NC0000272_Correspondence_20080219

Re:Extension Request for 2007 Dioxin in Fish Tissue Report
Subject: Re: Extension Request for 2007 Dioxin in Fish Tissue,Report
From: Keith Haynes <[e-mail]>
Date: Tue, 19 Feb 2008 07:27:26 -0500
To: [e-mail]
CC: Keith Haynes<[e-mail]>, Roger Edwards<[e-mail]>
In order to save time this email will serve as the official approval for your
request for a 60 day extension for the submittal of the 2007 Dioxin Fish Tissue
Report. The Report will now be due on April 16, 2008. Please print a copy of this
email for your files. If you have any questions, please do not hesitate to call.
[e-mail] wrote:
Thank you.
Paul Dickens
Manager, Environmental Affairs
Blue Ridge Paper Products, Inc.
[e-mail]
828-696-6141 FAX [phone]
*Keith Haynes <[e-mail]>*
02/19/2008 07:11 AM
To
[e-mail]
CC
Subject
Re: Extension Request for 2007 Dioxin in Fish Tissue Report
We are in receipt of your request for a 60 day extension for the 2007
Dioxin Fish Tissue Report. At this time we have no issues with the
request. A hard copy letter will follow.
dickep@blueridgenaper_com wrote:
> 2/7
> Keith -
> As discussed. Hard copy original will go out in today's mail.
> Paul Dickens
> Manager, Environmental Affairs
> Blue Ridge Paper Products, Inc.
1 of 2/19/2008 7:27 AM

Re:Extension Request for 2007 Dioxin in Fish Tissue Report
> [e-mail]
> 828-646-6141 FAX [phone]
Keith Haynes - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Keith Haynes - Keith.Havnes@ncmail..net
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Keith Haynes<Keith.Haynes a,ncmail.net>
NC DENR-Asheville Regional Office
Division of Water Quality-Water Quality Section
2 of 2 2/19/2008 7:27 At

I
Michael F.Easley.Governor
o�0F w A'Z 9 William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
Alan W.Klimek.P.E.Director
�_ Division of Water Quality
Coleco H.Sullins,Deputy Director
O < Division of Water Quality
June 6, 2006
Mr. Paul S. Dickens
Manager, Environmental Affairs
Blue Ridge Paper Products
P.O. Box 4000
Canton,North Carolina 28716
Subject: Revisions to Dioxin Monitoring Plan
Blue Ridge Paper Products
NPDES No.NC0000272
Dear Mr. Dickens:
The Water Quality Section has reviewed your request for modifications to the subject study plan
originally approved by the Division of Water Quality in February 1990. The 2001 dioxin fish
tissue monitoring plan is approved with the following changes:
• Elimination of main stem river sampling stations-beginning in 2006 fish tissue
samples will be collected only from Waterville Lake.
• Collect a least one whole body bottom feeder sample from Waterville Lake (stations
4A or 4B)to monitor ecological impacts of dioxin contamination in bottom species.
• Continue with the collection of bottom feeder fillet samples in Waterville Lake as
approved in the 1990 study plan.
After reviewing your request to eliminate whole body dioxin analyses from Waterville Lake, our
staff recommends that this analysis be continued. Although the Waterville Lake data submitted
in your 2005 report shows low levels of dioxin, data submitted by Progress Energy in 2005
showed a mean dioxin TEQ value of 6.7 pg/g for common carp. The value was above the 4.0
pg/g TEQ value used by NCDHHS to post fish advisories for dioxin. As this time the dioxin
advisory for Waterville Lake remains in effect, and in our view,warrants continued monitoring.
If you have any further questions or comments please feel free to contact Mark Hale at 919/733-
6946.
nce�ely,
immie verton
ironmental Sciences tt?n - --
n i? -
Ji
cc: Roger Edwards -ARO JUN 1 2 2006Dr. Luanne Williams—NCDHHS
Susan Wilson -DWQ Permits
John Crutchfield—Progress Energy
i
Customer Service
N.C.Division of Water Quality 1617 Mail Service Center Raleigh,North Carolina 27699-1617* [phone] C1877-623 6748

