NC0000272_NPDES Permit Renewal Info Supplemental_20100401

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Edwards, Roger
From: Wakild, Chuck
Sent: Wednesday, April 14, 2010 4:22 PM
To: [e-mail]; [e-mail];
[e-mail]; [e-mail]
Cc: [e-mail]; Edwards, Roger; Sullins, Coleen; Belnick, Tom; Chernikov,
Sergei; Matthews, Matt
Subject: FW: Friday Meeting location
Chris,
Our Friday meeting location is changed to the Buncombe County MSD Office at 2028 Riverside Drive,Asheville, NC
28804-3054. A telephone number there is listed below. I don't have Fritz's email and am not certain that I've captured
everyone so please forward as needed.
In order to focus the discussion, I suggest we limit the topics to the list below. The other items which EPA filed
objections will be resolved in the final permit to satisfy EPA. I also suggest we target finishing the meeting at noon in
order to allow reasonable travel time back for you and us, however, if continuing discussion is productive,we can stay
all day. Here is the list of discussion items for your consideration:
• Effluent color limits
o Initial limit
o limit at 4 years
• Variance removal/determination of compliance with color standard
• Allowable delta T
• Fish tissue monitoring for dioxin
Let me know if we need to add anything.
Have a safe trip to Asheville!
From: Edwards, Roger
Sent: Wednesday, April 14, 2010 12:47 PM
To: Wakild, Chuck; Belnick,Tom; Chernikov, Sergei; [e-mail]; [e-mail]
Cc: Haynes, Keith; Menzel, Jeff
Subject: Friday Meeting location
We will meeting at Metropolitan Sewerage District's(MSD),William H. Mull Administration Building first floor
conference room on Friday at 9:00 AM.
The web page address for directions
is....http://maps.google.com/maps/place?riz=1T4GG U—en US319 US216&u m=1&ie=UTF-
8&q=msd+buncombe+county+nc&fb=1&gl=us&hq=msd&hnear—bunco m be+cou my+nc&cid=630868207890884489&ei=
N M_FS5uOL4XK8wSDutS1Dg&sa=X&oi=loca I_result&ct=resu It&resn um=5&ved=OCBoQnQlwBA
My cell phone number is 828-776-2956, if you get lost. MSD phone number is 828-254-9646.
Let me know if you have questions.
Roger Edwards- Roger.Edwards(@ncdenr.go
' 1

Blue Ridge Paper and The Pigeon
River - A Success Story Through
World Class Performance
The Canton Mill is
among best pulp and
. t paper mills in world for
effluent color
performance and other
. t
wastewater parameters
y r
S
Pigeon River Below Clyde

Color Limit Discussion
• Detailed statistical calculation of the tolerance interval
on the annual means of color showed the appropriate
limit was 391501 as a value that should be maintained in
95% of all years monitored
• A bootstrap calculation was performed where 1000 years
of data was simulated using the 2006 to 2009 color data .
• To simulate a year, pick one of the 4 Januaries, at
random, one of the 4 Febru.aries and so on through
December
• The values averaged 36,900 but ranged from 34,005 to
39,851 illustrating the pure random nature of the
variability you can see from year to year.
Page 1

Color Limit Discussion
Simulated 1000 Years of Data
Histogram : Years simulated using historical data
34 35 36 37 38 39 40
Annual mean (thousands of CU)
Histogram Using 2006 — 2009 Color Data
Page 2

4
Initial Annual Color Limit
• World class color performance
• Color performance achieved through pollution
prevention
• Achieving the level of color performance that we
have is difficult and requires significant effort and
performance from our people, processes and
equipment
• Committed to further improvement
The standard deviation of the 2006-2009 data is 4,032 pounds
Page 1

Initial Annual Color Limit
Specific Objection 1, page 1
• Fundamentally, the confidence interval approach is flawed.
• The confidence interval is an interval designed to describe the long
term average color over many years of plant operation
• This future multi-year mean is not appropriate to set an annual limit
for color
• The confidence interval on this future multi-year mean has no
recognition of the fact there is random variability of the data from one
year to the next
• Therefore, the confidence interval is not relevant to individual years
data,and the Mill does not agree the 37,900 pound per day (revised to
38,020 ound per day) is an appropriate initial annual average color.
The EPA confidence interval is 1 ,139, or 28% of the standard deviation,
above the mean
Page 2 1

Initial Annual Color Limit
Specific Objection 1, page 1
• Rather than a confidence interval for the overall multi-year
mean what is required is a tolerance interval for a single years
data
• For a tolerance interval and using data from a finite period of
time, we move away from the hypothetical (confidence
interval) to a prediction about what actual data may look like
in the future
• Using prior years data a tolerance interval calculates a future
actual year with two-sided intervals called tolerance limits.
• Tolerance limits are limits within which we expect a stated
proportion of the population to lie.
Page 3

Initial Annual Color Limit
Specific Objection 1, page 1
• Tolerance Interval methodology
— Compute 48 individual monthly averages in the data set
— Calculate the mean m=36,855
— Calculate the standard deviation s=4,032
• A future year is made up of 12 months the formula
is :
m+tsi/(1/48+1/12)
— Where t is the cutoff on the t distribution with 47 degrees
of freedom. For a 95% tolerance interval, the required t
value is 2.01
Page 4

Initial Annual Color Limit
Specific Objection 1, page 1
• Substituting the required values then gives the
tolerance interval as:
36,885±2.01 *4032 *0. 3227 which gives 36,885±2, 616
giving a range of
34, 269 to 39,501 pounds of color
The current draft Permit annual average color limit of 39,000
pounds per day is 501 pounds per day less than the upper
tolerance limit and is an acceptable starting annual average
permit limitation for color
Page 5

Temperature Variance
Specific Objection 3, page 6
• The submitted 316a Demonstration is sufficient
and included more than required for variance
renewal ( Dr. Coutant 3/17/2010 memo)
• Mill agrees with EPA's recommendation to
conduct a Delta T study using thermal modeling
concurrent with the next 316a study
• Mill believes the referenced 8. 2 Delta T value is
not appropriate
Page 1

Temperature Limit
Blue Ridge Can Support
• Recommended Temperature Limitation
— Multiple testing approach addresses the multiple
opportunities situation
— Multiplicity correction by using the Bonferroni adjustment
• Bonferroni Multiplicity Adjustment
— Where M (months) tests are being performed and an
overall exceedance rate of no more than 5% is desired,
then each test should be carried out at the 5/M%
significance level.
Page 1

Temperature Limit
Blue Ridge Can Support Logic
• Bonferroni Multiplicity Adjustment
- 12 months in a year, and 12 tests will be
performed one for each month
— Bonferroni approach calls for the upper 5/12th
percentile, that is the upper 0.42% point of the
distribution of the Delta T which is the 99 . 58
percentile
— Requires a statistical calculation the upper 0.42%
point is 2. 64 standard deviations above the mean .
Page 2

Temperature Limit
Blue Ridge Can Support
• The mean monthly Delta T's of the 2005-2009 data and standard deviation
are:
2005-2009 Delta T Deg C Mean
and Standard Deviation
Standard
'! Mean Deviation
Cool Months 3.63 2.06
Warm Months 4.36 2.10
• Following the approach of setting the limit based on the larger of the Delta
T's from the warm and cool months the appropriate limit is:
4.36+2.64*2.10=9.90C--, ..N--
A
(mean warm months + 2.64(factor)*std dev)=Limit
Page 3

Temperature Limit Discussion
• Why conduct a delta T study?
— Reasoning behind using the 95th percentile is
flawed
— The 95th percentile has a 5% probably of being
exceeded by chance in each and every month by
chance alone
— The risk of exceeding this percentile somewhere
within the year by chance alone is far higher than
5% in fact it is near 50%
— Does not recognize the chance for multiple
opportunities for there to be a high temperature
Page 1

Daily Max Dioxin and Fish Tissue
Specific Objection 4, page 7
• Dioxin limits are impracticable, however . . .
• Mill can support daily max dioxin limit as
calculated by DWQ
• Mill can support one dioxin fish tissue
sampling event in Waterville Lake during
permit concurrent with 316a study using the
same methodology and locations as 2009
Page 1

Permit Number: NC0000272
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Draft PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission,
and the Federal Water Pollution Control Act, as amended,
Blue Ridge Paper Products Inc.dba Evergreen Packaging
is hereby authorized to discharge wastewater from a facility located at
Blue Ridge Paper Products Inc. dba Evergreen Packaging
Blue Ridge Paper Products Wastewater Treatment Plant
Off Highway 215
Canton
Haywood County
to receiving waters designated as the Pigeon River in the French Broad River Basin in accordance with
effluent limitations,monitoring requirements,and other conditions set forth in Parts I, II, III and IV
hereof.
This permit shall become effective.
This permit and authorization to discharge shall expire at midnight on
Signed this day DRAFT
Coleen H.Sullins.Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Number: NC0000272
SUPPLEMENT TO PERMIT COVER SHEET
Blue Ridge Paper Products,Inc. dba Evergreen Packaging
is hereby authorized to:
1. Continue operation of a 29.9 MGD wastewater treatment plant for the treatment of wastewater
associated with the Blue Ridge Paper Products Inc. pulp and paper mill, the Town of Canton's
chlorinated domestic wastewater and landfill leachate. The treatment system consists of the
following treatment units:
Grit Chamber
Bar Screen
• Lift Pumps
• Polymer addition
• pH control(COz injection or 1-12SO4 backup)
• Three primary clarifiers
• Nutrient Feed
• Aeration basins
Three secondary clarifiers
• Residual belt presses
• Effluent flow measurement
Cascade post aeration with oxygen injection
• Instream oxygen injection facilities
The facility is located at the Blue Ridge Paper Products WWTP, off Highway 215, Canton,
Haywood County,and;
2. Discharge treated wastewater from said treatment works at the location specified on the attached
map through outfall 001 into the Pigeon River, which is classified C water, in the French Broad
River Basin.

Permit Number: NC0000272
A. (1.)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,the Permittee
is authorized to discharge treated industrial,municipal,stormwater and landfill wastewater through
outfall(s)001. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics Effluent Limits Monitoring Requirements
Monthly Daily Measurement Sample Type Sample
Average Maximum Frequency Locationl
Flow 29.9 MGD Continuous Recording 1 or E,
BOD,5-day,200C 3205 Ib/da 10897 lb/day Daily Composite 1,Ei
Total Suspended Solids 12549 lb/day 49560 lb/day Daily Composite I,El
NH3-N Daily Composite E,
AOX2 2168 lb/day 3309 lb/day Weekly Composite El
Color 52,000lb/day 105,250 Daily Composite E,
lb/day
Dissolved Oxygen Dail Grab E,
Tem erature Daily Grab E,
THO Daily Grab E,
Conductivity Daily Grab E,
Fecal Coliform 200/ 100 mL 400/ 100 mL Weekly E,
COD Weekly EZinc Quarterl ETotal Nitrogen(NO2-N+NO3-N+TKN) Monthly Ei
Total Phosphorus Monthly E,
Chronic Toxicit uarterl Ei
Trichloro henol 30.6lb/da Quarterl E,
Pentachloro henol 4.9lb/day Quarterly Composite E,
Selenium Annual Composite El
2,3,7,8 Tetrachloro-dibenzo- 0.04 pg/L Annual Composite 1,E,
dioxin
Conductivit Daily Grab Pigeon River
Flow Daily rab Pigeon River
Fecal Coliform Weekly Grab Pigeon River
Color Variable Grab Pigeon River
Tem erature Variable Grab Pi eon River
Dissolved Ox en Variable Grab Pi eon River
Footnotes:
1. Sample Location: 1-Influent,E,—Effluent,Pigeon River-Inslream sampling as specified in A.(5.) Instream
Monitoring Special Condition.
2. AOX monitoring shall be in accordance with the Sampling Plan for Cluster Rule Parameters(dated March 19,
2001)or subsequent modifications approved by the Division. AOX data shall be submitted on a quarterly basis
along with other Effluent Guideline chemical data;refer to A.(7.) Effluent Guideline Sampling Plan Special
Condition.
3. Annual average color limit is 39,000 lb/day,which will decrease to 37,000 lb/day based on the performance of
the facility but no later than 4 years after permit effective date. See A.(8.) Color Analysis and Compliance
Special Condition,
4. The daily average effluent dissolved oxygen concentration shall not be less than 6.0 mg/L. See A.(10.)
Dissolved Oxygen Special Condition.
5. The monthly average instream temperature measured at a point 0.4 miles downstream of the discharge location
shall not exceed 320C during the months of July,August,and September and shall not exceed 29.0°C during
the months of October through June. The monthly average instream temperature measured at this location shall

