NC0000272_Historic_Files_1998

STATE OF NORTH CAROLINA
Department of Environment, Health, and Natural Resources
Water Quality Section
59 Woodfin Place, Asheville, NC 28801
704-251-6208
File Access Record
FACILITY NAME COUNTY
I/We, have been provided
(print name)
(print name)
access to the above-named file by personnel of the Water Quality
Section. I understand that this statement shall be made a
permanent part of any file which is viewed under the Freedom of
Information provision of the North Carolina General Statutes.
(signature) (date)
(signature) (date)
name/initials of WQ staff member
permit number

Ca^Tc:
Sox C -
Cantcn - _ ;"na .__ ._ .
US hamcson - -=.;:onai Cc;ocrauon
October 5, 1998
Mr. Donald Anderson
U. S. EPA
Engineering and Analysis Division
401 M Street, S. W.
Washington, D. C. 20460
Re: BFR TM - STATUS REPORT
Champion International Corporation- Canton Mill
Dear Mr. Anderson:
As you are aware, Champion has been demonstrating its patented Bleach Filtrate Recycle
(BFRTM) process at the Canton Mill in order to meet the December 1, 1998 color
reduction objectives set forth in Part III, Section E, Paragraph 10 of NPDES Permit No.
NC0000272. This paragraph begins as follows:
"Beginning December 1, 1998, the annual average discharge of true color shall not exceed
60,000 Ibs/day and the monthly average true color loading shall not exceed 69,000 Ibs/day.
However, ifby October 1, 1998, in accordance with the Settlement Agreement and the Revised
Color Variance, the Technology Review Workgroup determines, and the NPDES Committee
agrees, that there are overwhelming technical, economic or operational barriers to the
permittee's ability to attain the above-stated color loading limits, the Technology Review
Workgroup shall recommend to the NPDES Committee the alternate interim limits to become
effective December 1, 1998."
The color limitations set forth in this paragraph are contingent upon the successful
operation of the BFR TM technology on the mill's pine line. Specifically, paragraph 7 of
the permit reads:
"Based on the results of the demonstration effort, the permittee shall continue the full operation
ofthe BFRTM technology on the mill's pine line on a continuing basis, subject to the process set
forth in Paragraph E 10"

CFamcc� — —nonal Coroornon,
Mr. Donald Anderson
page 2
In 1998, the mill's monthly and annual daily average effluent color discharge has been
consistently below the limitations set forth in the Paragraph 10. Champion is committed
to operating BFRTM on a continuing basis. This is to advise the Technical Review
Workgroup that, at this point in the demonstration, no technical, operational or economic
issues have surfaced that are viewed as insurmountable obstacles to the continuous
operation of the technology.
One issue remains outstanding, however, to assure the continuous operation.of BFRTM.
That issue is an air permit determination by the Western North Carolina"Regional Air
Pollution Bureau (WNCRAPB). In order for that determination to be completed certain
data must be collected and analyzed. To support that determination, Champion is
currently finishing its final round of required air emissions testing on both recovery
boilers. Although Champion expects to be able to obtain appropriate air operating
permits for the BFRTM process, this evaluation remains to be completed. Champion
intends to complete the permitting process as soon as the air emissions testing and
analysis is complete. The timing for the completion of this emission analysis and
determination is the end of 1998 or early 1999.
The BFRTM process can not be deemed to be operational on a continuous basis until the
permit determination is complete and any appropriate authorization is received from the
WNCRAPB. If you have any questions, please feel free to contact me at(828) 646-2033.
Sincerely,
Robert Williams
Manager, Environmental, Occupational Health and Safety - Canton Mill
xc: Mr. Forrest Westall
Regional Supervisor
Division of Water Quality
NC Department of Environmental
and Natural Resources
59 Woodfin Place
Asheville,NC 28801

Page 2
December 1, 1986 - US District Court Judge Sentelle ruled
that EPA had jurisdiction to assume
authority over Champion' s NPDES Permit .
March 4, 1987 - Champion appeal of Sentelle ruling.
April 9, 1987 - First EPA Draft (public notice) of
Champion NPDES Permit with 50 unit color
limit applicable to Champion immediately
downstream of discharge at Fiberville
Bridge.
May 22, 1987 - Second EPA public notice for permit
issuance.
January 14, 1988 - First Public Hearing in Asheville Civic
Center for NPDES Permit issuance.
January 21, 1988 - First Public Hearing in Knoxville,
Tennessee Civic Center.
March 9, 1988 - Tennessee, North Carolina, Champion, and
EPA agree on change in proposed permit
from 50 Apparent Color units at NC/TN
state line (proposed as applicable at
the Fiberville Bridge immediately
downstream of the Champion Mill) to 85
True Color Units at the State line.
. North Carolina and Tennessee to grant
variance from color stream standard to
allow permit issuance .
May 5, 1988 - Champion formally requests water quality
color standard variance from EMC NPDES
subcommittee at public hearing in Raleigh.
June 24, 1988 - Champion appeal of Sentelle decision
denied by three judge panel of 4th US
Circuit Court of Appeals - verifying EPA
authority over Champion' s NPDES permit.
Ron Levine, Director, Division of

St of North Carolina
MICHAEL F. EASLEY Department of Justice REPLY T0:Daniel C.Oakley
A7rORNEY GENEML Y. G. BOX 629 Environmental Division y
RALEIGH [e-mail]
276020629 Telephone:[phone]
Fax:[phone]
MEMORANDUM
TO: Secretary Wayne McDevitt
FROM: Daniel C. Oakley-P(,0
DATE: October 1'), 1998
RE: Pigeon River Joint Watershed Advisory Committee
The attached correspondence will remind you of North Carolina's commitment to the
Joint Watershed Advisory Committee (JWAC), as one of the provisions in the settlement of the
Champion Paper matter. Forrest Westall and I have recently discussed the establishment of the
JWAC and the appointment of the North Carolina representatives, and wanted to bring it back to
your attention.
Please review this correspondence and advise whether you are in agreement with the
outline of the committee as set out in the exchange between Tennessee Deputy Attorney General
Barry Turner and myself. If the basic format is acceptable to you, Forrest and I feel we should
try to get the JWAC up and running in early 1999. This will require four(4) appointments to be
made by North Carolina. As DENR Secretary, you are the appropriate person to make those
appointments.
Please advise as to how Forrest and I should proceed.
Thanks.
/dw
cc: Bill Holman
Preston Howard
Forrest Westall OCT 2 2 lcoq
attachment
wp/28143

1 i
REPLY TO:Daniel C.Oakley
Environmental Division
[e-mail]
Telephone:[phone]
Fax:[phone]
MEMORANDUM
TO: Secretary Wayne McDevitt
FROM: Daniel C. Oakley
DATE: October 13, 1998
RE: Pigeon River Joint Watershed Advisory Committee
The attached correspondence will remind you of North Carolina's commitment to the
Joint Watershed Advisory Committee (JWAC), as one of the provisions irthe settlement of the
Champion Paper matter. Forrest Westall and I have recently discussed the establishment of the
JWAC and the appointment of the North Carolina representatives,4�-.J
Ju r . ZtU_.Cu--
Please review this correspondence and advise whether you are in agreement with the
outline of the committee as set out in the exchange between Tennessee Deputy Attorney General
Barry Turner and myself. If the basic format is acceptable to you, Forrest and I feel we should
try to get the JWAC up and running n early 1999. This will require four (4) appointments to be
made by North Carolina. YPc�{ y�pt,�s DENR Secretary, are the appropriate person to make
those appointments.
Please advise as to how Forrest and I should proceed.
Thanks.
/dw
cc: Bill Holman
Preston Howard
Forrest Westall
attachment
wp/23 143

STATE OF TENNESSEE
Office of the Attorney General RECEIVED
SEP 1 41993
u`ncucu I A
d. :n
ti.C. Af iORMEY GENERAL
Envimnmental Division
.....
JOHN KNOX WALKUP
ATTORNEY GENERAL AND REPORTER
ANDY D. BENNETT MICHAEL E. MOORE
CHIEF DEPUTY ATTORNEY GENERAL SOLICITOR GENERAL
LUCY HONEY HAYNES CORDELL HULL BUILDING
ASSOCIATE CHIEF DEPUTY NASHVILLE. TN 37243-043S
ATTORNEY GENERAL
74
September 10, 1998 FACSIMI EE(6115))741'20091
BY FACSIMILE TRANSMISSION
Daniel C. Oakley
Senior Deputy Attorney General
State of North Carolina
Department of Justice
P.O. Box 629
Raleigh,North Carolina 27602-0629
Re: Joint Watershed Advisory Committee
Dear Dan:
I recently met with Justin Wilson, Paul Davis and David McKinney, and what follows are
our thoughts regarding the Joint Watershed Advisory Committee the Settlement Agreement
requires Tennessee and North Carolina to establish. We think the focus of this Committee is to
be on both economic and environmental issues within the watershed. Information relating to
such issues would be provided to the.Committee by the States. With regard to Tennessee,
economic information would come from the state Department of Tourism and the Department of
Economic and Community Development. We have not yet determined what types of economic
information these agencies would provide to the Committee.
Environmental information would come from the Tennessee Department of Environment
and Conservation, the Tennessee Wildlife Resources Agency, and the Tennessee Department of
Agriculture. While not an exclusive list, we think the following environmental information
relating to the watershed could be provided to the Committee: water quality monitoring reports;
biological monitoring reports; NPDES-related planning and actual discharge information; non-
point source activities; soil and water conservation programs; and other environmental program
information, e.g., RCRA and air.
In response to the information provided by the state agencies, the Committee would
consider any specific proposals involving the watershed, and if it chose to do so, could prepare
comments or other materials regarding such proposals. These would be considered by the

appropriate state agency or agencies. We envision state agency support for the Committee to
involve supplying the Committee with copies of the information noted above, and reviewing
comments or other documents submitted to the agencies by the Committee. Although officials
from these agencies would not be regularly attending Committee meetings, officials could be
available to meet with the Committee from time-to-time to discuss specific matters if the
Committee requests this.
From Tennessee's perspective, we do not have resources available to provide funds or
agency staff to assist with the operations of the Committee. We would, however, be able to
make office space in Knoxville available to the Committee for meetings, and in conjunction with
those meetings, we also could make a copy machine and a telephone available for the
Committee's use. Tennessee would support the Committee seeking grant assistance from EPA
for funds to operate.
Concerning Committee membership, we think four members should be appointed by each
State. The members would have overlapping service periods, and one of each State's
appointments would be a co-chair of the Committee. The Tennessee appointees would be: (1) a
government official from a municipality situated on the Pigeon River; (2) a government official
of Cocke County; (3) a member of the rafting outfitters' association in Cocke County; and (4) a
member of an environmental citizens' group in Cocke County.
After you have had a chance to review this, please give me a call to discuss further. I
look forward to hearing from you.
Sincerely,
BARRYI"TURNER
Depu ,Attorney General
(615)�32-2586
xe: Justin Wilson
Paul Davis
David McKinney

,uK �
3�A
State of North Carolina
MICHAEL F. EASLEY Department of Justice
ATTORNEY GENERAL P.O. BOX 629 REPLY TO:
RALEIGH Environmental Division
[e-mail]
mail.jus.state.nc.us
2 7 602-0629 Telephone:[phone]
Fax:[phone]
July 23, 1998
Mr. Barry Turner
Deputy Attorney General
425 Fifth Avenue North
Nashville, Tennessee 37243-0495
RE: Joint Watershed Advisory Committee
Dear Barry:
Pursuant to Paragraph 32 of the Settlement Agreement Regarding 1996 Water Quality Color
Variance and 1996 NPDES Permit Issued to Champion International Corporation,North Carolina
and Tennessee are required to establish a Joint.Watershed Advisory Committee. The agreement is
silent as to the details for setting up and operating the Committee, but the goal is to "foster joint
planning and public input on decisions affecting the Pigeon River."
Both states need to establish the initial requirements for membership and operation, and it
appears you and I are in the best positions to move the committee along legally. Forrest Westall,
Paul Davis, Mike McGhee and others have had a general discussion of this on May 12, 1998; and
at that time North Carolina suggested several principles to follow. They may be summarized as
follows:
North Carolina and Tennessee should appoint three or four members each (with
concurrent or overlapping service periods), with one of each State's appointments
being a co-chair of the Committee (a partnership in direction). The criteria for
appointment would have to be established, but would likely include folks that live
in the basin and that have some special local interest or leadership role (political,
educational, or interest group affiliation). Staffing support of the Committee would
have to be agreed to by the two states. Since the basic objective of this section of the
Agreement seems to be to foster community interest in the River and the
management decisions affecting the River, it is anticipated that the Committee. after
completing its initial meetings and organization efforts, would develop its own path.

Mr. Barry Turner
Page 2
July 23, 1998
It would initiate its own agenda for interaction with federal, State and local agencies
having land and water management responsibilities within the watershed. The
Committee would develop its own "independent" view of these decisions or
proposals and would comment directly to those agencies. It should have broad
latitude to determine its role.
The purpose of this letter is to initiate a process under which the two states can agree on
Committee membership criteria and any staffing or logistics issues. Appointments may then be
made and the Committee charged with going forward as it determines appropriate.
Please consider this proposal and call me to discuss, at your convenience. I look forward to
working with you again on this matter. With best wishes, I am
Very truly yours,
jovv, 00
Daniel C. Oakley
Senior Deputy Attorney General
DCO/dw
cc: Secretary Wayne McDevitt
Preston Howard
Forrest Westall
wp26431