BLUE RIDGE - -
PAPER PRODUCTS INC.
Certified Mail I
Return Receigt BAuested
7099 3220 0007 0371 6235 -
30 March 2006
Mr. Mark Hale
Environmental Biologist
Environmental Services Section
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Subject: Study Plan Revision
Dioxin Monitoring in Fish Tissue—Waterville Lake
March 2006
NPDES No. NC0000272
Blue Ridge Paper Products Inc.
Canton Mill
Dear Mr. Hale—
The subject study plan revision is enclosed for Division of Water Quality(DWQ)review and
approval.
Background
The Blue Ridge Paper Products Inc. mill in Canton, North Carolina has completed biological
monitoring for dioxin in fish in the Pigeon River for the past 16 years. This annual biological
monitoring is a requirement of the Canton Mill's NPDES permit. The permit requires that we
follow a study plan approved by the DWQ for this work. Dioxin in fish sample collection and
reporting for 2002 through 2005 was conducted under the December 2001 Study Plan for
Pigeon River Dioxin Monitoring in Fish Tissue prepared by EA Engineering, Science and
Technology. EA Engineering completed the dioxin in fish sampling and reporting for years
2002 thru 2004. In 2005, Blue Ridge Paper contracted with the University of Tennessee,
Knoxville (UTK) Department of Forestry, Wildlife and Fisheries for the dioxin in fish tissue
work. UTK followed the 2001 Study Plan for the 2005 dioxin in fish sampling and report. The
2005 report was submitted to the DWQ on 20 Feb 2006.
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

Mark Hale, NC DENR DWQ,ESS-
3/30/06, Page 2
Biological Monitoring Review
The first annual dioxin fish tissue sampling study of the Pigeon River was in 1990. At that time,
public health fish consumption advisories related to dioxin were in place for the Pigeon River
downstream of the Canton Mill for both North Carolina and Tennessee reaches of the river.
Dioxin fish tissue concentrations determined from annual sampling declined sharply following
completion of the Canton Mill modernization in 1993. Dioxin fish tissue sample concentrations
in bottom feeding species at main stem river sample locations became non-detect in 2000 and
have remained below analytical detection levels since that time. Dioxin fish tissue sample
concentrations in sport fish species from all sampling locations in the Pigeon River became non-
detect in the mid-1990s.
Based on annual fish tissue sampling, the State of North Carolina lifted the dioxin in fish
advisory for the Pigeon River upstream of Waterville Lake in August 2001. The State of
Tennessee lifted the dioxin in fish advisory for the Tennessee portion of the Pigeon River in
January 2003. The only fish advisory remaining is for carp in Waterville Lake. Dioxin levels in
carp collected from Waterville Lake since 2000 continue to be at or near analytical detection
levels and are below the North Carolina Department of Health and Human Services (NC DHHS)
dioxin toxicity equivalent(TEQ) fish advisory action level of 4 parts per trillion(ppt).
The NC DHHS has indicated that two consecutive years of TCDD TEQ levels in carp of 3 ppt or
less would provide basis for lifting the public health advisory for consumption of carp from
Waterville Lake(e-mail correspondence from Dr. Luanne Williams, DHHS to Blue Ridge Paper
dated 9 Mar 2006). The TCDD TEQs for carp fillet composite samples from Stations 4A &4B
in Waterville Lake for the last two years are as follows:
Year Station 4A Station 4B
2004 2.5 ppt 2.2 ppt
2005 2.1 ppt 3.6 ppt
Study Plan Revision
Blue Ridge Paper proposes the following changes to the 2001 biological monitoring Study Plan:
• elimination of main stem river sampling stations -- fish tissue samples beginning in 2006
will be collected only from Waterville Lake
Blue Ridge Paper Products Inc
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mark Hale, NC DENR DWQ,ESS-
3/30/06, Page 3
• elimination of whole body fish composite samples from the lake-- only composite fillet
samples of target bottom feeding fish species will be collected for laboratory analysis of
dioxin.
The 2006 study plan revision is enclosed for your review and approval. A copy of the 2001
study plan is also enclosed for your reference.
Sutmnary
The 2006 dioxin in fish sampling work is planned for the mid-summer period of August and
early September. We request DWQ approval of the 2006 study plan revision no later than the
end of May 2006.
Please contact us if you have questions.
Paul S. Dickens J. Glenn Rogers
Manager, Environmental Affairs Water Compliance Coordinator
828-646-6141 828-646-2874
[e-mail] [e-mail]
Enclosures: Study Plan Revision, Dioxin Monitoring in Fish Tissue— Waterville Lake
March 2006
Prepared by University of Tennessee for Blue Ridge Paper Products
Study Plan for Pigeon River Dioxin Monitoring in Fish Tissue
December 2001
Prepared by EA Engineering for Blue Ridge Paper Products
cc (w/enclosures):
Bryn Tracy- NC DENR DWQ, ESS
Susan Wilson—NC DENR DWQ, Permits
Sergei Cherinkov—NC DENR DWQ Permits
Roger Edwards — NC DENR DWQ, ARO
Keith Haynes - NC DENR DWQ ARO
Dr. Louanne Williams—NC DHHS
Larry Wilson— UTK
Billy Clarke—Roberts & Stevens
John Crutchfield—Progress Energy
Blue Ridge Paper Products Inc
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
STUDY PLAN REVISION
DIOXIN MONITORING IN FISH TISSUE
Waterville Lake
Prepared for:
Blue Ridge Paper Products, Inc.
Canton Mill
Canton, North Carolina
NPDES No. NC 0000272
Prepared by:
J.Larry Wilson,Ph.D.
Departments of Forestry, WildlifSand Fisheries
University of Tennessee
Knoxvil►e, Tennessee
March 2006