Permit Number: NCOOOO272
not exceed the monthly average instream temperature of the upstream monitoring location by more than 13.9°C
[See Special Condition A.(12.)Temperature Variance Review Special Condition].
6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0(on the standard units scale).
7. Chronic Toxicity(Ceriodaphnia)at 90%Effluent Concentration: March,June,September,December(see A.
(4.)Chronic Toxicity Permit Limit(Quarterly)).
8. Trichlorophenol and-Pentachlorophenol limits and monitoring are provisionally waived since the facility has
certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include
chlorophenolic biocide,the Permittee shall notified the Division prior to use and the limits and monitoring
requirements shall become immediately effective.
9. See A.(9.) Dioxin Monitoring Special Condition.
10. See A.(5.) Instream Monitoring Special Condition.
11. Monitoring should be conducted in conjunction with Whole Effluent Toxicity Testing.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
See A.(6.) Best Management Practices(BMP)Special Condition.
See A.(11.) Town of Canton Inflow and Infiltration Special Condition.
Definitions:
MGD—Million gallons per day lb/day—Pounds per day
mL—Milliliter BOD—Biochemical Oxygen Demand
µg/L-Micrograms per liter AOX-Adsorbable Organic Halides
COD-Chemical oxygen demand pg/L-pleograms per liter

Permit Number: NC0000272
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
internal outfall(s)002 (E2),shall be limited and monitored by the Permittee as specified below and in A.
7. Effluent Guideline Sampling Plan Special Condition:
Effluent Characteristics Limits Monitoring Requirements
Monthly Daily Measurement SampleType3 Sample
Average Maximum Frequency Locations
Flow2 Weekly Calculated E2
Chloroform 5.1lb/day 8.6lb/day Quarterly Grab E2
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Annual Composite E2
dioxin(TCDD)
2,3,7,8 Tetrachloro-dibenzo- 31.9 pg/L Annual Composite E2
fi-furim(TCDF)
Trichlorosyringol < 2.5 pg/L' Quarterly Composite E2
3,4,5-Trichlorocatechol < 5.0 pg/L' Quarterly Composite E2
3,4,6-Trichlorocatechol < 5.0 pg/L Quarterly Composite E2
3,4,5-Trichloroguaiacol < 2.5 pg/L Quarterly Composite E2
3,4,6-Trichloroguaiacol < 2.5 Vg/L5 Quarterly Composite E2
4,5,6-Trichloroguaiacol < 2.5 pg/L' Quarterly Composite E2
2,4,5-Trichlorophenol < 2.5 pg/L' Quarterly Composite E2
2,4,6-Trichlorophenol < 2.5 µg/L Quarterly Composite E2
Tetrachlorocatechol < 5.0 pg/L' Quarterly Composite E2
Tetrachloroguaiacol < 5.0 µg/L5 Quarterly Composite E2
2,3,4,6-Tetrachlorophenol < 2.5 µg/L Quarterly Composite E2
Pentachlorophenol < 5.0 pg/L' I Quarterly Composite E2
Footnotes:
1. Sample Location:E2—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from CIO,bleaching stage D-100 and from tap installed on filtrate pump from C102
bleaching stage D-2)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E.). See A.(7.)Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters as prepared by the permittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently; refer to A.(7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or flow
meters,and report total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.
4. For compliance purposes,the permittee must report the total chloroform mass loading based on addition of
separate acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels(ML)specified in 40 CFR 430.01.
Definitions:
lb/day—Pounds per day pg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NC0000272
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
internal outfall(s) 003 (E3t),shall be limited and monitored by the Permittee as specified below and in A.
7. Effluent Guideline Sampling Plan Special Condition:
Effluent Characteristics Limits Monitoring Requirements
Monthly Daily Measurement Sample Type3 Sample
Average Maximum Frequency Locationt
Flo Weekly Calculated E3
Chloroform 6.5lb/day 10.9lb/day Quarterly Grab E3
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Annual Composite E3
-dioxin(TCDD)
2,3,7,8 Tetrachloro-dibenzo- 31.9 pg/L Annual Composite E3
-furan(TCDF)
Trichlorosyringol < 2.5 µg/L5 Quarterly Composite E3
3,4,5-Trichlorocatechol < 5.0 pg/L' Quarterly Composite E3
3,4,6-Trichlorocatechol < 5.0 µg/LS Quarterly Composite E3
3,4,5-Trichloroguaiacol < 2.5 µg/L5 Quarterly Composite E3
3,4,6-Trichloroguaiacol < 2.5 µg/L Quarterly Composite E3
4,5,6-Trichloroguaiacol < 2.5 µg/L Quarterly Composite E3
2,4,5-Trichlorophenol < 2.5 µg/L Quarterly Composite E3
2,4,6-Trichlorophenol < 2.5 µg/L Quarterly .Composite E3
Tetrachlorocatechol < 5.0 µg/LS Quarterly Composite E3
Tetrachloroguaiaeol < 5.0 pg/L' Quarterly Composite E3
2,3,4,6-Tetrachlorophenol < 2.5 µg/L5 Quarterly Composite E3
Pentachlorophenol < 5.0 pg/L' I Quarterly Composite E3
Footnotes:
I. Sample Location:E3—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from CIO,bleaching stage D-100)and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage E.).See A.(7.)Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters,as prepared by the permittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or by flow
meter,and report total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.
4. For compliance purposes,the permittee must report the total chloroform mass loading based on addition of
separate acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels(ML)specified in 40 CFR 430.01.
Definitions:
lb/day—Pounds per day pg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NC0000272
A.(4.) CHRONIC TOXICITY PERMIT LIMIT(QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubla at an effluent concentration of 90%.
The permit holder shall perform at a minimum,quarterly monitoring using test procedures outlined in the"North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised February 1998,or subsequent versions or
"North Carolina Phase 11 Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent
versions.The tests will be performed during the months ojMarch,June,September,December.Effluent sampling
for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit,then multiple-concentration testing shall be performed at a minimum, in each of the two following months as
described in"North Carolina Phase 11 Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival.The definition of"detectable impairment,"collection
methods,exposure regimes,and further statistical methods are specified in the"North Carolina Phase 11 Chronic
Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form(MR-1)for the months in which tests were performed,using the parameter code TGP313 for the
pass/fail results and THP3B for the Chronic Value.Additionally,DWQ Form AT-3 (original)is to be sent to the
following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete,accurate,include all supporting chemical/physical measurements and all
concentration/response data,and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,the
permittee will complete the information located at the top of the aquatic toxicity(AT)test form indicating the
facility name,permit number,pipe number,county,and the month/year of the report with the notation of"No Flow"
in the comment area of the form.The report shall be submitted to the Environmental Sciences Branch at the address
cited above.Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Should any test data from this monitoring requirement or
tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream,
this permit may be re-opened and modified to include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently then required by this permit,the results of such monitoring
shall be included in the calculation&reporting of the data submitted on the DMR&all AT Forms submitted.
NOTE: Failure to achieve test conditions as specified in the cited document,such as minimum control organism
survival,minimum control organism reproduction,and appropriate environmental controls,shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Permit Number: NC0000272
A. (5.) INSTREAM MONITORING SPECIAL CONDITION
Stream Mile Location Description Parameter Frequency
Designation Marker
UP 63.8 Pigeon River upstream of the Temperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the Conductivity Daily
discharge) Color 2/Week
Flow, Daily
Fecal Coliform Weekly
DN V 62.9 Pigeon River at Fiberville Bridge Temperature Daily
D.O. Daily
Conductivity Daily
Color' 2/Week
DN2 57.7 Pigeon River Above Clyde Temperature Daily
D.O. Daily
DN3 55.5 Pigeon River Below Clyde See Footnote 3 See Footnote 3
DN4 3 53.5 Pigeon River at NCSR 1625 See Footnote 3 See Footnote 3
bridge
DN5 42.6 Pigeon River at Hepco Temperature Weekly
D.O. Weekly
Color' Weekly
Flow, Daily
DN6 26.0 Pigeon River prior to mixing with Color Weekly
Big Creek
BC —26.0 Mouth of Big Creek prior to Color Weekly
mixing with the Pigeon River
DN7 24.7 Pigeon River at Browns Bridge Temperature Weekly
(—NC/fN State Line) D.O. Weekly
Color Weekly
All instream samples shall be grab samples.
Footnotes:
I. Color(See A. (8.) Color Analysis and Compliance Special Condition) All instream samples collected
shall be representative of the Pigeon River and Big Creek, respectively. Both true and apparent color
shall be monitored using the methods specified in A. (8.)Color Analysis and Compliance Special
Condition. Samples shall be collected at stations DN6,BC, and DN7 only when at least one generator
at CP&L is in operation and releasing water to the Pigeon River. Samples collected at DN1 shall be
collected from the middle or midpoint of the transect of the Pigeon River.
2. Flow monitoring is necessary, as specified above, for the True Color calculation stipulated in A. (8.)
Color Analysis and Compliance Special Condition.
3. Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9
(DNI),and 57.7(DN2),shall not be less than 5.0 mg/L and the instantaneous minimum dissolved
oxygen concentration shall not be less than 4.0 mg/L(See A. (10.) Dissolved Oxygen Special
Condition). If the dissolved oxygen drops below 5.0 mg/L at station 57.7 then monitoring shall be
required at stations 55.5 (DN3) and 53.5 (DN4).

Permit Number: NC0000272
A. (6.) BEST MANAGEMENT PRACTICES(BMP)SPECIAL CONDITION
The permittee must implement the BMPs specified below. The primary BMP objective is to prevent
leaks and spills of spent pulping liquors,soap, and turpentine. A secondary objective is to contain,
collect, and recover at the immediate process area,or otherwise control,those leaks, spills, and intentional
diversions of spent pulping liquor,soap,and turpentine that do occur. BMPs must be developed
according to best engineering practices and must be implemented in a manner that takes into account the
specific circumstances at the mill.
Section A. BMP Implementation Requirements
1. The permittee must return spilled or diverted spent pulping liquors, soap, and turpentine to the
process to the maximum extent practicable as determined by the mill,recover such materials outside
the process,or discharge spilled or diverted material at a rate that does not disrupt the receiving
wastewater treatment system.
2. The permittee must maintain a program to identify and repair leaking equipment items. This program
must include: (i) Regular daily visual inspections of process area with equipment items in spent
pulping liquor, soap,and turpentine service; (ii) Immediate repair of leaking equipment items,when
possible. Leaking equipment items that cannot be repaired during normal operations must be
identified,temporary means for mitigating the leaks must be provided, and the leaking equipment
items repaired during the next maintenance outage; (iii) Identification of conditions under which
production will be curtailed or halted to repair leaking equipment items or to prevent pulping liquor,
soap, and turpentine leaks and spills; and(iv)A means for tracking repairs over time to identify those
equipment items where upgrade or replacement may be warranted based on frequency and severity of
leaks, spills,or failures.
3. The permittee must operate continuous, automatic monitoring systems that the mill determines are
necessary to detect and control leaks,spills, and intentional diversions of spent pulping liquor,soap,
and turpentine.These monitoring systems should be integrated with the mill process control system
and may include,e.g.,high level monitors and alarms on storage tanks; process area conductivity(or
pH) monitors and alarms;and process area sewer,process wastewater, and wastewater treatment plant
conductivity(or pH)monitors and alarms.
4. The permittee must maintain a program of initial and refresher training of operators, maintenance
personnel, and other technical and supervisory personnel who have responsibility for operating,
maintaining,or supervising the operation and maintenance of equipment items in spent pulping
liquor,soap, and turpentine service.The refresher training must be conducted at least annually and
the training program must be documented.
5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor,soap,or
turpentine that is not contained at the immediate process area and any intentional diversion of spent
pulping liquor,soap,or turpentine that is not contained at the immediate process area.The report
must describe the equipment items involved,the circumstances leading to the incident,the
effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion,
and plans to develop changes to equipment and operating and maintenance practices as necessary to
prevent recurrence. Discussion of the reports must be included as part of the annual refresher training.
6. The permittee must maintain a program to review any planned modifications to the pulping and
chemical recovery facilities and any construction activities in the pulping and chemical recovery areas
before these activities commence. The purpose of such review is to prevent leaks and spills of spent
pulping liquor, soap, and turpentine during the planned modifications, and to ensure that construction
and supervisory personnel are aware of possible liquor diversions and of the requirement to prevent
leaks and spills of spent pulping liquors,soap, and turpentine during construction.
7. The permittee must install and maintain secondary containment(i.e.,containment constructed of
materials impervious to pulping liquors) for spent pulping liquor bulk storage tanks equivalent to the
volume of the largest tank plus sufficient freeboard for precipitation.An annual tank integrity testing
program, if coupled with other containment or diversion structures, may be substituted for secondary
containment for spent pulping liquor bulk storage tanks.

