of North Carolina 29 'h Page Ave Asheville, North Carolina 28801 David McKinney—Tennessee Wildlife Resources Ellington Agricultural Center P.O. Box 40747 Nashville, Tennessee 37204 Jonathon E. Burr—Tennessee Division of Water Pollution Control Regional Environmental Assistance Center 2700 Middlebrook Pike, Suite 220 Knoxville, Tennessee 37921 Robert Williams—Blue Ridge Paper 175 Main Street P.O.Box 4000 Canton,North Carolina 28716 Derric Brown—Blue Ridge Paper 175 Main Street P.O.Box 4000 Canton,North Carolina 28716 Patsy R.Williams—Chairman Newport/Cocke County Tourism Council 360 East Main Street Court House Annex,Suite 141 Newport,Tennessee 37821 Dianne Keys—Newport/Cock County Tourism Council 360 East Main Street Court House Annex, Suite 141 Newport,Tennessee 37821 Timothy L.Dockery—Director City of Newport Parks and Recreation Department 433 Prospect Avenue Newport,Tennessee 37821 A.Dean Williams—Coordinator Newport/Cocke County Economic Development Commission 433 Prospect Avenue Newport, Tennessee 37821 Ray Snader—News Director WNPC Radio AM/FM 377 Graham Street Newport,Tennessee 27821 Permit Number: NC0000272 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In :Epli�anc�eith��he ov}sio' n ofI h arolina/33g ra�Statute 143-21� lawful s n ards and regulatons promlg`ated an$ adopted b!y e North dar lira Environmental Management on mission, and the Federal Vlkate Po lu{ion-Contt� ct, as amended, Blue �"dge Paper Products II c. is ereL authorize to di charge wastew, as fyo r a facility I cated at Blue Ridge Paper Products Inc. Canton Mill Wastewater Treatment Plant Off Highway 215 Canton Haywood County to receiving waters designated as the Pigeon River in the French Broad River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective This permit and authorization to discharge shall expire at midnight on November 30, 2006. Signed this day � RA Gregory J.Thorpe,Acting Director Division of Water Quality By Authority of the Environmental Management Commission Permit Number: NC0000272 SUPPLEMENT TO PERMIT COVER SHEET Blue Ridge Paper Products, Inc. is hereby authorized to: 1. Continue operation of a 29.9 MGD wastewater treatment plant for the treatment of wastewater associated with the Blue Paper Products Inc. pulp and paper mill, the Town of Canton's chlorinated domestic wastewater and landfill leachate. The treatment system consists of the following treatment units: Grit Chamber Bar Screen iPd�nps • Polymer``a tioD • pH control injection r 2SO4 b ck p) • Threeiprimary c an ters • Nutrient ee� • Aeration basins • Three second clarifiers Resi al bel presses ffTneat flo measurement • Cascade post aeration with oxygen injection • Instream oxygen injection facilities The facility is located at the Blue Ridge Paper Products WWTP, off Highway 215, Canton, Haywood County, and; 2. Discharge treated wastewater from said treatment works at the location specified on the attached map through outfall 001 into the Pigeon River, which is classified C water, in the French Broad River Basin. . RA K. y k OutFall_001 �. w y 5 \ i _ 1• If Cr / f • Blue Ridge Paper's Cuffall Facility Information French Broad Hydrography Blue Ridge Paper Products, Inc. U�SteCgid:GS Canton NR NC0000272 Subbasin: 04-03-05 Hghways Haywood County M.INCIpaI BOUndafle5 xa �• '� 1 0 County Boundary N 0.5 0 0.5 1 Miles BLUE RIDGE PAPER PRODUCTS INC. A N Permit Number: NC0000272 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge treated industrial, municipal,stormwater and landfill wastewater through outfall(s) 001. Such discharges shall be limited and monitored by the Permittee as specified below: .QEfflrient Characteristks EffluenYLimits Monitoring Retautrements', —4.. e. . q.. — _ Ada' Morithly Aaily, Measurement1,,Sample .Ype". Sample gver`a a Maximum Fre uenc :' 1 f 9 9, y, Location. y Flow 29.9 MGD Continuous Recording I or El BOD, 5-day,20°C 3205 lb/day 10897 lb/day Daily Composite I,El Total Suspended Residue 12549 lb/day 49560 lb/day Daily Composite I,El NH3-N Daily Composite El AO? 56,9-Wday 2822.2lb/,day, Daily,—Composite, FT Co)or' \ \ \ Dailyl _ Oompsisite E. Dissolved Oxygaq \ \ ` / /\ Dailyl I Grab Ei Temperature \ \ ) Daily I I Grab I El p I I i I / J / / \ \ Daily Grab I El Conductivity I ( I / / \ Dailyl Grab I El Feeal i oliform J ( I 2OGN00,ml 4007 100-m \Weekly Grab I El COD I / / \ \ / Weekly I Composite I El Silyerj / J \ \ / / \Qdarteriy I Composite I E( Zinc / \. / / Quarterly Composite I El Total Nitrogen Monthly Composite E, (NO=-N+NO3-N+TKN) Total Phosphorus Monthly Composite El Chronic Toxicity Quarterly Composite E, Cadmium Quarterly Composite El Trichlorophenol 3.0 pg/L Quarterly Composite El Pentachlorophenol 8.9 pg/L Quarterly Composite El Selenium 10.6 pg/L Quarterly Composite El 2,3,7,8 Tetrachloro-dibenzo- 0.014 pg/L Quarterly Composite I,E, p-dioxin10 Conductivity Daily Grab Pigeon River Flow Daily Grab Pigeon River Fecal Coliform Weekly Grab Pigeon River Color Variable Grab Pigeon River Temperature Variable Grab Pigeon River Dissolved Oxygen Variable Grab Pigeon River Footnotes: 1. Sample Location:I-Influent,El—Effluent,Pigeon River-Instream sampling as specified in A. (5.)Instream Monitoring Special Condition. �� n 2. AOX monitoring shall be in accordance p :_W S plin 'Plan fo Cluster hle P ame ers da ed arc 19, 2001)or subsequent modifications approve, by the,)?�'vi icon. AOX datar�s}�akl��a submitted on a qu erly basis along with other Effluent Guideline chemical;dta. e er to AA:('1!�fflu'e t Gui\i e am ng Plan pecial Condition. 3. See A. (8.) Color Analysis and Compliance)Si ia o d ition. 4. The daily average effluent dissolved oxyg,n conce tratigr shall n t Jess than 6.O�ng/L. See A. 1 .) Dissolved Oxygen Special Condition. 5. See A.(13.) Temperature Variance Review Special Condition. 6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0(on the standard units scale). 7. Chronic Toxicity(Ceriodaphnia)at 90%Effluent Concentration: March,June, September,December(see A. (4.)Chronic Toxicity Permit Limit(Quarterly)). Permit Number: NCO000272 8. Trichlorophenol and Pentachlorophenol limits and monitoring are provisionally waived since the facility has certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include chlorophenolic biocide, the Permittee shall notified the Division prior to use and the limits and monitoring requirements shall become immediately effective. 9. If after 18 months selenium has not been detected,the facility may request that the Division review selenium data for possible removal of the limitation. 10. See A. (9.) Dioxin Monitoring Special Condition. 11. See A. (5.) Instream Monitoring Special Condition. See A.(6.) Best Management Practices(BMP) Special Condition. See A.(11.) Town of Canton Inflow and Infiltration Special Condition. Definitions: MGD-Million gallons per day lb/day-Pounds per day ml- I i iter" OD-Bioch micalOxygen errand µ Mit;ragramss er liter AOX-Adsor�abl'e-Oigaiit'6-Hlalides C D�Chemical oxygen defnan� o -picograms per liter Permit Number: NC0000272 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUHZEMENTS During the period beginning upon the effective date of the permit and lasting until expiration, the discharge of wastewater from the pine bleach plant to the wastewater treatment plant through outfall(s) 002 (E21), shall be limited and monitored by the Permittee as specified below and in A. (7.) Effluent Guideline Sampling Plan Special Condition: Effluent Charactensties ' ti LIri11t6-), Momtoring:°RequirementS2 r' z Monthly Daily Measurement Sample Type3; Sample F ._l , w Average Mazlmum h' * :Frequency u 'fa '..,.' Location Flo Weekly Calculated E2 Chloroform 5.15 lb/day 8.60lb/day Weekly Grab E2 2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E2 p- ioxm TCDD). 2, ,7,8-Tetrachloro liibenzo- 1 31.9 p r\ \Monthly rCottTppsite =E3 r p 4ua! (TCDF) t Tr(chlbrosyringol , ;:` f )k 2.5 Monthly Composite E# 3,4,5-�richlorocate6hol I l < 5.0 µW \M nthly o`C mpostfe E 3, ,6-' richlorocatechol i < 5.0,µ dVthly I omposr a E} 3,j,5-Trichloroguaiac9l I N < 2.1jigl0— odthly I I Composite Ej 3,4,6-�richloroguziacol I .\< 2S µ Mont6l Composite E}g 4,N,6-Trichloroggaiacol I 2.5�g/L Motrthly I Composite El I 2,4,5-Trichlorophenol < 2.5 µg/L5 Monthly Composite E2 2,4,6-Trichlorophenol < 2.5 µg/LS Monthly Composite E2 Tetrachlorocatechol < 5.0 µg/L5 Monthly Composite E2 Tetrachloroguaiacol < 5.0 µg/L5 Monthly Composite E2 2,3,4,6-Tetrachlorophenol < 2.5 pg/L' Monthly Composite E2 Pentachlorophenol < 5.0 µg/L5 Monthly Composite E2 Footnotes: 1. Sample Location: E2—Effluent is composed of Bleach Plant Effluent-acid (acid sewer collected from tap installed on filtrate pump from CI02 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(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, 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-anda aline streams which w}71 then be-composit d-separatel by the lab,and analyzed as separate 24-hr coin sit % and alkalmesampl€sl Composite=colfeeetse azat grab samples every 4 hours for 24-hour period pm bot e laud and alkaline/s{ri a\ins,then prepare and alyze a single flow-proportioned composite of the acid and l,catine-waseesheatt / \ 4. For compliance purposes,the permittee mush report)t}a 00 chlo ofonn mas loading ba' sed on additi n of separate acid and alkaline chloroform mass ��oad. // \� 5. Limits are based on Minimum Levels(Ml.)specited in CFR 30 01�, Definitions: lb/day—Pounds per day µg/L—Micrograms per liter pg/L—Picograms per liter Permit Number: NCO000272 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: > Z 'Efl og'Rm t �K � "e = Monthly Daily Average _Measurement ' SampleType3 £ Sample;, Average Frequency Location- Flow Weekly Calculated E3 Chloroform 7.14lb/day 11.93lb/day Weekly Grab E3 2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E3 p-groxm DD), F— r 1 � 2, ,7,8-Tetrachl ro-Uibenzo- 31.9 pg/IJ /\ \Monthly ( �otl[1T-sl —Ej p-Ir (TCDF)1 Tr ichlbrosyringol 1 4 I . ) k 2.5 µg/L'I i4onthly I I Composite E# 3,4,5- richlorocatechol I < 5.0 µg/Lt Mpnthly Uomposita E# I 3,4,,6-xrichlorocatedhoj I —\ ` < 5.0 µg dnthly I ompost a E# I 3,4,5-�richloroguaiacol I < 2.�'µ otithly I I Composite Et{ 3,1,6,�richlorogu5iacol I \< 215 µg/L Mont ly 1 , I Composite E# I 4,5�,6-Trichloroguaiacol j 1.5lig/L Mo�tthly I Composite E# I 2,4,5-Trichlorophenol < 2.5 pg/L' Monthly Composite E3 2,4,6-Trichlorophenol < 2.5 pg/L' Monthly Composite E3 Tetrachlorocatechol < 5.0 pg/L' Monthly Composite E3 Tetrachloroguaiacol < .5.0 µg/L' Monthly Composite E3 2,3,4,6-Tetrachlorophenol < 2.5 µg/L' Monthly Composite E3 Pentachlorophenol < 5.0 pg/L' Monthly Composite E3 Footnotes: 1. Sample Location:E3—Effluent is composed of Bleach Plant Effluent-acid (acid sewer collected from tap installed on filtrate pump from C102 bleaching stage D-100)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate pump from alkaline extraction stage 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(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, 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 acjd-andalkalinelstreams which will then bc-composited-separately by the lab, and analyzed as separate 24-hr coin�josite� 'd annc all ftfie ampl�M `Comp 3i�ite=cultdctae rate grab samples every 4 hours for 24-hour periodQm bo a c*d and j aline/s tioadit s,tl}e prepare and p alyze a single flow-proportioned composite of d abid and 1'ca]inewastes&e r 4. For compliance purposes,the permittee m t report e o 1 ctt o ofo g based on add ti n of separate acid and alkaline chloroform moadin�es 5. Limits are based on Minimum Levels(Mll s ecr ed in (�CFR�SOOI� Definitions: lb/day—Pounds per day µg/L—Micrograms per liter pg/L—Picograms per liter Permit Number: NCOOOO272 A. (4.) CHRONIC TOXICITY PERMIT LIMIT(QRTRLY) The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia duhia at an effluent concentration of 90%. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised February 1998,or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent versions. The tests will be performed during the months of March,June,September,December.Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit,then multiple-concentration testing shall be performed at a minimum,in each of the two following months as described in"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent versions. The c' hranic Yalue for multiple n' centration tests will be determined using a geome` ' mn£Yh 'ghest_J con�Icentration n g�ro detect ble impairm�ent�f reproduction o)�survival and the lowest concentration that does Ir e a detectable �pa yment o reproduction on survival /The hefmition of`d etectable impairment," co legion m thods, exposure regunes,an�further statistical methods�e specified. tRe` orth Caro lina Phase II Ch onic Whole Effluent Toxici . Test Pro�are'r(R Pro -February 1998)dr subse uent versions. Al{toxicity testing es Its required as past o this permit condition wil be entered on the Effluent Discharg Monitoring Form -1)fort le months in w�tch teas} ere�perfortre:using the parameter code TGP�B 'or the pals/fail)ts�nd HP3Bfo the Chronic Va]pe. tSd;itiond ally,DQ�orr AiT-3 (original)is to be sent to the fol owin addre / u u Attention: North Carolina Division of Water Quality Environmental Sciences Branch 1621 Mail Service Center Raleigh,North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,the permittee will complete the information located at the top of the aquatic toxicity(AT)test form indicating the facility name,permit number,pipe number,county,and the month/year of the report with the notation of"No Flow" in the comment area of the form.The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor dur ng a month n hic toxicity-monitorin is required rrtonitoring will be required during the following month. e q �� )d yMeorth � � �Should an test data from this monitorin°re u ment or t s er b � Cara inn rv�sto f Water Qualityindicate potential impacts to the recei 'n stream,[h emrttlna be re-o a ed and modified to ' clude alternate monitoring requirements or limits. f J \�y/ NOTE: Failure to achieve test conditions as specified in the cited document,such as minimum control organism survival,minimum control organism reproduction,and appropriate environmental controls,shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Permit Number: NC0000272 A. (5.) INSTREAM MONITORING SPECIAL CONDITION Stream Mile Location Description Parameter Frequency Designation Marker UP 63.8 Pigeon River upstream of the Temperature Daily waste treatment plant outfall D.O. Daily (prior to mixing with the Conductivity Daily discharge) Color' 2/Week Flow Daily Fecal coliform Weekly DNl 62.9 Pigeon River at Fiberville Bridge Temperature Daily D.O. Daily Conductivity Daily Color t 2/Week DN2' 57.7 Pi eon River Above Clyde Temperature Daily D.O. Daily DN3 \ 55\5 Pigeon Rives Below Clydc\ See Footnote 3 See Footnote 3 DN4 3.5 Pigeon River at NCS71625` See IT othote 3 See Fogto'te 3 I bridge ) .) \ ` I I ` DN5 42.6I —Piged—n Ri dr at HepJco ( \ \Temperature i Weekl D.O. Weekl Color 2)Wee Flown F Daily Waterville RgservoiV' See Footnote 4 Annually DN�6.0 U Pigeon Ri�er p,Lor fo mixing with Color j Variableu Big Creek BC —26.0 Mouth of Big Creek prior to Color Variable mixing with the Pigeon River DN7 24.7 Pigeon River at Browns Bridge Temperature Weekly (—NC/TN State Line) D.O. Weekly Color Variables All instream samples shall be grab samples. 1. Color(See A. (8.) Color Analysis and Compliance Special Condition) All instream samples collected shall be representative of the Pigeon River and Big Creek, respectively. Both true and apparent color shall be monitored using the methods specified in A. (8.)Color Analysis and Compliance Special Condition. Samples shall be collected at stations DN6, BC, and DN7 only when at least one generator at CP&L is in operation and releasing water to the Pigeon River. 2. Flow monitoring is necessary, as specified above, for the True Color calculation stipulated in A. (8.) Color Analysis and Compliance Special Condition. 3. Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9 (DNI), 57.7 (DN2),shall not be less than 5.0 mg/1 and the instantaneous minimum dissolved oxygen concentration shall not be less than 4.0 mg/1 (See A. (M) Dissolved Oxygen Special Condition). If the dissolved oxygen drops below 5.0 g/1._ tati n5 —7— t en mom oring h;Lb�equire at tations 55.5 (DN3) and 53.5 (DN4). 4. See A. (12.) Waterville Reservoir Sam ling Spec ial IEGndi"t n. � `\ 5. Sampling is required 2/week during t},e�summer a d on per wcel�unng thewmr. Sum er is defined as the period from April 1 th loYt�c obnler� 31,wh le winis� of ed as Novem�er 1 through March 31. Permit Number: NC0000272 A. (6.) BEST MANAGEMENT PRACTICES(BMP) SPECIAL CONDITION The permittee must implement the BMPs specified in Section A below. The primary BMP objective is to prevent leaks and spills of spent pulping liquors, soap, and turpentine. A secondary objective is to contain, collect, and recover at the immediate process area, or otherwise control,those leaks, spills, and intentional diversions of spent pulping liquor, soap, and turpentine that do occur. BMPs must be developed according to best engineering practices and must be implemented in a manner that takes into account the specific circumstances at the mill. Section A. BMP Implementation Requirements 1. The permittee must return spilled or diverted spent pulping liquors, soap, and turpentine to the process to the maximum extent practicable as determined by the mill,recover such materials outside the process, or discharge spilled or diverted material at a rate that does not disrupt the receiving was ewater-treatmen sY s em. , 2. The-permit�ee ust es tablislraprog�a to identify�n repair lea ing�quipment items-This ogram must include}(i Regular daily visual inspections of rocess area if h equipment items in sp nt i t I 7 u � I l pulping liquo , soap, �n turpentin�se�ice; (ii�I�medi ;e repair o�leaking equipment it m ,when possible. Leaking equipment-items tlt at canno b repaired durin normal-operations muss H identified, te4orarylmeans-for mitigating thf leaks muAe provided and-the,leaking equipment items repaired during the next maintenance g to e; iii Ideetificatidn of conditions underlwlich production'(VJ11 die curtailed or ha k ko repair leaking equipment items or to prevent pulping liquor, soap,and-t rpentine teal:s and spills- and 9v),A means for�tracking repairs over time to idcnt fy those Le items where cpgrade or rI lacement may be warranted based on frequency and se ierity of leaks, spills, or failures. 3. The permittee must operate continuous,automatic monitoring systems that the mill determines are necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap, and turpentine. These monitoring systems should be integrated with the mill process control system and may include, e.g.,high level monitors and alarms on storage tanks; process area conductivity(or pH)monitors and alarms; and process area sewer,process wastewater, and wastewater treatment plant conductivity(or pH) monitors and alarms. 4. The permittee must establish a program of initial and refresher training of operators, maintenance personnel, and other technical and supervisory personnel who have responsibility for operating, maintaining, or supervising the operation and maintenance of equipment items in spent pulping liquor, soap, and turpentine service.The refresher training must be conducted at least annually and the training program must be documented. 5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor,soap, or turpentine that is not contained at the immediate process area and any intentional diversion of spent pulping liquor, soap, or turpentine that is not contained at the immediate process area. The report must describe the equipment items involved, the circumstances leading to the incident, the effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion, and plans to develop changes to equipment and operating and maintenance practices as necessary to prevent recurrence. Discussion of the teportst�ust e-included as part\of the;annual-refreshertra}ning. 6. The permittee must establish a program to rev any planned modifications o theme pulpind chemical recovery facilities and any c� stmcti�rl activitiesiolthe1plp�ir�g and chl emical re very areas before these activities commence. Th urpos f�uch- e iew is tQplevent leaks-a�i d spil s of spent pulping liquor, soap, and turpentine d ring t) la ed mod�fic�tions and to gsure that c struction and supervisory personnel are aware c ossi liq r diverSt s and o e requirement t revent leaks and spills of spent pulping liquors, soap, and urpentine duffing construction. 7. The permittee must install and maintain secondary containment(i.e., containment constructed of materials impervious to pulping liquors)for spent pulping liquor bulk storage tanks equivalent to the . volume of the largest tank plus sufficient freeboard for precipitation.An annual tank integrity testing program, if coupled with other containment or diversion structures, may bd substituted for secondary containment for spent pulping liquor bulk storage tanks. Permit Number: NCOOOO272 8. The permittee must install and maintain secondary containment for turpentine bulk storage tanks. 9. The permittee must install and maintain curbing, diking or other means of isolating soap and turpentine processing and loading areas from the wastewater treatment facilities. 10. The permittee must conduct wastewater monitoring to detect leaks and spills, to track the effectiveness of the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must be performed in accordance with Section E. Section B. BMP Plan Requirements 1. The permittee must prepare and implement a BMP Plan. The BMP Plan must be based on a detailed engineering review as described in this section. The BMP Plan must specify the procedures and the practices required for the mill to meet the requirements of Section A,the construction the mill determines is necessary to meet those requirements including a schedule for such construction, and the monitoring program (including the statistically derived action levels that will be used to meet the re uirementssof Section E. The BMp lan also m st s ecify the eriod of time that the mill d termmes the�ctio �le}'elr s establishe under Secf�n may be xceeded ut trigger n the rgspo�ec it-ed n Section E. 2. Tpe permitteelmust c6ii uct a detailed/8ngineermprev\iew of the�ul'pinQ and chemical re Iov�ry operations--including but not limi�d �o process gquipr ent, storap tanks, pipelines and pum)ing systems, loading and�unlo�ac i'ng�fac�ities, and other-appurttnant puling and chemical recQve�y equipment items in spe�t pulping�liq or, soap,,and-turpe�tige se;�ice--for the purpose of determining tl�e magnitude and routing of poregtia leaks, spills, and i to tional diversions of spent pu p�t{g li r , soap an tur�eritine during he olfowing periods f�per�ation: (i)Process start-ups and shut owns;(iiyMaintenance; (in)Production-grade changes; iv}Storm or other weather events, (v) Power failures; and (vi)Normal operations. 3. As part of the engineering review, the permittee must determine whether existing spent pulping liquor containment facilities are of adequate capacity for collection and storage of anticipated intentional liquor diversions with sufficient contingency for collection and containment of spills.The engineering review must also consider: (i)The need for continuous, automatic monitoring systems to detect and control leaks and spills of spent pulping liquor, soap, and turpentine; (ii)The need for process wastewater diversion facilities to protect end-of-pipe wastewater treatment facilities from adverse effects of spills and diversions of spent pulping liquors, soap, and turpentine; (iii)The potential for contamination of storm water from the immediate process areas; and (iv)The extent to which segregation and/or collection and treatment of contaminated storm water from the immediate process areas is appropriate. 4. The permittee must amend its BMP Plan whenever there is a change in mill design, construction, operation, or maintenance that materially affects the potential for leaks or spills of spent pulping liquor,turpentine, or soap from the immediate process areas. S. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP Plan is prepared and,except as provided in Section BA., once every five years thereafter. As a result of this review and evaluation, the permittee must amend the BMP Plan within three months of the review if the mill determines that any new or modified managementpractices and engineered controls are necessary to reduce significantly t liklike��ood o =spent ulping ai nor, Opp,-an rpentne eaks, spills or intentional diversions from t ih mined t rocess a eas /S�u ding a schedule for implementation of such practices and ¢ntrols.) J // 6. The BMP Plan, and any amendments h reto,mist b�re 16 ed yrth&s is cc mcal man ger at the mill and approved and signed by the rii I ma a�er.my p rson Wing he MP Plan or iIs amendments must certify to the Divis onsnder per a ty of I&W Lt the BMP, lan(or its amendments) has been prepared in accordance with good engineering practices and in accordance with this regulation. The permittee is not required to obtain approval from the Division of the BMP Plan or any amendments thereto. Permit Number: NC0000272 Section C. BMP Recordkeeping Requirements 1. The permittee must maintain on its premises a complete copy of the current BMP Plan and the records specified in Section C.2 and must make such BMP Plan and records available to the Division for review upon request. 2. The permittee must maintain the following records for three years from the date they are created: (i) Records tracking the repairs performed in accordance with the repair program described in Section A; (ii)Records of initial and refresher training conducted-in accordance with Section A; (iii) Reports prepared in accordance with Section A; and(iv)Records of monitoring required by Sections A and E. Section D. Establishment of Wastewater Treatment System Influent Action Levels 1. The permittee must conduct a monitoring program per Section D.2, for the purpose of defining wastewater treatmentrsystem influent characteristics or action levels , described in Section D.3 that will trigger requirements to initiate investigation on BMP effect veness and to to a corrective action. 