PF
Study Plan—2006 Dioxin Monitoring in Fish Tissue,Waterville Lake
University of Tennessee for Blue Ridge Paper Products Inc.Canton Mill
Page 1
INTRODUCTION
The Blue Ridge Paper Products Inc. Canton Mill conducts annual biological monitoring of
dioxin in fish in the Pigeon River under conditions of the NPDES permit for the mill. This
monitoring for years 2002 thru 2005 was in accordance with the December 2001 Study Plan for
Pigeon River Dioxin Monitoring in Fish Tissue prepared by EA Engineering, Science and
Technology(EA 2001a). This document details changes for dioxin in fish monitoring beginning
in 2006. The 2001 study plan is incorporated by reference. The specific changes to the 2001
study plan include:
• elimination of main stem river sampling stations -- fish tissue samples in 2006 will be
collected only from Waterville Lake
• elimination of whole body fish composite samples from the lake-- only composite fillet
samples of target bottom feeding fish species will be collected for laboratory analysis of
dioxin.
The 2006 dioxin in fish tissue sampling from Waterville Lake will be conducted by personnel
from the University of Tennessee, Knoxville(UTK), Department of Forestry, Wildlife and
Fisheries.
SAMPLE LOCATIONS
The schedule for fish tissue collection will be consistent with prior years targeting dry weather
periods in late August and early September. UTK will collect and prepare fish tissue samples
from two locations in Waterville Lake on the Pigeon River(PRM 39.0-41.5). In previous
studies, the fish collection sites in Waterville Lake have been designated 4A(PRM 41.5) and 4B
(PRM 39.0). Site 4A is located approximately 21.8 RM downstream from the Canton Mill
outfall,near the Messer Branch-Pigeon River confluence. Site 4B is in the vicinity of the
Wilkins Creek-Pigeon River confluence, approximately 24.3 RM downstream from the Canton
Mill outfall. Fish sampling will be conducted in the vicinity of each location described above;
however, the distance or effort at each station will depend on how difficult it is to collect target
fish species at that location. In 2005, common carp in the lower portion of the Waterville Lake
were extremely difficult to collect.
FISH COLLECTION TECHNIQUES AND TARGET SPECIES
The goal of the 2006 fish collection effort is one composite bottom feeder fillet sample at each
Waterville Lake sampling station 4A and 4B. Each composite consists of 3 to 5 similarly sized
(shortest specimen within 75% of the length of the longest) adult individuals of the target
species. Common carp (Cyprinus carpio) and channel catfish(Ictahtnts punctatus) are the
targeted bottom feeder species at sites 4A and 4B. Every reasonable effort will be made to
collect the desired size, species, and number of fish. However, the outcome of sampling effort

Study Plan—2006 Dioxin Monitoring in Fish Tissue,Waterville Lake
University of Tennessee for Blue Ridge Paper Products Inc.Canton Mill
Page 2
each year is dependent on physical river conditions and the natural diversity and abundance of
target fishes at each location.
The field investigators will be equipped with an array of collecting gear, which will enable
sampling of all habitats regardless of river conditions. The US EPA recommends active methods
of fish collection in the Sampling Guidance Manual (Versar 1984), such as electrofishing,
trawling, angling, or seining. These are preferred over passive methods (e.g., gill nets, trap nets,
trot lines)because samples are collected from more defineable areas (Versar 1984). Electro-
fishing may be used at both locations (4A and 4B); gill nets may also be used in areas where
water depth will limit the electro-fishing gear. A boat electrofrshing unit(pulsed direct current,
Smith Root Type VIA electro-fisher powered by a 240-volt, 5000-Watt generator) will be
provided. Electra-fishing techniques will follow those described in the National Dioxin Study
(Versar 1984). All gill nets will be pulled and examined on a regular basis to reduce specimen
stress or mortality, and specimens submitted for analysis will be selected for good health and
condition.
Fish collection techniques and level of effort(time) expended at both locations (4A and 413)will
be recorded. Total study effort for the 4A/413 collections in 2005 took 460 gill-net hours and
approximately six hours of electro-fishing over a four-day period to obtain the necessary
specimens. Channel catfish were easily caught,but common carp were extremely difficult to
collect, particularly in the lower portion of the lake (413).
In summary,fish tissue samples will be collected as follows:
• bottom-feeder composite—one composite bottom feeder fillet sample at each location
4A and 413
• catfish composite—one composite catfish fillet sample at each location 4A and 413
SAMPLE PREPARATION
All fish tissue samples will be prepared in accordance with U.S. EPA Region IV
recommendations (Cummingham 1990 as described in EA 2001a). To prevent cross-
contamination between sampling stations, all sampling equipment likely to come into contact
with the fish will be rinsed extensively with site water between stations.
Specimens collected at each location will be sorted by size and species, and target species
identified. UTK will obtain a 3 to 5-fish composite sample at each location(4A and 413) which
meet the species/size objectives discussed earlier. All specimens retained will be immediately
placed on ice for later processing. All fish submitted for tissue analysis will be measured to the
nearest millimeter(TL) and weighed to the nearest gram (wet weight).
Following collection of channel catfish and common carp, each specimen will be prepared for
shipment and analysis. Samples will consist of epaxial muscle tissue and skin from one side of
the fish. Fillet samples will be prepared by removing scales (or removing the skin from