Permit Number: NC0000272
8. The permittee must install and maintain secondary containment for turpentine bulk storage tanks.
9. The permittee must install and maintain curbing,diking or other means of isolating soap and
turpentine processing and loading areas from the wastewater treatment facilities.
10. The permittee must conduct wastewater monitoring to detect leaks and spills,to track the
effectiveness of the BMPs,and to detect trends in spent pulping liquor losses. Such monitoring must
be performed in accordance with Section E.
Section B. BMP Plan Requirements
1. The permittee must maintain and implement a BMP Plan. The BMP Plan must be based on a detailed
engineering review as described in this section. The BMP Plan must specify the procedures and the
practices required for the mill to meet the requirements of Section A,the construction the mill
determines is necessary to meet those requirements including a schedule for such construction, and
the monitoring program(including the statistically derived action levels)that will be used to meet the
requirements of Section E.The BMP Plan also must specify the period of time that the mill
determines the action levels established under Section D may be exceeded without triggering the
responses specified in Section E.
2. The permittee must conduct a detailed engineering review of the pulping and chemical recovery
operations--including but not limited to process equipment,storage tanks, pipelines and pumping
systems, loading and unloading facilities, and other appurtenant pulping and chemical recovery
equipment items in spent pulping liquor,soap, and turpentine service--for the purpose of determining
the magnitude and routing of potential leaks, spills,and intentional diversions of spent pulping
liquors,soap, and turpentine during the following periods of operation: (i) Process start-ups and shut
downs;(ii)Maintenance; (iii)Production grade changes; (iv)Storm or other weather events; (v)
Power failures; and(vi)Normal operations.
3. As part of the engineering review,the permittee must determine whether existing spent pulping liquor
containment facilities are of adequate capacity for collection and storage of anticipated intentional
liquor diversions with sufficient contingency for collection and containment of spills.The engineering
review must also consider: (i)The need for continuous,automatic monitoring systems to detect and
control leaks and spills of spent pulping liquor,soap,and turpentine;(ii)The need for process
wastewater diversion facilities to protect end-of-pipe wastewater treatment facilities from adverse
effects of spills and diversions of spent pulping liquors,soap, and turpentine; (iii)The potential for
contamination of storm water from the immediate process areas;and(iv)The extent to which
segregation and/or collection and treatment of contaminated storm water from the immediate process
areas is appropriate.
4. The permittee must amend its BMP Plan whenever there is a change in mill design, construction,
operation, or maintenance that materially affects the potential for leaks or spills of spent pulping
liquor,turpentine, or soap from the immediate process areas.
5. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP
Plan is prepared and,except as provided in Section BA., once every five years thereafter. As a result
of this review and evaluation, the permittee must amend the BMP Plan within three months of the
review if the mill determines that any new or modified management practices and engineered controls
are necessary to reduce significantly the likelihood of spent pulping liquor,soap,and turpentine leaks,
spills,or intentional diversions from the immediate process areas, including a schedule for
implementation of such practices and controls.
6. The BMP Plan, and any amendments thereto, must be reviewed by the senior technical manager at the
mill and approved and signed by the mill manager.Any person signing the BMP Plan or its
amendments must certify to the Division under penalty of law that the BMP Plan(or its amendments)
has been prepared in accordance with good engineering practices and in accordance with this
regulation.The permittee is not required to obtain approval from the Division of the BMP Plan or any
amendments thereto.
Section C. BMP Recordkeeoina Requirements

Permit Number: NC0000272
1. The permittee must maintain on its premises a complete copy of the current BMP Plan and the
records specified in Section C.2 and must make such BMP Plan and records available to the Division
for review upon request.
2. The permittee must maintain the following records for three years from the date they are created: (i)
Records tracking the repairs performed in accordance with the repair program described in Section A;
(ii) Records of initial and refresher training conducted in accordance with Section A; (iii)Reports
prepared in accordance with Section A; and(iv)Records of monitoring required by Sections A and E.
Section D. Establishment of Wastewater Treatment System Influent Action Levels
1. The permittee must conduct a monitoring program per Section D.2, for the purpose of defining
wastewater treatment system influent characteristics(or action levels),described in Section D.3,that
will trigger requirements to initiate investigations on BMP effectiveness and to take corrective action.
2. The permittee must employ the following procedures in order to develop the action levels'required by
Section D:
• Monitoring parameters.The permittee must collect 24-hour composite samples and analyze the
samples for a measure of organic content(e.g., Chemical Oxygen Demand(COD)or Total
Organic Carbon(TOC)). Alternatively,the mill may use a measure related to spent pulping liquor
losses measured continuously and averaged over 24 hours(e.g., specific conductivity or color).
• Monitoring locations.The permittee must conduct monitoring at the point influent enters the
wastewater treatment system. For the purposes of this requirement,the permittee may select
alternate monitoring point(s) in order to isolate possible sources of spent pulping liquor,soap, or
turpentine from other possible sources of organic wastewaters that are tributary to the wastewater
treatment facilities(e.g., bleach plants, paper machines and secondary fiber operations).
3. By the permit effective date the permittee must complete an initial six-month monitoring program
using the procedures specified in Section D and must establish initial action levels based on the
results of that program. A wastewater treatment influent action level is a statistically determined
pollutant loading determined by a statistical analysis of six months of daily measurements.The action
levels must consist of a lower action level,which if exceeded will trigger the investigation
requirements described in Section E,and an upper action level,which if exceeded will trigger the
corrective action requirements described in Section E.
4. Six month after the permit effective date,the permittee must complete a second six-month monitoring
program using the procedures specified in Section D and must establish revised action levels based on
the results of that program.The initial action levels shall remain in effect until replaced by revised
action levels.
5. Action levels developed under this Section must be revised using six months of monitoring data after
any change in mill design, construction, operation, or maintenance that materially affects the potential
for leaks or spills of spent pulping liquor,soap, or turpentine from the immediate process areas.
Section E. BMP Monitoring, Corrective Action,and Reporting Requirements
1. The permittee must conduct daily monitoring of the influent to the wastewater treatment system in
accordance with the procedures described in Section D for the purpose of detecting leaks and spills,
tracking the effectiveness of the BMPs, and detecting trends in spent pulping liquor losses.
2. Whenever monitoring results exceed the lower action level for the period of time specified in the
BMP Plan,the permittee must conduct an investigation to determine the cause of such exceedance.
Whenever monitoring results exceed the upper action level for the period of time specified in the
BMP Plan,the permittee must complete corrective action to bring the wastewater treatment system
influent mass loading below the lower action level as soon as practicable.
3. Although exceedances of the action levels will not constitute violations of an NPDES permit, failure
to take the actions required by Section E.2 as soon as practicable will be a permit violation.

"IN
Permit Number: NC0000272
4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to
Section E.1.Such reports must include a summary of the monitoring results,the number and dates of
exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to
respond to such exceedances. Submission of such reports shall be annually, by March 31"of the
following year.
Section F. BMP Definitions
I. Action Level:A daily pollutant loading that when exceeded triggers investigative or corrective action.
Mills determine action levels by a statistical analysis of six months of daily measurements collected at
the mill. For example,the lower action level may be the 75th percentile of the running seven-day
averages(that value exceeded by 25 percent of the running seven-day averages) and the upper action
level may be the 90th percentile of the running seven-day averages(that value exceeded by 10
percent of the running seven-day averages).
2. Division: North Carolina DENR,Division of Water Quality, 1617 Mail Service Center, Raleigh,
North Carolina 27699-1617.
3. Equipment Items in Spent Pulping Liquor, Soap,and Turpentine Service:Any process vessel,storage
tank,pumping system,evaporator,heat exchanger, recovery furnace or boiler, pipeline, valve, fitting,
or other device that contains, processes,transports,or comes into contact with spent pulping liquor,
soap, or turpentine. Sometimes referred to as "equipment items."
4. Immediate Process Area:The location at the mill where pulping,screening, knotting, pulp washing,
pulping liquor concentration,pulping liquor processing, and chemical recovery facilities are located,
generally the battery limits of the aforementioned processes. "Immediate process area" includes spent
pulping liquor storage and spill control tanks located at the mill,whether or not they are located in the
immediate process area.
5. Intentional Diversion:The planned removal of spent pulping liquor, soap, or turpentine from
equipment items in spent pulping liquor,soap, or turpentine service by the mill for any purpose
including, but not limited to, maintenance, grade changes, or process shutdowns.
6. Mill:The owner or operator of a direct or indirect discharging pulp, paper, or paperboard
manufacturing facility subject to this section.
7. Senior Technical Manager:The person designated by the mill manager to review the BMP Plan.The
senior technical manager shall be the chief engineer at the mill,the manager of pulping and chemical
recovery operations, or other such responsible person designated by the mill manager who has
knowledge of and responsibility for pulping and chemical recovery operations.
8. Soap: The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the
wood,which precipitate out when water is evaporated from the spent pulping liquor.
9. Spent Pulping Liquor: For kraft and soda mills"spent pulping liquor"means black liquor that is used,
generated,stored, or processed at any point in the pulping and chemical recovery processes.
10. Turpentine:A mixture of terpenes,principally pinene, obtained by the steam distillation of pine gum
recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft
pulping process. Sometimes referred to as sulfate turpentine.

Permit Number: NC0000272
A. (7.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION
The bleach plant effluent samples(Outfalls 002 and 003)shall be analyzed for 2,3,7,8-TCDD in
accordance with EPA Method 1613. A single sample, from each of the bleach plant effluents,may be
analyzed to determine compliance with the daily maximum effluent limitation.
The bleach plant effluent samples(Outfall 002 and 003)shall be analyzed for the 12 chlorinated phenolic
compounds in accordance with EPA Method 1653. A single sample, from each of the bleach plant
effluents, may be analyzed to determine compliance with the daily maximum effluent limitation. The
Minimum Levels for each of the 12 chlorinated compounds are the same as the Daily Maximum
concentrations listed on the effluent pages for the respective outfall(s).
The final wastewater treatment.plant effluent sample(Outfall 001)shall be analyzed for AOX in
accordance with EPA Method 1650, or subsequent test methods approved by the Division.
The permittee may request future monitoring modifications to the Effluent Guideline requirements,
including 1)use of ECF certification in lieu of monitoring for chloroform in the bleach plant effluents
(Outfall(s) 002 and 003)2)demonstrating compliance using samples collected less frequently than every
four hours; 3)using automated composite volatile samplers for chloroform sampling; and 4)using
automated composite samplers for chlorophenolic,2,3,7,8 TCDD and 2,3,7,8 TCDF sampling. Such
future requests will be evaluated in accordance with 15A NCAC 2H.0114.
The flow calculations for internal Outfall(s) 002 and 003 shall not be subject to accuracy requirements
specified under Part 11, Section D.3. This exclusion is similar to that provided for pump log flow
calculations.
Chemical data for Effluent Guideline parameters(Outfall(s)002 and 003 parameters+AOX from Outfall
001)shall be submitted to the Division on a quarterly basis or more frequently(January-March,April-
June,July-September, October-December). Quarterly submissions shall be due 60 days following the
last day of each quarter(Due dates=May 31,August 31,November 30,and February 28). Chemical data
shall be submitted on Division-approved DMR forms,with a separate form provided for each month.