Effluent
NPDES No.: NC 0000272 IDischarge No.: 001 Month: November Year: 1998
Facility Name: Champion International Corporation Class: IVI lCounty: Haywood
Operator in Responsible Charge(ORC): David M.Cody Grade: IV I Phone [phone]
Certified Laboratories: (1)Champion Int'1 #198;(2)Pace #40,#12,(3)Brooks Rand#546(4)Burlington Research#002
Check Box if ORC Has Changed Person(s)Collecting Samples: Operators on Duty
Mail ORIG'L+1 COPY to:
Attn:Central Files /
Div.of Environmental Mgt X
DEHNR (Signature of Operator in Responpi6le Charge) D
P.O.Box 29535 BY THIS SIGNATUR CERTI T THIS REPORT IS ACCURATE AND COMPLETE
Raleigh,NC 27626-0535 TO THE BEST OF NOW G
50050 00010 00400 0031 00530 31505 00300 00600
E in LL O � /r�m'•„
044 /�yz \m/ € '
E E in � � � m {t/9 0 �/ �.;` y/5� o a z
i o H Fqy��
0 0 o w / / / _
0 o LL �7nn SFia; ®mod °LL
HRS YIN MGD °C Std Units Sid Units Ib,lday- - IbJday 1 #1100mi mgf- mg1L
�1� ,:07.00. „24 ' i yN4 ' �22.$0$+.c3;'3g2,�� �aa7�,rs', ��$,,<� •'�„`r1091"`'�0.11$ �'� �Sk+:rt�,' `� ,�7�+'�B `� t�
2 0700 24 Y M 23.684 32.8 7.9 7.8 2773 < 0.082 " 4346 2 12.80
3 t 0700,;A 24 W'. ,_Y 20,528?, 33 8 . 3 g' ,s.= .$; 308 U,231 r S,0' l , ?.2 05 f
4 0700 24 Y 22.413 33.3 7.8 7.8 2882 0.239 5982 12.14
5; 0700, 2d Yx�,11 3.2TxZ4, �,A 9� 1,7:$S`..
6 0700 24 Y 22.710 33.0 7.9 7.8 3597 0.173 5493 11.67
24L 2LL L1 L 9M?a 2920 §5, ' S1Qs.z LLL ;�Lill
8 1 0700 24 N 21.721 28.8 8.0 8.0 2389 0.099 4348 11.13
485�
6ry
h�` fx`
10 0700 24 Y 22.926 31.0 7.9 7.9 2407 < 0.082 4971 10.63
11'= _0700, r}.24c t 3 $()x
12 0700 24 Y 23.158 29.7 8.1 7.9 1215 < 0.082 3476 9.87
23 „}` fit}Q82 v 366$ . #1013MOAQ
14 070024 Y 2233.(5110 331(.g2 88.0{ �7.9
� 1174
< 0{.0(8y2j 392�11 10.83
16 0700 24 Y 23.582 30.7 8.1 8.0 1280 < 0.082 2360 1 9.78
1T' 0700)' }T24 r, a .a F23452 T $ _ nc* Qy 0082: 3fL91 3 9v9$ �; �:.
18 0�7/0}0 T24
( Y 2}4.5}011 �¢30.5 g 8}.1} 8.0� 1545 ¢<1e0ry.(0�82 326}9(�j � 10.12 W
,3� 4 ?.VILQ 'b IG7S;£tf $,® § imIG etijLf,$>.Fd4RV.$ "�Y '"a'acQ4`e`SC -,t'#? (,VY r LV154. v. VY�b fW+'_11, J# 1113`+ Ri, �I -'?'�$.'
20 070{0y 24} Y 24.110 31.4 8.2 7.9 1468 < 0.082 32177 9.98
22 0700 24 N 22.848 29.4 8.0 7.9 1000 < 0.082 1906 10.43
23a�,OZDQ= r4�, �, B >�,•, �*/�t} !{, �y Q(f,�s ,'�} ry�(�r3�,`� �+�yQ .�+�e��sx Yp,,�, (�C�J ;y�
24 0700 24 1 B 23.622 31.5 7.9 7.9 1194 < 0.082 2561 10.80
25 `V,00, „24' �B ' 22AL 6 ;79
26 0700 24 N 23.122 30.4 8.0 7.9 2108 < 0.082 5014 11.10
27` ,0700` 24. .N . 231597 2$<7 86 "tl i3$= 124322833sx h[184:
28 0700 24 N 23.558 29.6 8.0 7.9 1183 0.099 2358 11.21
•29' �:0700 ';24;: ,�,tJ�� x23238: �.;�29,41� °�: �4a�`k�_T,:9 ` xf'1452_ �Q082,�! "�2713� �'��-,;� ��i�t2� .�:�A„-fir
30 0700 24 Y 24.548 29.4 8.0 7.9 1402 0.091 2866 2 12.03
f' q,+,111k
Average 23.112 30.9 1869 0.11 3719 3 10.86 4.60
Maldmgm xx_.. ;; x 24 54$, , 3 8,; t12,., .8:?_: 3673 is10 24m 5982 n 23 .,1280 460
Minimum 20.528 28.8 7.8 1 7.8 1000 < 0.08 1906 1 9.66 4.60
Comp(C)/Gr'ab"(G); G, . ,;;G` w_G, Cr`' ` C ',.Ci3 ,"G 1,Gh
Monthly Limit 29.9 9 1 6 1 3,598 '12,549 200 6

Facility Status:(Please check one of the following) ,
All monitoring data and sampling frequencies meet permit monitoring requirements.
Compliant
All monitoring data and sampling frequencies do NOT meet permit monitoring requirements.
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment,
operation,maintenance,etc. and a time table for improvements to be made.
.r
r;Y
a
e
'I certify,under penalty of law,that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel property gather and evaluate the information submitted.
Based on my inquiry of the person or persons who manage the system,or those persons directly responsible forgathering the
information,the information submitted Is,to the best of my knowledge and belief,true,accurate,and complete.I am aware that there are
significant penalties for submitting false information,including the possibility of fines and imprisonment for knowing violations'
William R.Manzer
Permittee(Please print or type)
Signature of Permittee" Date
P.O.Box C-10 Canton,NC 28716 704-646-2840 Permit Expires Nov.30,2001
Parameter Codes
00010 Temperature 00556 Oil&Grease 00951 Total Fluoride 01067 Nickel 50060 Total
00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual
00080 Color(Pt-Co) 00610 Ammonia Nitrogen 01092 Zinc Chlorine
00082 Color(ADM[) 00625 Total IGeldahl 01027 Cadmium 01105 Aluminum
00095 Conductivity Nitrogen 01147 Total Selenium 71880 Formaldehyde
00300 Dissolved Oxygen 00630 NidateslNrdites 01032 Hexavalent Chromium 31614 Fecal Colifono 71900 Mercury
00310 BOD5 01034 Chromium 32730 Total Phenolics 81551 Xylene
00340 COD 00665 Total Phosphorus 34235 Benzene
00400 pH 00720 Cyanide 01037 Total Cobalt 34481 Toluene
00500 Total Solids 00745 Total Sulfide 01042 Copper 38260 MBAs
00530 Tot Suspended 00927 Total Magnesium 39516 PCBs
Residue 00929 Total Sodium 01045 Total Iron 50050 Flow
00545 Settleable Matter 00940 Total Chloride 01051 Lead
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at(919)733-5083,extension 581 or 534.
The monthly average for fecal coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data.
ORC must visit facility and document visitation of facility as required per 15A NCAC 8A.0202(b)(5)(B).
'94 signed by other than the permittee,delegation of signatory authority must be on file with the State per 15A NCAC 2B.0506(b).

.may.. ioai. wu
Facility Name: Champion International Corporation County Haywood
ORC: David M. Cody
Persons)Collecting Samples: Operators on Duty
EFFLUENT CON'T
DO 65 00500 70301 00900 00340 M5 00080 00080 71900 01092
g
o $ m
0
d. s 2 Z, a
m E U� o 0 0 o
c x
� F O O � N O
HRS mg/L mg/L I mg/L mg/L I mg/L I umhos/cm mg/L mg/L ug1L ug/L mgA
9WIM .,
2 0700 2040 2074 3826 324 423
4 0700 2046 2060 3768 268 409 1.8
FIR l Qj.; am No no-am ROORM4WINOW
6 0700 2107 2038 186 3019 242 397
t? 2700 . 20 4
8 0700 2146 2068 3298 294 423
10 0700 1851 1739 3444 277 396
iav
12 0700 1781 1834 208 3114 246 338 <0.2 20
__
14 0700 1800 1842 2806 239 308
16 0700 1848 1857 2920 272 324
18 0700 2223 2219 3168 301 390
I M
20 0700 1986 1946 E176 3011 313 412
F o ou WEIMMM MMMMUMMMSO
22 0700 1712 1648 2421 319 399
24 0700 1868 1878 2666 356 493
r2rf'ffl
26 0700 1885 1885 2926 496 808
— t
28 0700 1732 1706 2790 Y 274 398
ry'� xi/{{'+ rv. F¢�' t ' ' ,}+r£�✓,�jy'",' ax, ,ynx'y''x -t Y � ' '
30 0700 1722 1736 2394 268 326
E `� 5}'Yt "1 u t M{' 'y# � :." R¢ey<.F 3S`.T. f .i l
� zi r"`sa'JS`a .g �* �� :a. �' � t,,
Average 0.31 1958 1935 218.00 178 3060 303 413 <0.2 20 1.8
PAaiarituri% l?3F , 2536 5 ? �9 .1 '`.38 -1 im k808_" c02; x # 48 s
Minimum 0.31 1712 1648 208 170 2394 234 290 <0.2 20 1.8
Can C GCLb� "C x, C�" m 4�� �. �`^�C�'a •��.. � ,��-.= ��s � �, >f s < � �� x�, ax..tt�gs,.
Monthly Limit 0.014~

Influent
NPDES No.: NC 0000272 Influent to WW rP Month: November IYear. 1998
Facility Name: Champion International Corporation County: Haywood
00310 00530 00080 00080
32
Y
x � � 2 a
O N y�
N � y y y
m n '
o E o m o 0 0
HRS HRS mglL mg/L mg/L mglL
NXI
7 29 Or
2 735 24 366.0 600 431 2498
3 . 41w 1 .7,7 2422
4 720 24 408.0� 710 276 1998
Egmm! _ v!c S WON
6 630 24 362.9 748 312 3100
8 630 24 408.7 758 447 1654
10 725 24 384.3 802 403 2290
mmam— =m Im NNEW—N ON ON
12 840 24 424.3 746 470 3040
7 2 y
14 900 24 350.4 468 321 1182
16 715 24 380.0 598 477 1773
18 715 24 474.4 764 774 3033
9 0
20 715 E24
319.8 666 397 2104
22 900336.1 562 322 2174
99
24 730 24 429.3 460 438 1495
.Wit„
26 930 24 346.4 592 431 1820
28 755 24 351.7 540 318 1592
30 720 24 347.4 500 �302 2658 y
Average 392.9 668 396 2042
Md'— � a 4 626 i28Q'a 16{T 3100 �' � s a k .,.
T 4<.s.3C. f'S` '"k +� .Yv� s ..,�.} f..iRx 'r ..�
Monthly Min. 289.2 460 177 1182
�k.c' i, . A -

NPDES No.: NC 0000272 Receiving Stream Month: November IYear. 1998
Facility Name: Champion Intemational Corporation County: Haywood
Stream: Pigeon River-UP
Location: Canton (River Mile -64.5)
UPSTREAM
50050 00010 00310 00300 31505 000a0 00080 00095
m
o �
m E F m g y o 0 0
LL
HRS MGD -C mglL mglL #1100ml mglL SOON r lL umhos/cm
2 805 30.9 13.10 <2.00 8:32 90 35.30
t _S 8 0 w ;
4 750 39.0 13.80 <2.00 7.95 25 54 39.50
r. N21 ^):.; _ 50
6 745 33.2 10.40 <2.00 9.04 40.00
8 900 32.1 7.90 <2.00 10.01 27.50
10 735 35.9 10.20 <2.00 9.48 19 41 37.10
12 855 54.8 10.50 <2.00 8.14 27.30
14 930 40.6 10.60 <2.00 9.13 39.30
9 _ 5 0
16 745 62.8 11.20 2.35 9.04 500 45.70
18 745 68.3 9.70 <2.00 9.65 22 52 31.60
20 740 50.0 10.00 <2.00 9.36 37.80
2, 9
22 925 42.4 7.20 <2.00 10.24 36.30
24 800 40.1 8.80 <2.00 10.07 12 34 36.10
26 947 42.8 8.70 <2.00 9.66 37.80
28 825 35.7 7.20 <2.00 10.10 37.90
30 825 36.0 6.70 <2.00 10.43 300 35.90
Wrza t�v"'�. x -j'�t t`�'.Mx �s�e,�.�t 2ra .n`� q-s�s, L ra x E
_r m,._ r-. ..3,.�.x. ��,,, �."?-� .stx�" °^�u s, �'?° � �� rr+,.u,�w
Average 47.8 9.9 2.01 9.31 233 24 5y7� 37.39
� �' to � <".f0`64r1,,, �.ax-+�.�.36�n s.' ,�.o� 1 7'7 (t�,.�.(]a Mon,9dyN12lG._. �1883 1380,.t*` �° ,..' a ';<Y r �.
Monthly Min. 30.9 6.20 <2.00 7.95 90 1 12 34 27.30

NPDES No.: NC 0000272 IDISCHARGE N0: Month: November IYear. 1998
Facility Name: Champion Intemational Corporation County: Haywood
Stream: Pigeon River-DN1
Location: Fiberville (River Mile 62.9)
DOWNSTREAM
00010 00010 00300 00300 31505 00095 00080 00080
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6 820 22.60 12.20 9.05 9.05 1951.0
8 930 21.00 13.10 9.20 9.20 1919.0
10 800 22.60 12.40 8.94 8.94 1898.0 178 246
12 910 17.00 6.50 9.35 9.35 938.0
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24 815 19.90 11.10 10.00 10.00 1291.0 170 217
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777777
7
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Average 19.79 9.89 9.46 9.46 145 1491.0 141 1 211
Monthly Min. 13.30 2.30 1 8.28 8.28 20 400 67 117
Month)
.<yi:ia ➢ »R

NPOES NO: NC 0000272 DISCHARGE No: MONTH: November YEAR: 1998
FACILITY NAME: Champion Intemabonal Corpora8on COUNTY: Haywood
STREAM: Pigeon River-DN2 STREAM: Pigeon River-DN3
LOCATION: Above Clyde (River Mile 57.7) LOCATION: Below Clyde (River Mile 55.5)
Downstream Downstream
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24 830 15.60 7.64 7.64 840 14.70 8.26 8.26 151 179
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7 887
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14.65 7.74 7.74 13.88 8.23 8.23 144 213
y
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-I NPDES NO: NC 0000272 IDISCHARGE NO: MONTH: November YEAR: 1998
FACILITY NAME: Champion International Corporation COUNTY: Haywood
STREAM: Pigeon River-DN7 STREAM:
LOCATION: 1-40 Bridge (River Mile 24.7) LOCATION:
Downstream Downstream
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NPDES No.: NC 0000272 IDischarge No.: 001 Month:November Year: 1998
Fadlity Name: Champion Intemational Corporation County: Haywood
ORC:David M.Cody
Person(s)Collecting Samples:Operators on Duty
QA / QC DATA SPECIFICATIONS
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Canton.North Carolina 28716
Champion
Champion International Corporation
December 15, 1998
Forrest R. Westall
Regional Water Quality Supervisor
NC Department of Environment and Natural Resources
Division of Water Quality, Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
RE: NPDES Permit No. NC0000272
Dear Mr. Westall:
Champion International Corporation's Canton Mill has an on-going process improvement
effort to reduce effluent color emissions. In support of this commitment, an additional
opportunity for color reduction has been identified for the hardwood secondary knotter
accepts tank overflow.
The control strategy for minimizing color losses from the hardwood secondary knotter
accepts tank overflow line is detailed in Section 4.6.1 of the June 1,"1998 Color Technology
Measures Report", that was submitted to you on May 27, 1998. The current control strategy
on this tank employs a temperature probe in the overflow line. If a tank overflow occurs, the
increase in temperature is detected by the temperature probe and a process signal
immediately alarms the hardwood brownstock operator station and appropriate action is
taken.
Planned improvements are underway to relocate the accepts tank overflow line into an
existing sump in the hardwood brownstock washing building. This will improve color
containment and the temperature probe will no longer be required for operator notification. A
sump conductivity probe will be used for operator notification in the future.
Please accept this as notification of the removal of the temperature probe and
implementation of an improvement to mill color -control. If you have any questions or
concerns, please contact me at [phone] by January 6, 1999.
Sincerely,
�Obff VVV� °
_ p
Robert V. Williams
Manager 6 ,
Environmental, Occupational Health and Safety 1 (7