Study Plan—2006 Dioxin Monitoring in Fish Tissue,Waterville Lake
University of Tennessee for Blue Ridge Paper Products Inc.Canton Mill
Page 3
catfishes) and then making an incision behind the opercula (on both sides of the fish)from the
base of the spine (behind the skull) to just below the pectoral fin. Care will be taken to cut
through the epaxial muscle without puncturing the rib cage or gut lining. A second incision will
be made along the length of the spine to the caudal fin on both sides of the fish. The muscle will
be cut away from the rib cage to obtain a fillet. Fillet knives will be solvent rinsed (hexane and
acetone)between fish from different locations. Each composite sample will be wrapped in
aluminum foil (dull side toward sample), labeled, and placed on dry ice. One side fillets will be
sent to Severn Trent Laboratory for analysis; the opposite side fillets will be retained by Blue
Ridge Paper as back-up fillets.
All individual specimens (fillets) composing a single composite sample will placed together in a
water-tight plastic bag labeled with the station name, sample number, and the number of samples
in that composite. All labels will contain following information: sample identification number,
sample location and station identification, sampling team initials, date of collection, species
name, and sample type (i.e., fillet). A chain-of-custody form will be filled out for each cooler of
samples submitted for analysis, and each form will include composite specific information and
instructions.
All samples will be frozen solid prior to shipment to the analytical laboratory. The frozen
samples will be packed on dry ice and shipped via overnight delivery to Severn Trent Laboratory
(STL)—Sacramento for analysis. The back-up fillets will be retained in a freezer at the Canton
Mill until laboratory analytical results for the composite fillet samples are received and verified;
the back-up fillet samples will then be destroyed.
SAMPLE ANALYSIS
The composite fillet fish tissue samples received by STL will be analyzed for dioxin (2,3,7,8-
TCDD), furan (2,3,7,8-TCDF) and related isomers using EPA Method 8290 (US EPA 1994).
Percent lipids will also be determined for each composite sample. STL will provide laboratory
analytical reports including QA/QC summaries and completed chain-of-custody forms
documenting receipt by the lab.
REPORTING
Results of 2006 dioxin in fish tissue sampling from Waterville Lake will be submitted to the NC
DENR within 180 days of the completion of field work as required by the Blue Ridge Paper
NPDES permit. The fish tissue sampling and analytical report will follow the general format of
prior year reports. Dioxin toxicity equivalent(TEQ)levels will be calculated for all 17
chlorodibenzo dioxin and furan (CDD/F) isomers included in EPA Method 8290. The TEQ of
each detectable isomer will be calculated based on the toxicity equivalent factor(TEF)for the
isomer provided by the World Health Organization(WHO 1997). The measured concentration
of each CDD/F isomer will be multiplied by its appropriate TEF to obtain a concentration of the
isomer equivalent to the toxicity of 2,3,7,8-TCDD, the most toxic of the CDD/F isomers. Non-
detectable concentrations will be treated as zero values for TEQ calculation. As requested by the