Permit Number: NCOOOO272
A. (8.) REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE SPECIAL CONDITION
I. The color reduction requirements contained in this special condition have been derived directly
from the mill's efforts to identify possible reduction measures and from the EPA Technology
Review Workgroup(TRW report dated February 25,2008)
2. The average annual discharge of true color for each calendar year shall not exceed 39,000 pounds
per day. The monthly average effluent true color loading shall not exceed 52,000 pounds per day.
For the purpose of this permit only, "pounds of true color" is calculated by the following
equation:
Effluent Flow(MGD)x Effluent True Color Level(Platinum Cobalt Units)x 8.34.
3. All samples collected for color analysis and for use in the above calculation shall be measured
and reported using the procedure referenced in 39 FR 430.11 (b)(May 29, 1974)-true and
apparent color or as amended by the EPA.
4. Four years after the permit effective date,the average annual discharge of true color for each
calendar year shall not exceed 37,000 pounds per day
5. The permittee shall not increase the mill's pulp production capacity during the term of this permit,
unless the permittee can demonstrate that the increased production can be achieved while
reducing color loading. In addition, increasing the mill's pulp production capacity may require
permit revision in accordance with North Carolina's NPDES Permitting rules.
6. The NPDES Permit shall be subject to reopening in order to modify the color requirements based
upon the following the required triennial reviews:
• Any breakthrough in color removal technologies. Such breakthroughs shall be brought to
the NPDES Committee for consideration,by Blue Ridge Paper and the Division of Water
Quality, as soon as they are discovered.
• An acceptable statistical analysis of effluent color discharge data demonstrating
significantly better color removal performance than that currently prescribed in the
permit, except as noted herein.
• Successful application of end-of-pipe color reduction technology or in-mill color
minimization effort that results in significant and measurable reduced mass color
discharge.
7. The transfer of this NPDES permit will not proceed until any successor-in-interest to the current
permittee has agreed to accept the provisions of this permit.
8. The facility will provide annual progress reports to the Division on the color reduction efforts.
9. 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.
10. Based on the EPA TRW recommendations,the permittee shall evaluate the technologies
identified below and develop an implementation plan that would either utilize these technologies
when technically,operationally,or economically feasible,or identify other options that will result

Permit Number: NC0000272
in similar increments of color reduction. The TRW may review and comment on the justification
for any item among the following recommendations found by Blue Ridge Paper to be technically,
operationally, or economically infeasible:
A. The following suite of items will be implemented by the permittee, upon further expedited
evaluation if necessary to refine detailed design and operating parameters, during this permit
term:
• further improvements in leak and spill prevention and control (BMP's)covering all
process lines, including probable color-generating sources(e.g.,sulfide containing)
among white and green liquors in the recovery cycle
• process optimization(enhanced extraction stages, reduced bleaching chemical use, etc.);
and
• addition of second stage oxygen delignification on the softwood/pine fiber line
The time necessary for Blue Ridge Paper to implement these items or alternatives in logical
sequence should realistically reflect the Mill's ability to design,fund,and install or implement
them at the earliest possible date. For example, an updated and detailed evaluation of the addition
of second stage oxygen delignification on the softwood fiber line should identify necessary
adjustments to upstream pulp digestion(e.g.,kappa number targets),bleaching(e.g.,bleaching
chemical usage rates,kappa factors)and downstream brightness/strength and other relevant
process control and product quality parameters, designing and costing, and refining color
reduction projections.
B. The following items will be evaluated and implemented as appropriate during this permit
term:
• increasing filtrate recycle and use of the existing BFR process for the hardwood fiber line
• reducing black liquor carryover by further evaluating in detail and adjusting operating
conditions in the direct contact evaporators(DCEs)
• reducing impact of Chloride Removal Process(CRP)purge on treated effluent color by
gathering data sets over as long a period as possible,preferably at full scale,with and
without the CRP purge to better understand the impact on treatability of this source of
color. If it is determined that CRP color is found not to be removed in the treatment
system, further study should assess:
o securing whatever additional reductions are possible based on any
demonstrated technology that works and can be economically applied to this
waste stream,either within the mill and sewer system, or chlorine dioxide
pretreatment to reduce color in the CRP purge stream prior to introduction to
the treatment system
o avoiding release of the CRP purge during periods of low flow in the receiving
stream
• better understanding and controlling, if possible,the physical and chemical mechanisms
underlying"sewer generated color". This will require a sustained effort going forward
beyond this permit term given that process changes and BMP improvements to be made
will more than likely further change the chemistry and mechanisms underlying"sewer
generated color".
• improving color removal by the Mill's wastewater treatment plant via:
o better equalizing and further optimizing treatment by using polymers and other
chemicals to pretreat highly-colored segregated wastewaters including streams
that are diverted to the extra primary clarifier,or by other operational and/or
treatment means not yet identified

Permit Number: NC0000272
o investigating use of polymers or other chemicals upstream of the secondary
clarifiers,especially during periods of high influent color and/or low river flow
A. (9.) DIOXIN MONITORING SPECIAL CONDITION
The permittee shall perform the analyses for dioxin and dibenzofuran as outlined below:
Sampling Point Monitoring
Re uirements
Measurement Sample Type
Fre uenc
Influent to Wastewater Annual Composite
Treatment Plant
Effluent Annual Composite
Sludge Annual Composite
Landfill Leachate Annual Composite
Footnotes:
1. The samples shall be analyzed for 2,3,7,8-TCDD and 2,3,7,8 TCDF in accordance with EPA Method
1613. A single sample may be analyzed. Alternatively,the sample volumes may be collected to
enable the sample to be split(duplicate analysis).The Minimum Level in the effluent for 2,3,7,8-
TCDD and 2,3,7,8 TCDF by EPA Method 1613 is 10 pg/l.
2. The effluent samples shall be analyzed for the full range of dioxin and furan isomers as identified in
the list below and shall be in accordance with EPA Method 1613. A single sample may be analyzed.
Alternatively, the sample volumes may be collected to enable the sample to be split(duplicate
analysis).The minimum level using these methods for the purpose of compliance evaluation is
considered to be 10 picograms per liter
DIOXIN DIBENZOFURAN
Isomer Isomer
2,3,7,8 TCDD 2,3,7,8 TCDF
1,2,3,7,8 PeCDD 1,2,3,7,8 PeCDF
2,3,4,7,8 PeCDF
1,2,3,4,7,8 HxCDD 1,2,3,4,7,8 HxCDF
1,2,3,7,8,9 HxCDD 1,2,3,7,8,9 HxCDF
1,2,3,6,7,8 HxCDF
1,2,3,6,7,8 HxCDD 2,3,4,6,7,8 HxCDF
1,2,3,4,6,7,8 HpCDD 1,2,3,4,6,7,8 HpCDF
1,2,3,4,7,8,9 HpCDF
If dioxins or dibenzofurans are detected in the effluent above the minimum level,the permittee shall
initiate Quarterly monitoring of sludge, landfill leachate, and effluent.
Additional Requirements
Annual dioxin fish tissue analysis shall be performed through 2009 in accordance with the Division of
Water Quality approved monitoring plan,which will be reviewed as necessary. The permit requirement
will drop from the permit after 2009 unless fish tissue analysis indicates a public health hazard exists.The
monitoring plan is an enforceable part of this permit. All dioxin data collected as part of this monitoring
requirement will be reported as required in the plan, no later than 180 days after sampling.

Permit Number: NC0000272
A. (10.) DISSOLVED OXYGEN SPECIAL CONDITION
The permittee shall maintain an average daily dissolved oxygen concentration of not less than 5.0 mg/L
with a minimum instantaneous value of not less than 4.0 mg/L at River Miles 62.9(DNI)and 57.7
(DN2). The permittee shall operate oxygen injection facilities at the outfall structure, at 0.9 miles
downstream of the discharge,and at 2.1 miles downstream of the discharge, as necessary,to comply with
this requirement. These facilities shall be operated in a manner which will maintain the water quality
standard for dissolved oxygen in the Pigeon River downstream of the discharge. Blue Ridge Paper shall
report the date and duration of oxygen injection use as a supplement to the monthly Discharge Monitoring
Report(DMR)forms. If the dissolved oxygen drops below 5.0 mg/L at station DN2 then monitoring shall
be required at stations DN3 and DN4.
A. (11.) TOWN OF CANTON INFLOW AND INFILTRATION SPECIAL CONDITION
The permittee shall make continued efforts to promote reduction of inflow/infiltration to the Town of
Canton's wastewater collection system.
A. (12.) TEMPERATURE VARIANCE REVIEW SPECIAL CONDITION
Blue Ridge Paper shall complete an analysis of temperature and shall submit a balanced and indigenous
species study,no later than 180 days prior to the permit expiration date. As part of this analysis,Blue
Ridge Paper shall submit a complete temperature variance report documenting the need for a continued
temperature variance.
The study shall be performed in accordance with the Division of Water Quality approved plan.The
temperature analysis and the balanced and indigenous study plan shall conform to the specifications
outlined in 40 CFR 125 Subpart H and the EPA's Draft 316a Guidance Manual,dated 1977.The EPA
shall be provided an opportunity to review the plan prior to the commencement of the study.

N.C. Department of Environment and Natural Resources dWArt,O
Division of Water Quality y
Fact Sheet For NPDES Permit NC0000272
Facility Information
Applicant/Facility Name: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Applicant Address: P.O. Box 4000
Facility Address: 175 Main Street, Canton NC
Permitted Flow: 29.9 MGD
Type of Waste: Industrial,domestic, stormwater, and landfill leachate
Facility/Permit Status: Renewal
County: Haywood
Miscellaneous
Receiving Stream: Pigeon River
Stream Classification: C
303(d) Listed?: Yes. Biological impairment.
Subbasin: 04-03-05
Drainage Area(mi2): [calculated] 130 mi'
Summer 7Q 10(cfs): 52 cfs at Canton and 120 cfs at Hepco
Winter 7Q10(cfs): 63 cfs at Canton and 183 cfs at Hepco
30Q2 89.9 cfs at Canton
Average Flow(cfs): 325 cfs at Canton and 677 cfs at Hepco .
IWC(%): 100%(See Text Below)
Primary SIC Code: 2621
Regional Office: Asheville
USGS Topo Quad: Canton(E 7 SE—State Grid)
Permit Writer: Sergei Chernikov
Date: February 2, 2009
SUMMARY
Blue Ridge Paper Products Inc.has requested renewal of their National Pollutant Discharge Elimination
System(NPDES)discharge permit NC0000272 allowing discharge of industrial,stormwater, municipal
and landfill leachate wastewaters to waters of the state.This fact sheet summarizes the rationale used to
develop the limits and monitoring conditions for the draft permit.North Carolina Division of Water
Quality(Division)also recommends renewal of the temperature variance and deletion of the color
variance.
BACKGROUND
The facility was established in 1908 to produce pulp for the Champion paper mill in Hamilton, Ohio.
Blue Ridge paper acquired ownership of the mill in May of 1999 from Champion International. In 2007,
the facility was purchased by the Rank Group and now operates as a subsidiary of Evergreen Packaging.
The company currently employs about 1,500 people in North Carolina.
Blue Ridge Paper is an integrated,elemental chlorine free(ECF)bleached kraft pulp and paper mill with
oxygen deligninifeation, and bleach filtrate recycle in Canton,North Carolina.Processes at the mill
include a pine bleach line; hardwood bleach line,paperboard and fine paper production lines. Pine and
Fact Sheet
NPIA"',Renew d
Page 1