State of North Carolina
MICHAEL F. EASLEY OeiJ8rtmeru of Justice
REPLY TO:Daniel C,OaAle_v
ATTORNEY GENERAL P. O. BOX 629 Environmental Division
FUM.EIGH Doakleynmail.jus.state.nc.us
27602.0629 Telephone:[phone]
Fax:[phone]
November 17, 1998
Mr. Barry Turner
Deputy Attorney General
425 Fifth Avenue North
Nashville, Tennessee 37243-0495
RE: Joint Watershed Advisory Council
Dear Barry:
Thanks for your September 10, 1998. letter regarding the formation of the Pigeon River Joint'
Watershed Advisory Council. I have discussed our exchange of correspondence with Secretary McDevitt
and Forrest Westall,and North Carolina is in agreement with you on the broad,general goals for the Council.
We have not taken the step of further discussions with EPA.
For initial membership, the four(4)North Carolina representatives will be as follows: l) a member
of a local environmental citizens group; 2) a local government representative; 3) a person with pulp and
paper knowledge and experience; and 4) a Departmental employee in the DENR Western Regional Office,
Asheville, North Carolina. The Secretary is ready to make his appointments. and will ask one of the
representatives to act as Co-Chair. We are also agreeable to overlapping service periods. Do you have a'
mechanism you prefer?
It would be timely to have the Council schedule a formation meeting in early 1999, in either
Asheville or Knoxville. Please give me a call at your convenience to discuss our next steps.
Sincerely, l
//J(/('1 �ON
Daniel C. Oakleey
Senior Deputy Attorney General
DCO/so
cc: Secretary Wayne McDevitt
Preston Howard
Forrest Westall V 0 �558
Laura DeVivo
/28866

n Mill Box C _
' BOX -10 -
Canton, North Carolina 28716
Champion
Champion International Corporation
November 20, 1998
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Health
and Natural.Resources
Water Quality Section
Division of Environmental Management
59 Woodfin Place
Asheville, NC 28801
Re: NPDES Permit No. NC0000272
Dear Mr. Westall:
As required under the,referenced permit, Part III - Special Conditions, Section E -
Requirements for Compliance and Analysis, Paragraph 13, Champion International,
Canton Mill is submitting the attached"Low Flow Contingency Plan".
If you have any questions, please call me at [phone].
Sincerely;
Robert V. Williams
Manager
Environmental, Occupational Health & Safety

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
Canton, North Carolina
I. Introduction
The following report on the low flow contingency plan details the Canton mill's progress to
fulfill the requirements of the 1997 modified Color Variance and NPDES Permit. Part III,
Paragraph E 13 of the 1997 Permit provides that:
'As the 1997 Revised Color Variance recognizes, there could still be
some periods of time, corresponding to periods of lower flows in the
river, when color at the Hepco gage might exceed 50 true color units. i
The permittee shall develop a contingency plan for mitigating the
occurrence and degree of these potential exceedances which correlates
measures designed to achieve mitigation with periods of lowest flow,
with particular attention being given to periods of higher recreational
use in the river. In developing the plan, the permittee shall evaluate
any reasonable means, including scheduling of maintenance,
intermittent treatment, and production curtailment, which would
achieve additional color reductions during temporary periods of lower
flows in the river when color at the Hepco gage might exceed 50 true
color units."
This plan fulfills the requirements of Part III, Paragraph E 13.
1

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
Canton, North Carolina
If.Color Performance Review
The mill's commitment toward continuous management of color is illustrated in Figure 1, which
shows a color reduction of over 85% from the 1988 secondary effluent annual average. The
improved color performance is due to the Canton Modernization Project and mill-wide efforts
detailed in the June 1, 1998 Color Technology Measures Report.
The January 1998 - August 1998 average secondary effluent color discharge of 50,524 pounds
per day is well below the 60,000 pound per day effluent limitation specified in Part III,Paragraph
E 10 of the 1997 Permit. During the same period, the measured monthly averages for true color
at the Hepco bridge are all below 50 standard color units(scu's), even at flows less than the 30Q2
occurring in August.
Using North Carolina's governing flow criteria (30Q2), historical flow records, and the 1998
January- August secondary effluent color discharge, it is expected that color in the Pigeon River
at the Hepco gage will be less than 50 scu's 97% of the applicable time. Therefore, Champion's
actual color performance results in significant mitigation of the occurrence and degree of color at
the Hepco gage.
2

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
Canton,North Carolina
M. Contingency Plan Discussion
Based on the current color performance, the mill is below 50 scu's 97% of the applicable time,
using North Carolina's 30Q2 flow criteria. The sustained level of low secondary effluent color
discharges has been achieved through extensive and ongoing mill-wide efforts. However, in
accordance with Part III, Paragraph E 13, the scheduling of maintenance, intermittent treatment,
and production curtailment were evaluated for further color reduction benefit during loAiest flow
periods.
3.1.1 Scheduling of Maintenance
The loss of excess color during outages and upon start-up continues to be a focus of the mill's
color minimization activity as detailed in the June I, 1998 Color Technology Measures Report.
To minimize color discharges during periods of lowest river flow and higher recreational use in
the river, no major maintenance outages will be scheduled during the months of June, July and
August.
3

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
Canton,North Carolina
3.1.2 Intermittent Treatment
A Primary Clarifier will normally be empty and available for outage or unplanned brown colored
material storage. When color cannot be reclaimed by the mill's extensive sump system, or when
unplanned process losses occur, colored material will be stored in the primary clarifier for
managed, intermittent release to the secondary wastewater treatment system. The clarifier will be
utilized for managing colored material storage and release based on information provided by
continuous sewer conductivity monitoring, daily sewer color monitoring, and normal milk
operations communication. This management tool will allow the mill to provide a relatively
stable color load to the activated sludge system and subsequent optimization of the activated
sludge color removal effect.
3.1.3 Production Curtailment
Production curtailment through reduced pulp manufacturing is not a viable color reduction
option for the Canton Mill. The mill is designed to achieve the most effective and efficient color
control at normal production rates and maximum fiberline"turndown" capacity is approximately
80% of normal production. Therefore, complete fiberline shutdown would be required to
effectively reduce pulping process effluent color during periods of lowest flow. Capital
expenditures to install a dry furnish system to replace the pulp production for one fiberline would
4

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
Canton,North Carolina
total several million dollars in addition to dry furnish pulp costs. Production curtailment is
neither a technically nor economically reasonable option for intermittent color reduction.
W. Conclusion
The Canton mill's January 1998 - August 1998 average secondary effluent color discharge of
50,524 pounds per day, coupled with the measures detailed in the June 1, 1998 Color Technology
Measures Report, demonstrate the Canton Mill's commitment toward brown colored material
management. Using North Carolina's governing flow criteria (30Q2), historical flow records,
and the January 1998 - August 1998 secondary effluent color discharge, it is expected that color
in the Pigeon River at the Hepco gage will be less than 50 true color units 97% of the applicable.
time. The mill's commitment to not schedule major maintenance outages during June, July and
August, the months of greatest recreational river use, and optimizing use of the primary clarifier
for brown colored material storage and management will result in mitigation of the occurrence
and degree of color during periods of lowest river flow.
5

Champion International Corporation - Canton, NC
Figure 1: Canton Mill Secondary Effluent Color Performance
Annual Averages: 1988- 1997
Monthly Averages:January 98 October 98
400000
350000
v 300000 SE Color
�N December 1, 1998 Limits:
G —60000 Annual
a.
O 250000 —r-69000 Monthly
U
y 200000
w
.1 150000
v
o 100000
d
50000 h I
0
0o 0) O r N M 1* U) W n 00 00 Co 00 00 00 Co 00 00 Co
00 00 0) 0) 0) 0) O) 0) 0) O) 03 0) 0) 0) 0) 0) 0) O) a) 0)
r r r r r r r r r r 10 10 C W V
LL Q ' Q W 0
December 1, 1998 Report - Low Flow Contingency Plan

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
November 23, 1998
NCDENR 198
Mr. John J. Pryately
Champion International WWTP Lab.
..JAMESB.HUNTJR�YN P.O. BOX 4000
=r.
GOVERNOR �1.',:y,`�I Canton, NC 28716
r 1 r
SUBJECT: Deleting Parameter(s) from Certificate
TWA`Ti+R_`MCDEYITf J� COD
kr-SECFIETARY .�v-„��
Dear Mr. Pryately:
E
Per your request we are deleting the above parameters from your certificate.
r ._ ResTDHHor Enclosed is an updated certificate reflecting this change which is effective on
fpsq:�IR 'P �Y •.
C1�>'9 �r"� •S� November 23, 1998.
-. If you have questions or we can be of any further assistance, please contact us at
z4 [phone].
^:GI INti�:
Sincerely,
Bernard E. Sims, Ph.D.
Chief, Laboratory Section
rj
BES:mod
exit` �:
_ Enclosure
cc James W. Meyer
Gary W. Francies
Marilyn O. Deaver
�•Y4��jQ�y C
14r Y
y��y��_VVnn♦gyp T,;
'Y?4•"a'I�iR,�',v LABORATORY SECTION
4405 REEDY CREEK ROAD,RALEIOH,NORTH CAROLINA 27607-6445
{ •'.S
PHONE'BI B-733-3906 FAX BIB-]33.6241
AN EQUAL O PPOgTUNITY/AFFI RMATI V E ACTION EMPLOYER-SOX RBCYCLED/10X P09T-CON9tlMER PAPER

Attachmentl
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Champion International WWTP Lab. Certificate Number. 198
,,.rces P.O. Box 4000 Effective Date: 1/1/96
r'y Canton,NC 28716 Expiration Date: 12/31/98
Date of Last Amendment: 11/23/98
The above named laboratory,having duly met the requirements of 15A NCAC 2H.0e00,is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANIC
SOD
COLOR,PLATINUM COBALT
CONDUCTIVITY
AMMONIA NITROGEN
pH
RESIDUE,TOTAL
RESIDUE,DISSOLVED 180 C
RESIDUE,SUSPENDED
r
This certification requires maintance of an acceptable quality assurance program,use of approved methodology,and satisfactory pertomrance on evaluation samples. Laboratories are
subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.oam

• Canton Mill
Box
Canton.North Carolina 28716
ampion
�III
Champion International Corporation
November 16, 1998
`VERt«��vR
Mr. Bradley Bennett
Supervisor, Stormwater and General Permits
North Carolina Department of Environment and Natural Resources
P. O. Box 27687
Raleigh,NC 27611-7687
Subject: Request for Designation of Representative Outfall Status.
Champion International Corporation, Canton Mill, Haywood County
Stormwater Permit NCS000105
Dear Mr. Bennett:
The purpose of this letter is to request representative status for stormwater outfall 6-16
with 5C-17 and 513-20 being considered typical for closed landfills, as granted in our
permit for analytical sampling.
Outfall 6-16 is a new outfall. This outfall collects stormwater from the closed and capped
in accordance with the Division of Solid Waste approved plans Cell H at the No. 6
Landfill (see attachments ). Our"Stormwater Pollution Plan"has been revised to reflect
the addition of the new outfall and to include the outfall in our facility inspection .
If you have any questions or need additional information, please contact me at(704)646-
2372.
Sincerely, �
Louie Justus
Senior Envirogme al Engineer
xc: Mr. Forest Westall Mr. William R. Manzer
NCDENR Vice-Pres./Operations Manager
Water Quality Section Champion International Corp.
59 Woodfin Place 175 Main Street, P.O. Box 4000
Asheville,NC 28801 Canton,NC 28716

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General Location Map
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Drawing Legend: Outfall # 16 (Landfill # 6 )
Total Drainage Area: 230,868 Square Feet (See Note, Below) -
Drainage Area Outline:
Drainage and Discharge Structures: Drop Basins
Culvert Pipes "5
Impervious Surfaces: Roads -
Buildings -
Stormwater'Structural Control Measures: Rip-Rap
Springs
Hazardous Waste Storeage Area
Satellite Hazardous Waste Storage Area
Materials Loading and Access Areas LOAD
Note: New outfall added 11/10/98 due to capping of cell H at landfill
No. 6
r

C&M--ma.
P.O. BOX 37564 • RALEIGH, NORTH CAROLINA 27627 '
September 26, 1997 � n 1
7 �d 1n
Governor James B. Hunt, Jr.. w��i� ,� �4r�•
The Capitol
Raleigh, N.C. 27611
Re: CHAMPION PAPER MILL -- Canton
Dear Governor:
The U.S. Environmental Protection Agency is presently reviewing the variance granted by
the State to the Champion International Paper Mill in Canton. I am writing today to Carol
Browner to deny the variance as EPA has done before.
The Pigeon River will never begin the long restoration process it needs for fish, wildlife and
people without a significant change in the way Champion does business. Compliance with
the relevant wastewater discharges should be at the discharge pipe, not several miles
downstream. A recent study shows that can reduce its pollution discharges by almost
50% without any significant cost to the company.
I hope you and your staff had an opportunity in Europe to visit some of the paper mills
there. They use much more efficient, less polluting processes. North Carolina could be a
leader in bringing this technology to the rest of this country, n
Thank you for your consideration. IN ���� U
Sincerely,
OCT 0 6 1997
VVA I k�7 QUALITY` nn SCCTiON
John D. Runkle �� �
President
G
CC. Wayne McDevitt
Preston Howard
Dan Oakley
e
i,\

State of North Carolina `
Department of Environment,
Health and Natural Resources 1 •
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary p E HIV R
A. Preston Howard, Jr., P.E., Director
Asheville Regional Office
WATER QUALITY SECTION
August 21, 1997
Mr . Glen Goodrich
1863 Barnard Road
Marshall, North Carolina 28753
Subject: Requested Information
Pigeon River Color Data
Haywood County
Dear Mr. Goodrich:
Per your request, please find attached the data concerning
improvements in the color of the Pigeon River before and after
modernizations to Champion' s Canton Mill . Hopefully, this is
enough information for your needs . If it is not, or if you have
questions concerning what the numbers actually indicate, please
do not hesitate to contact me at 251-6208 .
Si erelyZ � +
D. Keith Hayne
Environmental Specialist
Interchange Building,59 Woodfin Place ` 4FAX [phone]
Asheville,North Carolina 28801 Nif An Equal Opportunity/Affirmative Action Employer
Voice 704-251-6208 50%recycles/100/.post-consumer paper

GHnmpION EDHS I0:704-646-6892 AUG 20'97 14 :20 No .008 P .02
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Canton Mill -
Box C-10
Canton,North Carolina 28716
V Champion
Champion International Corporation
September 10, 1998
CFo �
4/4qR
y pUA
Mr. Keith Haynes AS -!lt�REG;o wrlo
North Carolina Department of NA[0 F
Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: Petroleum Release at Champion International Corporations Canton Mill on
September 7, 1998
Dear Mr. Haynes:
Champion .International Corporation is providing written notification of a release''- of
approximately 5 galloffs of hydraulic fluid. The release was discovered on September 7,
1998, at approximately 5:00 a.m. This letter is a follow-up to our telephone notification on
September 7, 1998 at 9:55 a.m. to the NCDENR in Raleigh.
Hydraulic fluid leaked from a pump coupling at the Beaverdam Creek pump system. The
pump system automatically shut-off on low hydraulic fluid as designed. Most of the fluid was
contained behind the underflow pump intake structure. A contractor (NEO Corporation)
used absorbent booms and pads to absorb the fluid. No sheen was observed downstream
of the pump. The coupling was tightened and a permanent system of oil booms was
installed around and downstream of the pump.
On Tuesday, September 9, 1998, McAusland, the pump supplier/manufacture was
dispatched from Florida and a new type of coupling was installed on the hydraulic line to the
pump to further prevent any future losses.
If you need further information regarding this release please contact me at [phone]
or Jim Giauque at [phone].
Sincerely,
Louie•Justus,--- -- . Jim Giauque
Senior Environmental Engineer Senior Environmental Engineer