Study Plan—2006 Dioxin Monitoring in Fish Tissue,Waterville Lake
University of Tennessee for Blue Ridge Paper Products Inc.Canton Mill
Page 4
NC DHHS (Williams 2006), the TEQ results for the last two years will be presented in a
columnar, side-by-side format to allow easy comparison against health advisory action levels.
References
EA Engineering,Science,and Technology Inc. 1990. Study Plan for the Monitoring of Dioxin in Fish
Tissue. EA Report No. 11370.01,prepared for Champion International Corporation, Canton,
North Carolina.
EA Engineering,Science,and Technology Inc. 1991. Results of the 1990 Dioxin Monitoring in Fish Tissue.
EA Report No. 11370.02,prepared for Champion International Corporation,Canton,North
Carolina.
EA Engineering,Science,and Technology Inc. 1992. Results of the 1991 Dioxin Monitoring in Fish Tissue.
EA Report No. 11370.03,prepared for Champion International Corporation, Canton,North
Carolina.
EA Engineering,Science,and Technology Inc. 1993a. Results of the 1992 Dioxin Monitoring in Fish Tissue.
EA Report No. 11370.05,prepared for Champion International Corporation,Canton,North
Carolina. April.
EA Engineering,Science,and Technology Inc. 1993b. Results of the 1993 Dioxin Monitoring in Fish
Tissue. EA Report No. 11370.06,prepared for Champion International Corporation, Canton,
North Carolina. December.
EA Engineering,Science,and Technology Inc. 1994. Results of the 1994 Dioxin Monitoring in Fish Tissue.
EA Report No. 11370.07,prepared for Champion International Corporation, Canton,North
Carolina. December.
EA Engineering,Science,and Technology Inc. 1995. Results of the 1995 Dioxin Monitoring in Fish Tissue.
EA Report No. 13043.01,prepared for Champion International Corporation,Canton,North
Carolina. December.
EA Engineering,Science,and Technology Inc. 1996. Results of the 1996 Dioxin Monitoring in Fish Tissue.
EA Report No. 13176.01,prepared for Champion International Corporation, Canton,North
Carolina. December.
EA Engineering„Science,and Technology Inc. 1997. Results of the 1997 Dioxin Monitoring in Fish Tissue.
EA Report No. 13353.01,prepared for Champion International Corporation,Canton,North
Carolina. November.
EA Engineering,Science,and Technology Inc. 1998. Results of the 1998 Dioxin Monitoring in Fish Tissue.
EA Report No. 13478.01,prepared for Champion International Corporation,Canton,North
Carolina. December.
EA Engineering,Science,and Technology Inc. 2000. Results of the 1999 Dioxin Monitoring in Fish Tissue.
EA Report No. 13478.01,prepared for Champion International Corporation, Canton,North
Carolina. January.
EA Engineering,Science,and Technology Inc. 2001a. Study Plan for Pigeon River Dioxin Monitoring in
Fish tissue. Prepared for Blue Ridge Paper Products,Canton,North Carolina. November.

Study Plan—2006 Dioxin Monitoring in Fish Tissue,Waterville Lake
University of Tennessee for Blue Ridge Paper Products Inc. Canton Mill
Page 5
EA Engineering,Science,and Technology Inc. 2001b. Results of the 2000 Dioxin Monitoring in Fish
Tissue. EA Report No. 13745.01,prepared for Blue Ridge Paper Products, Canton,North Carolina.
December.
EA Engineering,Science,and Technology Inc. 2001c. Results of the 2001 Dioxin Monitoring in Fish Tissue.
EA Report No. 13900.01,prepared for Blue Ridge Paper Products,Canton,North Carolina.
December.
EA Engineering,Science,and Technology Inc. 2003. Results of the 2002 Dioxin Monitoring in Fish Tissue.
EA Report No. 13900.02,prepared for Blue Ridge Paper Products,Canton;North Carolina.
December.
EA Engineering,Science,and Technology Inc. 2004. Results of the 2003 Dioxin Monitoring in Fish Tissue.
EA Report No. 13900.03,prepared for Blue Ridge Paper Products,Canton,North Carolina.
January.
Henry,A.G.and J.L.Wilson. 2006. Results of 2005 Dioxin Monitoring in Fish Tissue. Center for
Environmental Biotechnology and Department of Forestry,Wildlife and Fisheries, University of
Tennessee,Knoxville,Tennessee.
U.S. Environmental Protection Agency(US EPA). 1994. Analytical Procedures and Quality Assurance for
Multimedia Analysis of Polychlorinated Dibenzo-para-dioxins and Polychlorinated Dibenzofurans by
High Resolution Gas Chromotography/High Resolution Mass Spectrometry(Method 8290).
Versar,Inc. 1984. Sampling Guidance Manual for the National Dioxin Study. U.S.Environmental
Protection Agency. EPA Contract 68-01-6160. Work Order Number 8.7. Office of Water
Regulations and Standards,Monitoring and Data Support Division,Washington,D.C. Final Draft.
July.
Williams, L. 2006. E-mail correspondence from North Carolina Department of Health and Human Services
to Blue Ridge Paper Products concerning review of 2005 Dioxin Monitoring in Fish Report, March
9.
World Health Organization(WHO). 1997. Exposure and Human Health Reassessment of 2,3,7,8-
Tetrachlorodiben2o-p-dioxin (TCDD) and Related Compounds: Part II Health Assessment of
2,3,7,8-Tetrachlorodibenzo-P-dioxin (TCDD and Related Compounds.