hardwood chips are transported to the site via rail or truck and subsequently processed into pulp for paper
or paperboard production.
In 1990, Champion International Corporation initiated a$300 million dollar modernization project
termed the Canton Modernization Project(CMP). This project eliminated the use of elemental chlorine
and implemented significant changes to both the pine and hardwood bleaching lines.
The mill upgrade included two changes that significantly improved the mill's environmental
performance. The first major change was the use of oxygen delignification. This process is used to
separate the lignin from the fiber. This resulted in significant improvement in the mills environmental
performance. The second major change was the implementation of full-scale bleach filtrate recycle
(BFR)on the pine bleach line and caustic extraction stage(E.) filtrate recycle(-20%) on the hardwood
bleach line. For a more detailed description of the mill improvements, refer to the Canton Modernization
Project Section.
The Canton Modernization Project greatly reduced the wastewater generated and eventually discharged
to the Pigeon River. Even with these improvements,significant quantities of wastewater are generated in
the production of pulp and paper and proper treatment prior to discharge is required.
Wastewater generated by the Canton Mill, along with the Town of Canton's domestic wastewater, is
treated at Blue Ridge Paper's Wastewater Treatment Plant. The treatment plant is a 29.9 MGD
wastewater treatment system consisting of the following unit processes:
• Grit Chamber
• Bar screens
• Lift pumps
• Polymer addition
• pH control (CO2 injection or H2SO4 backup)
• Three primary clarifiers(one normally off-line)
• Nutrient feed
• Aeration basins
• Three secondary clarifiers
• Residual belt presses
• Effluent flow measurement
• Cascade aeration(with oxygen injection)
• Oxygen injection facilities
Solids at this facility are deposited into a dedicated landfill.A portion of the energy at the facility is
generated by burning coal. Coal ash is landfilled into a double-lined landfill,which is equipped with
leachate collection. Leachate is treated at the wastewater treatment system.
The history of this mill has been controversial. Under Champion Paper,the environmental impacts of the
Canton Mill were noted by concerned citizens,environmental groups,the State of Tennessee, State of
North Carolina,and the United States Environmental Protection Agency(EPA). The issues raised by
these individuals and groups contributed to the Canton Mill's improved environmental performance and
resulted in a settlement agreement issued January 8, 1998.All the conditions in the settlement agreement
have been met.
This permit has centered around four main issues associated with the mill's discharge: color,
temperature, oxygen consuming waste and dioxin, and a brief synopsis follows.
Color
On July 13, 1988, Champion Paper was granted a variance from North Carolina's narrative water quality
standard for color,which the EPA interpreted to be 50 color units. The EPA subsequently issued a
NPDES permit to Champion Paper facility.
In 1994, the EPA returned NPDES permitting authority for the Canton Mill back to North Carolina's
Division of Water Quality. During the permit renewal the original color variance was modified, and both
the permit and the variance were issued in December 1996. As outlined above,over the course of this
variance the mill has initiated significant color improvements,which have markedly reduced the color
loading and other effluent characteristics.
Fact Sheet
NPDES Renewal
Pane 2

Though the mill has made significant strides, color continues to be the major issue surrounding this
permit renewal. EPA chaired Technology Review Workgroup(TRW)has recommended additional color
reduction for this permit renewal. The recommendations issued by the Technology Review Workgroup
were based on the findings of a third party evaluation of Blue Ridge Paper's Canton mill and a report
issued by the EPA Tech Team. The evaluation conducted by Dr.Norm Liebergott in 2001 was co-
sponsored by Blue Ridge Paper and several environmental groups and provided valuable information for
the TRW. The latest report of Dr. Liebergott was issued on July 7, 2006 and sponsored by Blue Ridge
Paper. In addition to identifying areas for improvement and available technologies, Dr. Liebergott
compared the Canton mill to 76 similar mills around the world. Dr.Liebergott concluded that the Canton
mill's environmental performance is among the best in the world. The latest TRW recommendations
were issued on February 25, 2008 and are incorporated into this permit renewal. Color limits for the
permit are developed in accordance with the TRW recommendations.
Temperature
The facility first requested and received a 316(a)variance(approved by EPA) for temperature on August
6, 1985. This determination demonstrated that the effluent limitations relating to the thermal component
of the Champion discharge were more stringent than necessary to assure protection and propagation of a
balanced indigenous population of shellfish, fish,and wildlife in the Pigeon River. Therefore,the 316(a)
temperature variance was approved based on protection of the appropriate use classification of the
Pigeon River. The temperature variance was reviewed and renewed as part of the Triennial Review in
1997.
Blue Ridge Paper submitted a Balanced and Indigenous Species Study on the Pigeon River in May of
2006. The study was conducted by the University of Tennessee. DW Q scientists have reviewed the
report and concluded that continuance of the temperature variance is appropriate. Therefore,the
Division of Water Quality is recommending continuation of the temperature variance with reporting
requirements consistent with the previous permits.
Oxygen Consuming Waste
An EPA approved model predicted that even with a BOD5 loading of 1209 lb/day(5.0 mg/L at 29 MGD)
that the dissolved oxygen in the Pigeon River would not be protected. Since Blue Ridge Paper cannot
comply with such stringent effluent limitations, an instream oxygen augmentation method was
implemented to protect the dissolved oxygen in the receiving stream. For further discussion on this
subject refer to the Oxygen Consuming Waste Pollutants section.
Dioxins
Elevated levels of dioxins were found in fish tissue in the Pigeon River(around the late 1980s).
Subsequently, a fish consumption advisory was issued for sport fish, catfish,and carp.The Canton Mill
has not discharged any detectable levels of 2,3,7,8 TCDD to the Pigeon River(since 1989) and dioxin in
fish tissue continues to decline.
Most fish consumption advisories in North Carolina and Tennessee were removed in 1998 and 2002.The
last fish advisory for Common Carp in Waterville Lake was removed on January 7, 2007. There are no
fish advisories in the Pigeon River at this time.
INSTREAM MONITORING
The current permit requires Blue Ridge Paper to conduct an extensive instream monitoring program
consisting of 9 monitoring sites (I-upstreamof mill in Pigeon River, and 7-downstream of mill in Pigeon
River and 1-Big Creek; See Figure 1 and Table 1).
Fact Sheet
NPDFS Renewal
Page 3