2. The permittee must etnp oy—the following procedu r& in order to deVelop the action levels rerzethe y S ction D: � } � / • Monitoring parameters.The permittee must/ ollect�2 ;hour Iomposite samples and analsamples for a measur' orgairic content�(e.g;Ehemical Ox,'ge Demand(COD)or {o Organic Carbon 'r6C)). Aliemutivelygiie/mill-ma)vse\a meas re related to spent pulp g liquor ure losses easd continuously na average over 24 hours (e. pecifrc conductivity r olor). • nitoring locations.The permittee must conduct monitorin,a the point influent en ersi the stervvater treatment system. For-thie-purposes of this regIiirement,the permittee ma elect alternate monitoring point(s) in order to isolate possible sources of spent pulping liquor, soap, or turpentine from other possible sources of organic wastewaters that are tributary to the wastewater treatment facilities(e.g.,bleach plants,paper machines and secondary fiber operations). 3. By the permit effective date,the permittee must complete an initial six-month monitoring program using the procedures specified in Section D and must establish initial action levels based on the results of that program.A wastewater treatment influent action level is a statistically determined pollutant loading determined by a statistical analysis of six months of daily measurements. The action levels must consist of a lower action level,which if exceeded will trigger the investigation requirements described in Section E, and an upper action level,which if exceeded will trigger the corrective action requirements described in Section E. 4. By January 15,2002, the permittee must complete a second six-month monitoring program using the procedures specified in Section D and must establish revised action levels based on the results of that program. The initial action levels shall remain in effect until replaced by revised action levels. 5. Action levels developed under this Section must be revised using six months of monitoring data after any change in mill design, construction, operation, or maintenance that materially affects the potential for leaks or spills of spent pulping liquor, soap, or turpentine from the immediate process areas. Section E. BMP Monitoring, Corrective ction a d Re Ie o�rti�e uirements 1. The permittee must codduct daily moq'i oring f,h 3nfluen o thI�4\s\� ewa ertreatment s rtemin accordance with the procedures descnb d in S�c io otthe pddSuse'o�detecti�eaks nh spills, tracking the effectiveness of the BMP$,Hai nd detects tren st'n p�rentt ppulpmg iquor losses 2. Whenever monitoring results exceed the loy a mti level o, �e period ofitune specific .1 the BMP Plan,the permittee must conduct an investigation to determine the cause of such exceedance. Whenever monitoring results exceed the upper action level for the period of time specified in the BMP Plan,the permittee must complete corrective action to bring the wastewater treatment system influent mass loading below the lower action level as soon as practicable. 3. Although exceedances of the action levels will not constitute violations of an NPDES permit, failure to take the actions required by Section E.2 as soon as practicable will be a permit violation. Permit Number: NC0000272 4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to Section E.1. Such reports must include a summary of the monitoring results,the number and dates of exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to respond to such exceedances. Submission of such reports shall be annually, by March 31"of the following year. Section F. BMP Compliance Deadlines 1. The permittee is subject to the following BMP deadlines: • Prepare BMP Plans and certify to the Division that the BMP Plan has been prepared in accordance with this regulation not later than the permit effective date. • Implement all BMPs specified in Section A that do not require the construction of containment or diversion structures or the installation of monitoring and alarm systems not later than the permit effective date. • Establish�nitial action levels req 'red by Sec ion not later han the ermit a fective date. r--� • Commence�cperatio�t of any new o[[upgrade c6t nuous, an omatic monitoring systems that the mill dete Ines to be necessaryim er Section A., (other than I hose associated with construction of containment ordive Sion structure)not later(han the permit�effective date. • Complete cc structim and commence operation o�ar� spen pulping liquor, collection, containment(diversion, oi-ot er facilities; including an associated continuous monitoring systems a essary't�fully ii pl� nt BMPsspeeifi\p Se �tion A not later than the i eirit y \b effectiv da�e. EM151is revised action levels re red b/Section D ads s on as�ossible after fully implementing the-BMPs specifi- n Section A, 4hot later than January 15;2002. CJ Submit Annual Reports required by Section EA to the Division by March 31`of the following year. Section G. BMP Definitions 1. Action Level: A daily pollutant loading that when exceeded triggers investigative or corrective action. Mills determine action levels by a statistical analysis of six months of daily measurements collected at the mill. For example,the lower action level may be the 75th percentile of the running seven-day averages(that value exceeded by 25 percent of the running seven-day averages) and the upper action level may be the 90th percentile of the running seven-day averages (that value exceeded by 10 percent of the running seven-day averages). 2. Division: North Carolina DENR, Division of Water Quality, 1617 Mail Service Center,Raleigh, North Carolina 27699-1617. 3. Equipment Items in Spent Pulping Liquor, Soap,and Turpentine Service: Any process vessel, storage tank,pumping system, evaporator, heat exchanger, recovery furnace or boiler, pipeline,valve, fitting, or other device that contains, processes,transports, or comes into contact with spent pulping liquor, soap, or turpentine. Sometimes referred to as"equipment items." 4. Immediate Process Area: The location at the mill where pulping, screening knotting, pip washing, pulping liquor concentration, pulping liquor prgces i g,a�� hem( as recov facilities-ark locAted, generally the battery limits of the afor entio)ed r cesse$. 'Imm• dtlihte prlo�es:area" inullides spent pulping liquor storage and spill contr I anks I tAdLLLLLLat they ill, i �et�i�r or bt the are 1 �clated in the immediate process area. 5. Intentional Diversion:The planned rerr�� v�I of s e I t pu�lpi I 'uor so o tu' rpentine fr� equipment items in spent pulping liquor soap or turpe' ntinesede by the ;mill for any pulp�ose including, but not limited to, maintenance, grade changes,or process shutdowns. 6. Mill: The owner or operator of a direct or indirect discharging pulp, paper, or paperboard manufacturing facility subject to this section. 7. Senior Technical Manager: The person designated by the mill manager to review the BMP Plan. The senior technical manager shall be the chief engineer at the mill,the manager of pulping and chemical Permit Number: NC0000272 recovery operations, or other such responsible person designated by the mill manager who has knowledge of and responsibility for pulping and chemical recovery operations. 8. Soap: The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the wood, which precipitate out when water is evaporated from the spent pulping liquor. 9. Spent Pulping Liquor:For kraft and soda mills "spent pulping liquor" means black liquor that is used, generated, stored, or processed at any point in the pulping and chemical recovery processes. 10. Turpentine: A mixture of terpenes,principally pinene, obtained by the steam distillation of pine gum recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft pulping process. Sometimes referred to as sulfate turpentine. DD 1 � LD D -RA Permit Number: NC0000272 A. (7.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION The bleach plant effluent samples (Outfalls 002 and 003)shall be analyzed for 2,3,7,8-TCDD in accordance with EPA Method 1613. A single sample,from each of the bleach plant effluents, may be analyzed to determine compliance with the daily maximum effluent limitation. The bleach plant effluent samples (Outfall 002 and 003) shall be analyzed for the 12 chlorinated phenolic compounds in accordance with EPA Method 1653. A single sample, from each of the bleach plant effluents,may be analyzed to determine compliance with the daily maximum effluent limitation. The Minimum Levels for each of the 12 chlorinated compounds are the same as the Daily Maximum concentrations listed on the effluent pages for the respective outfall(s). The final wastewater treatment plant effluent sample (Outfall 001)shall be analyzed for AOX in accordance with EPA Method 1650, or subsequent test methods approved by the Division. Tl�e permittee-�na request g modifica�t''o s to the Effluent Guideline requirement inclining 1) use•of ECF cert fication iAeu of monitoring�?r chloro'orm in the bleach plant cffl ents (Oiu ll(s) 002 and 003)whn this rules promulgated by\EP`A;2)demonstrating compliance�stg samp es collected,less frequently-tha every four hours; 3)wsmg automated composite volatile samplers fo cliloroform samplling;land-4)-ugingd61omated/( ositL s�nplers for ehlorophenolic, 2,3, ,8 TCDD an 2I3,7,8 TCDF sainpling.� Such tur\requesis will be evalu ted in accordance with 15A2i.0 1 � Ind ITheflow calcpla ions for internal Outfal (s) 0 2 003 shall not be subject to accuracy requ�rements specified under Part II, Section D.3. This exclusion is similar to that provided for pump log flow calculations. Chemical data for Effluent Guideline parameters (Outfall(s) 002 and 063 parameters+AOX from Outfall 001) shall be submitted to the Division on a quarterly basis or more frequently (January-March,April- June, July- September, October-December). Quarterly submissions shall be due 60 days following the last day of each quarter(Due dates=May 31, August 31,November 30, and February 28). Chemical data shall be submitted on Division-approved DMR forms,with a separate form provided for each month. D j %A Permit Number: NC0000272 A. (8.) REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE SPECIAL CONDITION 1. The average daily discharge of true color for each calendar month shall not exceed 55,000 pounds per day. The annual average effluent true color loading shall not exceed 48,000 pounds per day. For the purpose of this permit/variance only, "pounds of true color" is calculated by the following equation: Effluent Flow(mgd)x Effluent True Color Level (Platinum Cobalt Units)x 8.34. 2. All samples collected for color analysis and for use in the above calculation shall be measured and reported as true color and apparent color using the procedure referenced in FR 39 430.11 (b) (May 29, 1974)-true and apparent color or as amended by the EPA. 3. ul e_Rid'ge,Paper has a red y egu`n he process of icientifying an imp ementrng posst a process optimization measures ti clt cair-be taken to fucfhdr reduce colordischfi gas Prom`the rnlll. permittee is directed to continue evaluating mi1L/opleatt4ons with he goal of fully identifyi�pg opportunitiest€or,preve ing and controlling measarablAlack liq, of leaks and spills(Besf Management Practices-BMPs}_§ucli BMPsAnclude`burare not lliri ited-ro. >I Continuous improvement,Qf oR eating practices `or`leak) al d spillsare recovere i ra her than discharged to sewers \\\ ➢; Improvement in preparation for planne�outages to maximize ca ture of tank clean-out vJaste and routing to recovery; eductin of clean I ater that continuo-us ly runs into se e s tb prevent dilution of smilllel spills and facilitate recovery of highly colored wastewaters; and Improvement in the equipment used for handling of knot rejects to prevent black liquor leaks into the recovery sumps. 4. By October 1, 2003,Blue Ridge Paper shall submit to the North Carolina Division of Water Quality a report including a statistical analysis of the Blue Ridge Paper's monthly average color discharge, mill performance as related to color, all available data necessary to derive the lowest achievable monthly average color loading limits. By November 1, 2003,the Division of Water Quality(in consultation with the Technology Review Workgroup) shall recommend, considering the statistical analysis report submitted by the permittee and the demonstrated performance of the mill, the lowest achievable monthly average color loading effluent limitations. The monthly average effluent limit and the flow criteria used for instream color determined to be achievable shall become effective on December 1, 2003, by written notification from the Director. 5. Beginning December 1, 2003,the annual average discharge of true color shall not exceed 42,000 pounds per day and the monthly average color shall not exceed the limit established according to Special Condition A.(8.)Paragraph 4. However, if by October 1,2003,the Division of Water-Quality (DVl+fl), in consultation with-t e Technology Review Committee, and the NPD`E1S ommitte�agre4 t}at therelare overwhelming technical, economic, or operational barriers to th ermittee� abi�ity to�attain the2bove-sta�ed color loading limits, DWQ shall recommend o the P S C- nfmittee,alternate interim-limits tc become effective December 1,2003. At that tim�,DWlshal recom(rtetid a new effective date for achieving an annual average color loading limit 4t 2-,O poili5ds per\&,�Ahese recommendations 4 all be based on what DWQ concludes Blue Ridge Paper can reasonably achieve, giving consideration to the actual demonstrated color levels discharged and process optimizations implemented pursuant to The Technology Review Workgroup shall act in an advisory role to the Nortt Carolina Division of Water Quality, and NC DWQ shall consult with Technology Review Workgroup prior to mg any decisions regarding color reduction activities at the Canton Mill. Permit Number: NC0000272 r• Special Condition A. (8.) Paragraph 3. Based on DWQ's recommendations,the NPDES Committee will determine the alternate interim limits to become effective on December 1, 2003, and the new effective date for achieving an annual average color loading limit of 42,000 pounds per day. After the NPDES Committee's final decision, the NPDES Permit will be modified in accordance with North Carolina's permitting process. 