EA Project 13900.01
STUDY PLAN FOR PIGEON RIVER
DIOXIN MONITORING IN FISH TISSUE
Prepared for:
Blue Ridge Paper Products
Canton, NC
Prepared by:
EA Engineering, Science, and Technology
444 Lake Cook Road, Suite 18
Deerfield, IL 60015
QQ
-
December 2007 Pr� AP
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I
TABLE OF CONTENTS
Page
I..........Introduction .................................................................................... 1-1
2. Station Locations .............................................................................. 2-1
3. Fish Collection Techniques and Target Species .......................................... 3-1
4. Sample Preparation ........................................................................... 4-1
5. Analysis of Fish Tissue Samples ............................................................ 5-1
6. Quality Assurance ............................................................................. 6-1
7. Project Schedule ............................................................................... 7-1
8. Monitoring Report ............................................................................. 8-1
9. References ...................................................................................... 9-1
i

I
1. INTRODUCTION
This study plan details the materials and methods that will be used to annually assess the levels
of dioxins and furans in fish tissues from the Pigeon River downstream of the discharge from
the Blue Ridge papermill in Canton, North Carolina. This study plan was developed in
response to requirements in the mill's currentNPDFS permit(Permit No. NC0000272).
Changes to original permit conditions as detailed in letters from North Carolina Division of
Water Quality (NCDWQ) and North Carolina Department of Health and Human Services
(NCDHHS) dated 22 August 2001 and 31 August 2001,respectively have been incorporated
into this study plan. Section 2 of this study plan provides information regarding the locations
of the sampling stations. Section 3 details the techniques that will be used to collect fish at
each station and the target species. Section 4 describes the procedures that will be used to
prepare the collected fishes for tissue analysis. Section 5 specifies the analytical technique that
will be used to determine the concentrations of the different dioxin and furan isomers in each
tissue sample. The Quality Assurance plan is presented in Section 6, and the project schedule,
monitoring report, and references are found in Sections 7, 8, and 9, respectively.
1

I
2. STATION LOCATIONS
Six stations have been established for the collection of fishes (Figure 2-1 and Table 2-1).
Station 1, the background site, is located at Pigeon River Mile(RM) 64.5 adjacent to the
Canton Recreational Park, approximately 1.2 RM upstream from the Canton Mill outfall.
Except at very high flows, the Canton Mill dam blocks the movement of fishes thereby
preventing the interaction of control and monitoring station fishes. Station 2 is located at RM
59.0, upstream from Clyde, NC and approximately 4.3 RM downstream from the Canton Mill
outfall. Station 3 is located at RM 52.3 just upstream of the old Rt. 209 bridge, approximately
11.0 RM downstream from the Canton Mill outfall. Stations 4A and 4B are located in
Waterville Lake at RM 41.5 and 39.0, respectively. Station 4A is located approximately 21.8
RM downstream from the Canton Mill outfall,near the Messer Branch-Pigeon River
confluence. Station 4B is in the vicinity of the Wilkins Creek-Pigeon River confluence,
approximately 24.3 RM downstream from the Canton Mill outfall. Stations 4A and 4B
correspond to the upper and lower ends, respectively, of Waterville Lake. Station 5 is at RM
19 near Bluffton,TN,44.3 miles downstream of the mill outfall. Fish sampling will be
conducted in the immediate vicinity of each location described above,however, the sample
reach may be extended somewhat, if necessary, to facilitate collection of the required number
of fish.
2

I
1-40
Station 5
RM 19.0 5
Bluffton TN
(19.3f
Hartford,TN N
TENNESSEE
NORTH
............. CAROLINA
B�9 Hydro Plant it o
(26.0)
jr a
�n
w \(i G(.
5
Walters Dam B
Station 4B Station 4A
RM 39.0 RM 41.5
4
Waterville Lake
Fines Creek
New Hepco Bridge
FLOW Jonathan
Creek Old Rt.209 Mill Outfall
3 Station 3 Station 2 RM 63.3
RM 52.3 RM 50.0
Waynesville STP 2 Canton,NC
Outfall Oa
a
RM 50. CI de Station 1 1
RM 64.5
(Control)
Figure 2-1. Fish tissue sampling station locations on the Pigeon River.