Figure 1. Instream Monitoring Stations for Blue Ridge Paper Products—Canton Mill.
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•.•` J ` � ��� '.% /'/�tf�9a0m b.5-Lb4..mef�eW.B•Pm
USGS Sites
Primary Highways
Pigeon River Hydrography
NPDES Discharger
® Municipal boundaries
Instream Monitoring by Parameter
Blue Ridge Paper is required to monitor conductivity upstream(at station UP) and downstream(at
station DNI). The Division's recommends that conductivity monitoring continue as required by 15A
NCAC 2B .0508(d).
Blue Ridge Paper monitors temperature upstream at station UP and downstream at all monitoring
stations except station DN6 and station BC. Review of the data from 01/01/2004 through 12/31/2008
indicated that the monthly average temperature of the Pigeon River did not exceed the permitted limits of
32 °C(summer)or 29°C(winter).
Blue Ridge Paper monitors dissolved oxygen(DO)at all the instream stations except station DN6 and
station BC. Over the period of review(0 1/0 1/2004-12/31/2008), daily average dissolved oxygen
concentration did not drop below the North Carolina's standard of 5.0 mg/L for Class C streams at any of
the instream monitoring locations. The lowest oxygen concentrations occurred at the DN2 monitoring
stations.
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uPDGS hcnewal
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Table 1. Instream Monitoring Requirements According to the 1997 NPDES Permit and Color Variance.
Stream Mile Location Description Parameter Frequency
Designation Marker
UP 63.8 Pigeon River upstream of the Temperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the BOD5 I/Week
discharge) Conductivity Daily
Color 2/Week
Flow Daily
Fecal coliform 1/Week
DNl 62.9 Pigeon River at Fiberville Bridge Temperature Daily
D.O. Daily
Conductivity Daily
Fecal Coliform I/Week
Color 2/Week
DN2 57.7 Pigeon River Above Clyde Temperature Daily
D.O. Daily
DN3 55.5 Pigeon River Below Clyde Temperature 1/Week
D.O. I/Week
Color 2/Week
DN4 53.5 Pigeon River at NCSR 1625 Temperature I/Week
bridge D.O. 1/Week
Color 21Week
DN5 42.6 Pigeon River at Hepco Temperature 1/Week
D.O. l/Week
Color 1/Week
Flow Daily
DN6 26.0 Pigeon River prior to mixing with Color 1/Week
Big Creek
BC —26.0 Mouth of Big Creek prior to Color I/Week
mixing with the Pigeon River
DN7 24.7 Pigeon River at Browns Bridge Temperature 1/Week
(—NC/TENNESSEE State Line) D.O. I/Week
BOD5 1/Week
Color 1/Week
During the 1997-2001 permit cycle, an EPA-approved computer model indicated that BOD5 limits were
required to protect North Carolina's instream dissolved oxygen standard of 5 mg/L for Class C waters.
An economically feasible end-of-pipe technology capable of consistently treating to levels necessary to
meet the limits specified by the model did not exist. North Carolina agreed with the continuation of the
requirement that Blue Ridge Paper meet the instream dissolved oxygen standard by use of sidestream
oxygen injection facilities. Blue Ridge Paper maintained these oxygen injection facilities at the effluent
and at approximately 0.9,and 2.1 miles downstream of the discharge.
To ensure compliance with the above requirement,the average daily instream dissolved oxygen levels at
stations DNI,DN2 and DN3 were required to equal or exceed 5.0 mg/L and the minimum instantaneous
instream values were required to be greater than or equal to 4.0 mg/L. If dissolved oxygen drops below
the prescribed values, Blue Ridge Paper shall utilize the instream dissolved oxygen injection stations to
increase the dissolved oxygen in the river.
The oxygen injection facilities will continue to be maintained at the effluent,0.9, and 2.1 miles
downstream,and used as necessary to maintain an instream dissolved oxygen level of 5 mg/L. The
cdndition to maintain the instream dissolved oxygen stations shall remain a condition of the permit until
such time that the permitted loading of oxygen consuming waste to the Pigeon River is less than or equal
to that proposed by an appropriate water quality model.
If dissolved oxygen at station 57.7 drops below 5.0 mg/L, the facility is required to monitor dissolved
oxygen at river mile 55.5 and 53.5.
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Instream monitoring continues to be required in order to assess Blue Ridge Paper's impact on the Pigeon
River and to ensure that the dissolved oxygen standard is maintained within the river.
Compliance Summary
The facility has a good compliance history. During the review period(0 1/0 1/2004 through 12/31/2008)
the following NOVs (notices of violation)have been issued: 08/24/2006—failure of the whole effluent
toxicity test; 10/21/2005 and 10/22/2005—violation of the BOD daily maximum limit.
The Compliance Evaluation Inspection conducted on 01/08/2009 found the facility to be in compliance.
Previous inspections had identical findings.
Permitting Rationale—Toxicity Testing
The facility has consistently passed the chronic toxicity test at 90%effluent during the previous 5 years
(19 of 20 tests passed).Therefore, chronic toxicity is not an issue. The permit renewal retains the same
chronic toxicity test limit.The draft permit retains the Quarterly Chronic Toxicity limit @ 90%effluent.
Permitting Rationale—Color
The annual average color limit of 39,000 lb/day was established in accordance with the TRW
recommendations. The company will have to achieve a new stricter limit of 37,000 lb/day by the end of
the permit cycle.
The monthly average color limit of 52,000 lb/day was established in accordance with the TRW
recommendations
The newly established daily maximum color limit is 105,250 lb/day. This limit is based on best
professional judgment.The established number is within 3 standard deviations from the mean during the
period from 1/l/1998 through 12/31/2009.
Permitting Rationale—Toxicants
Using the self-monitoring data required per the NPDES permit for Outfall 001, reasonable potential
analyses were conducted on the following toxicants: dioxin,zinc,cadmium,selenium and silver. The
standards used for the analyses are consistent with North Carolina standards for a class C waterbody.
Cadmium—Based on the Division's analysis of self-monitoring data,this discharge does not pose a
reasonable potential to cause a violation of the North Carolina stream standard for cadmium. Effluent
monitoring of cadmium will be removed because all the values were below detection level.
Silver-Effluent monitoring of silver will be removed because all the values were below detection level.
Selenium—Based on the Division's analysis of self-monitoring data, this discharge does not pose a
reasonable potential to cause a violation of the North Carolina stream standard for selenium. Therefore,
the selenium limit will be removed and the effluent monitoring will be reduced to annual.
Zinc- Based on the Division's analysis of self-monitoring data, this discharge does pose a reasonable
potential to cause an exceedence of the North Carolina's Action Level Standard for zinc. However,
numerical limits for zinc are not being included since zinc is an action level water quality standard and
the whole effluent toxicity requirements are adequate to control toxicity due to the presence of zinc in the
facility effluent. Though no limit is proposed, if the facility experiences chronic toxicity violations the
discharge will be re-evaluated and a zinc limit may be implemented according to the Division's Action
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MIDES Renewal
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Level Policy. Monitoring requirements will be reduced to semi-annual due to the very good toxicity
record.
Dioxin—Based on the Division's analysis of self-monitoring data,this discharge does not pose a
reasonable potential to cause a violation of the North Carolina stream standard for dioxin. However,the
dioxin limit will be maintained because of the EPA requirement. Effluent monitoring will be reduced to
annual because the facility had no dioxin detection in it's effluent since 1989. Currently, Blue Ridge
Paper is required to monitor dioxin and dibenzofuran isomers from the influent,sludge, landfill leachate,
and effluent. Based on an'evaluation of the data, the Division is recommending that the monitoring
frequency in the draft permit be maintained
Annual dioxin fish tissue analysis shall continue through 2009 in accordance with the recommendations
of the Division's biologists.
Permitting Rationale—Oxygen Consuming Waste Pollutants
A site-specific Best Available Technology(BAT) based limit was calculated for the 2001 permit to
determine the monthly average 5-day biochemical oxygen demand (SODS) limit. A site-specific
BAT approach was used because North Carolina's Division of Water Quality continues to agree that an
economically feasible end-of-pipe technology capable of reliably meeting the water quality limit
specified by the existing model does not exist at this time and no violations of the dissolved oxygen
standard in the river have been observed in recent years.
The North Carolina Division of Water Quality's recommendation for the 2001 permit BOD5 limit was
established based on the demonstrated level of performance for the existing treatment plant. Data on
treatment plant performance and influent loading from the Canton Mill (1998 through 2000)was
evaluated and examined for outliers. The maximum influent loading and lowest treatment plant
performance were used to develop the monthly average BOD5 limit. The data set was sufficient to
account for the day to day variability of the treatment system.
Over the time period evaluated, the treatment plant has performed extremely well. The lowest percent
removal was 96.9-/.and the highest influent loading was 414.9 mg/L. Based on this analysis,North
Carolina's Division of Water Quality recommends to retain a monthly average BOD5 loading of 3205.0
lbs/day in the draft permit
Because Blue Ridge Paper has oxygen injection facilities in place to maintain the instream dissolved
oxygen standard should instream dissolved oxygen dictate a need,Blue Ridge Paper complies with the
conditions set forth by 40 CFR 125.3 (f).
The methodology used for the daily maximum 5-day biochemical oxygen demand (BODs) limit was
developed during the 1997 permit cycle. A site-specific daily maximum to monthly average multiplier
was used for determination of the recommended daily maximum limit. Using this methodology and
reviewing data since the Canton Modernization Project(1998—2/200 1)the recommended daily
maximum limit was based on a multiplier of 3.4 (daily maximum/monthly average) is 10897 lb/day. The
draft Permit retains the existing BOD5 daily maximum limit.
Ammonia monitoring requirements are retained in the draft permit to provide data concerning levels of
ammonia discharged to the Pigeon River(which may affect instream dissolved oxygen).
Effluent dissolved oxygen is limited at no less than 6 mg/L based on the above discussion. Daily
monitoring is required based on 15A NCAC 2B .0508 (d),Paper and Allied Products, Class IV facility.
Chemical Oxygen Demand (COD) monitoring is required to assess the potential impact of chemical
oxygen demand from the Blue Ridge Paper wastewater effluent. Neither federal effluent guidelines nor
North Carolina water quality standards require a limit for COD. Though no limit is proposed,the EPA
has reserved COD for potential future limits. Therefore,COD monitoring will be continued.
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Permitting Rationale—Nutrients
Total phosphorus and total nitrogen monitoring is required by 15A NCAC 2b .0508(d)(2)(A).
Monthly monitoring is required to assess the contribution of nutrients from Blue Ridge Paper and the
potential impact to Waterville Reservoir.
Permitting Rationale—Conventional Pollutants
The total suspended solids(TSS) limits were calculated using the EPA promulgated Effluent Guidelines
for the Pulp, Paper, and Paperboard Point Source Category-40 CFR 430 Subpart B and compared to
existing limits .The TSS limits contained in the current NPDES permit are more stringent than the
calculated federal effluent guidelines since the current limits are based on the 1993 proposed guidelines
for the oxygen delignification process. The existing TSS limits remain unchanged for this permit
renewal.
North Carolina does not have a numeric standard for TSS. The rules specifically regulate floating solids,
settleable solids, and sludge deposits [ref. 15A NCAC 2B .0211(3)(c)]. The draft permit restricts floating
solids.
The temperature requirement is based on a Section 316(a)temperature variance determination issued
by the NC Environmental Management Commission October 11, 1984 and approved by EPA August 6,
1985.
In making the recommendation to retain the current 316(a)temperature variance, DWQ staff evaluated
Blue Ridge Paper's Balanced and Indigenous Species Report and concluded that temperature was not
prohibiting a Balanced and Indigenous population. In addition, DWQ staff reviewed existing
temperature data and concluded that Blue Ridge Paper still cannot meet the North Carolina temperature
requirement. Therefore, DWQ is recommending that the 316(a)temperature variance continue,with
Blue Ridge Paper conducting a Balanced and Indigenous Species Study prior to the next permit renewal.
The flow limit is based on Blue Ridge Paper's current flow values and post-CMP production, and
includes 0.9 MGD for the Town of Canton's wastewater. This flow limit remains unchanged.
Limitations for fecal coliform are based on the contribution of domestic wastewater from the Town of
Canton and the requirements of 15A NCAC 213 .0211 (b)(3) (E).
Conductivity monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products
(Water Quality Limited Facilities), for a Class 1V facility.
Limitations for pH 6.0—9.0 are based on 15A NCAC 2B .0211 (b) (3) (G).
Permitting Rationale—EPA Effluent Guidelines
The facility is subject to the Cluster Rules (40 CFR 430 Subpart B).The Pulp and Paper Cluster
Rule was established by EPA to protect human health and the environment by reducing toxic
releases to the air and water from U.S. pulp and paper mills.
Adsorable Organic Halides(AOX). Weekly effluent monitoring and limits for AOX is required. AOX
is an overall test for adsorbable organic halides,which includes chlorinated organics. Trends in
concentration changes have been observed between AOX and specific pollutants(dioxins,chlorinated
organics)at pulp and paper mills. Therefore, any decrease in AOX may also indicate a decrease in
chlorinated organics.
Chloroform. Chloroform limits for bleach plants have been recalculated for the proposed permit.
Limits contained in the NPDES permit on the bleach plant effluent are based on the EPA promulgated
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iJl PDFS Renewal
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Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category. Since Blue Ridge Paper
operates two separate fiber lines,there shall be two compliance points for chloroform as stipulated in the
sampling plan.
Dioxin. In addition to the dioxin conditions stated in the "Permitting Rationale — Toxicants" section,
dioxins shall be limited and monitored on the effluent from the each bleach plant. 2,3,7,8 TCDD and
2,3,7,8 TCDF limits are based on the EPA promulgated Effluent Guidelines for the Pulp, Paper, and
Paperboard Point Source Category.
Chlorinated Phenolics. Per 40 CFR 430.24,the daily maximum limits for 12 chlorinated phenolics are
'less than Minimum Level' (<ML as specified in 40 CFR 430.01.
Trichlorophenol/Pentachlorophenol limits and monitoring are not required. The permittee has
certified that chlorophenolic biocides are not used at the facility. This certification eliminates the
requirement to include effluent limits for these two parameters based on 40 CFR 430. However, if the
facility changes future operations to include chlorophenolic biocides, limits and monitoring will be
required. Limits for these parameters were recalculated to reflect the current level of the production
(please see attached).
Best Management Practices(BMPs) requirements for spent pulping liquors,turpentine, and soap have
been maintained in the permit. At this time, Blue Ridge Paper is in compliance with the best
management practices stipulated in the EPA promulgated Effluent Guidelines for the Pulp,Paper, and
Paperboard Point Source Category.
Blue Ridge Paper has notjoined the Voluntary Advanced Technology Incentives Program.(VATIP) for
existing direct or new direct dischargers as outlined in 40 CFR 430 Subpart B. The VATI P'program was
set up for new or existing direct dischargers whereby mills agree to accept enforceable effluent
limitations and conditions in their NPDES permits that are more stringent than the BAT limitations, in
exchange for regulatory and enforcement related rewards and incentives.
Blue Ridge Paper will use steam stripping to treat process condensates, rather than hard piping to the
W WTP; thus interface with the Division of Air Quality is not necessary.
SUMMARY-PROPOSED PERMIT CHANCES
I) Section A. (8.) Requirements for Color Analysis and Compliance Special Condition of the permit
has been updated in accordance with the latest EPA Technology Review Workgroup(TRW)
recommendations.
2) Annual average color limit has been reduced from 42,000 lb/day to 39,000 lb/day in accordance
with the latest TRW recommendations(Outfall 001),and will be reduced to 37,000 lb/day based
on the performance of the facility but no later than 4 years after permit effective date: See A. (8.)
Color Analysis and Compliance Special Condition.
3) Monthly average color limit has been reduced from 55,000 lb/day to 52,000 lb/day(Outfall 001).
4) The daily maximum color limit of 105,250 lb/day has been added to the permit in accordance
with the latest TRW recommendations(Outfall 001).This limit is based on the analysis of the
color discharge data from Outfall 001.
5) Section A. (12.) Waterville Reservoir Sampling Special Condition was removed from the permit
due to the elimination of the Color Variance-and all fish consumption advisories in North
Carolina and Tennessee.The application to remove the Color Variance has been filed.
6) Color monitoring at the following stations have been reduced to weekly(summer and winter)due
to the improved stream conditions: DNS, DN6, BC, and DN7.
7) Chloroform limits have been recalculated to reflect the current production level (Outfalls 002 and
003).
8) Monitoring frequencies for chloroform have been reduced to quarterly(Outfalls 002 and 003).
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9) AOX(adsorbable organic halides) limits have been recalculated to reflect the current production
level(Outfall 001).
10) Monitoring frequency for AOX has been reduced to weekly(Outfall 001).
11) Pentachlorophenol and trichlorophenol limits have been recalculated to reflect the current
production level (Outfall 001).
12) Low flow condition requiring that facility will not plan any outages during the low flow periods
was added to the permit(Section A. (8.)).
13) The daily maximum limit for selenium was removed from the permit based on a
statistical analysis of the effluent data(Outfall 001).
14) Monitoring frequency for selenium has been reduced to annual due to the removal of the limit
(Outfall 001).
15) Monitoring frequency for pentachlorophenol has been reduced to quarterly(Outfalls 002 and
003).
16) The daily maximum limit for dioxin was re-calculated based on the average flow in the
receiving stream. (Outfall 001).
17) Monitoring frequency for dioxin has been reduced to annual because this parameter was
consistently below detection level during the past permit cycle. (Outfall 001).
18) Monitoring frequency for dioxin has been reduced to annual (Outfalls 002 and 003).
19) Monitoring for cadmium has been removed from the permit based on a statistical
analysis of the effluent data(Outfall 001).
20) Monitoring for silver has been removed from the permit based on a statistical analysis of
the effluent data(Outfall 001).
Rationale for Temperature Variance Renewal
Blue Ridge Paper submitted the latest Balanced and Indigenous Species Study on the Pigeon River in
May of 2006. The study was conducted by the University of Tennessee. DWQ biologists have reviewed
the report and concluded that continuance of the temperature variance is appropriate. Therefore,the
Division of Water Quality is recommending continuation of the temperature variance with reporting
requirements consistent with the previous permits.The facility will be required to provide a new
Balanced and Indigenous Species Study prior to the next permit renewal.
Color Variance Removal Rationale
On July 13, 1988, Champion Paper was granted a variance from North Carolina's narrative water
quality standard for color. The Color Variance was last renewed in 2001, and the variance
requirements were implemented as a Special Condition in the NPDES permit issued in 2001. A
goal of this Color Special Condition was to achieve color reductions indentified by the TRW and
lay the foundation for removal of the Color Variance prior to the next permit renewal. Blue
Ridge Paper is requesting removal of the Color Variance, based on improvements in effluent
color and instream conditions..
During the last 30 years Blue Ridge Paper has made significant improvements to the facility in
order to reduce effluent color load and improve it's overall environmental performance. As a
result, the annual average effluent color loading has been reduced from 380,000 lb/day in 1988 to
38,000 lb/day today(Fig. 2). Since 1997 the color in the effluent has decreased from 60,000
Ibs/day to 38,000 Ibs/day.
In order to achieve this result, the mill has spent over$526 million in expenditures on
environmental process improvement since 1990. One of the major accomplishments was
Fact Sheet
MIDES Renewal
age10