6. The permittee shall submit to the Division of Water Quality,the Technology Review Workgroup and the NPDES Committee by December 1, 2003, a report on the feasibility of achieving a target annual average color loading within the range of 34,000 pounds per day and 39,000 pounds per day. This report shall include identified process improvements and any other actions that would result in additional color reductions, actions taken by the permittee to reduce color loading(since permit issuance), and the technical, economic, and operational feasibility of implementing the identified process improvements on a continuous or intermittent basis, in order to achieve a target annual avera a within the range of 34 000 pounds per day and 39,000 pounds dav_The report shall identi specic economic and impleljtentation issues ssociated iw th the tm royelnents. The re ort shall also protect expected adds t not al color reduciiori�f�Qr each tectnolog}�e evaluated ul ted and max mum color reducti n Possible using the iden`fied tec(indlo ies The re ort shall also include a pro osed schedule for iinp�ementation of pr9Ees5 impro ementss re uired t a hieve an effluent color loading w'ithin the targeted range. The pe tt�ee shallj�,gvide�hig evaluaiion/report,together with ar updated report on the estilts of o�gotng a d additiona•l planner-col r reduction a h ties,to the Division of Water Quality, the Technology Review Workg oup amd Te�IPDES Committee.By Februar} 1, 2004, DWQ (ink nstOation tiith the Te�ehnology Review Workgroup) 3hall approve or modify Mule Ridge Papui recommended an for achieving t�34,000—39,b0O-, ouu per day target annua, average. If the limits determined to be achievable, pursuant to Special Condition A.(8.) Paragraph 7, by the Division of Water Quality(in consultation with the Technology Review Workgroup) are not within the target range,the Permit shall be modified in accordance with North Carolina's permitting process to reflect those limits. 7. By December 1, 2005,Blue Ridge Paper shall submit as related to the implementation of the process improvements evaluated according to Special Condition A. (8.)Paragraph 6, a statistical analysis of Blue Ridge Paper's effluent and a feasibility report on color reduction technologies associated with the Chloride Removal Process. This report shall include a statistical analysis of the Blue Ridge Paper's monthly average and annual average color discharge,mill performance as related to color, all available data necessary to derive the lowest achievable annual average and monthly average color loading limits. By January 1, 2006, the Division of Water Quality(in consultation with the Technology Review Workgroup)shall recommend, considering the statistical analysis report submitted by the permittee and the demonstrated performance of the mill,the lowest achievable annual average and monthly average color loading effluent limitations. If the limits determined to be achievable are within the target range established pursuant to Special Condition A.(8.) Paragraph 6, the limits shall become effective on March 1, 2006, by written notification from the Director. If the limits determined to be achievable by the Division of Water Quality_(in consultation with the gY Workgroup) P gl? I g ge,the'llSennit hale Ibe mfied to Technology Review Work rou are Jot wit t th tar et. accordance with North Carolina's e I�ttin Ir ce� to refl`ec�t thosse�I" its. This report also shall evaluate and reportt on coa r duto�techn/d �e as oct' 'ated with tie Chloride Removal Process(CRP)wastestream.� he C - an�alysts � I cop e�to o� the technical, economic, and operational feasibility f._impleinen"Ig the Me }" ied tee tnb(o�ies. The report shall identify specific economic and implementation issues associated with the improvements. The report shall also project expected additional color reduction for each technology evaluated and maximum color reduction possible using the identified technologies. The Division of Water Quality (in consultation with the Technology Review Workgroup) shall evaluate the feasibility of implementing identified technologies for further color reduction and shall submit to the NPDES Committee by Permit Number: NC0000272 December 1, 2005,DWQ's recommendations regarding color reductions associated with the treatment of the CRP wastestream. 8. By March 1, 2006, the permittee shall submit a report to Division of Water Quality,the Technology Review Workgroup and the NPDES Committee on the comparative evaluation of the color reduction efforts as part of the Variance review process (Triennial Review of North Carolina's Water Quality Standards). This report shall also include an evaluation of color in the Pigeon River at the Fiberville Bridge, and an evaluation on the feasibility of complying with North Carolina's Color Standard. 9. The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco USGS gauge station. The new effluent limits in this permit are more stringent than the provisions in the 1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is possible to calculate the monthly flow at the Canton gage station above which instream color at the Fiberville Bridge will not exceed 50 true color units. Using the 55,000 pounds perms monthly average true color loadin limit im lemented on the effective date of the ermit the flow at the Canton s ation,�w ich�owi&for color legs han 50 true Dolor units at the Fbervil e Bridge is 171.8 MUD. �herefo e, the monthlylaverage/coioi.m�the Pigeon rver at the Fiberville Badge will be less than 54 true c�lo units whenever the mbnthly}average flow !at the Canton gage static ) is greater than I 1.�MGD. b i } 10! The governing flow w Iriterion for rue color at Canton-is 58.2 MGD (30Q2 stream flow). The flow established4upuant'to §pecial Condition A. (B.) Paragraph`9, islgreater than this 30Q2 stream flow, tli-erefore, for flows less than the 171,8�dl)at the Canton Uage tation but greater than 1i93�3 MGD —(30Q2-flo�t the Hepco gage station,—the-rnonthly average-coloHn the Pigeon River at Hepco will be less than 50 true color units. 11. Beginning December 1, 2003,the monthly average color in the Pigeon River at the Fiberville Bridge will be less than 5.0 true color units whenever the flow at Canton is greater than the flow established using the following equation and based on the monthly average effluent limit established per Special Condition A.(8.)Paragraph 4: (Monthlykerage_Effbent—Color Limitjb/day-12468.3) Flow_at_Ca�ton_USGSiNIGD)= — +31.6+2.4 308.58 For flows at the Canton Gage station.less than the flow established here but greater than 193.3 MGD at the Hepco gage station,the monthly average color in the Pigeon River at Hepco will be less than 50 true color units. 12. The potential exist that there could still be periods of time corresponding to periods of lower flow in the river,when color at Fiberville might exceed 50 true color units. Therefore, the permittee shall continue to implement the approved Low Flow Contingency Plan for mitigating the occurrence and degree of these potential exceedences. _ rn1 �1 . �-- 13. The permittee shall not increase the mil s�pul roduction capact /du mg t g term of this permit, unless the permittee can demonstrate�ha't the c eese�tp,oductio> a he a(hte`ve-while reducing color loading. In addition, increasing th, ,e mill��u�p;prodb q:capaclma . require perm�t revision in accordance with North Carolinas DEES,P/'ermu+r,ng ru es. 14. The NPDES Permit shall be subject to reopening in order to modify the color requirements based upon the following and in association with the required triennial reviews: ➢ Any breakthrough in color removal technologies. Such breakthroughs shall be brought to the NPDES Committee for consideration, by Blue Ridge Paper and the Division of Water Quality, as soon as they are discovered. Permit Number: NC0000272 An acceptable statistical analysis of effluent color discharge data demonstrating significantly better color removal performance than that currently prescribed in the variance and permit. Successful application of end-of-pipe color reduction technology or in-mill color minimization effort that results in significant and measurable reduced mass color discharge. 15. The transfer of this NPDES permit will not proceed until any successor—in—interest to the current owner has agreed to accept the provisions of this permit and request and received from the NPDES Committee a transfer of 2001 Revised Color Variance. U \v RA �i Permit Number: NC0000272 A. (9.) DIOXIN MONITORING SPECIAL CONDITION The permittee shall perform the analyses for 2,3,7,8 TCDD and 2,3,7,8 TCDF as outlined below: SainplingPoi Wn"itoring, Re_-ti r -inents s Measurement, Sampleiype , Fre uenc"i Influent to Wastewater Quarterly Composite Treatment Plant Effluent Quarterly Composite Sludge Annual Composite L��andfi�ll�L�eachate Annual Composite �� The samp' les shall lie analyzed fo,3�8- '�CDD apel , 8 TCDF in actor' dance with EPA ethod 1613.1 A single sample may�be analyzed. 4lternatilsample volumes may be collected to enable th sample to be split(du lieate.analy s)JIhe Mi} ittaum I in the e luent for-2,3,7,8-TC D and 2,I,7,I TCDF by PA Meth $ 13 i�3'0 pg/l. � \ / If ,31,7,8 TCDD or 2,37, TCDF'u�e�etected�nn the effluent above the quantitation le el the permute eshadi hate note frequent\m—om�ng of sludge and iu fill leachate. Additional Requirements Fish tissue analysis shall be performed in accordance with the Division of Water Quality approved monitoring plan, which will be reviewed as necessary. The monitoring plan is an enforceable part of this permit. All dioxin data collected as part of this monitoring requirement will be reported as required in the plan, no later than 180 days after sampling. D L) J \ Permit Number: NC0000272 A. 10. DISSOLVED OXYGEN SPECIAL CONDITION + ( ) The permittee shall maintain an average daily dissolved oxygen concentration of not less than 5.0 mg/1 with a minimum instantaneous value of not less than 4.0 mg/1 at River Miles 62.9 (DN1) and 57.7 (DN2). The permittee shall operate oxygen injection facilities at the outfall structure, at 0.9 miles downstream of the discharge, and at 2.1 miles downstream of the discharge, as necessary, to comply with this requirement. These facilities shall be operated in a manner which will maintain the water quality standard for dissolved oxygen in the Pigeon River downstream of the discharge. Blue Ridge Paper shall report the date and duration of oxygen injection use as a supplement to the monthly Discharge Monitoring Report (DMR)forms. If the dissolved oxygen drops below 5.0 mg/L at station DN2 then monitoring shall be required at stations DN3 and DN4. A. (11.) TOWN OF CANTON INFLOW AND INFILTRATION SPECIAL CONDITION The-permitte,e shall maker or orts to promote-re uction of i flawlinfiltration to-thesown-of Cant n s—wastewvla er coll ections-yst=..\ /J�` A. (12� ) A El LE RESERVO R SAMP 1 G S ECIAL CONDITION // . Sampling for Waternlle Reservoirshall�eI conducte�onch aannuallyun1tig2002-atid 2004. S I ling shall.�e performed dsring a ow-flow�enods to corresponcj with the is tissue-study (see A. ( ) toxin M�niioring Special�ond�ti�n). \\ 46ir �Sa piing shall,be performe at Waterv\ille Res prior to a rel ranch, Waterville Reservoir near W lkins ree and Watervil e Reservoir nX&dam. Each loc�aion�all be sampled for the following pararni;ters:�• I PARAMETEhS , Temperature Dissolved Oxygen Conductivity pH Total Nitrogen Nitrite+Nitrate Ammonia TKN PO4 Total Phosphorus Chlorophyll-a Secchi Depth All samples shall be collected at 0.1 meters beneath the surface of the water in the lake. A. (13.) TEMPERATURE VARIA ERE L PECI CO ION r � i �, I �� During the next permit renewal, Blue Rid Paper Ishal camp' e an analyg i of em er tuTanshall submit a balanced and indigenous specieperature/variande dy, no 1/at r aha \May 1:,2007 s arty f this anAl sis, Blue Ridge Paper shall submit a complete temL repo nd men t G need for a y�optinned temperature variance. LJ L1 LI LJ The study shall be performed in accordance with the Division of Water Quality approved plan. Request for revisions to this plan shall be submitted for approval no later than March 1, 2005. The temperature analysis and the balanced and indigenous study plan shall conform to the specifications outlined in 40 CFR 125 Subpart H and the EPA's Draft 316a Guidance Manual, dated 1977. Pe ar..fr';!ent of Enviro(tment and Natural Resources oFVAre F l� ality � 1 ll ac� S�' s Permit NC0000272 0 < Facility Information Applicant/Facility Name4: Blue Ridge Paper Products Inc. Applicant Address': P.O. Box 4000 Facility Address": 175 Main Street Permitted Flow2,4'7: 29.9 MGD Type of Waste ,'J: Industrial, domestic, stormwater, and landfill leachate Facility/Permit Status': Renewal Coun&.4,1: Haywood Miscellaneous Receiving Stream2,': Pigeon River Stream Classifications': C 303(d) Listed?': Yes - Fish Advisory, Dioxins Subbasin2: 04-03-05 Drainage Area (mi2�: (calculated] 130 mil Summer 7Q10 (cfs) . 