Canton Mill
Box C-10
Canton,North Carolina 28716
V Champion
Champion International Corporation
a 1 r�
October 6, 1998 r su u i�
s OCT — 1998
Mr. Keith Haynes _
NCDENR 'RATER QUALITY SECTIC2i
SFIZT REGIONAL OFFICE
Division of Water Quality — --
59 Woodfin Place
Asheville,NC 28801
Subject: Petroleum Release at Champion's Canton Mill on October 6, 1998.
Dear Mr. Haynes:
Champion International Corporation is providing written notification of a release of approximately
450 gallons of lubricating fluid (machine oil) at the Canton Mill. The release was discovered on
October 6, 1998, at approximately 1:15 AM.
Machine oil from the Canton Mill 19 Paper Machine had been leaking from a containment area
sump designed to return it to the storage tank but this pump was not functioning. The sump filled
and overflowed to the in mill sewer. Upon discovery at 1:15 AM on October 6, the machine oil
storage area re-circulation pump was repaired by 2:00 AM. The machine oil traveled through mill
sewers to the Waste Treatment Plant. Waste Treatment Plant personnel have not seen evidence
of a machine oil spill on the clarifiers or on the river.
If you need further information regarding this release please contact me at 704-646-6814 or Jim
Giauque at 704-646-2028.
Sincerely,
Chns Leitsch Jim Giauque
Air Group Coordinator Senior Environmental Engineer

Canton Mill
Box C-10
Canton,North Carolina 28716
V Champion c'`�-
Champion International Corporation
September 25, 1998
Mr. Keith Haynes
North Carolina Department of
Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: Petroleum Release at Champion International Corporation's Canton Mill on September 22, 1998
Dear Mr. Haynes:
Champion International Corporation is providing written notification of a release of less than
800 gallons of paper machine lubrication oil. The release was discovered on September 22,
1998, at approximately 7:50 a.m. This letter is a follow-up to our telephone conversation on
September 23, 1998.
The oil was released from the overflow line of a 6000 gallon bulk storage tank. The overflow
line shutoff valve had been inadvertently left in the open position. The oil flowed into the
tank containment where most of the oil was contained. The released oil flowed out of the
containment to the mill sewer system through an open drain line. The contained oil was
removed by a contractor. The open drain line will be permanently closed. No oil was
observed at the Wastewater Treatment Plant as a result of this release.
If you need further information regarding this release please contact me at [phone]
or Jim Giauque at [phone].
Sincerely,
Derric Brown Jim Giauque
Environmental Supervisor Senior Environmen?alEngineer

(� Canton Mill
(�►`t/''� Box C-10
4 Canton,North Carolina 28716
��
V Champion
Champion International Corporation
August, 31, 1998
gs�glF ,3'99S
Mr. Gary Francies HFV(�R�QUq�(
NCDENR Division of Water Quality RfCro �FCI(Qy
Laboratory Section �FF(CF
59 Woodfin Place
Asheville, NC 28801-2414
Subject: Total Nitrogen&Total Phosphorus sample out of hold time.
Dear Mr. Francies,
This letter is notification that the July 1998, sample for total nitrogen and total
phosphorus did not meet sample holding time requirements. The sample was collected,
preserved, and refrigerated on July 16, 1998. The sample was left in the refrigerator and
not sent for analysis until the error was discovered August 20, 1998. No other preserved
sample was available that met the 28 day holding time requirement. The test results from
this sample were qualified on the July DMR as not meeting holding time requirements.
Corrective action taken to prevent this problem for future samples is to match retained
chain of custody forms for periodic testing done by contract laboratories to the posted
schedule for periodic testing. Taking this action will bring to our attention in a timely
manner any deviations from the testing schedule established to meet regulatory
requirements.
If you have any questions, comments, or need additional information please contact me
at 704-646-6720.
Sincerely,
JPryately
Laboratory Supervisor
cc: Derric Brown, Mike Cody, Joe Deschene,
Bob Williams,Bill Manzer,
Keith Haynes, James W. Meyer,Marilyn Deaver

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
• DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
—� September 4, 1998
CD,ENR I ..
�JntAEs 6.HLINT.IFi.'
faOVERNOR
Mr. Derric Brown
Champion - Canton Mill
BOX C-10
Canton, North Carolina 28716
��WyY"JE,M�nEvm -
.•.a'�
v Subject: Acceptance of Activated Sludge
.` Canton Mill
•P.E blrtEcrG NPDES Permit No. NC0000272
Haywood County
Dear Mr. Brown:
µ •
I
This Office does not foresee a problem with your waste
water treatment accepting activated sludge from the Town of
Maggie Valley. It is suggested that you maintain a record
of all sludge received including the date and number of
gallons .
If you have any questions concerning this matter or if
14
you require additional information, please do not hesitate
1 to contact me at 251-6208 .
" Sin rel ,
D. Keith Haynes
Environmental Specialist
xc: Al Matthews
champmv.let
p�P INTERCHANGE BUILDING,59 WOOOFIN PLACE,ASHEVILLE,Na 28801-24 1 4
Y'"• l• PHONE [phone] FAX[phone]
e{1 AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-50%RECYCLED/10q POST-CONSUMER PAPER
R'� ti

Canton Mill
Box C-10
Canton,North Carolina 28716
UChampion
Champion International Corporation
September 2, 1998
Mr. Keith Haynes
Environmental Specialist
Division of Environmental Management
Water Quality Section
59 Woodfin Place
Asheville, NC 28802
RE: Bark Boiler Ash/Clinker Handling System Overflow at Champion's
Canton Mill on August 29, 1998
Dear Mr. Haynes:
Champion International is providing written notification of a release of approximately
8,500 gallons of bark boiler ash/clinker system sluicing water that occurred on
August 29, 1998. Your office was notified of the release at approximately 10:05
a.m., August 30, 1998 and this is a follow-up to our conversation.
Attached is the Water Quality Section report with additional details. If you have any
questions or require additional information, please call Jim Giauque at (828) 646-
2028.
Sincerely,
m Giauque
Senior Environme al Engineer
copy: Derric Brown
Dick Carlow
Louie Justus

Sanitary, Sewer, Pump Station and WWTP Spill or Bypass Report Form
(Please Print or Type-Use Attachments if Needed)
Permittee; Champion International Corp_ Permit Number, NC0000272 County : Haywood
Incident Started: Date: 8/29/98 Tithe: After 9 p.m. Incident Ended: Date: 8/30/98 Time:Approx.7 a.m.
Source of Spill/Bypass(Check One): O Sanitary Sewer X Pump Station O Waterwater Treatment Plant
Level of Treatment(Check One): O None A Primary Treatment O Secondary Treatment O Chlorination Only
Estimated Volume of Spill/Bypass: Approx.8,500 gallons (A volume must be given even if it is a rough estimate.)
Did the Spill/Bypass reach the Surface Waters? O Yes g No If yes,please list the following:
Volume Reaching Surface Waters: w1A_ Surface Water Name :Did the the Spill/Bypass result in a Fish Kill? O Yes O No A,, ,—
Location of the Spill/Bypass:
The bark boiler ash/clinker handling system. Due to the designed nature of this system the heavier solids would settle and
would not be present in the overflow.
Cause of the Spill/Bypass:
The primary sump pump was pumping slow and was unable to keep up with the influent ash sluicing water.
Describe the Repairs Made:
A contractor was mobilized with a portable sump pump to pump water from the settling system.
Action taken to contain spill,clean-up waste and remediate the site:
The water was pumped(still in process at 10 a.m.8/30/98)and the ash/clinkers will be removed by the normal procedure for
disposal in the Champion Landfill.
Action taken or proposed to be taken to prevent future spills at this location:
The spare emergency pump was out of service for maintenance repair. A back-up spare emergency pump will be maintained
to minimize the possibility of future spills.
Other Agencies Notified: Voice mail to Keith Haynes @ 10:05 a.m., 8/30/98
Person Reporting Spill/Bypass: Derric Brown Phone Number: [phone]
Signature : Date: 8/30/98
For DWQ Use Only:
Oral Report Taken By: Report Taken: Date: — Time:
DWQ Requested an Additional Written Report: O Yes O No
If Yes, What Additional Information is Needed :

LABORATORY SECTION
August 26, 1998
MEMORANDUM
TO: Forrest Westall
FROM: Gary W. Francies w �G
Laboratory Section, ARO
SUBJECT: Holding Time Compliance Violation
Please be advised that Pace Analytical has analyzed Total Nitrogen
and Total Phosporus samples, at the clients request, which were out
of holding time. Per 15A NCAC 2H . 0805 (a) (7) (N) any time a
sample is received which does not meet sample collection, holding
time, or preservation requirements, the laboratory must notify the
sample collector or client and secure another sample if possible.
If another sample cannot be secured, the original sample may be
analyzed but the results reported must be qualified with the nature
of the infraction(s) and the laboratory must notify the State
Laboratory about the infraction(s) .
The following information was supplied by Pace Analytical:
Client name: Champion, International
Contact person: John Pryately
Address: P. 0. Box 4000 Canton, NC 28716
Telephone: [phone]
Sample dates : 7/16/98
The client has been notified by the enclosed letter. Please let me
know if I can be of further assistance.
If you have questions or need additional information contact me at
(828) 251-6208 extension 285.
Attachment
cc: James W. Meyer
Marilyn Deaver

N a
NORTH CAROLINA DEPARTMENT OF
., •�, oT:�1' ENVIRONMENT AND NATURAL RESOURCES
w �
-4 = DIVISION OF WATER QUALITY
ASHEVILLE- REGIONAL OFFICE
CDEM R August 26, 1998
' � a• b '�r 198
JAAI ES S.HUNr](i;"�� '
:GOVERNOR Tz MR. JOHN PRYATELY
TV
CHAMPION INTERNATIONAL WWTP LAB
xaan:
P.O. BOX 4000
CANTON, NC 28716
� a
WAYjJ E, CDEVITi
;�SpecRET` v Dear Mr. Pryately:
We have been notified that on August 20, 1998, you submitted
a*
Total Nitrogen and Total Phosphorus sample(s) for analysis of '
to Pace Analytical Laboratory. At your request the sample was
analyzed out of holding time.
Please be advised that under provisions of N. C. Regulations
15A NCAC .0805 (a) (7) (N) , anytime a laboratory receives samples
''a;, . �•^'*; -x r t" that do not meet sample collection, holding time, or preservation
requirements, the laboratory must notify the sample collector or
_ ? client and secure another sample if possible. If another sample
cannot be secured, the original sample may be analyzed but the
results reported must be qualified with the nature of the
" •�. ,'� infraction(s) , and the laboratory must notify the State Laboratory
about the infraction(s) . The notification must include a statement
indicating corrective actions taken to prevent the problem for
future samples.
We are requesting that you take the appropriate steps to
avoid recurrence of this in the future. All sample preservation
is P' ti and holding requirements must be met in accordance with the
'-• f r' Federal Register, July 1, 1995; 40 CFR 136.
7 ('
I *•� � ^'d Thank you again for your cooperation. Contact us at (828)-251-
. 6208 extension 285 if you have questions.
^id _ ri
L
�.... _....yl-
_ __ _ — a Sincerely,
FJ
_ Gary rancies
Laboratory Section
`L
T
t b
" cc: James W. Meyer
-, Maril n Deaver
AS'717i eg a ye
�� - 2 J!J r. INTERCHANGE BUILDING,S9 WOODFIN PLACE,ASHEVILLE,NC 28801-2414
PHONE 828-ZSI.6200 FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-50%RECYCLED/10% POST-CONSUMER PAPER

NORTH CAROLINA DEPARTMENT OF
e 1
(\').T '"'' ENVIRONMENT AND NATURAL RESOURCES
s .P D
KS,al', EY✓'' ,. AJ\ DIVISION OF WATER QUALITY
/v ASHEVILLE REGIONAL OFFICE
August 26, 1998
5
'21�`,JAF1ES HLINT.1Rd` Tom`
GOVERNOR "' 198
MR. JOHN PRYATELY
^2 .- .•_. s' CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX 4000
1 T - CANTON, NC 28716
` wyf1It C`,DEvITT
ser�"'ke. ETASRY
Dear Mr. Pryately:
Your letter dated August 13, 1998 that describes corrective
' n REcrQ actions for your analytical procedures has been received and
-/ >*- reviewed. The actions taken are acceptable for your North Carolina
1145w, Was laboratory certification. We can accept
your MDL (Method Detection Limit) study. 'It is recommended that
this MDL study be done annually along with the verification of the
standard curve stored in the memory of the spectrometer.
Thank you again for your cooperation. Contact us at (828)-251-
,I_� : 'd 6206 extension 285 if you have questions.
' il I. A Sincerely,
Gary Francies .
Laboratory Section
s,{
W t:
r
cc: James W. Meyer
.. . . - --
�-t� _
i pA4 �y y"t'x'�y INTERCHANGE BUI4DINGp59 WOODFIN PLALE,A9HEVILLE,NC 28801-2414
PHONE [phone] FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-509'.RECYCLED/I C19G POST-CONSUMER PAPER

V ATFR r .
ASy:V(L1FQ0f(( 1 RT Q
I
FAX COVER SHEET
ENVIRONMENTAL, OCCUPATIONAL,
HEALTH AND SAFETY
CHAMPION INTERNATIONAL CORPORATION
CANTON MILL
FROM:
DATE: S J.30�ga
NUMDER OF PAGES:
(INCLUDING COVER) a S
NOTE: S
The material contained in this communication is intended only for the use of the addressee.
It may contain information that Is confidential, proprietary, attorney-privileged, and exempt from
disclosure under applicable law. If the reader of this communication Is not the intended recipient,
you are hereby notified that any dissemination,distribution or duplication of this communication is
prohibited. If you have recti,ed this communication In error, please notify us immediately by
telephone and return,by mall,the original message to us. Thank you,
SENDERS PHONE NUMBER: (828) 04"700
FAX NUMBER: [phone]
FAX PROBLEMS: (828) 64"700
10' d i00' oN 2S:6 86.0£ 9f1H Z689-9V9—VO4:GI SH03 NDI&1UH3

-� 3►,ft
-"cASHNUEMI NACU 40
�y/?''rR
- �F t� .UAL! �•�
nita v ewer. PumpStationd V P * r ..V 1 Re p nySFCTjp r
(Pltase Priet or Ygpc • Use Attacmnerns ti.leedod
permitter: 5"a T.r kerr.o\a+o\ Cor permit Number: bL D 011 Count;::
:idea[Started:Date-13-J991% Time A pr, Incident Faded:Date �f, 4� �e d ,, n ,
SourceTC-
of Spill/Bypass (Check One): :C Sanitary sewer Pumo Stauon t]Wastetivater'I rcatment P ant
Level of Treatment(Check One)::^,Nono Primary Treatment C Secondarv''i naatment hlorination Only
Estimated Volume of Spili/Bvpass: W , ('A volume must be given even if it is a tough estimate.)
Did the Spill/Bypass reach the Surface Waters' Yes No : If yes,please list the following:
Volume Reaching Surface Waters: _ Surface Water Name:
Did the Spill/Bypass result in a Fish Kill? ^� ems 0 No ;
Location t 1
"Ike. bark bo.\e.r as\,l C�inker tno .�\art oe �o �e c.05. r.
4 5`�seer-t, S� ` � t
r,0.A,Jre a[C +v' zE, SZ56�em {-Me heaa,er`y So\`.a 6 �o�\a Se'X\e. drJ, tZOA. , V%6V �r
of the,$gill/Ryp-cs Presentr '.n A4v`e rwer -\oa. `\
e. �r,Mar.� Sor•,p i�am`J tw7G.s` PJ M�;fJ S`o.nl 4nA vZ4S .]nCMC
ko keep
De,5cribe the gepni]M
� �JMp Wa�4t- '�w+tn fiche. 5e��.+-cam SvJS�@,rn.
Action non M C QUIRin58 an Un Waste mri Rem .fiat the Site:
I^V\ >, ww�er vna"s �o�nPea process a1r `tDa«, 8 �30)
and 'Y``e_ Q tN% I C.\"4\k4_r-s W:\\. �2 •remb,4, �. 10� -Sb.rt, hDrtnc.`
yeoCeO.Jre -inr p:.sOOSa1 :n 5rr.¢. C.l�c....�P:a✓, Gwn��'•l\
Action Taken or Pro ced to bq Taken to Prevent Fu trP Cnin� hr rh' r�C_r
W'.\\ �'o\\o..�- uP or, � act �r•.�c�.-• v'e(ao.�' o., -�i.5 i�£?v1.
Other Agencies Notified: VUIL4 Mr+•\ k:oe-' \\a res @ 1u�oS t{$
Person ReportingSpiU/Bypa_ss: DP-rr",t_ 'Qvb,on PhoneNurnber: _L&2g) 64(6-aQ19
Signature Date: �12o1Ja
For DWQ 1 se Only: / -_
Oral Report Taken by: Report Taken: Date ZSme
WQ Requested an Additional Written Report: es O o
If Yes,What Additional Ittformation is Needed:
SpfflMypass Repotting Ftmn W97
ZO' d i"0 ON 8S: 6 86.0£ 9f1H Z689-9b9-D0L=9I SH03 N0IdHUH9