development of a unique technology—BFR(bleach filtrate recycling process). BFR removes
color from the effluent. It was installed in 1998 at a capital cost of$30 million.
Fig. 2.Annual Average Effluent True Color
Blue Ridge Paper, 1988 through 2008
T
v 400 380
m & 333 301 307
0 300 243
ki a
200 0
$ 120
v 100 93
41 43 43 41 45 40 39 37 36 37
m d 0 11 g g A a 3 e! o ® a a
0 0 O '� `� A 0 O '� O O '� `, 9 b 0 'I
We ^00 ^00 400 ^00 q o ^09p ^000 14^0 01 r�00 ry00 ry00 ry00 ry00 ry0o°'ry00 e e ry00
According to the latest report of consultant Dr. Liebergott(issued on July 7, 2006) the mill is
ranked# I in the world in regards to the BOD, COD, and color removal. Dr. Liebergott was
originally hired in 2001 by the consortium of environmental groups to evaluate the facility for
color reduction options. Dr. Liebergott also concluded, after evaluating data from 76 similar
mills around the world, that BRPP is ranked# 2 in the world in regards to the TSS and AOX
(adsorbable organic halides) removal.
During the period from 2001 through 2006 (last permit term) the mill spent almost$6 million
dollars to undertake 35 separate color reduction initiatives. Some for these initiatives were
recommended by the TRW, and some of them were independently identified by the BRP staff.
During the last permit term the permit color limit was reduced from 48,000 lb/day to 42,000
lb/day.This draft renewal will require the end of the pipe limit of 39,000 lb/day, decreasing to
37,000 lb/day after 4 years.
A biological study conducted by the University of Tennessee in 2005 concluded that.the Pigeon
River has a"balanced and indigenous fish community". This study also found a diverse and
healthy macroinvertebrate community in the Pigeon River. Although, according to the North
Carolina indicators, the benthic community in the Pigeon River is currently deemed "impaired"
and is listed on the state's 303(d) list. The Division believes that this impairment is not caused
by the color constituents in the mill discharge, it is likely a combination of many factors.
Scientific studies indicate that stream color concentrations below 100 color units have no effect
on health of aquatic organisms (NCASI Special Report 9407, Human Perception and Biological
Impacts of Kraft Mill Effluent Color, June 1994).
According to the information the Division received from the state of Tennessee, the River Run
Walleye has returned to the Pigeon River. This is a very sensitive species that indicate high water
quality. The Pigeon River has also became a trophy smallmouth bass fishery and the number of
rafters in Tennessee has increased from —21,000 in 1995 to almost 150,000 in 2007.
Fact Sheet
NPDES Renewal
Pane 11

Figures 3 through 5 demonstrate trends in the color conditions of the receiving stream. It is
necessary to mention that the exceptional drought of 2007-2008 made a significant negative
impact on the color conditions in the Pigeon River.
Fig.3.Monthly Average True Color in the Pigeon River at Fiberville
January 1997 through December 2008
225
excep10-1 dmughl condifiansin
Pigeon'.' W,sunmer and
200 — -- 1a00f2007aM2008
17$
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G
125 --
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o N N 9 ID A h 0 M
m m m m m m o 0 o g o 0 o q q q o O o e o q
During the 3 years beginning December 2002, monthly average color at Fiberville (0.4 miles
below discharge) has been 31 true color units.The exceptional drought that began in 2007 has
shifted the general downward color trend, and color values have increased substantially.
Fig.4.Monthly Average True Color in the Pigeon River at Hepco
January 1988 through December 2008
350
325
300 __.._.-
275
250
225
200 —
° 175
O� gn f Pig on
01$0 — Riwrdwngsmmerandlaflof2007
ed 2008 :i
r 125
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75 —
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6]Cf OI OIOOe�e�NNMMO VtnNlp tOh ANe00f OfOO��NN MMyaNNbtOAACf OD
mm mm wmmmmm Mmmmmmmmmmm mMm 000 oo0000000000goo
Fact Sheet
NI'DFS Renewal
Pagc 12

Monthly average color at 14EPCO (20 miles below discharge) during the last Permit term
beginning December 2001 has averaged 24 true color units.
Fig.5. Pigeon River Color Upstream of the Canton Mill
and at Brown's Bridge(-NC/TN State Line): 1988 thru 1 211 7/2 0 0 8
225 _.__. -._........--...
200 -- -- --- ------ -------- -
U 175
..
IL
`0 150
0
m 125
0t
A
y` 100 —
Exceptional drought in Pigeon River duirg
Q sunnier and fall of 2007&2008 "
= 750
25 -- —
0
OD OI O N M V N O A O OI O N M of h W A W
op oq to m a a a m m w m m 4 4 4 4 4 4 4 4 4
to c c c c c c c c c c c c c c e c c c c
A A to l0 A nl nl A A to N AM R Al A t0 N c to A t0
—State Line Color —Color Upstream of Canton Mill(Background)
Monthly average color at the North Carolina/Tennessee line during the last Permit term has
averaged 17 true color units, which is significantly below the value that was interpreted by EPA
as the color water quality standard agreed upon by both states—50 color units. Figure 5 indicates
there is no significant difference between color concentration upstream of the mill and at the state
line. Review of the data for the period beginning on 0 1/0 1/2004 through 12/31/2008 indicates
that monthly average limit of 50 at the state line was never exceeded,there were only two daily
maximum exceedences during extreme drought: 09/26/2007—52 color units, 08/27/2008—65
color units.' This drought (2007-2008)was so severe that the water flow in the Pigeon River was
below 7Q10 for 6 weeks, and below 30Q2 for 32 weeks.
In order to evaluate the color compliance we need to review the color narrative water quality
standard definition from the North Carolina Administrative code. 15A NCAC 213.0211 Fresh
Surface Water Quality Standards for Class C Waters:
Oils, deleterious substances; color or other wastes: only such amounts as shall not render the
waters injurious to public health, secondary recreation or to aquatic life and wildlife or
adversely affect the palatability of rsh, aesthetic quality or impair the waters for any
designated uses ....
Therefore, the narrative color standard consists of several components, and each of the
components has to be evaluated:
Fact Sheet
NPDES Renewal
Page 13

1) Public Health-There has never been a public health advisory related to color in North
Carolina.
2) Aquatic Life and Wildlife-The University of Tennessee biological study conducted in
2005 concluded that the Pigeon River has a"balanced and indigenous fish community in
the Pigeon River below the mill's discharge".The facility is also consistently passing
WET tests during the last 5 years and for an extended time period before that.Therefore,
the benthic macroinvertebrate impairment is not believed to be associated with the color
discharge.
3) Palatability of Fish—Color is not a parameter associated with fish palatability.
4) Secondary Recreation-Pigeon River in North Carolina continues to be used for
secondary recreation. Division's employees from the central office and the regional office
have observed people fishing below the discharge on numerous occasions.
5) Aesthetic Quality-NC has generally viewed color as primarily an aesthetic issue, and the
interpretation of color as an aesthetic impact is subjective. Similar to odor issues, the
number of complaints received serves as one means to gage public perception of color
impact. The NC DWQ regional office in Asheville has received only one color complaint
in recent years. Aside from actual color complaints, the most definitive color perception
research on pulp mill color discharges has been conducted by Dr. Prestrude of Virginia
Tech Department of Psychology. His research was funded in part by the State of
Tennessee, and included color perception studies in both Tennessee and North Carolina
waters (Pigeon River). Prestrude (July 1996) reported that the vast majority of persons
participating in the research projects considered water quality color in the receiving
stream as aesthetically acceptable in the 100-110 PCU color range. This instream color
range is generally achieved by Blue Ridge Paper over the past seven years, except under
extreme low flow conditions:
• Instream Color at Fiberville (0.4 miles below Blue Ridge Paper discharge). Between
CY2002-08, there were 64 of 592 individual instream samples (10.8%) that exceeded 100
PCU. The majority of values exceeding 100 PCU occurred during extreme drought
conditions in 2002 and 2007-2008, when instream flows fell below 30Q2 and sometimes
below 7Q 10. In more typical water years, there were no individual values>100 PCU in
2003 and 2004, and only 1 value>100 PCU in 2005 and 2006.
• Instream Color at HEPCO (20 miles below Blue Ridge Paper discharge). Between
CY2002-08, there were 3 of 592 individual instream samples (0.5%) that exceeded 100
PCU.
• Instream Color at NC/TN state line (38 miles below Blue Ridge Paper discharge).
Between CY2002-08, there were 0 individual instream samples that exceeded 100 PCU.
The instream color at the state line was compliant with the 50 PCU instream color
standard for 577 of 579 individual samples (a 99.6%compliance rate), despite extreme
drought conditions and no consideration for background color.
Based on actual instream color measured between 2002-08, DWQ believes that
compliance with the effluent color limits established in the 2001 permit were protective
of NC's narrative water quality color standard. Only under extreme drought conditions
(below 30Q2/7Q10 flows) were instream color values reported to exceed the Prestrude
aesthetic threshold of 100 PCU, and NC regulations do not consider aesthetic color
standards violated by the permittee when stream flows fall below 30Q2 design flow.
Fact Sheet
NYDLS Renewal
Page la