TABLE 2-1 PIGEON RIVER SAMPLING STATIONS
Station River Station Location and
Number Mile Distance from Outfall Site Description/Habitat Tvoe Fish Communi[v
1 64.5 Pigeon River upstream from Canton, Characterized by riffle,on,and pool habitats. Maximum Relative abundance dominated by minnows and darters. River
NC,adjacent to Canton Recreational depth approximately 6 ft. Substrate primarily cobble and chub,greenfin darter and rock bass are dominant. Northern hog
Pak'(1.2 RM upstream from Canton boulders interspersed with gravel and sand. sucker,black redhorse,minor shiner,redbreast sunfish,central
Mill outfall). stoneroller,greenside darter,and mottled sculpin are common.
2 59.0 Pigeon River upstream from Clyde,NC Characterized by riffle,run,and pool habitats with canopy Relative abundance dominated by redbreast sunfish,central
(4.3 RM downstream from the Canton cover. Maximum depth approximately 5 ft. Substrate stonemller,and northern hog sucker.
Mill outfalq, primarily cobble/gravellsand with some boulders and bedrock.
3 52.3 Pigeon River in the vicinity of the Rt. Characterized by riffle,on,and pool habitats with some Redbreast sunfish,northern hog sucker,and common carp are
209 bridge(11.0 RM downstream canopy cover. Maximum depth approximately 5 ft. dominant. Central stoneroller is common.
from the Canton Mill outf dl) Substrate primarily bedrock and boulders with some
cobble and sand/gravel/fines deposited in pool areas.
4A 41.5 Upper Waterville Lake(21.8 RM Characterized by deep-water lentic habitat,bedrock, Relative abundance dominated by black crappie. Bluegill,
downstream from the Canton Mill and soft bottom sediments. Maximum depth sampled flathead catfish,channel catfish,largemouth bass,and common
outfall) approximately 14 ft. carp are common.
4B 39.0 Lower Waterville Lake(24.3 RM Characterized by deep-water lentic habitat,bedrock, Relative abundance of catch dominated by black crappie:
downstream from the Canton Mill .and soft bottom sediments. Maximum depth sampled Bluegill,channel catfish,flathead catfish,and carp are common.
outfall) approximately 40 ft. Very steep banks with little cover.
5 19.0 Pigeon River near Bluffton,TN,just Characterized by deep pools and tuns with some shallow Central stoneroller and northern hog sucker are dominant.
upstream of I40(44.3 RM downstream riffles. Maximum depth approximately 6 to 8 ft. Substrate Smallmouth bass,whitetail shiner,telescope shiner,greenside
from the Canton Mill outfall) primarily bedrock,boulder,and cobble. darter,and banded sculpin are common. Except for
smallmouth bass and rock bass,centrarchids are uncommoon.

3. FISH COLLECTION TECHNIQUES AND TARGET SPECIES
A listing of the Pigeon River fish collection techniques is provided below:
Station Number River Mile Sampling Technique
1 64.5 Electrofishing
2 59.0 Electrofishing
3 52.3 Electrofishing
4A 41.5 Gill nets
4B 39.0 Gill nets
5 19.0 Electrofishing
Except in Waterville Lake, the principal sampling gear will be electrofishing. Depending on
depth, either a pram or boat electrofrsher will be used. Gillnetting is the most effective
technique for the collection of bottom-feeder species from the Waterville Lake monitoring
stations. Gill nets will be checked at least once a day, usually within 12 hours of being
deployed. Other appropriate sampling techniques may be used if necessary.
Field notes will be recorded at each sampling station including the type of sampling gear, level
of effort(time),flow and clarity conditions, and selected physiochemical data (e.g., dissolved
oxygen, water temperature, and conductivity [electrofishing locations only])using accepted
proceedures and equipment. All fishes submitted for tissue analysis will be measured (total
length), weighed (wet weight), examined for anomalies, and recorded on a standard Fisheries
Data Sheet (Figure 3-1).
The goal of the fish collection effort is to collect one composite bottom feeder fillet sample at
each of the six sampling stations. Each composite will consist of 3 to 5 similarly sized (shortest
specimen within 75% of the length of the longest) adult individuals of the target species.
Common carp will be the target species at Stations 2, 3, 4A, and 4B, with northern hog sucker
and black redhorse as alternative species in the riverine portion of the river below the mill (i.e.,
Stations 2 and 3). Common carp are absent at Stations 1 and 5. At these stations, black
redhorse will be the target bottom feeder, with northern hog sucker and smallmouth buffalo
being alternative species. Alternative representative bottom feeder species may be collected in
the rare event that these target species are not collected.
In Waterville Lake, one additional fillet composite sample using either channel catfish or
flathead catfish will be collected at Stations 4A and 4B. Catfish are rare in the river between
the mill and Waterville Lake. However, in the event that three or more catfish of a similar size
are encountered at either Stations 2 or 3, a catfish fillet composite will be prepared for either or
both of these stations.
In addition to the fillet composites, a whole body composite consisting of 3-5 similarly sized
common carp will be collected at either Station 4A or 4B in Waterville Lake.
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Table 3-1 Fish Collection Techniques
Station Number Station Location Sampling Technique
1 Pigeon River Mile 64.5 Electrofishing
2 Pigeon River Mile 59.0 Electrofishing
3 Pigeon River Mile 52.3 Electrofishing
4A Pigeon River Mile 41.5 Gill nets
4g Pigeon River Mile 39.0 Gill nets
5 Pigeon River Mile 19.0 Electrofishing