NORTH CAROLINA DEPARTMENT OF
., ._ ENVIRONMENT AND NATURAL RESOURCES
- DIVISION OF WATER QUALITY
ASHEVILLE-REGIONAL OFFICE
$ ® WATER QUALITY SECTION
September 4, 1998
HUNT.I ` '
..•'faOVERNOR
Mr. Derric Brown
2 -•:; Champion - Canton Mill
..
Box C-10
E .1�4DEvlrT Canton, North Carolina 28716
A7 ,, 1
ECR Y
,
Subject: Acceptance of Activated Sludge
a _ Canton Mill
IRE , NPDES Permit No. NC0000272
Haywood County
�ecC�c
Dear Mr. wn:
This Office does not foresee a problem with your waste
`4 water treatment accepting activated sludge from the Town of
Maggie Valley. It is suggested that you maintain a record
of all sludge received including the date and number of
gallons .
If you have any questions concerning this matter or if
you require additional information, please do not hesitate
to contact me at 251-6208 .
Sin rel ,
D. Keith Haynes
Environmental Specialist
Post-KO Fax Note 7671 Date pages,
FrOM
.r
CoMept Co. -DW
xc: Al Matthews
Phone# Phone# •l51 _ (qz C3
Fax# /1. I pn Fax# o� l b
r., champmv.1et --
INTERCHANGE BUILDING,58 WOODFIN PLACE,ASHEVILLE,NC 28801-2414
PHONE [phone] FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-SO,p RECYCLED/10%POST-CONSUMER PAPER

Faux C-Mill / /Jo /—
^ Canton;North Carolina 28716 .l t�a4
\' v AUG 18 1998
Champion
nal Corporation
�J U+=C,".'TORY SECTION
Certification Number 198 August 13, 199
Mr. James W. Meyer
NCDENR, Division of Water Quality
9G r�
Laboratory Section
4405 Reedy Creek Road
-6445
Raleigh, North Carolina 27607 lyF�oPs
9
Subject Laboratory Certification Maintenance Inspection Response °o
July 16, 1998 Letter and Attached Inspection Report.
Dear Mr. Meyer.
The laboratory inspection report from July 2, 1998 by Mr. Gary W. Francies
contained a comment that needed a reply. This correspondence is the response,,to
your letter dated July 16,1998 and received July 21, 1998 that includes the reply to
the comment.
COLOR
COMMENT: The signal reading on the low standard is not sufficiently greater than
the blank (.002 absorbance units obtained on a 10.c.u. standard). This makes the
lower limit of detection or reporting limit questionable due to inviable signal readings.
REQUIREMENT: The lab must obtain a signal in which the constituent concentration
in reagent water is 2(1.645)s above the mean of blank analysis (Lower Limit of
Detection). The constituent concentration that produces a signal sufficiently greater
: : than the blank, that it can be detected within specified limits, by good laboratories,
during routine operating conditions, is the Limit of Quantitation. Typically it is the
concentration that produces a'signal 10s above the reagent water blank signal. In
most cases, this requires an absorbance value greater than .005 units, preferably
greater than .010 units. Reference: Standard Methods, 18th Edition - Method 1010
C. And 1030 E.
RESPONSE: The Hach DR4000 instrument used to perform the color tests has a
very sensitive detector that enables the user to perform low level color tests that are
statistically valid. Replicate blank analysis were performed to determine the mean
and standard deviation of the blank, this data was used to calculate the ( Lower Limit
of Detection ) and the ( Limit of Quantitation) see Table 1 for raw data.

Champion International Corporation
Table 1
Hach DR4000 Color Test Replicate Blank Analysis
Test Replicate Color Units
Set Up Blank 0.00
1 0.30
2 0.35
3 1.05
4 0.70
5 0.56
` 6 1.05
7 0.48
The mean of the blank analysis is 0.64 c.u., the standard deviation is 0.309 c.u., and
the highest blank value is 1.05 c.u..
The Lower Limit of Detection is 2(1.645)(0.309) + 0.64 = 1.66 c.u.
The Limit of Quantitation is 10(0.309) + 1.05 =4.14 c.u.
The statistical analysis based on the Hach DR4000 replicate blank testing
demonstrates that the low standard of 10 C.U. is a viable standard sufficiently greater
than the blank. Based on this information the Canton mill will continue to use 10 c.u.
as the low standard for DMR reporting.
If.you have any questions, comments, or need additional information, I can be
contacted by phone at 704-646-6720 or by fax at 704-646-2993.
Sincerely,
a l l
John J. Pryately
Laboratory &WWfP Supervisor

Canton Mill
Box C-10 �(
Canton,North Carolina 28776
l�J Champion
Champion International Corporation
August 26, 1998 �d
'9s�'9T L9/
l '
Mr. Keith Haynes °tigFCr
North Carolina Department of
Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: Petroleum Release at Champion International Corporations Canton Mill on August 22, 1998
Dear Mr. Haynes:
Champion International Corporation is providing written notification of a release of
approximately 10 gallons of hydraulic fluid. The release was discovered on August 22, 1998,
at approximately 7:00 a.m. This letter is a follow-up to our telephone conversation on
August 24, 1998.
Hydraulic fluid leaked from the pump head of the Beaverdam Creek pump system. The
pump system automatically shut-off on low hydraulic fluid as designed. Most of the fluid was
contained behind the underflow pump intake structure. A contractor used absorbent booms
to absorb the fluid. No sheen was observed on the creek, nor was there any effect observed
on aquatic life.
If you need further information regarding this release please contact me at [phone]
or Jim Giauque at [phone].
Sincerely,
butam
Derric Brown Jim Giauque
Environmental Supervisor Senior Environmental Engineer

Imo" NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
�ENR DIVISION OF WATER QUALITY
F�;C Y
JAMES B.HUNTJR.,GOVERNOR
WAYNE MCDEVITT,SECRETARY
A PRESTON HOWARD,JR.,P.E.,DIRECTOR
July 16, 1998 41
198 vG �e*
Mr. John J. Pryately Frye
Champion International WWTP Lab: <<99l
P.O. Box 4000 f9Fc,9�s
Canton, NC 28716
SUBJECT: Laboratory Certification Maintenance Inspection �F
Dear Mr. Pryately:
Enclosed is a report for the inspection performed on July 2, 1998 by Mr. Gary W.
Francies. A response is not required if there were no violations cited. A response is not
required for comments or recommendations unless specifically requested. We appreciate
the fine job you and your staff are doing. As a certification requirement, your laboratory
must continue to carry out the requirements set forth in 15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from
this office. Thank you for your cooperation during the inspection. Please contact us at
919-733-3908, if you have questions or need additional information.
Sincerely,
s1
James W. Meyer
=t Laboratory Section
Enclosure
cc: Gary W. Francies
Marilyn O. Deaver
LABORATORY SECTION
4405 REEDY CREEK ROAD,RALEICH,NORTH CAROLINA 27 6 07-6 44 3
PHONE [phone] FAX [phone]
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ON- SITE INSPECTION REPORT
LABORATORY NAME: Champion International Corp. WWTP Laboratory
ADDRESS : P. O. Box 4000
'Canton, NC 28716
CERTIFICATE #: 198
DATE OF INSPECTION: 7/2/98
TYPE OF INSPECTION: Maintenance
EVALUATOR(S) : Gary Francies
LOCAL PERSON(S) CONTACTED: John Pryately, Derric Brown
Mike Cody, Chad Salisbury, Heather Hager
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the
requirements of 15A NCAC 2H . 0800 for the analysis of environmental
samples .
II. GENERAL COMMENTS :
The laboratory is spacious and well equipped. All equipment is well
maintained. Two new desiccators have been obtained. Records are well
kept and most data appeared accurate. The lab analyzes quarterly
performance evaluation samples for all parameters . Since the last
inspection, control limits have been set for duplicate sample analyses
for all parameters . Also, most of the forms, logs, and bench sheets
have been updated. The staff has done an excellent job of maintaining
the laboratory certification program.
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
S COLOR
COMMENT : The signal reading on the low standard is not sufficiently
greater than the blank ( . 002 absorbance units obtained on a 10 c.u.
standard) . This makes the lower limit of detection or reporting limit
questionable due to inviable signal readings . We request a reply to
this comment.
REQUIREMENT:- The lab must obtain a signal in which the constituent
concentration in reagent water is 2 (1. 645) s above the mean of blank
analyses (Lower Limit of Detection) . The constituent concentration
that produces a signal sufficiently greater than the blank, that it
can be detected within specified limits, by good laboratories, during
routine operating conditions, is the Limit of Quantitation. Typically
it is the concentration that produces a signal 10s above the reagent
water blank signal . In most cases, this requires an absorbance value

Page 2
greater than . 005 units, preferably greater than . 010 units . Ref :
Standard Methods, 18th Edition - Method 1010 C. And 1030 E.
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory
bench sheets and contract lab reports to DMRs submitted to this
Division. Data were reviewed for these months : March, April, and May
1998 . No errors were noted. It appears the facility is doing a good
job of accurately transcribing data .
V. CONCLUSION:
This laboratory is doing a good job overall . The staff is
cRn.gratulated for doing an excellent job of maintaining the laboratory
program.
Report prepared by: Gary Francies Date : 7/6/98
S:
e_�

NORTH CAROLINA DEPARTMENT OF
' ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
41i r WATER QUALITY SECTION
CDENR :_: August 11, 1998
:JAMEs 6.HUNTJ1q Mr. Derrlc Brown
OVERNOR i--T "•" Champion International Corporation
Canton Mill
Post Office Box C-10
Canton, North Carolina 28716
I.P[k .•
P E.MCDEVITT � -
tF'sect a-ad5
SEcxrwaY * Subject : Performance Audit Inspection
PAI Grade: "A"
. rc a Canton Mill WWTP
` NPDES Permit No. NC0000272
k•�„aP�REs,oNdrnA, JR„ __ Haywood County
3 r
4; ,.
Dear Mr. Brown:
On July 2, 1998 Mr. Gary Francies of the Division' s
Regional Office Laboratory and I conducted a Performance
Audit Inspection on Champion' s Canton Mill wastewater
£ treatment program. Personnel present from the Mill during
' the inspection were: Derric Brown, Chad Salisbury, John
P' Pryately, Melanie Hager, and Mike Cody. It should be noted
that the effluent samples were collected on July 22, 1998 .
The purpose of this inspection was to determine the
quality of the self-monitoring program being conducted by
the Mill and assess the reliability of its reported data.
The inspection consisted of evaluation of the following:
flow monitoring equipment, sample collection and
r' ti preservation techniques, and of laboratory analytical
rtiH1 i techniques, record keeping and data reporting procedures .
--- The self-monitoring program being conducted by the Mill
- was shown to be operating according to applicable standards .
Flow measurement and sampling procedures were acceptable .
The Performance Audit Inspection (PAI) rating for this
facility is "A" . A PAI rating sheet is attached for your
review.
a 4 INTERCHANGE BUILOINO,59 WOODFIN PLACE,ASHEVILLE,NC 28 801-241 4
PHONE [phone] FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-SO RECYCLED/10q POST-CONSUMER PAPER

Mr. Derric Brown
August 11, 1998
Page Two
A. FIELD EVALUATION
1 . FLOW MEASUREMENT: Flow is measured prior to the
001 covered discharge structure using an eight
foot free flow Parshall flume in conjunction with
a Fischer & Porter Ultra-sonic flow meter with
Foxboro recorder and totalizer.
2 . The effluent sampling devices for outfall 001 are
three ISCO model 3710 composite samplers with
refrigeration. Proportional composite samples are
collected for every 250, 000 gallons of effluent .
one of the samplers is used for special studies .
Sampler tubing is changed on a monthly basis .
The two influent composite samplers are both ISCO
model 3170 with refrigeration. The temperature in
each of the samplers was 40C or less .'
3 . RECORD MAINTENANCE: Records and data handling
procedures appear to be satisfactory and
consistent with self-monitoring requirements
contained in the NPDES Permit .
4 . PERMIT VERIFICATION: The Permit was issued with
an effective date of January 1, 1997 .
B. LABORATORY EVALUATION
1 . FACILITIES AND EQUIPMENT: Laboratory space is
adequate for testing performed for the facility.
All equipment is well maintained. The lab
routinely conducts NPDES testing for temperature,
ammonia nitrogen, pH, five-day biochemical oxygen
demand (BODS) , dissolved oxygen, total suspended
solids, total dissolved solids, total solids,
chemical oxygen demand (COD) , total hardness,
color, and settleable matter. Burlington Labs,
performs testing for effluent toxicity. Dioxin
analysis is performed at Quanterra. Zinc,
hardness, nitrite, nitrate, fecal coliform and TKN -
analyses are performed at Pace Labs in Charlotte,
NC. AOX is performed by Galbriath in Knoxville,
Tennessee. Mercury by Brooks Rand.