52 cfs at Canton and 120 cfs at Hepco Winter 7Q10 (cfs)': 63 cfs at Canton and 183 cfs at Hepco Average Flow (cfs)': 325 cfs at Canton and 677 cfs at Hepco IWC (%): 100% (See Text Below) Primary SIC Code: 2621 Regional Office: Asheville USGS Topo Quad: Canton(E 7 SE - State Grid) Permit Writer: Michael Myers Date: July 24, 2001 SUMMARY Blue Ridge Paper Products Inc. has requested renewal of their National Pollutant Discharge Elimination System (NPDES) discharge permit NC0000272 allowing discharge of industrial, stormwater, municipal and landfill leachate wastewaters to waters of the state. The NPDES permit will expire on November 30, 2001 and the application for renewal was received on February 23, 2001. This fact sheet summarizes the rationale used to develop the North Carolina Division of Water Quality's recommendations for the draft permit. BACKGROUND Blue Ridge Paper is an employee-owned and operated integrated, elemental chlorine free (ECF) bleached kraft pulp with oxygen deligninifcation and bleach filtrate recycle, and paper mill in Canton, North Carolina. Processes at the mill include a pine bleach line; hardwood bleach line, paperboard and fine paper production lines. Pine and hardwood chips are transported to the site via rail or truck and subsequently processed into pulp for paper or paperboard production. In or around 1990, Champion International Corporation (Champion Paper -now Blue Ridge Paper) initiated a $300 million dollar modernization project termed the Canton Modernization Project. This project eliminated the use of elemental chlorine and implemented significant changes to both the pine and hardwood bleaching lines. The mill upgrade included two changes that dramatically improved the mill's environmental impact. The first major change was the use of oxygen delignifrcation. This process is used to separate the lignin from the fiber. This resulted in significant improvement in the mills environmental performance. The second major change was the implementation of full-scale bleach filtrate recycle (BFR) on the pine bleach line and caustic extration stage (E.) filtrate recycle (-20%) on the hardwood bleach line. For a Fact Sheet NPDES Renewal Page 1 more detailed description of the mill improvements, refer to the Canton Modernization Project Section below. The Canton Modernization Project greatly reduced the wastewater generated and eventually discharged to the Pigeon River. Even with these improvements, significant quantities of wastewater are generated in the production of pulp and paper and proper treatment prior to discharge is required. Wastewater generated by the Canton Mill, along with the Town of Canton's domestic wastewater, is treated at Blue Ridge Paper's Wastewater Treatment Plant. The treatment plant is a 29.9 MGD wastewater treatment system consisting of the following unit processes: • Grit Chamber • Bar screens • Lift pumps • Polymer addition • pH control (CO2 injection or H2SO4 backup) • Three primary clarifiers (one normally off-line) • Nutrient feed • Aeration basins • Three secondary clarifiers • Residual belt presses • Effluent flow measurement • Cascade aeration (with oxygen injection) • Oxygen injection facilities Solids at this facility are deposited into a dedicated landfill. The history of this mill, under the ownership of Champion Paper and now Blue Ridge Paper, has been controversial. Under Champion Paper, the environmental impacts of the Canton Mill were noted by concerned citizens, environmental groups, the State of Tennessee, State of North Carolina, and the United States Environmental Protection Agency (EPA). The issues raised by these individuals and groups contributed to the Canton Mill's improved environmental performance and resulted in a settlement agreement issued January 8, 1998. Today the relationship among the various stakeholders has evolved to one of cooperation. The Division commends all the groups for their willingness to work together to improve water quality. This permit has centered around four main issues emanating from the mill's discharge: color, temperature, oxygen consuming waste and dioxin, and a brief synopsis follows. Color On July 13, 1988, Champion Paper was granted a variance from North Carolina's narrative water quality standard for color, which the EPA interpreted to be 50 color units. The EPA subsequently issued a NPDES permit to Champion Paper facility in Canton, North Carolina. In 1994, the EPA returned NPDES permitting authority for the Canton Mill back to North Carolina's Division of Water Quality. During the permit renewal the original color variance was modified and both were issued around December 11-12, 1996. As outlined above, over the course of this variance the mill has initiated significant improvements, which have dramatically reduced the color loading and other effluent characteristics. Though the mill has made tremendous strides, color continues to be the focal point surrounding this permit. The EPA chaired Technology Review Workgroup have recommended additional color reduction for the up coming permit cycle. The recommendations issued by the Technology Review Workgroup included the findings of a third party evaluation of Blue Ridge Paper's Canton mill and the report issued by the EPA Tech Team'. The evaluation conducted by Dr. Norm Liebergott was co- sponsored by Blue Ridge Paper and several environmental groups and provided valuable information for the TRW'. In addition, to identifying areas for improvement and available technologies, Dr. Liebergott compared the Canton mill to similar mills around the world. Dr. Liebergott concluded that the Canton mill's environmental performance is among the best in the world. Though incredible work has been done, there continues to be a need to reduce color further. Blue Ridge Paper's openness and willingness to work towards continued improvements has resulted in an atmosphere of trust and cooperation among all the interested parties. This cooperation has been extremely valuable and will continue to be critical as the additional color reductions recommended by the Technology Review Workgroup are implemented (see attached July 24, 2001, memo from the EPA Tech Team to the Technology Review Workgroup). Fact Sheet NPDES Renewal Page 2 The Technology Review Workgroup report identifies process improvements that will result in permitted color reductions of 6,000 pounds per day. In addition, the report identifies process improvements that will require further study but are likely to result in total color reductions in the range of 9,000 - 14,000 pounds per day. The mill will also evaluate the feasibility of treating the highly colored low flow wastestream from the chloride removal process (CRP). The feasibility of additional color reductions associated with the treatment of the CRP wastestream is highly uncertain and no color reductions have been established for this permit cycle. The result of a feasibility study on the Chloride Removal Process wastestream will be evaluated for possible additional color reductions for the next permit cycle. As shown in Table 1, the 6,000 pound per day annual average color reduction will become effective on December 1, 2003. Additionally, the mill will evaluate additional process improvements in order to achieve an annual average effluent color loading of 34,000 - 39,000 pounds per day. If the limits determined to be achievable are within the target range,the limits shall become effective on December 1, 2005, by written notification from the Director. In the event that the achievable limits are outside of this range then the NPDES will be reopened. At that time,public comments will be.gathered and the permit may be modified. Table 1. Major Dates for Compliance/Reports. Submittal/Compliance ate Requirement 2002 1-is issue Study Report October 1,2003 Statisticalevaluation ot pertormance tor determination ot the monthly average effluent color limit December 1, 2003 First reduction in effluent color limit December 1, 2003 keasibility report on additional process improvements tor further color reductions 2004 is issue Study Report December 1,2005 Statisticalanalysis and feasibility report on treatment of UXF wastestream March econ reduction in effluent color limit March omparative Evaluation Report May 1, 2006 Balancedand Indigenous Species Study Report Temperature The facility first requested and received a 316 (a) variance (approved by EPA) for temperature on August 6, 1985. This determination demonstrated that the effluent limitations relating to the thermal .component of the Champion discharge were more stringent than necessary to assure protection and propagation of a balanced indigenous population of shellfish, fish, and wildlife in the Pigeon River. Therefore, the 316(a) determination was approved based on protection of the appropriate use classification of the Pit eon River. The temperature variance was reviewed and renewed as part of the Triennial $ }r'e}ti 1• 9- �,' •'; j } 4I 31ue Ridge pl si1! " d a Balance and Indigenous Species Study on the Pigeon River on June 1, 2001. DWQ scien 'L-viewed the report and concluded that continuance of the temperature ,variance is approp � t ; -irefore, the Division of Water Quality is recommending continuation of the temperature variariesa *itti�';porting requirements consistent with the previous permits (see Table 1). ' I "Oxygen Consuming Waste{'{' t' �Ip o e�?irredicted that even with a BODS' loading of 12091b/day (5.0 mg/L at 29 ¢ ;sl �:. Yx � l, xygen in the Pigeon River would not be protected. Since Blue Ridge Paper Ic,t' j�1 1, � afi'Juch trmgent limitations, an instream method was implemented to protect the assolved oxygen in th ra,ceiving stream. For further discussion on this subject refer to the ' !; conventional pollutants ' 'lion below. Dioxins Elevated levels of dioxins were found in fish tissue in the Pigeon River (around the late 1980s). Subsequently, a fish consumption advisory was issued for sport fish, catfish and carp. The Canton Mill has not discharged any detectable levels of 2,3,7,8 TCDD to the Pigeon River (since 1989) and dioxin in fish tissue continue to decline. Currently, a fish consumption advisory continues for carp and catfish. North Carolina has lifted the advisory on sport fish. However, the State of Tennessee continues to post a precautionary fish consumption advisory for carp, catfish and red breasted sunfish. ' BOD5 is an analytical method used to estimate the biochemical oxygen demand. Fact Sheet NPDES Renewal Page 3 The fish consumption advisories in North Carolina and Tennessee are currently under review for possible modification of the advisories. The North Carolina Division of Environmental Health (DEH) has initiated a review of the fish consumption advisory on Pigeon River and Waterville Lake. DEH is evaluating dropping the advisory on catfish in the North Carolina portion of the Pigeon River and limiting the advisory on Carp to Waterville Lake. A final determination may not be finalized prior to permit renewal, therefore, recommendations presented in this permit do not reflect this evaluation. STREAM CONDITIONS The facility discharges to the Pigeon River near Canton, North Carolina. The Pigeon River rom Canton to Hurricane Creek is listed as an impaired water, according to North Carolina's 20 Draft 303(d) List, due to a fish consumption advisory for dioxins. Recent data indicate that the di` j in levels in fish tissue continue to decline. There has been no detection of 2,3,7,8 TCDD in sport fis 'since 1995 and below North Carolina's fish consumption advisory level for 2,3,7,8 TCDD in catfish since 1997, based on Blue Ridge Paper's data. 2,3,7,8 TCDD continues to be detected in carp, though levels continue to decline and are below North Carolina's advisory level. The Pigeon River has been experiencing extremely low flows, due to extended drought conditions in the western part of the state, with flows often less than the 7Q10 flows of 52 cfs (near Canton). Curtis Weaver, with the USGS, provided the updated low flow statistics noted above using data from 1933 through 1999. The low flow statistics at Canton include the influence of Lake Logan, which was constructed in 1932 and the influence of both Lake Logan and Lake Junaluska (constructed in 1913). This reflects the current hydrography within the watershed and does not reflect conditions prior to construction of the lakes. The impact of this reevaluation of the low flow statistics is that the lowest seven day average flow expected once in ten years (7Q10) has been reduced from 54 cfs to 52 cfs. This affects the instream waste concentration which is used to determine the limits for the toxicity testing (discussed later). INSTREAM MONITORING The current permit requires Blue Ridge Paper to conduct an extensive instream monitoring program consisting of 12 monitoring sites (1-upstream of mill in Pigeon River, 3-Waterville Reservoir, and 7- downstream of mill in Pigeon River and 1-Big Creek; See Figure 1 and Table 2). Instream Monitoring by Parameter Blue Ridge Paper is required to monitor fecal coliform upstream (at station UP) and downstream of the discharge (at station DNI). Analysis indicates no discernable difference between the upstream and downstream fecal conform levels. Upstream fecal coliform is generally in the range of 100 to 200 /100m1. The