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In summary, fish will be collected as follows:
• Bottom feeder fillet composite--one sample at all six stations
• Catfish fillet composite—one sample at Stations 4A and at 4B
• Common carp whole body composite—one sample from either Station 4A or 4B
• Catfish fillet composite—one sample at Stations 2 and at 3, if specimens are encountered
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4. SAMPLE PREPARATION
Fillet samples will consist of the epaxial muscle tissue from one side of the fish. The fillet
from the other side will be retained as a backup until laboratory results are obtained. Bottom
feeder whole-body samples will consist of the entire fish. Specimens collected will be rinsed in
site water, stunned with a sharp blow to the head and placed on wet ice until processing. Each
fish selected for analysis will be weighed and measured. Fillet samples will be prepared by
removing all scales (or removing skin from catfishes) and subsequently making an incision
behind the opercula(on both sides of the fish) from the base of the spine(behind the skull) to
just below the pectoral fin. Care will be taken to not puncture the gut lining. A second incision
will be made along the length of the spine to the caudal fin on both sides of the fish. The
epaxial muscle will then be gently cut away from the rib cage to obtain a fillet. In this fashion,
all flesh and skin (except catfishes) will be obtained from head to tail. The fillets from
specimens comprising a particular composite will be combined, then the sample will be
wrapped in aluminum foil (dull side toward sample), placed in a water-tight plastic bag, labeled
(see Section 6), and placed on wet ice. Within 24 hours of processing, the samples will be
frozen.
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5. ANALYSIS OF FISH TISSUE SAMPLES
Samples will be analyzed for dioxin using EPA Method 8290 (U.S. EPA 1994). Percent lipids
will also be determined for each sample. The laboratory will measure the concentration of 17
isomers of chlorodibenzo dioxins and furans (CDD/F). The toxic equivalent(TEQ) of each
detectable isomer will be calculated based on toxicity equivalent factors (TEF) provided by the
World Health Organization(WHO 1997). The measured concentration of each CDD/F isomer
will be multiplied by its appropriate TEF to obtain a concentration of that isomer equivalent to
the toxicity of 2,3,7,8-TCDD, the most toxic of the many CDD/F isomers. As per the directive
of NCDHHS,non-detectable concentrations will be treated as zero values for TEQ calculations.
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6. QUALITY ASSURANCE
The following procedures will be followed to prevent contamination of samples collected at
different stations or between composites collected at the same station. Dip nets, fish scalers,
and holding containers will be rinsed with site water prior to use at each station. All fish will
be rinsed in site water to remove any debris (e.g., sediment) prior to processing. During
processing, the measuring board will be wrapped with clear plastic wrap and this wrap will be
changed among stations. Fillet knives will be solvent rinsed (hexane and acetone) between fish
from different stations. Each composite sample will be wrapped in aluminum foil (dull side
toward sample), labeled, and placed on dry ice within 24 hours of processing.
All fillets or whole bodies composing a single composite sample will be foil-wrapped, then
placed in a water-tight plastic bag labeled with the station name, sample number, and the
species in that composite. All labels will contain the following information:
+ Sample identification number,
• Station identification,
• Sampling team initials,
• Date of sample collection,
• Species name,
• Sample type(i.e.,fillet or whole body)
• A unique composite number
Chain-of-Custody(COC) sheets will be completed following sample preparation and
compositing. The composite identification number and corresponding number and type of fish
comprising that composite sample will be recorded on the COC. Copies of all COCs will be
retained.
Following completion of sampling, samples will be shipped on dry ice to the analytical
laboratory via an overnight courier. Upon receipt, the laboratory will compare the contents
with that noted on the COC sheets and will note the condition of the samples.
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7. PROJECT SCHEDULE
To be consistent with past collections, all samples will be collected in August or September. A
final report will be provided to NCDEQ within 180 days of sampling.
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8. MONITORING REPORT
Each annual monitoring report will include the sampling methods and procedures employed, a
description of the sampling locations, descriptions of each fish collected (e.g., species, length,
and weight), as well as the results of the chemical analysis (reported as individual TCDD/F
isomers and 2,3,7,8-TCDD Toxic Equivalent Values). Also included in appropriate appendices
will be field notes, copies of all chain-of-custody sheets, and any pertinent memorandum or
communication record forms.
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9. REFERENCES
U.S. Environmental Protection Agency (U.S. EPA) 1994. Analytical Procedures and Quality
Assurance for Multimedia Analysis of Polychlorinated Dibenzo-para-dioxins and
Polychlorinated Dibenzofurans by High-Resolution Gas Chromatography/High-
Resolution Mass Spectrometry(Method 8290).
World Health Organization(WHO). 1997. Exposure and Human Health Reassessment of
2,3,7,8-Tetrachlorodibenzo-p-dioxin(TCDD) and Related Compounds: Part II Health
Assessment of 2,3,7,8-Tetrachlorodibenzo-p-dioxin(TCDD) and Related Compounds.
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