Mr. Derric Brown
August 11, 1998
Page Three
2 . METHODOLOGY: All testing procedures are based
upon Standard Methods 18th edition. Any concerns
are discussed in detail in the attached ON-SITE
INSPECTION REPORT completed by Mr. Francies as
part of the Laboratory Certification Program.
3 . RECORDS KEEPING: Laboratory record keeping
generally was appropriate and consistent with good
laboratory practice .
Should you have any questions concerning the Report,
please do not hesitate to contact me at 251-6208 . The
assistance provided to me by all Mill personnel involved
during the inspection was greatly appreciated.
Si cere1
D. Keith Hayne
Environmental Specialist
Attachment
xc : Roger Pfaff, EPA
Gary Francies

United States Environmental Protection Agency Form Approvev,
Washington, D.C.20460 OMB No. 2040-0003 '
PA NPDES Compliance Inspection:Report Approval Expires 7-31-85
-Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type inspector Fac Type
1 IN 1 215 I 3 1 NC0000272 11 12 98/07/03 17 18 Iq I 19 20 �z
u u Remarks u u u
I I I I I I I I - I I I I I I I I I I I I I I I I I I I
31 Reserved Facility Evaluation Rating BI QA
J Reserved
67 LI 69 70 J 71 IonI 72 ) ] 73 LJ 74 75L LL 80
Section B:Facility Date
Name and Location of Facility Inspected Entry Time Permit Effective Date
Champion International Corp. 9:00 am 970101
Canton Mill
Canton, Haywood County Exit Time/Date Permit Expiration Date
3:30 pm 011130
' Name(s)of On-Site Representative(s)/Title(s) Phone No(s)
Derric Brown - Environ. Supervisor 704-646-2318
Name,Address of Responsible Official Title
Mr. William Manzer Vice-PresidentlOperations Mgr.
PO Box 10-C
Canton, NC 28716 Phone No. Contacted
No
Section C:Areas Evaluated During Inspection CODES S---Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated/Not applicable
$ Permit $ Flow Measurement qS
Pretreatment $. Operations &MaintenanceRecords/Reports $ Laboratory Compliance Schedules $ Sludge Disposal
SFacility Site Review E$ Effluent/Receiving Waters Self-Monitoring Program Other:
Section D:Summary of Findings/Co; menfs (Attach additional sheets if necessary)
Effluent Data ARO Mill Permit Limits(Daily Avg/Mon Avg)
BOD, 6.1 mg/I 4.26 mg/I 30.0 mg/I - 45.0 mg/I
TSS — 6 mg/I 7 mg/I 30.0 mg/I - 45.0 mg/I
TDS — 1400 mg/I 1280 mg/I
TR — 1400 mg/I 1304 mgA
NH, — 0.60 mg/I 0.63 mg/I
Fecal Coliform 12/100 ml 13/100 ml
Three of the four aeration basins were in operation, with the other one in the digester mode. The remainder of the plant was in full operation. The Parshall
Flume/flow meter is calibrated quarterly. Effluent flow at the time of sampling was26.3 MGD. Maintenance records are kept by computer in the treatment
•• maintenance shop. Effluent samples were split with the facility on July 22. All sampler refrigeration units were operating at or below the proper temperature.Twc
of the four belt presses were in operation.
Name(s)and Signature(s) Inspector(s) Agency/Office/Telephone Date i-
D. Keith Haynes
DWQ/ARO 828-251-6208
Signatur Rev' wer Date
DWQ/ARO 828-251-6208
' Regulatory Office Use Only C
Action Taken Date Compliance Status
13 Noncompliance
Compliance

IAO
State of North Carolina
MICHAEL F. EASLEY Department of Justice
ATTORNEY GENERAL P.O:BOX 629 REPLY TO: .
RALEIGH Environmental Division
[e-mail]
27602-0629 Telephone:919nl6-6600
Fax:919nl6-6767
July 23, 1998 _
Mr. Barry Turner ��- )
Deputy Attorney General ,.
425 Fifth Avenue North
Nashville, Tennessee 37243-0495
RE: Joint Watershed Advisory Committee
Dear Barry:
Pursuant to Paragraph 32 of the Settlement Agreement Regarding 1996 Water Quality Color
Variance and 1996 NPDES Permit Issued to Champion International Corporation,North Carolina -.
and Tennessee are required to establish a Joint Watershed Advisory Committee. The agreement is
silent as to the details for setting up and operating the Committee, but the goal is to "foster joint
planning and public input on decisions affecting the Pigeon River."
Both states need to establish the initial requirements for membership and operation, and it
appears you and I are in the best positions to move the committee along legally. Forrest Westall,
Paul Davis, Mike McGhee and others have had a general discussion of this on May 12, 1998; and
at that time North Carolina suggested several principles to follow. They may be summarized as
follows:
North Carolina and Tennessee should appoint three or four members each (with
concurrent or overlapping service periods), with one of each State's appointments
being a co-chair of the Committee (a partnership in direction). The criteria for
appointment would have to be established, but would likely include folks that live
in the basin and that have some special local.interest or leadership role (political,
educational, or interest group affiliation). Staffing support of the Committee would
have to be agreed to by the two states. Since the basic objective of this section of the
Agreement seems to be to foster community interest in the River and the
management decisions affecting the River, it is anticipated that the Committee, after
completing its initial meetings and organization efforts,would develop its own path.

Mr. Barry Turner
Page 2
July 23, 1998
It would initiate its own agenda for interaction with federal, State and local agencies
having land and water management responsibilities within the watershed. The
Committee would develop its own "independent" view of these decisions or
proposals and would comment directly to those agencies. It should have broad
latitude to determine its role.
The purpose of this letter is to initiate a process under which the two states can agree on
Committee membership criteria and any staffing or logistics issues. Appointments may then be
made and the Committee charged with going forward as it determines appropriate.
Please consider this proposal and call me to discuss, at your convenience. I look forward to
working with you again on this matter. With best wishes, I am
Very truly yours,�
Daniel C. Oakley
Senior Deputy Attorney General
DCO/dw
cc: Secretary Wayne McDevitt
Preston Howard
.-Forrest Westall
wp26431
@C,
s..

f- c
't NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
�pn DIVISION OF WATER QUALITY
July 22, 1998
CDER 198
h Mr. John J. Pryately 0
Champion International WWTP Lab.
^+J/AMES B.NUNF7R.
P.O. Box 4000
{=- b
�.coveRNOR. Canton, NC 28716
.r SUBJECT: Deleting Parameter(s) from Certificate �shE4�oRATo 0
r" cD�n: RESIDUE, SETTLEABLE �FRE�jOSf0
-
Dear Mr. Pryately:
Per your request we are deleting the above parameters from your certificate.
Enclosed is an updated certificate reflecting this change which is effective on
July 22, 1998.
If you have questions or we can be of any further assistance, please contact us at
[phone].
sr s
E _ t
}' - - Sincerely,
Bernard E. Sims, Ph.D.
_ Chief, Laboratory Section .
BES:mod
- - Enclosure
_ — cc James W. Meyer
Gary W. Francies
m Marilyn O. Deaver
W
LABORATORY SECTION
4405 REEDY CREEK ROAD,RALEIGH,NORTH CAROLINA 27607-6445
_ PHONE 9I9-733-300B FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-50%RECYCLED/109o' POST-CONBUMER PAPER

Attachment I
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Lab Name: Champion International W WTP Lab. Certificate Number. 198
Address: P.O.Box 4000 Effective Date: 1/1196
Canton,NC 28716 Expiration Date: 12/81/98
Date of Last Amendment: 7/22I98
The above named laboratory,having duly met the requirements of 15A NCAC 2H.0800,is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANIC
BOD
COD
COLOR,PLATINUM COBALT _
CONDUCTIVITY
AMMONIA NITROGEN
pH
RESIDUE,TOTAL
RESIDUE,DISSOLVED 180 C
! RESIDUE,SUSPENDED
This certification requires maintance of an acceptable quellty assurance program,use of approved methodology.and safisfactory performance on evaluation samples. Laboratories ere
subject to civil pena8ies andtor decertificetlon for infractions as set foM in 15A NCAC 2H.0807.

: r NORTH CAROLINA DEPARTMENT OF '
" ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
August 11, 1998
Mr. Derric Brown
1RE3 B.HUriTJ-"
N.
,;�„E,:r„R.•. '_-_?� Champion International Corporation
Canton Mill
.. Post Office Box C-10
Canton, North Carolina - 28716
.e
•c. �E.DEvrrt'
Subject : Performance Audit Inspection
PAI Grade: "All
Canton Mill WWTP
NPDES Permit No. NC0o00272
Haywood County
'Dear Mr. Brown:
On July 2, 1998 Mr. Gary Francies of the Division' s
1' Regional Office Laboratory and I conducted a Performance
,_Audit Inspection on Champion' s Canton Mill wastewater
"treatment program. Personnel present from the Mill during
'the ' inspection were: Derric Brown, Chad Salisbury, John
Pryately,. Melanie Hager, and Mike Cody. . It should be noted
+n
J that ' the 'effluent samples were collected on July 22, 1998 .
The purpose of this inspection was to determine the
'quality of the self-monitoring program being conducted by
'the Mill and assess the reliability of its reported data.
The inspection consisted of evaluation of the following:
flow monitoring equipment, sample collection and
', t,� .•; preservation techniques, and of laboratory analytical
techniques, record keeping and data reporting procedures.
The self-monitoring program being conducted by the Mill
_ - _ was shown to be operating according to applicable standards .
Flow measurement and sampling procedures were acceptable.
_ The Performance Audit Inspection (PAI) rating for this
facility is 'IA" . A PAI rating sheet is attached for your
review.
INTERCHANGE BUILDING.39 WOOOFIN PLACE,ASHEVILLE,NC 28801-2414
PHON9028-231-6208 FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-30%RECYCLED/10%POST-CONSUMER PAPER

s
Mr. Derric Brown
August 11, 1998 s
Page Two
A. FIELD EVALUATION "
1. FLOW MEASUREMENT:. Flow .is measured prior, t' the
001 covered discharge structure-using an eigtit'a";;.A
foot free flow Parshall flume in conjunction with.,
a Fischer & Porter Ultra-sonic flow meter with
Foxboro recorder and totalizer.
2 . The effluent sampling devices for outfall 001 are
three ISCO model 3710 composite samplers with
refrigeration. Proportional composite samples are
collected for 'every 250, 000 gallons of effluent.
One of the samplers is used for special studies.
Sampler tubing is changed on a monthly basis.
The two influent composite samplers are both ISCO
model 3170 with refrigeration. The temperature in
each of the samplers was 40C or less .
3 . RECORD MAINTENANCE: Records and data handling
procedures- appear' to .be .satisfactory and
consistent with self-monitoring requirements
?contained in the NPDES- Permit.
4 . PERMIT VERIFICATION: The .Permit was issued with
an effective date of January 1, 1997.
B. LABORATORY EVALUATION
1. FACILITIES AND EQUIPMENT: Laboratory space is
adequate for testing performed for the facility.
All equipment is well maintained. The lab
routinely conducts NPDES testing for temperature,
ammonia nitrogen, - pH, five-day biochemical oxygen
demand (SODS) , dissolved oxygen, total suspended
solids, total dissolved solids, total solids,
chemical oxygen demand (COD) , total hardness,
color, and settleable matter. Burlington Labs,
performs testing for effluent toxicity. Dioxin
analysis is performed at Quanterra. ' Zinc,
hardness, nitrite, nitrate, fecal coliform and TKN—
analyses are performed at Pace Labs in Charlotte,
NC. AOX is performed by Galbriath in Knoxville,
Tennessee. Mercury by Brooks Rand. '

Mr. Derric Brown
August 11, ' 1998
Page Three
2 . METHODOLOGY: All testing procedures are based
upon Standard Methods 18th edition. Any concerns
are discussed in detail in the attached ON-SITE
INSPECTION REPORT completed by Mr. Francies as
part of the Laboratory Certification Program.
3 . RECORDS KEEPING: Laboratory record keeping
generally was appropriate and consistent with good
laboratory practice.
- Should you have any questions concerning the Report,
please do not hesitate to contact me at 251-6208 . The
assistance provided to me by all Mill personnel involved
during the inspection was greatly appreciated.
Si cerel.
D. Keith Hayne
Environmental Specialist
Attachment
xc: Roger Pfaff, EPA
Gary Francies
I
_ I

United States Environmental Protection Agency Form Approvea'�
Washington, D.C.20460 OMB No.2040-0003
PA NPDES Compliance Inspection-Report Approval Expires 7-31.85
—Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 215 3 1 NC0000272 11 12 98/07/03 117 18 u 19 U 20IJ
Remarks
I I I I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I I I
r' Reserved Facility Evaluation Rating _ _ BI CA Reserved 66
67 69 !70L� 71 72 at 73 LLJ74 - 75 80
Section B: Facility Date
Name and Location of Facility Inspected Entry Time Permit Effective Date
Champion International Corp. 9:00 am 970101
Canton Mill
Canton, Haywood County .. Exit Time/Date Permit Expiration Date
3:30 pm 011130
Name(s)of On-Site Repmsentative(s)/Title(s) Phone No(s)
Derric Brown- Environ_Supervisor 704-646-2318
Name,Address of Responsible Official _ Title
Mr.William Manzer Vice-President/Operations Mgr.
PO Box 10-C
Canton, NC 28716 Phone No. Contacted
11 No
Section C:Areas Evaluated During Inspection - CODES yr S-Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated(Not applicabl
$ Permit $ Flow Measurement S Pretreatment $ Operations &Maintenant
$ Records/Reports Laboratory :3. $ Compliance Schedules S Sludge Disposal
$ Facility Site Review - $ Effluent/Receiving Waters $ Self-Monitoring Program Other.
Section D:Summary of Findings/Comments (Attach additional sheets if necessary) ,
Effluent Data ARO Mill Permit Limits(Daily Ave/Mon Avg)
BODs - 6.1 mgA 4.26 mgA 30.0 mg/I - 45.0 mgA
T55 - 6 mgA 7 mg/I 30.0 mgA - 45.0 mgA
TDS - 1400 mgA 1280 mg/1
TR - 1400 mg/I 1304 mgA
NH, - 0.60 mgA 0.63 mgA
Fecal Coliform 12/100 ml 13/100 ml '
Three of the four aeration basins were in operation, with the other one in the digester mode. The remainder of the plant was in full operation.The Parshall
- Flume/flow meter is calibrated quarterly. Effluent Sow at the time of sampling was 26.3 MGD. Maintenance records are kept by computer in the treatment
maintenance shop. Effluent samples were split with the facility on July 22. All sampler refrigeration units were operating at or below the proper temperature.Tv
of the four belt presses were in operation.
Name(s)and Signatur s) Inspector(s) Agency/Office/relephone Date .tj.
D. Keith Haynes _
DWQ/ARO 828-251-6208
Signatur Rev' wer Agency/Office Date -
DWQ/ARO 828-251-6208 8
Regulatory Office Use Only 14
Action Taken Date Compliance Status
Noncompliance
Compliance

ALT 71.9% NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
■ B. TJ E"R DIVISION OF WATER QUALITY
JAMES B.HUNJR.,GOVERNOR
WAYNE MCDEYITT,SECRETARY
A.FRESTON HOWARD,JR.,P.E.,DIRECTOR
July 16, 1998 41
198 ��/� lop
Mr.Mr. John J. Pryately
Champion International WWrP Lab:
P.O. Box 4000
Canton, NC 28716
SUBJECT: Laboratory Certification Maintenance Inspection
.s
Dear Mr. Pryately:
Enclosed is a report for the inspection performed on July 2, 1998 by Mr. Gary W.
Francies. A response is not required if there were.no violations cited. A response is not
required for comments or recommendations unless soecifically requested. We appreciate
the fine job you and your staff are doing. As a certification requirement, your laboratory
must continue to carryout the requirements set forth in 15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from
this office. Thank you for your cooperation during the inspection. Please contact us at
919-733-3908, if you have questions or need additional information.
Sincerely,
' /�/
Gv" v( ��
James W. Meyer
Laboratory Section
Enclosure
cc: —Gary W. Francies
Marilyn O. Deaver
"k
= 1
\i LABORATORY SECTION
4405 REEDY CREEK ROAD,RALEIGH,NORTH CAROLINA 27607-644S
PHOHE919-733-3908 FAX [phone]
AN EQUAL OPPORTUNITY/ARPI RNATI V E ACTION EMPLOYER-50%RECYCLE0/10%"5T CONOUMER PAPER