same trend is evident at the downstream sampling point. These data suggest that Blue Ridge Paper does not contribute significant levels of fecal coliform. Monitoring of the effluent is sufficient to monitor the mill's impact on the river. Blue Ridge Paper has volunteered to conduct upstream sampling and this requirement will remain as a condition in the permit. Thus, the Division's recommendation is the elimination of the downstream fecal monitoring and once per week fecal monitoring upstream. Blue Ridge Paper is required to monitor conductivity upstream (at station IJP) and downstream (at station DNl). There is a significant increase in conductivity between the upstream and downstream monitoring sites. Conductivity measurements are less than 50 umhos/cm2 at the upstream monitoring station and generally greater than 250 umhos/crn' at the Fiberville Bridge. This increase in conductivity is expected since conductivity is a measure of inorganic material. Thus, the Division's recommends that conductivity monitoring continue as required.by 15A NCAC 2B .0508(d). Fact Sheet NPDES Renewal Page 4 Figure 1. Instream Monitoring Stations for Blue Ridge Paper Products — Canton Mill. /Station]o-xcrtx u., r Ste don 25 o-ee...alp cn.. f 01 ..TSi SMWM e].7-Above Clyde to I. andC eh Su0Pn02.e-F%.MH&Bride. M1ein B.d-UP.B..m of B W NIdO.Pepn USGS Sites Primary Highways Pigeon River Hydrography NPDES Discharger Municipal boundaries The facility is required to monitor 5-day Biochemical Oxygen Demand (BODS) upstream at station UP and downstream of the discharge at the station DN7. Levels of BODS have been less than 2.0 mg/L. Based on this information and the Division's lack of need for the data, it is recommended that instream BOD5 monitoring be eliminated from the permit. Fact Sheet NPDES Renewal Page 5 Table 2. Instream Monitoring Requirements According to the 1997 NPDES Permit and Color Variance. [ream mile Location Description Parameter Frequency Designation Marker UP 3.h Pigeon River upstream of the emperature Daily waste treatment plant outfall D.O. Daily (prior to mixing with the BOD5 1/Week discharge) Conductivity Daily Color 2/Week Flow Daily Fecal coliform I/Week Pigeon River at P iberville ri ge I emperature Daily D.O. Daily Conductivity Daily Fecal Coliform l/Week Color 2/Week Pigeon River Above Clyde emperature Daily D.O. Daily Pigeon River Below Clyde TemperatureI/Week D.O. 1/Week Color 2/Week Pigeon River at NCSX 1625 TemperatureI/Week bridge D.O. I/Week Color 2/Week igeon River at Hepco emperaturel/Week D.O. l/Week Color 2/Week Flow Daily Waterville Reservoir Annually DN6 26.0 Pigeon River prior to mixing Color2/Week with Big Creek Mouth of Big Creek prior to Color 2 Week mixing with the Pigeon River Pigeon River at Browns Bridge emperature ee (—NC/TN State Line) D.O. I/Week BOD5 1/Week Color 2/Week Blue Ridge Paper monitors temperature upstream at station UP and downstream at all monitoring stations except station DN6 and station BC. Comparing upstream to downstream, see Figure 2, the temperature difference ranged from between 1.78 °C and 11.65 'C. At no time did the monthly average temperature of the Pigeon River exceed the permitted limits of 32 °C (summer) or 29 °C (winter). Blue Ridge Paper monitors dissolved oxygen (DO) at all the instream stations except station DN6 and station BC. Over the period of review (1998 —2000), dissolved oxygen did not drop below the North Carolina's standard of 5.0 mg/L for Class C streams at any of the instream monitoring locations. Figure 3 summarizes the results of this analysis. During the previous permit cycle, an EPA-approved computer model indicated that BODs limits were required to protect North Carolina's instream dissolved oxygen standard of 5 mg/L for Class C waters. An economically feasible end-of-pipe technology capable of consistently treating to levels necessary to meet the limits specified by the model did not exist. North Carolina agreed with the continuation of the requirement that Blue Ridge Paper meet the instream dissolved oxygen standard by use of sidestream oxygen injection facilities. Blue Ridge Paper maintained these oxygen injection facilities at the effluent and at approximately 0.9, 2.1, and 3.7 miles downstream of the discharge. The previous NPDES permit required Blue Ridge Paper to maintain the oxygen injection facilities located 0.9 and 2.1 miles downstream. To ensure compliance with the above requirement, the average daily instream dissolved oxygen levels at stations DN1, DN2 and DN3 were required to equal or exceed 5.0 mg/L and the minimum instantaneous instream values were required to be greater than or equal to 4.0 mg/l. If dissolved oxygen drops below the prescribed values Blue Ridge Paper shall utilize the instream dissolved oxygen injection stations to increase the dissolved oxygen in the river. Fact Sheet NPDES Renewal Page 6 This method fulfilled the requirements of 40 CFR 125.3 (f). Blue Ridge Paper has compiled an extensive database on instream dissolved oxygen concentrations and stream flow. These data suggest that the dissolved oxygen sag occurs at station DN2. Figure 2. Temperature in the Pigeon River Upstream and Downstream of Blue Ridge Paper's NPDES Discharge. 35 Permitted Limits NC 1i 30 Summer Um!=VC WutterLmi=29°C ar-C2SC 25 L 20 -Statlon UP o - Statlon DN, n +Dena T c 15 Permi9eED' =13.9°C ,0 5 0 Nov-96 Feb-99 May-99 Aug-99 Deo-99 Mar-00 Jun-00 Oct-00 Jan-01 Apr-01 Time Figure 3. Average and Minimum Dissolved Oxygen in the Pigeon River from River Mile 63.5 to the NC/TN State Line. (Average DO* = In (DO)) 12.00 10.00 6.00 2 m E ii '- Average DO 6.000 a -ill-Minimum —212ndard a > 'Average DO' 0 w N 4.00 0 4P disebatge N(YIFliNShteLiae 2.00 0.00 70.00 60.00 50.00 40.00 30.00 20.00 10.00 0.00 River Mlle Fact Sheet NPDES Renewal Page 7 Stations DN2 and DN3 were included because the dissolved oxygen model predicted that the DO sag occurred in this area and because they represented monitoring locations upstream and downstream of Clyde's discharge. The Town of Clyde has recently removed their discharge and the Division has received a letter from the Town requesting rescission of the permit. Based on a review of the instream data and the removal of Clyde's discharge, it is recommended that the dissolved oxygen compliance point at station DN3 be eliminated. The Division reviewed the 1998 through 2000 instream dissolved oxygen data. Over this time period, Canton, North Carolina has experienced extreme drought conditions and flow in the Pigeon River has often dropped below the updated 7Q10 stream flow. Under these conditions, the lowest dissolved oxygen level observed in the North Carolina portion of the Pigeon River was 5.0 mg/L and occurred at river mile 57.7. Additionally, a review of the average daily instream dissolved oxygen data and the average over this time period indicates that the dissolved oxygen sag occurs at river mile 57.7. Based on this analysis, the compliance point and monitoring requirement at river mile 55.5 have been dropped. The oxygen injection facilities will continue to be maintained at the effluent, 0.9, and 2.1 miles downstream, and used as necessary to maintain an instream dissolved oxygen level of 5 mg/l. The condition to maintain the instream dissolved oxygen stations shall remain a condition of the permit until such time that the permitted loading of oxygen consuming waste to the Pigeon River is less than or equal to that proposed by an appropriate water quality model. If dissolved oxygen at station 57.7 drops below 5.0 mg/L, the facility is required to monitor dissolved oxygen at river mile 55.5 and 53.5. Instream monitoring continues to be required in order to assess Blue Ridge Paper 's impact on the Pigeon River and to ensure that the dissolved oxygen standard is maintained within the river. COLOR The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco USGS gauge station. The new effluent limits in this permit are more stringent than the provisions in the 1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is possible to calculate the monthly flow at the Canton gage station above which instream color at the Fiberville Bridge will not exceed 50 true color units. Using the 55,000 pounds per day monthly average true color loading limit(implemented on the effective date of the permit)the flow at the Canton Gage station,which will provide for color less than 50 true color units at the Fiberville Bridge is 171.8 MGD. Therefore,the monthly average color in the Pigeon River at the Fiberville Bridge will be less than 50 true color units whenever the monthly average flow(at the Canton gage station) is greater than 171.8 MGD. North Carolina is recommending that the Fiberville bridge be the basis for the color variance. The governing flow criterion for true color at Canton is 58.1 MGD (30Q2 stream flow). The flow established is greater than this 30Q2 stream flow,therefore,for flows less than the 171.8 MGD at the Canton Gage station but greater than 193.3 MGD at the Hepco gage station, the monthly average color in the Pigeon River at Hepco will be less than 50 true color units. Currently, the basis for the color variance is the Hepco station (DN5) within North Carolina, therefore with the moving of the station from Hepco to Fiberville, DWQ recommends that the mill monitor the Hepco station 2/week during the summer and once per week during the winter. During the permit cycle,the effluent color limit will be reduced, therefore, the instream color criteria will be adjusted accordingly. The monthly average color in the Pigeon River at the Fiberville Bridge will be less than 50 true color units whenever the flow at Canton is greater than the flow established using the following equation and based on the monthly average effluent limit established per Special Condition A.(8.)Paragraph 4: FlowatCanbnUSGS(MGD) _ (MonthlyAverageEfflueztColorLinit,lb/dcry-12468.3)+31.6+2.4 308.58 For flows at the Canton Gage station less than the flow established here but greater than 193.3 MGD at the Hepco gage station, the monthly average color in the Pigeon River at Hepco will be less than 50 true color units. Compliance Summary The facility has been in compliance with permit conditions during this cycle. Fact Sheet NPDES Renewal Page 8 Toxicity Testing Current Requirement: Chronic toxicity limit monitored quarterly @ 87% In December 1999 the facility reported a chronic level of 81% (with a state split sample greater than 87%), with the following two months greater than 100. All other toxicity tests over the past four years were greater than the stipulated 87%. The toxicity testing requirement is placed on all major facilities and other facilities with complex wastestreams. The toxicity limit is based on the instream waste concentration under 7Q10 conditions (52 cfs updated April 2001). For Blue Ridge Paper, the instream waste concentration was determined by also accounting for the out-take of surface water from the facility (31.6 MGD, as per application) and water withdrawal by the Town of Canton (allocated 6.8 MGD). Therefore, the instream waste concentration was determined to be 100% under 7Q10 conditions. The Division has set a ceiling on the toxicity test of 90%. This was done because of difficulties associated with averaging toxicity test with limits of 100%. The Division feels that 90% is sufficiently stringent to assess the chronic toxicity of an effluent, while allowing for the averaging of multiple tests. Recommended Requirement: Quarterly Chronic Toxicity @ 90% Mar, Jun, Sep, Dec Blue Ridge Paper is required to perform the NC Whole Effluent Toxicity Test or an equivalent method (as approved by the Division) on a quarterly basis at 90%. Any equivalent method shall also be performed on a quarterly basis. Toxicant Analysis Using the self-monitoring data required per the NPDES permit, reasonable potential analyses were d t d llowing toxicants: mercury, zinc, cadmium, selenium and silver. The standards s , ,cq,�}s stem with North Carolina standards for a class C waterbod f�C�ll � � bl� i � y. athmrunt )�ised oft e s46, fist nalysis of self-monitoring data, this discharge does not pose a reasonable potential to cause a vioikiz"a of the North Carolina stream standard for cadmium. Effluent itor_i e dad iu rt hall continue; ince cadmium continues to be detected in the effluent. (IJ�i�il1 �� I # II; If,� 11r11 � 11; �1 Me cur p they�tvisjon��l nfalysis of self-monitoring data, this discharge does not pose a �9. reasonable pote t c el,a viol t i f the North Carolina stream standard for mercury. Add'ti Hall ai> uiy s lesa 'k � d since January 1999 have been below North Carolina's e '� < n f dldt6con leve� of b.2 µg/L. Inc ults from the Division's 1996 Fish Tissue Mercury Ib �} < �yr1�u ;c to Pigeon River indicate, "total mercury results were comparable to `background' 1 1'cv��s exo�e�� 7or fish across North Carolina." Based on the findings in this report and the `Reaso a ?e otential' Analysis, it is recommended that mercury monitoring and limitation be removed permit. SilJer - Based on the Division's analysis of self-monitoring data, this discharge does pose a reasonable potential to cause an exceedence of the North Carolina's Action Level Standard for silver. Numerical limits for silver are not being included since silver is an action level water quality standard and the biomonitoring requirements are adequate to control toxicity due to the presence of silver. Though no limit is proposed, if the facility experiences chronic toxicity violations, the discharge will be re- evaluated and a silver limit may be implemented according to the Division's Action Level Policy. Selenium — The Division's analysis indicates that the maximum predicted concentration for selenium is greater than the allowable concentration. This analysis included only seven data points, with six data points below the quantitation level. One sample indicated the presence of selenium, however the concentration reported was at the quantitation level for the method. Additionally, the QA/QC data questions the validity of this data point. However, the Division has limited Blue Ridge Paper for Selenium. After collecting for one and half years (six data points) of data, the facility can request that the Division review the Selenium data for possible elimination of the limit. Zinc - Based on the Division's analysis of self-monitoring data, this discharge does pose a reasonable potential to cause an exceedence of the North Carolina's Action Level Standard for zinc. Numerical limits for zinc-are not being included since zinc is an action level water quality standard and the biomonitoring requirements are adequate to control toxicity due to the presence of zinc in the facility effluent. Though no limit is proposed, if the facility experiences chronic toxicity violations the discharge will be re-evaluated and a zinc limit may be implemented according to the Division's Action Level Policy. Monitoring requirements for zinc are consistent with 15A NCAC 2H .0508 (d). Fact Sheet NPDES Renewal Page 9 OXYGEN CONSUMING WASTE POLLUTANTS A site-specific Best Available Technology (BAT) based limit was calculated to determine the monthly average 5 - day biochemical oxygen demand (BOD5) limit. A site-specific BAT approach was used because North Carolina's Division of Water Quality continues to agree that an economically feasible end-of-pipe technology capable of reliably meeting the water quality limit specified by the existing model does not exist at this time and no violations.of the dissolved oxygen standard in the river have been observed in recent years. The North Carolina Division of Water Quality's recommendation for the draft permit BODS limit is established based on the demonstrated level of performance for the existing treatment plant. Data on treatment plant performance and influent loading from the Canton Mill (1998 through 2000) was evaluated and examined for outliers. As indicated in the "Bleach Environmental Process Evaluation and Report", the performance of this mill is among the best in the world. The maximum influent loading and lowest treatment plant performance were used to develop the monthly average BOD5 limit. The data set was sufficient to account for the day to day variability of the treatment system. Over the time period evaluated, the treatment plant has performed extremely well. The lowest percent removal was 96.9% and the highest influent loading was 414.9 mg/L. Based on this analysis, North Carolina's Division of Water Quality recommends a monthly average BOD5 loading of 3205.0 lbs/day. The limit presented in the draft permit represents and a 71-ton per year reduction in BOD5 loading to the Pigeon River. Because Blue Ridge Paper has oxygen injection facilities in place to maintain the instream dissolved oxygen standard should instream dissolved oxygen dictate a need, Blue Ridge Paper complies with the conditions set forth by 40 CFR 125.3 (f). The methodology used for the daily maximum 5 - day biochemical oxygen demand (BODS) limit was recommended during the previous permit cycle. A site-specific daily maximum to monthly average multiplier was used for determination of the recommended daily maximum limit. Using this methodology and reviewing data since the Canton Modernization Project (1998 — 2/2001) the recommended daily maximum limit based on a multiplier of 3.4 (daily maximum/monthly average) is 10897 lb/day. The limit proposed represents an achievable level and approximately a 12.5% reduction in the daily maximum BOD5 limit. Ammonia monitoring requirements are included in the permit to provide data concerning levels of ammonia discharged to the Pigeon River (which may affect instream dissolved oxygen). Effluent dissolved oxygen is limited at no less than 6 mg/1 based on the above discussion. Daily monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products, Class IV facility. NUTRIENT POLLUTANT ANALYSIS Total phosphorus and total nitrogen monitoring is required by 15A NCAC 2b .0508 (d) (2) (A). Monthly monitoring is required to assess the contribution of nutrients from Blue Ridge Paper and the potential impact to Waterville Reservoir. Waterville Reservoir is to be monitored once annually (during opposite years of CP&L's montioring) to assist in the continued characterization of nutrient impacts to the lake. � ,",,,,CANTS 4 Rgurrently a fah consgnption advisory due to dioxin for the Pigeon River downstream of the dtsciE11 A It it a vi was initially in effect for consumption of all fish species, this x ^p r s e1 , 1 H 1h rY Y P P . d c arp and catfish species only, reflecting continued improvements in the l ,n 9' rr tly, Blue 12t gGG��R� a er required to monitor dioxin and dibenzofuran isomers quarterly from the influent, sludge, land f1 'ate, and effluent. Based on an evaluation of the data, the Division is recommending a rev o a pie special condition requiring dioxin and dibenzofuran isomers monitoring. An improve 11giledge of the dioxin and dibenzofuran isomers indicates that only 2,3,7,8 TCDD and 2,3,7,8 TCDF are pollutants of concern. Therefore, it is recommended that the dioxin isomer special condition be modified to require monitoring only for 2,3,7,8 TCDD and 2,3,7,8 TCDF. Fact Sheet NPDES Renewal n..-- 1n It is further recommended that the monitoring frequencies be modified based on the fact that measurable quantities of dioxins and dioxin isomers have not been detected in the influent (since 1997), the effluent (since 1996), sludge (since 1996) and the landfill leachate (since 1996). The effluent limit for 2,3,7,8 TCDD has been reduced. During North Carolina's development of the Total Maximum Daily Load for Dioxins on the Pigeon River, the EPA commented that the chronic standard adopted by North Carolina should be applied as an effluent limit at the end of pipe. North Carolina did not agree with this methodology, since it is inconsistent with the standard and North Carolina rules. In addition, the management strategy implemented by North Carolina to address dioxins in the Pigeon River for several years and the data show that this management strategy is resulting in declining dioxin levels in the Pigeon River. The EPA, NC DWQ and Blue Ridge Paper agreed that the TMDL requirement could be waived as long as Blue Ridge Paper's effluent was limited at 0.014 pg/L. Therefore, the dioxin limit has been reduced to 0.014 pg/L and no TMDL will be developed. Annual fish tissue analysis shall continue to be performed by the facility in accordance with the monitoring plan approved by the Division until such time that the fish advisory is lifted in both Tennessee and North Carolina, according to North Carolina's delisting procedures. Trichlorophenol/PentacMorophenol limits and monitoring are not required. The permittee has certified that chlorophenolic biocides are not used at the facility. This certification eliminates the requirement to include effluent limits for these two parameters based on 40 CFR 430 H facility changes future operations to include chlorophenolic biocides, limits a d In i o`iii j 'i Ie nlred. 1 "'� Y i ) 4), �} q V�S„ � ' �'� �� 1�� 111�'I � �� .�ln�l�i�l a 131 �� 1 � �, 1. Il d la 1 I 1 { ih OC� `i��,U ��1Y1IT q ; !!!� I c to alls� spende solids SS) ,unt s were calculated using the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category and compared to existing limits. The TSS limits contained in the current NPDES permit are more stringent than the calculated federal effluent guidelines since the current limits are based on the 1993 proposed guidelines for the oxygen delignification process. The Division recommends that the existing TSS limits remain unchanged for this permit cycle. North Carolina does not have a numeric standard for TSS. The rules specifically regulate floating solids, settleable solids, and sludge deposits [ref. 15A NCAC 2B .0211(3)(c)]. The draft permit restricts floating solids. Both benthic and IBI studies have indicated fiirther improvement to the Pigeon River. Therefore, a monthly average TSS limit of 12,549 lbs/dayal,5•l [!commended and a daily ('d m t S, imit f 9, 60 lbs/da is recommended. g lit III' y 1 F I111 �J �I� �fI`I � Fln' T4 i 7Ffi "1 E� tU � �1 11► � � �� i 3 p7t�11 �(' I �� ,�i�� lt�`. � id�)r�hil � Ilya n urt 9Y i 6a ti A N A 0 ) Cl ss adihty tyl�� r The temperature requiremnt'is based � , a ectinjj 1 (a) Variance dete ' �i 'oi]>f�.ueQ, t �i�,j, �d fit �y1,rP Environmental Management Co i lion October 11, 1984 and approved by A A 4 t,6J 11., .,: ff lli{('v In making the recommendatioiS�t�bi Ire a "�°.he current 316(a) variance, DWQ scientist° ai�t,xted Blue Ridge Paper's Balanced and I jigenou ��^pecies Report and concluded that temperate ['could not be identified as prohibiting a Bal 'nced an Lidigenous population. In addition, DWQ staff reviewed existing temperature data and althougr suime improvement in the instream temperature has occurred (most likely due to overall effluent fl �Secrease, associated with process improvements reducing temperature impacts), Blue Ridge Pa m�' >r itill cannot meet the North Carolina temperature requirement as indicated in Figure 2 above. There�s`ore, DWQ is recommending that the 316(a) variance continue, with Blue Ridge Paper conducting a Balanced and Indigenous Species Study prior to the next permit renewal. The flow limit is based on Blue Ridge Paper's current flow values and post-CMP production plus 0.9 MGD for the Town of Canton's wastewater. Future plant improvements may reduce the contribution of the mill's wastewater, however the Town of Canton is proposing to increase their contribution to the treatment plant as they expand Canton's municipal boundary. Since flows are currently approximately 80% of the permitted capacity, the Division recommends that the flow limit remain unchanged. During the next permit cycle the flow limit should be re-evaluated Fact Sheet NPDF-S Renewal Page 11 It is further recommended that the monitoring frequencies be modified based on the fact that measurable quantities of dioxins and dioxin isomers have not been detected in the.influent (since 1997), the effluent (since 1996), sludge (since 1996) and the landfill leachate (since 1996). r�Ull 1 tl The of t ,limit for 2,3,7,8 TCDD has been reduced. During North Carolina's development of the I01aI I.+kiiim Daily Load for Dioxins on the Pigeon River, the EPA commented that the chronic -' !standam adopted by North Carolina should be applied as an effluent limit at the end of pipe. North Carolina did not agree with this methodology, since it is inconsistent with the standard and North Carolina rules. In addition, the management strategy implemented by North Carolina to address dioxins the Pigeon River for several years and the data show that this management strategy is resulting 1ineclining`, dioxin levels in the Pigeon River. The EPA, NC DWQ and Blue Ridge Paper a n, d th e}1,e TMDL requirement could be waived as long as Blue Ridge Paper's effluent was limited a�p ��P A0— Therefore, the dioxin limit has been reduced to 0.014 pg/L and no TMDL will be Jtl de eiti ed. Annual fish tissue analysis shall continue to be performed by the facility in accordance with the monitoring plan approved by the Division until such time that the fish advisory is lifted in both Tennessee and North Carolina, according to North Carolina's delisting procedures. Trichlorophenol/Pentachlorophenol limits and monitoring are not required. The permittee has certified that chlorophenolic biocides are not used at the facility. This certification eliminates the requirement to include effluent limits for these two parameters based on 40 CFR 430. However, if the facility changes future operations to include chlorophenolic biocides, limits and monitoring will be required. OTHER POLLUTANTS OF CONCERN The total suspended solids (TSS) limits were calculated using the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category and compared to existing limits. The TSS limits contained in the current NPDES permit are more stringent than the calculated federal effluent guidelines since the current limits are based on the 1993 proposed guidelines for the oxygen delignification process. The Division recommends that the existing TSS limits remain unchanged for this permit cycle. North Carolina does not have a numeric standard for TSS. The rules specifically regulate floating solids, settleable solids, and sludge deposits [ref. 15A NCAC 2B .0211(3)(c)]. The draft permit restricts floating solids. Both benthic and IBI studies have indicated further improvement to the Pigeon River. Therefore, a monthly average TSS limit of 12,549 lbs/day is recommended and a daily maximum TSS limit of 49560 lbs/day is recommended. Daily monitoring is required based on 15A NCAC 2B .0508 (d), Class IV facility. The temperature