ON- SITE INSPECTION REPORT
LABORATORY NAME: Champion International Corp. WWTP Laboratory
ADDRESS : P. O. Box 4000
Canton, NC 28716
CERTIFICATE #: 198
DATE OF INSPECTION: 7/2/98
TYPE OF INSPECTION: Maintenance
EVALUATOR(S) : Gary Francies
t LOCAL PERSON(S) CONTACTED: John Pryately, Derric Brown
3
Mike Cody, Chad Salisbury, Heather Hager
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the
requirements of 15A NCAC 2H . 0800 for the analysis of environmental
samples .
II. GENERAL COMMENTS:
The laboratory is spacious and well equipped.- All equipment is well
maintained. Two new desiccators have been obtained. Records are well
kept and most data appeared accurate. The lab analyzes quarterly
performance evaluation samples for all parameters . Since the last
inspection, control limits have been set for duplicate sample analyses
for all parameters . Also, most of the forms, logs, and bench sheets
have been updated. The staff has done an excellent job of maintaining
the laboratory certification program.
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
COLOR
COMMENT: The signal reading on the low standard is not sufficiently
greater than the blank ( . 002 absorbance units obtained on a 10 c.u.
standard) . This makes the lower limit of detection or reporting limit
questionable due to inviable signal readings . We request a reply to
this comment.
REQUIREMENT: The lab must obtain a signal in which the constituent
concentration in reagent water is 2 (1 . 645) s above the mean of blank
analyses (Lower Limit of Detection) . The constituent concentration
that produces a signal sufficiently greater than the blank, that it
can be detected within specified limits, by good laboratories, during
routine operating conditions, is the Limit of Quantitation. Typically
it is the concentration that produces a signal 10s above the reagent
water blank signal. In most cases, this requires an absorbance value

Page 2
greater than .005 units, preferably greater than . 010 units . Ref:
Standard Methods, 18th Edition - Method 1010 C. And 1030 E .
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory
bench sheets and contract lab reports to DMRs submitted to this
Division. Data were reviewed for these months : March, April, and May
1998 . No errors were noted. It appears the facility is doing a good
job of accurately transcribing data .
V. CONCLUSION:
This laboratory is doing a good job overall . The staff is
_ congratulated for doing an excellent job of maintaining the laboratory
program.
Report prepared by: Gary Francies Date : 7/6/98
;a'

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
` WASHINGTON,D.C.20460
J�\t6D STgTFs
A
�'9C F120ZE�
MEMORANDUM
DATE: July 25, 2001
SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue
Ridge Paper Products, Canton,NC
FROM: EPA Tech Team'
TO: Technology Review Workgroup
Purpose of this Analysis
As required by the 1997 Settlement Agreement, this memorandum presents a summary of an
analysis of available technologies that may be employed to further reduce color discharges from
the Blue Ridge Paper Products, Inc. (Blue Ridge) mill in Canton,NC. The analysis also includes
a summary of the economic impact ("gross margin test") of the cost of implementing identified
color reduction technologies.
Members of the Tech Team visited the Canton mill on March 14, 2001 to observe and gather
information and data on the status of technologies implemented and color discharges at the mill
since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered
from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical
and financial data. This final memorandum is based on the May 4, 2001 preliminary draft
memorandum, and revisions to the July 10, 2001 draft final memorandum, based on a review of
Blue Ridge's comments, the June 8, 2001 Bleach Environmental Process Evaluation and Report
(BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group,Inc,
and additional comments from the Clean Water Fund of North Carolina, and the States of
Tennessee and North Carolina. This memorandum presents to the Technology Review
EPA Tech Team is comprised of--Mark Perez,EPA/EAD;Karrie-Jo Shell,EPA Region 4;Don Anderson,
EPA/EAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,subcontractor to
ERG.

Workgroup (TRW)process improvements evaluated by the Tech Team and considered to be
available technologies and briefly addresses relevant technologies evaluated in the BEPER.
Background and History
Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton,NC, which it
purchased from Champion International Corporation in May 1999. Operations at the mill began
in 1908, but the mill has been extensively modernized,most recently in 1993. The mill currently
operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking,
pulp from each line is further delignified in single-stage oxygen delignification systems installed
in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence; pine pulp is bleached
with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery
(BFR )process, developed by Champion. A portion of the hardwood line bleach plant Eo-
stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated
paper including offset,tablet and envelope grades. The mill also produces 281,000 tons per year
of bleached paperboard used for liquid packaging and paper cups, including FDA approved
grades for milk and juice cartons. Since November 2000, pulp production has been reduced by
approximately 30 percent as the result of a major project to upgrade the No. 19 bleached
paperboard machine.
Continued Color Reduction Opportunities Since the 1997 NPDES Permit
The Canton Mill's 1997 NPDES permit included a schedule requiring continued study,
evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge
submitted a series of reports to the NC Department of Environment and Natural Resources,
Division of Water Quality, evaluating the performance of the BFRTM process, end-of-pipe color
reduction technologies, and practices for minimizing color losses from manufacturing processes.
Since 1997 Blue Ridge has:
• continued full-scale operation of BFR for the pine line;
c I Waded that full-scale BFR is not feasible for the hardwood line, but
�hented 1 a portion of the Eo-stage filtrate as an effective
�� �� 1��' � i 1p
�osses of highly-colored
en e 1 im i anent �I�I� r 'E dVl
black liquor from manufAtti� ng processes, a d
• evaluated 16 end-of-pipe color removal technologies and determined that they
were presently economically and/or technically infeasible for the Canton mill.

Page 3
Process Improvements Analyzed by the Tech Team
The Tech Team identified five mill improvements capable of further reducing the discharge of
color in the mill effluent. For each of these improvements, technical feasibility, capital and
operating costs, and potential color reduction were reviewed. Each improvement can be
implemented independently of the others or in any combination. The costs incurred to
implement the improvements are additive, however separate evaluations are necessary to
accurately estimate the associated color reduction achieved by implementing any combination of
improvements. End-of-pipe color treatment technologies (e.g., chemically assisted clarification
with sludge dewatering and disposal) typically require initial capital investment and ongoing
operating expenses, not savings, and are likely to incur non-water quality environmental impacts.
For this reason, the Tech Team focused on pollution prevention approaches that offer the
potential to be more cost-effective: color reduction in low flow,highly color-concentrated
wastestreams,through manufacturing process changes or in-process treatment.
The first two process improvements, discussed below (improvements in BFR reliability and leak
and spill prevention and control -Best Management Practices (BMPs)), are improvements which
the Tech Team concludes offer the highest certainty for technical feasibility and color reduction.
Blue Ridge also identified these technologies as feasible color reduction opportunities that will
be implemented, but differed from the color reduction estimates included in this memorandum.
The next two process improvements (ozone addition to an existing chlorine dioxide bleaching
stage on the hardwood fiber line; adding a second stage to the current oxygen delignification
system on the softwood fiber line) also were evaluated by Liebergott, et. al., as feasible color
reduction opportunities. Additional technical evaluation and/or laboratory testing would be
appropriate to reliably determine the technical details of how to incorporate these processes into
the existing fiber lines and to more accurately predict their achievable color reduction, and the
relationship of these technologies to BFR. Additional analyses would be appropriate to
determine the most cost-effective design and the most economically feasible schedule for
im en m one or both of se im rove e s V
i1I i P ,� �i i]
� {III ��'•.,l.7 •. �� �i ii ll,, . .13
{ 1�•11 l� .i� I
�,I '_' .I � � �1{ 14 � 04111111the ni m oCessl v .n n color calll�hf ror td e�lo�de e, o s�' t t•4 , �i, ,t, p')�
stream (one of the two key components of the BFR process),has the potenti{ l of iiriE ]Jhl3' �t+�'
color reduction. However, based upon initial bench-scale treatability studies by Blue Ridge,
further study of additional color treatment technologies is necessary. Process optimization on
both the hardwood and softwood fiber lines, as recommended in the BEPER, is anticipated to

Page 4
provide additional color reduction and is identified as the sixth process improvement. It was
concluded that the process optimization option was among those with the highest certainty for
technical feasibility and color reduction.
All color reductions resulting from the mill improvements are estimates based solely on available
data and information. While the Tech Team has concluded that these technologies would reduce
the color discharge from the Canton mill,there is a lack of directly comparable operating
experience with these technologies in other bleached papergrade kraft mills that can be used to
develop precise predictions of the extent of the color reduction benefits.
The BEPER evaluated additional in-process technology options for color discharge reduction
potential, including the implementation of a hot pressurized peroxide-enhanced extraction stage
in both fiber line bleach plants. At this time,the Tech Team does not have sufficient information
to confirm the applicability of this technology at the Canton mill nor relevant data to predict its
potential color discharge reduction capabilities. Therefore, while this memorandum does not
address this technology option, it may be feasible for implementation by Blue Ridge and
contribute to reducing color. In addition, the Tech Team did not analyze nor did the BEPER
recommend a Totally Chlorine-Free (TCF)bleaching option because of the high cost.of this
technology and the lack of experience in producing and successfully marketing products made
by Blue Ridge at the Canton mill.
1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal
Process (MRP). Blue Ridge has found that this process element has been more challenging and
expensive to maintain than originally planned. The target BFR recycle rate (percent closure) for
the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and
metallurgy problems (e.g., erosion of multi-media filtration tank lining) in the MRP, however,
the pine line closure has averaged only 74 percent from October 1998 to the present. Blue Ridge
has undertaken improvements to the MRP system in order to maintain the process closure rate
and increase operating time. Improvements include rebuilding piping and valves, and changing
construction materials and metallurgy to better withstand the chemical and physical stress
experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80
cept, annual average final effluent color discharge will be reduced by 1,000 to 1,200 lbs/day.
1 Ate � �1111TI,e sno means of making an alternative quantitative prediction of
r c, o
31 a �ri�aP el' nM l t 'p `uedYr C
„t r jipare to the Blue Ridge estimate.
ii
jjJ�'''i,

Page 5
2. Improved black liquor leak& spill collection and control (BMPs). The Canton mill has an
extensive spill recovery system. Sumps in this system, including one sump added in the court
yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped
with pumps that are activated automatically when sensors detect wastewaters with high
conductivity and color. High conductivity material is routed to the recovery system. Further
improvements to the black liquor collection system include:
• continuous improvement of operating practices so more leaks and spills are
recovered rather than discharged to sewer;
• further improvement in preparation for planned outages to maximize capture of
tank clean-out waste and routing to recovery;
• further reducing clean water that continuously runs into sewers to prevent dilution
of smaller spills and facilitate recovery of highly colored wastewaters; and
• further improvement in the equipment used for handling of knots rejects to
prevent black liquor leaks into the recovery sumps.
The plot below shows the color of wastewater treatment influent at the Canton mill. The
vari il� v a i uent tole d s�harge to wastewater treatment is attributed to color discharge
�►�� , Vi fi p�„I ;; � � ,
eaks tha e t Yn �ii ned spills or leaks discharged to sewers or intentional
op
ollg''�1111syyl�lbl jol r liquor or other color sources routed to sewers during mill
100
kg/t
Figure 1
75 Daily color at influent to W WTP for Canton
50
25
0 30 60 90 120 150 180

Page 6
Due to the nature of the manufacturing processes and practical equipment operation and
reliability, all spills and color losses to sewers cannot be fully anticipated, predicted, and
completely contained. However, a comparison of the variability of the Canton mill influent color
data to available primary influent color data at another bleached papergrade kraft mill indicate
that a detailed review of the spill prevention and recovery system at the Canton mill (by mill
staff or external consultants), including involvement by the mill operators, can further uncover
the causes of and better quantify black liquor losses and other color sources that can be avoided
or recovered. This will result in an overall reduction in color discharge, both in long-term
average and variability. Through improved planning of mill equipment shutdowns, continuing
efforts to minimize process operation variability, and increased recovery of highly-colored leaks
and spills, discharges of highly colored material to the wastewater treatment system can be
reduced more consistently below existing levels.
Further reducing peaks in color discharges within the mill and preventing highly colored flows
from reaching the wastewater treatment system will further reduce the variability of color
discharges from the wastewater treatment system to the Pigeon River. For example, limiting the
color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to
improve the mill's BMP system and process operations would reduce the color loadings from
mill processes to the end-of-pipe wastewater treatment system by more than 8,000 lb/day. The .
Canton mill operated under this primary clarifier influent color threshold approximately 74
percent of 2000, excluding November through December 2000. This time period was considered
not to be representative of steady-state operations because of the reduced pulp production
resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average
reduction of 45 percent across this wastewater treatment system for"brown" color derived from
black liquor, this would result in a minimum decrease of 4,400 lb/day in the average final
effluent color load.
Clean water, such as packing gland water, presently flows in several sewers with recovery
sumps. These colorless streams dilute other colored wastestreams, such as small black liquor
leaks {3 spills, to the point where the in-stream conductivity is too low to trigger recovery. By
►,��r�' ' e ,iwa �tre s o d vert3 a av f>o s ers. at GGllee ack quor �
1 _ � ,�� ill : ��� JrI F�i�� fl� � I � �� � ai'
to a r s c e e va c c e e v r_
� ;e 1 N
p R ggI ��I�I � I (� d L� • ,Ii �J ��i, ���i�� ��!�i ���
in a reduction m color discharJ ' e' c� -6rppe wastewter lystem. e
unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can
be recovered.
''I'11� �11� �'� jb� t ;lglf.i),i1�11Ii�l I� �II i�lltil 'r
u� 1 1 ': I`
�!
, yt j I p��:IluuJlla ijJ rSa� I i��lipI'llilii,il�)�i 1 � y�bklll.' �a

Page 7
At this time, the Tech Team has no basis for determining an accurate correlation between
unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill
Environmental Performance Update presented by Blue Ridge during the March 14, 2001 Tech
Team Canton mill visit. During the March 14 visit, Blue Ridge staff indicated that results of
studies of sewer generated color showed a relationship between bleach plant filtrate pH and
temperature and unaccounted color generated in mill sewers. By operating within the range of
pH and temperatures identified during the studies the Canton mill has had some success in
controlling this source of unaccounted color. Based on this information,the Tech Team
concludes that by further reducing process operation variability, including operating within the
pH and temperature range identified during the studies, the mill can continue to also minimize
sewer generated color, thereby reducing one source of unaccounted color. Reducing overall
color discharges through BMPs and other management practices will likely further reduce
remaining unaccounted color. However, additional studies are necessary to further develop any
relationship between accounted and unaccounted color sources.
As noted above, analysis of primary clarifier influent color loading data demonstrates that color
loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during
steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and
nten i n i c arges ]� a stream a cn tinuing efforts to minimize process operation
17JdfIJ ' 3 t u { R ,1
ltll I til� ti I �' ail � ��' y�� r �1 it ii l,i
r! v I �ttry g Yo il c�hleve N h'e 7rg dyd 9. •�c� 7e i e;� Jor lo� d 7
` � II
^I �MC61 Ilr.� Il� ,i ! I ar6r, I II h ( ' I'�ht114k1� li a aSrJ.�
tib �c eri rfu�a effi t color n4 chargelw tfu>4 is rang ja', ,� Co
demonstrated in 2000 (i.e., more than 74 percent of the time). On this basis hey
concluded it is feasibl tr edu . f al ue�r r b 4 e than 5.000 qa't
r` { �,
�Pjbt� � a1 � � 1 �99a �� �ICG
u „ improve( black li uor an t co a ton fr(1yj�
t' IP �( I Jll�i,� 7 ^I1B3 ti '1
�i� ) ����i����' I 1���II��h� � �.
Oi! ne/ hlorine dioxide sta e fol rr ha o0d 6 each line. Ozone is used in more than ten kraft
mills around the world to bleach pulp, including two in the US and one in Canada. There are
several process configurations, but the most common is to operate an ozone (Z) mixer and
reactor immediately upstream of a chlorine dioxide reactor, without any washing between the
application of the two chemicals. This is known as a"ZD" stage. A system of this type was
retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999.2 Bleaching with ozone on
the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 27 percent reduction in
the discharge of color in the combined mill treated effluent' The conversion to a ZD stage
2 Munro,Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching Sequence,Tappi,2000.
3 Ibid.