requirement is based on a Section 316 (a) variance determination issued by the NC Environmental Management Commission October 11, 1984 and approved by EPA August 6, 1985. In making the recommendation to retain the current 316(a) variance, DWQ scientist evaluated Blue Ridge Paper's Balanced and Indigenous Species Report and concluded that temperature could not be identified as prohibiting a Balanced and Indigenous population. In addition, DWQ staff reviewed existing temperature data and although some improvement in the instream temperature has occurred (most likely due to overall effluent flow decrease, associated with process improvements reducing temperature impacts), Blue Ridge Paper still cannot meet the North Carolina temperature requirement as indicated in Figure 2 above. Therefore, DWQ is recommending that the 316(a) variance continue, with Blue Ridge Paper conducting a Balanced and Indigenous Species Study prior to the next permit renewal. The flow limit is based on Blue Ridge Paper's current flow values and post-CMP production plus 0.9 MGD for the Town of Canton's wastewater. Future plant improvements may reduce the contribution of the mill's wastewater, however the Town of Canton is proposing to increase their contribution to the treatment plant as they expand Canton's municipal boundary. Since flows are currently approximately 80% of the permitted capacity, the Division recommends that the flow limit remain unchanged. During the next permit cycle the flow limit should be re-evaluated Fact Sheet NPDES Renewal Page 11 and if appropriate adjusted. Due to potential inflow/infiltration from the Town of Canton, the Division continues the provision that requires Blue Ridge Paper to work with Canton to reduce III problems. ' Chemical Oxygen Demand (COD) monitoring is required to assess the potential impact of chemical oxygen demand from the Blue Ridge Paper wastewater effluent. Neither federal guidelines nor NC water quality standards require a limit for COD. Though no limit is proposed, the EPA has reserved COD for potential future limits. Therefore, COD monitoring will be continued. Limitations for fecal coliform are based on the contribution of domestic wastewater from the Town of Canton and the requirements of 15A NCAC 2B .0211 (b) (3) (E). Metals toxicity is a function of water hardness, since Blue Ridge Paper has demonstrated reliable compliance with toxicity, the Division recommends the elimination of hardness monitoring. Conductivity monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products (Water Quality Limited Facilities), for a Class IV facility. Monitoring for total residue/total dissolved solids is required according to the existing NPDES permit. The required conductivity monitoring is sufficient to assess Blue Ridge Paper's inorganic loading to the Pigeon River. Therefore, the Division recommends removal of total residue and total dissolved solids monitoring from the permit. Limitations for pH 6.0 —9.0 are based on 15A NCAC 2B .0211 (b) (3) (G). ISSUES ASSOCIATED WITH EFFLUENT GUIDELINE IMPLEMENTATION Relevant Background Information Over the past five-year permitting cycle, the maximum 12-month production occurred from May 1999 through April 2000. Table 3 outlines the total production of various products generated at the Canton Mill over this time period. Pulp produced at the Canton Mill is supplemented with pine and hardwood pulp purchased from off-site and pulp produced from trim or broke paper off the paper machines. The pulp is then used in paperboard and fine paper production using one of the four paper machines on-site. Table 3. Itemized Production Figures for the Maximum 12 Month Average Production Period. Product Total for 12 Month Period Units Pine Pulp 217,634.48 Air Dried Tons Hardwood Pulp 298,833.91 Air Dried Tons Purchased Pine Pulp 24,306.87 Air Dried Tons Purchased Hardwood Pulp 22,252.21 Air Dried Tons Broke Paper or Trim Pulp 46,559.08 Air Dried Tons Paperboard Production 313,625.90 Off Machine Tons Fine Paper Production 321,264.00 Off machine Tons Blue Ridge Paper has not joined the Voluntary Advanced Technology Incentives Program (VATIP) for existing direct or new direct dischargers as outlined in 40 CFR 430 Subpart B. The VATI Program was set up for new or existing direct dischargers whereby trills agree to accept enforceable effluent limitations and conditions in their NPDES permits that are more stringent than the BAT limitations, in exchange for regulatory and enforcement related rewards and incentives. Blue Ridge Paper will use steam stripping to treat process condensates, rather than hardpiping to the WWTP; thus interface with the Division of Air Quality is not necessary. Relevant Issues Daily effluent monitoring for Adsorable Organic Halides (AOX) is required. AOX is an overall test for adsorbable organic halides, which includes chlorinated organics. Trends in concentration changes have been observed between AOX and specific pollutants (dioxins, chlorinated organics) at pulp and Fact Sheet NPDES Renewal Page 12 paper mills. Therefore, any decrease in AOX may also indicate a decrease in chlorinated organics. Limits and daily monitoring for AOX are required in the EPA Cluster Rules. The cluster rules are the combined air and water rules issued by the EPA for the pulp and paper industry. The compliance/monitoring point for the AOX limits shall be as defined in the sampling plan. During the next permit cycle, the Division will review the AOX data for possible reduction in monitoring frequencies. Chloroform monitoring/limits have been added to the permit. During the previous permitting cycle, it was determined that the discharge from Blue Ridge Paper did not have a reasonable potential to exceed the allowable level. Therefore, no effluent limit is proposed. Limits contained in the NPDES permit on the bleach plant effluent are based on the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category. Since Blue Ridge Paper operates two separate fiber lines, there shall be two compliance points for chloroform as stipulated in the sampling plan. In addition to the dioxin limits and conditions stated, above dioxins shall be limited and monitored on the effluent from the each bleach plant. 2,3,7,8 TCDD and 2,3,7,8 TCDF limits are based on the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category. The compliance/monitoring points for each bleach plant is required as stipulated in the sampling plan. Best Management Practices (BMPs) have been added for spent pulping liquors, turpentine, and soap. At this time, Blue Ridge Paper is in compliance with the best management practices stipulated in the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category with one remaining issue. The remaining issue deals with the BMP Plan. As part of the EPA promulgated effluent guidelines, facilities, which fall under subpart B, must develop a BMP Plan. This plan does not require the approval of any regulatory authority, but must be certified by the mill manager. Currently, the BMP Plan is in the development process and it is anticipated that this requirement will be completed prior to issuance of this NPDES permit. Per 40 CFR 430.24, the daily maximum limits for 12 chlorinated phenolics are "less than Minimum Level" (<ML) as specified in 40 CFR 430.01. The compliance/monitoring point shall be set at the effluent from the bleach plants as outlined in the sampling plan. PROPOSED CHANGES FROM THE CURRENT NPDES PERMIT • Monthly average BOD5 limit reduced 71 tons per year to 3205 lb/day. • Daily maximum BOD5 limit reduced 12.5% to 10897 lb/day. • Toxicity testing concentration increased to 90%. • Removal of downstream fecal coliform monitoring with once per week upstream fecal monitoring. • Removal of instream BOD5 monitoring. • Removal of instream monitoring station 55.5. • Removal of instream monitoring station 53.5. • Reduce monitoring frequency at NC/TN monitoring station. • Eliminate mercury monitoring and limitation. • Add selenium limit. • Trichlorophenol/pentachlorophenol monitoring has been removed. • The upstream river mile marker now indicates that the upstream monitoring location is located at river mile 63.8. • The dioxin special condition has been modified to require 2,3,7,8 TCDD and 2,3,7,8 TCDF individual isomer monitoring and to reduce the monitoring frequency of the sludge and landfill leachate. Fact Sheet NPDES Renewal . Page 13 • The 2,3,7,8 TCDD effluent limit has been modified to 0.014 pg/L. • Two internal outfalls (002 and 003) have been added. • Removal of hardness monitoring. • Removal of total dissolved solids monitoring. • Removal of total residue monitoring. • An AOX limit and daily monitoring has been added to the permit per EPA Cluster Rules. • Dioxin, chlorophenolics and chloroform limits/monitoring have been added for the effluent from the pine and hardwood line bleach plants per EPA cluster rule. • -The BMP special condition has been updated according to the requirements of the EPA Cluster Rule. • For color recommendations refer to the July 24, 2001, memo from the EPA Tech Team to the Technology Review Workgroup. This fact sheet represents North Carolina's recommendations. The Division will review all pertinent comments received during the public comment period and the September 6, 2001 public hearing. After reviewing all public comments, the Director of the Division of Water Quality and the NPDES Committee of the Environmental Management Commission will make their recommendations. PROPOSED SCHEDULE FOR PERMIT ISSUANCE Public Notice Draft Permit, temperature variance, color variance and Public August 3, 2001 Hearing Public Hearing September 6, 2001 ADDITIONAL INFORMATION CANTON MODERNIZATION PROJECT Prior to 1993, knotting hardwood brownstock was washed through one of two brownstock washer lines. After washing brownstock was screened using a two-stage fine screening process and bleached in one of the two bleaching lines. The two bleaching lines were operated independently for 'low' brightness and 'high' brightness. Since 1993, the hardwood fiberline has incorporated numerous modifications designed to increase mill performance from both an environmental and product quality standpoint. Currently, the hardwood fiberline consist of two stage knotting followed by pre-oxygen delignification washers. After pulp is processed through the oxygen delignification unit, it is washed again prior to the four stage pressurized fine screening. After screening, the pulp is bleached through one medium consistency bleach line. Prior to 1992, pine (softwood)pulp was processed through one brownstock washing line prior to the two stage screening process. After screening, pulp was processed through one of the two bleaching lines. Similar to the hardwood fiberline, the softwood fiberline bleaching was operated independently for 'low' brightness and 'high' brightness. Like the hardwood fiberline, the softwood fiberline has incorporated numerous modifications in order to enhance product quality and environmental performance. 'Currently, the softwood fiberline process consist of two stage knotting followed by a brownstock pre-oxygen delignification line. After the initial washing the pulp is processed through the oxygen delignification unit followed by another washing. After the second washing pulp is screened using four stage pressurized fine screen before entering a medium consistency bleach line. In addition to the improvements noted,the facility has implemented full scale bleach filtrate recycle of the pine bleach line and caustic extraction stage (Eo) recycle on the hardwood bleach line. Fact Sheet NPDES Renewal Page 14 References 1. Division of Water Quality's Basinwide Information Management System, April 20, 2001, http://h2o enr.state.ne.us/bims/reportstbasinsandwaterbodies/alpha/Neuse.pdf 2. 1995. NPDES Regional Staff Report for NPDES Permit NC0000272, January 18, 1995, Asheville Regional Office. 3. 2000. French Broad River Basinwide Water Quality Plan. North Carolina Division of Water Quality, Water Quality Section. 4. 2001. NPDES Permit Application EPA Forms 1 and 2C, Blue Ridge Paper Products Inc. 5. 2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of Water Quality, Water Quality Section. Copies obtained through Planning Branch, Archdale I J Building, 512 N. Salisbury St., Raleigh, North Carolina. 117. 3 Low Flow Characteristics of Streams in North Carolina, United States Geological tc :f ebc' W t¢ -Su y 1per 2403. Copies obtained at U.S. Geological Survey, Map � 'tlP ; t ri J tp�,li ��L�5 �6 MS306, Federal Center Denver CO 80225. atA � ' ,1Q2 . P iS Permit. Issued to Champion Paper, expiration November 30, 2001. Copi s obd rough The Division of Water Quality, Central Files, Archdale Building, 512 N. Sali3 ry St., Raleigh, North Carolina. 8. 2001. Bleach Environmental Process Evaluation and Report. Dr. Norman Liebergott, PhD, ociates Liebergott and Ass Consulting, Inc, and Lew Shackford, June 8, 2001. 9. 2001. Additional Color Removal Technologies and Their Economic impacts on Blue Ridge Paper Products, Canton, NC. July 25, 2001 Memorandum from EPA Tech Team to Technology Review Workgroup. State Contact If you have any questions on any of the above information or on the attached permit, please contact Michael�M7y,errss at (919) 733-5038 ext. 508. NAME://9 � y DATE: Z�c� T NPDES SUPERVISOR/ NAME: I /l^— DATE: nJ ZOoI Fact Sheet NPDES Renewal Page 15