Page 8
would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for
ozone. The energy requirements for ozone production would be offset by the energy savings
from less chlorine dioxide and caustic production, resulting in a net reduction in energy
consumption with the ZD stage.
As of September 2000, the long-term average color discharge from Canton's hardwood bleach
line was 12,800 pounds/day°. The Espanola experience suggests that implementation of a ZD
stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by
3,000 to 6,400 lbs/day. Based on comments received,the Tech Team acknowledges that
operating parameters, such as wood species processed and technology supplier performance
guarantees, may influence the practical color reduction achievable through implementation of a
ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are
based solely on the demonstrated performance and the Tech Team's assumption of color sources
at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada
(PAPTAC)meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible
communication between Blue Ridge and Domtar staff would be necessary to reliably predict the
achievable color reduction possible with this option for the Canton mill.
The technical evaluation of this process improvement included in the BEPER yielded a
hardwood filtrate color discharge reduction within the range of Tech Team estimates.
4 2"d stage OD_for pine line. Oxygen delignifrcation (OD) on the Canton Mill pine line is a
single stage system installed in 1993. It has been concluded that retrofitting a second OD stage
for the pine line could contribute to reduced color discharges in two ways. The first would be a
reduction in color for those filtrates presently not captured and reused in the BFR process. The
second would be a color reduction in the Chloride Removal Process (CRP) purge stream as a
result of less chloride from chlorine dioxide used for bleaching.
Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed
upstream of the existing reactor. Previously, the Tech Team anticipated increasing the kappa
number(lignin content) of the cooked pulp from 24 to 32 and utilizing a two-stage OD system to
reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two-
stage system. Based upon comments from BRP and further technical analysis, and review of the
BEPER, it was concluded that it is technically feasible for a two-stage OD system at the Canton
4 Jacobs Engineering Group,2001 Color Removal Technology Assessment,February 2001.

Page 9
mill to achieve an overall reduction of 50 percent in kappa number, rather than 65 percent as
pTeviouslv ant i te The efore, with the Canton mill continuing to pulp to a kappa number of
stda; 'uld reduce pulp kappa number into the bleach plant from
Y;r• . ie currEl ou ut o 6 to a6 u 1 , corresponding to a 50 percent kappa number reduction from
the current digester output of 24. The quantity of color released from the bleach plant will be
reduced in proportion to the reduction of the input kappa number.
By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a
two-stage OD system, the quantity of chemicals required in the first two stages of the bleach
plant can be reduced, because there is less lignin present in the incoming pulp to remove by
bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional
reduction in chloride load to the CRP and reduce color discharged from the purge stream in
proportion to the reduction in chloride being treated.
In response to comments received, it has been concluded that implementing a two-stage OD
system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve
a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving
greater delignification with the proposed two-stage OD system. However, operating a two-stage
OD system with a higher than 50 percent delignification rate and a digester kappa number higher
than currently employed at the Canton mill is commonly seen at comparable bleached
papergrade kraft mills. Therefore, the Tech Team anticipates that additional process engineering
will maximize the benefits of a two-stage OD system at the Canton mill and enable the mill to
capture the increased delignifcation and yield gain potential of this technology and achieve
annual wood cost savings of up to approximate $950,000 from up to a 1.5 percent yield increase
across the proposed two-stage OD system.
Based on additional information supplied by Blue Ridge regarding operational limitations of the
BFR system, the Tech Team concludes that a two-stage OD system would not have a significant
impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on
a day-to-day basis.
For this analysis, it was estimated preliminarily that a second OD stage could reduce total
influent color discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from
reductions in pine line bleach plant filtrate color and CRP purge stream color.

Page 10
The technical evaluation of two-stage OD included in the BEPER yielded reduction in color
discharge influent to the wastewater treatment system within the range of the Tech Team
estimates.
5. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP) purge is a low
flow, highly concentrated waste stream. Color is typically 50,000 pcu, in a 10 gpm (0.01 MGD)
flow. The CRP purge contributes up to approximately 5,000 lbs/day (13 percent) to the total mill
loading to the wastewater treatment system influent, but only 0.06 percent of the discharge flow.
It was originally speculated that it may be feasible to reduce the color in this stream by
precipitating the colored organic material with lime at a dosage of 20 g/L5, and burning the
resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials
would be necessary to test the feasibility of color removal from the CRP purge stream by lime
treatment.
Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium
compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The
preliminary results of these trials show that at a dosage of 20 g/L, none of the compounds tested
reduced color in the CRP purge stream. Although color removal was demonstrated at higher
dosage rates, increased chemical usage would result in substantially higher operating costs,
require larger sized equipment at higher capital cost, and also result in a higher production rate of
sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not
burned must be landfilled at additional cost.
Based on preliminary laboratory trials, Blue Ridge concluded that lime treatment of the CRP
purge is not a feasible color reduction option for the Canton mill. However, the Tech Team
recommends additional review of other innovative technologies for treatment of color in the CRP
purge stream, such as the application of the X-Filter process recently implemented at a totally
chlorine free (TCF) mills. By minimizing color contributions from this stream, the potential
exists to achieve a significant reduction in primary influent color discharge of up to 5,000
lbs/day.
5 NCASI Technical Bulleting No.239,The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching
Effluents with Lime.I. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970.
6 Comments on the Draft Report on Additional Color Removal Technologies and Economic Impacts for BRPP,Hope
.Taylor,Clean Water Fund of North Carolina,July 18,2001

Page 11
6. Process Optimization. The BEPER identified sixteen recommendations for optimizing the
hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching
operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the
first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood
line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction
of up to 700 lbs/day from the hardwood line and up to 400 lbs/day from the softwood line. The
Tech Team estimated an additional color reduction from the CRP purge stream of 600 lbs/day
resulting from the decreased chlorine dioxide usage. At this time, the Tech Team has no means
of making an alternative quantitative prediction of bleach filtrate color reduction to compare to
estimates presented in the BEPER. Therefore, it is estimated that through efforts by mill staff to
maximize the color reduction benefits from the process optimization opportunities identified by
Liebergott, et, al., the Canton mill would achieve a total color reduction of 1,700 lbs/day in
wastewater treatment system influent.
Color Reduction Summary
The Tech Team estimates that by improving BFR reliability and black liquor leak and spill
collection and control, the Canton mill final effluent will be reduced by more than 5,000 lbs/day.
Process optimization, as outlined in the BEPER, would result in a further final effluent color
reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45
percent across the existing wastewater treatment for the CRP purge stream and other "brown"
color sources derived from black liquor and no reduction in color from bleach plant filtrates.
Table 1 presents a summary of the estimated reductions in final effluent color attainable with the
highest certainty by implementing improved BFR reliability, improved BMPs, and process
optimization.

Page 12
Table 1: Summary of Process Improvements and Associated Color Reductions
(Highest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(Ibs/day) (Ibs/day)
1 BFR reliability improvement -- 1,000-1,200
2 Improved black liquor leak& spill collection and --- > 5,000
control
6 Process Optimization 1,700 1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION >7,400
Additional potential mill improvements to reduce color discharge at the Canton mill were also
identified. These process improvements require further study to more accurately determine
achievable color reduction and thus are not recommended at this time for immediate
implementation. These improvements include a ZD stage in the hardwood bleach plant, with a
preliminary estimate of a 3,000 to 6,400 Ibs/day color load reduction in influent to the
wastewater treatment system, and a second OD stage for the pine line, with a preliminary
estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment
system. Table 2 presents a summary of preliminary estimates of color reductions for these two
additional process improvements that need further study. Reductions presented in Table 2 are
preliminary estimates with reduced certainty compared to those presented in Table 1, but are
based upon identified technology options available for the Canton mill.

Page 13
Table 2: Summary of Process Improvements and Associated Additional Color Reductions
Needing Further Study (Reasonable Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(Ibs/day) (Ibs/day)
3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400
line
4 2"d stage OD for pine line 1,500-2,000 1,100-1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 - 7,800
Table 3 presents a preliminary estimate of color reduction potential for the removal of color from
the CRP purge stream. The Tech Team recommends this stream for additional review of
potential color reduction technologies but cannot identify a particular technology option at this
time. Potential for additional color load reduction up to 2,750 Ibs/day in final effluent to the
Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty.
Table 3: Summary of Additional Potential Color Reductions Needing Further Study
(Lowest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
hti{i ' 'ti')
"�I'II1� 1 (Ibs/day) (Ibs/day)
ent r e tF am 45,000 #2,750
tr i C. I EFFLUENT COLOR #2,750

Page 14
Economic Analysis
The estimated capital and operating costs for the process improvements one through four were
estimated and are summarized below. Costs could not be developed at this time for process
optimization or CRP treatment and thus are not presented. However, costs for these
improvements should be modest.
Table 3: Estimated Costs
Process Improvement Capital Cost Annual O&M
($) ($/year)
1 BFR reliability improvement $1,300,000 $85,000'
2 Improved black liquor leak& spill collection and $100,000 $50,000
control
3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000)
line savings
4 2"d stage OD for pine line $2,000,000 ($2,100,000)
savings
Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven
plants (including the Canton Mill) from Champion International Corporation. Blue Ridge Paper
Products is owned 55 percent by KPS Special Situations Fund, L.P. and 45 percent by the
employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the
1997 report EPA documented substantial losses over five years for the Canton Mill and
Champion had just announced its intention to sell or close the mill. However, because of the sale
of the mill to the Blue Ridge, the previous data are not comparable to the more recent data.
Further, the data submitted by Blue Ridge is still confidential, so this report cannot present as
much detail as the 1997 report.
The current analysis is based on information submitted by Blue Ridge covering part of
1999 (May-December) and all of 2000 (all of the existing financial data for the company). The
l , 1 a may be relatively uncertain because of the lack of data and the company may be too
� � i1�j �1�
' 11' r*Zcurrent data to reflect its ultimate financial health. EPA used three measures of
t tanctal�, � s, t *p�, scIounted cash flow, and Altman's Z 7 to assess the impact of
, i , II �i
See Interim Ece notntc Guidatt le for W Gr +.10ity Standards:Workbook,EPA 823-B-95-002,March 1995,and
Economic Analysis for the N & n 01 ri ' sign I andards for Hazardous Air Pollutants for Source Category: Pulp and
Paper Production;Ef tL; to 'l1j 'Jidelines Pretreatment Standards,and New Source Performance
.Standards:Pulp,Pa j� i�i in and Category—Phase 1.

Page 15
air emissions control technologies and devices (not addressed in this memorandum, such as
MACT II and regional NOX control) and wastewater compliance costs (separate and combined)
on the mill and company. The costs for the wastewater control options presented in Table 3 do
not change the financial status of the mill or company. However, the costs for some of the air
emissions control options do impact the health of one or both entities. When the wastewater
costs are added to costs for air emissions control, the impacts of the water costs do not change
the financial status of either the mill or company when compared to the impact of the air costs
alone.
References
Blue Ridge Paper Products, Inc. Canton Mill Canton Mill Environmental Performance Update,
Prepared for U.S. EPA Technology Review Workgroup. March 14,2001.
Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic
Analysis of Blue Ridge Paper Products, from Bob Williams, May 18, 2001 (CBITS 00003911-
01)
Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown,Blue Ridge,
to Don Anderson, EPA, May 18, 2001
Comment Clarification of May 18, 2001 Blue Ridge Responses to EPA Questions, from Derric
Brown, Blue Ridge, June 4, 2001
Comments on Draft Final Tech Team Report, from Bob Williams, Blue Ridge, to Don Anderson,
EPA, July 13, 2001
Comments on Draft Final Tech Team Report, from Derric Brown, Blue Ridge,to Don Anderson,
EPA, July 17, 2001
Comments on Draft Final Report, email from Forrest Westall,North Carolina DENR, to Don
Anderson, EPA, July 17, 2001
Comments on Draft Final Report on Additional Color Removal Technologies and Economic
Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001

Comment on Draft Final Tech Team Report, email from Paul Davis, State of Tennessee, to Don
Anderson, July18, 2001
Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott, to
Don Anderson,EPA, July 19, 2001
Jacobs Engineering Group, 2001 Color Removal Technology Assessment, Blue Ridge Paper
Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001.
Liebergott,Norm, and Lew Shackford, Bleach Environmental Process Evaluation and Report,
June 8, 2001
McCord,Aimee,A Laboratory Analysis of Color removal Across a Pulp and Paper Mill
Wastewater Treatment Facility, Canton, North Carolina, Duke University, School of the
Environment, 1995
Munro;Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.
NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of
Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching
Effluent. July, 1970.
Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater
Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina, Duke University, School
of the Environment, 1996
Sp )��k' 141 ed. In ustrial Environme n nl Pul and Pa er Ind stry ag ,182
1�1j Tlll�ti
1 II I `` 1 1r,I iI -
y{ Wiley to s + f)9 jd)�`�l)I�tr�!�I
b �] '1�«) Lfl� ��1111191f f"- d . . JJ � �1 ` I ..I } ��' ➢,
iW
=�i �i� `( �
piD1 I9 ��� 11 rin l{� '� ,.- 13:1I ] 11 { 1 � { ¢I ii N) i fl' 7'' , �,
I,� ' I U ++ 1�I h� tt "� 119 rd
1
Spnner Alan M. ed. Industry E' t ! 11t rot P ' F' er ct 19,311.
o d
� � 1� '��� {pf�� i 1 � �
��.6'
I I„ „ t } 'al�1. 17 1� 11di71 Ill 1 x i
14
r

Appendix 1: Color Balance (9/1/00 to 12/31/00)
Figure 2.6, Presented by Blue Ridge on March 14, 2001
Sewer Description Color Load
ID I (Ibs/day)
213 Digester area sewer: Digesters, HW 4,323
line, knot rejects
3A Alkaline sewer: Pine and HW Eo, 12,954
Pine line BSW, 02 Delig
1 PMs1 1 & 12,HW weak liquor tank 1,991
513 Recovery,BLOx, CRP* 7,852
6A Acid sewer: Pine and HW D1 17,345
filtrate+Pine D2 filtrate
Contaminated Condensate 1,591
Combined Condensate 260
Total .46,316
Primarylnfluent(PI) 49,284**
Unaccounted Color 2,968
(PI minus Total)
Secondary Effluent 37,696
Percent Removal in Treatment 23
* CRP contributes 5,000 to 6,000 Ibs/day to 5B sewer
** Measured using test method in NCASI Tech. Brill. 803, An Update of Procedures for the
Measurement of Color in Pulp Mill Wastewaters, May 2000.

Appendix 2: Table of Effluent Color Limits, 1997 to Present
Color Limit True Color (lbs/day)
Monthly Average Annual (Long-term)
Average
1997 Permit 125,434 98,168
Settlement Agreement, February 1998 69,000 60,000
(starting December 1, 1998)
Settlement Agreement, February 1998 --- 48,000 to 52,000
(Ultimate Target)
Interim Limits, May 2001* 55,000 48,000**
* As recommended by Technology Review Workgroup (TRW) and incorporated by NC in
BRP's NPDES permit.
** Reduced end-of-pipe color discharges since November 2000 reflect, in part, reduced pulp
production (approximately 30 percent) during this period because of the ongoing project to
upgrade the No. 19 paper machine used to produce bleached paperboard.

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

Appendix 4: Two-Stage Oxygen Delignification
Comparison of one- and two-stage oxygen delignification systems
Item Current Single-Stage System Proposed Two-Stage System
Oxygen Reactors One two
Input Kappa Number 24 24
Output Kappa Number 16 12
Total C102 Used 28 kg/ton* 22 kg/ton*
Oxygen Used 23.4 kg/ton* 28.3 kg/ton*
Total NaOH Used 45 kg/ton* 37 kg/ton*,.
* air-dried metric ton of bleached pulp