pr I
Further downstream at the NC/TN state line, the instream color limit of 50 PCU has been
consistently met despite extreme low stream flows and no consideration of background
color. DWQ believes the Draft 2009 permit, which proposes even more stringent effluent
color limits, will continue to be protective of NC's narrative color water quality standard,
as well as the 50 PCU color limit established at the NC/TN line for protection of
Tennessee's color standard. In the future,NC DWQ will continue to evaluate aesthetic
color impact based on color complaints received by the Asheville Regional Office, in
tandem with color perception guidelines established by the Prestrude color studies
conducted in Tennessee and Pigeon River.
6) Designated Uses -The Pigeon River is classified as "Class C waters"-aquatic life
propagation and survival, fishing, wildlife, secondary recreation, and agriculture. All
designated uses are currently being met, benthic macroinvertebrate impairment in some
segments of the Pigeon River cannot be attributed to color discharges and is likely the
result of habitat degradation and NPS pollution.
Based on the evidence presented, the Division believes that the current discharge does not cause
violation of the North Carolina Color Standard and the Color Variance should be removed from
the permit. The facility will continue to implement color reduction measures identified by the
TRW. The facility will also continue to investigate feasibility of the new technologies that will
reduce color in the effluent and implement them (if economically achievable).
ADDITIONAL INFORMATION
CANTON MODERNIZATION PROJECT
Prior to 1993, knotting hardwood brownstock was washed through one of two brownstock
washer lines. After washing brownstock was screened using a two-stage fine screening process
and bleached in one of the two bleaching lines. The two bleaching lines were operated
independently for `low' brightness and `high' brightness.
Since 1993, the hardwood fiberline has incorporated numerous modifications designed to
increase mill performance from both an environmental and product quality standpoint.
Currently, the hardwood fiberline consist of two stage knotting followed by pre-oxygen
delignification washers. After pulp is processed through the oxygen delignification unit, it is
washed again prior to the four stage pressurized fine screening. After screening, the pulp is
bleached through one medium consistency bleach line.
Prior to 1992, pine (softwood) pulp was processed through one brownstock washing line prior to
the two stage screening process. After screening, pulp was processed through one of the two
bleaching lines. Similar to the hardwood fiberline, the softwood fiberline bleaching was operated
independently for `low' brightness and `high' brightness.
Like the hardwood fiberline, the softwood fiberline has incorporated numerous modifications in
order to enhance product quality and environmental performance. Currently, the softwood
fiberline process consists of two stage knotting followed by a brownstock pre-oxygen
delignification line. After the initial washing the pulp is processed through the oxygen
delignification unit followed by another washing. After the second washing pulp is screened
using four stage pressurized fine screen before entering a medium consistency bleach line.
In addition to the improvements noted, the facility has implemented full scale bleach filtrate
recycle of the pine bleach line and partial caustic extraction stage (Eo) recycle on the hardwood
bleach line.
Fact Sheet
NPDES Renewal
Page 15

PROPOSED SCHEDULE FOR PERMIT ISSUANCE
This fact sheet represents North Carolina's recommendations. The Division will review all
pertinent comments received during the public comment period and the public hearing. After
reviewing all public comments, the Director of the Division of Water Quality and the NPDES
Committee of the Environmental Management Commission will make their recommendations.
Public Notice Draft Permit, temperature variance, color variance and Public
Hearing
Public Hearing
State Contact
If you have any questions on any of the above information or on the attached permit, please contact
Sergei Chernikov at(919) 807-6393.
Fact Sheet
NPI?ES Rendv d
Pml,e 16

PPV
Executive Summary
DWQ Responses to EPA Permit Objection Letter
Blue Ridge Paper/NC0000272
March 17, 2010
Specific Objection 1: Technology-Based Color Limits and Compliance Schedule
EPA objections:
• Permit must require initial annual avg. color permit limit of 37,900 lb/day instead of 39,000 Ib/day.
• Permit must require annual avg. color limit of 32,000-36,000 Ib/day at end of 4-year compliance
schedule.
• Permit must require facility to submit implementation plan within first year of permit issuance
• Permit must include reopener to include interim requirements and dates for their achievement
DWO Response:
The first EPA TRW Report(2001)recommended a color range of 32,000-39,000 lbs/day annual average at end of
permit term(by 2006). Blue Ridge(2005) data supported 39,000 lb/day, and this value was applied as the starting
point for current Draft permit. EPA is requiring starting color limit of 37,900 lb/day,which would have been
violated in 2009.
The second EPA TRW Report(2008)recommended color range of 32,000-37,000 lbs/day as an annual average,
applied no later than end of upcoming permit term. EPA is now objecting to their 2008 proposal,and now
requires a color range of 32,000-36,000. Given uncertainties of color reduction efforts, DWQ staff believes
original EPA TRW recommended target range should remain.
DWQ can add an implementation plan submittal requirement into permit; however, it will only contain a color
evaluation schedule. It is impossible to predict which recommended measures will produce results. During the
previous permit term the Canton mill evaluated 35 different measures,and only a very few of them were effective
or found to be technically, operationally, and economically feasible.
Specific Obiection 2: Effluent Limit for Color; Protection of Water Quality and Status of
Variance to Narrative Color Criterion
EPA objections/recommendations:
• DWQ has not established that narrative color standard is being met.
• DWQ must revise terms of the color variance to reflect proposed permit conditions that EPA stipulated
in Specific Objection 1, and resubmit variance extension to EPA for approval.
• EPA recommends that BRPP provide funding for an independent, unbiased site-specific color study to
determine how the NC narrative color standard should be applied to Pigeon River near Canton.
DWO Response:
EPA historically interpreted the NC color standard as 50 PCU. However,this interpretation is based on old data
that is not defensible. EPA relied on one study(NCASI 1975)which was designed to determine detectable levels
of color,rather than objectionable levels.
In contrast,DWQ supported its decision regarding color compliance with its narrative standard utilizing more
relevant and up-to-date reports that included color perception studies conducted by Dr Prestrude(which evaluated
color objectionability as opposed to color detection, and included site specific evaluations in TN/NC Pigeon
River). These studies indicate color is not objectionable below 100-110 PCU. Also,NCASI study(1995)
1

indicates color has no aquatic life impacts at levels below 100 PCU. Only one color complaint has been logged at
the ARO over the past few years, and recent data shows the rafting community on the TN side of the Pigeon River
is booming. Overall,the color record supports the DWQ conclusion that the six components of its narrative
standard are being met.
Ultimately,DWQ will rely on the independent NC Environmental Management Commission(EMC)to determine
whether the narrative color standard is being met. This EMC meeting is scheduled for May. The EPA objection
includes a requirement for extension of the color variance, but NC has no legal authority to force the variance on
the facility. Also, if the EMC determines the color standard is being met,then the variance is unnecessary.
Specific Objection 3. Temperature Variance
EPA objections:
• Permit must require completion of an updated BIP study that includes thermal modeling
• Permit must require monitoring/reporting of Daily Max and Monthly Avg. effluent temperatures
• Permit should include, in interim period, a reduction in Delta T limit to 8.2°C
DWO Response:
The Draft permit already requires the permittee to complete a BIP study during this permit term, and also requires
daily effluent temperature monitoring. DWQ can add a requirement for Monthly Average temperature
calculation.
The last BIP report(May 2006)concluded that there is a demonstrated presence of a Balanced and Indigenous
Population in the Pigeon River. This study was supervised and written by experts in the field(Dr. Larry Wilson
and Dr.David Etnier of the University of Tennessee-Knoxville), and reviewed by Dr. Charles Coutant(who was
one of the original panel members assisting EPA with 316(a)Technical Guidance). However, EPA objects to the
study conclusion and believes the study is not sufficient to make the required BIP demonstration. EPA sent
blanket objections to all facilities with 316 (a)variances in Region IV.
EPA is requiring a reduction in the Delta Temperature limit(from 13.9 degrees C to 8.2 degrees C)until the BIP
study is concluded. EPA's proposed delta T is arbitrary. During the period 2001-2009 the proposed delta T would
have caused at least 6 violations. Blue Ridge Paper may propose an alternative for consideration. A new
temperature study would cost—$500,000.
Specific Obiection 4. Absence of Daily Maximum Dioxin Limit and Fish Tissue Monitoring
EPA objections.
• Permit must contain an effluent Daily Maximum dioxin limit.
• Permit must require fish tissue dioxin monitoring in the Is;P and 5 h years of the permit term.
DWO Response:
The Draft permit contains a Monthly Average dioxin limit; we will add a Daily Max limit to appease objection.
DWQ staff recommends a compromise on the dioxin fish tissue monitoring. Since switching to ECF technology,
dioxin levels have been non-detect in the effluent and further up in the bleach plant wastestreams. Most fish
samples have no detectible level of dioxin/furan. In the few remaining samples,concentration of dioxin/furan is
well below FDA and NC DHHS thresholds.All fish consumption advisories have been removed, and the
dioxin/furan concentration in fish has been steadily decreasing since 1990. In order to achieve a compromise,
DWQ can suggest a fish monitoring event during 2"d year of the permit. If the observed concentration of
dioxin/furan is still below FDA and NC DHHS recommended thresholds, further monitoring would not be
required. Blue Ridge proposes to do the dioxin sampling in concurrence with the 316 (a)temperature study.
2

PPV
Specific Obiection 5. Absence of Turbidity Monitoring
EPA objections.
• Permit must require turbidity monitoring at Fiberville Bridge, 2/Month,April-Oct.,for one year.
• Permit must contain specific turbidity reopener to add turbidity limit if reasonable potential exists.
DWO Response:
DWQ can add this requirement to the permit.
Specific_Objection 6. Absence of Effluent Hardness Monitoring To Evaluate Zinc Tolicity
EPA objections.
• Permit must include quarterly effluent hardness monitoring.
DWO Response:
DWQ can add this requirement to the permit. However, it will be noted that this is the only facility in NC that
EPA has required this from. Our current zinc water quality standard has no provision for hardness,and our
Action Level Policy would indicate no zinc issues since the facility has consistently passed the WET test.
Hardness data may be useful to facility in the long run, following Triennial Review proposed changes.
EPA Recommendation Regarding AOX Limits
• Recommends retaining reduced AOX limits from last permit.
DWO Response:
DWQ can add this recommendation to the permit provided Blue Ridge will not object, since there is no basis for
it. Basically EPA is recommending to the State to implement a performance based limit for AOX, and disregard
their own procedures for developing Effluent Guideline Limits. The basis for EPA's recommendation appears to
arise from a few public comments raised at the public hearing. Nevertheless,the facility has an excellent AOX
performance record, and the limits from the 2001 permit can be retained in the proposed 2010 permit.
EPA Recommendation Regarding TRW
• Recommends including provision in permit to ensure that TRW will assess color reduction
technologies and provide recommendations to DWQ at end of next permit term.
DWO Response:
The TRW was established by the 1997 settlement agreement to serve during the term of the next permit cycle. Its
goal has been achieved. During the current permit renewal,the TRW added significant delays to the process(2
years). DWQ staff recommends that annual color reports and the color implementation plan be distributed to
EPA and TN for their comments,with specified deadlines. However,DWQ does not see the need to continue the
TRW process.
3

PPV ,
"This variance shall extend for an indefinite period of time, subject to consideration
during the water quality standards triennial reviews. Any modification or termination
based thereon shall be subjected to the public hearing process required by N.C.G.S. 143-
215.3(e)".
Therefore, until the administrative process for removal of the variance is completed,the 2001
variance remains in effect. Nevertheless, the fact sheet indicates that the variance has been
removed and does not provide an explanation as to how the procedural ements for its
removal have been met.
Also, as mentioned above, the actions required in Section B:8 of the 2001 variance and
the 2001 permit do not appear to have been completed. That section of the variance required an
evaluation of mill performance related to color and a recorntnndation byDWQ of the lowest
achievable annual average and monthly average color,lo°Oadg"effluent limitations for the mill.
This section also required that, if the analysis supported a revis on to average annual color limits
in the range of 32,000 to 39,000#/day,the revised-limit was to become effective on March 1,
2006. However,the current effective annual average 1 tat./0- color is 42,000'#/day.
In addition to not completing the;procedures for variagc,removal, DWQ also did not
include in the fact sheet a defensible scienWfhc7ationale for its determination that the draft permit
will ensure compliance with North Carolina' narrative water quality standard for color. The
fact sheet for the draft permit states that the monthly and`annual average color limits are"in
accordance with the TRW recommendations e'fact sheet a1j o states:
Based on actual<instteam,color measured between 2002-2008, DWQ believes that
complianceAthbthe effluent color limits established in the 2001 permit were protective
of NC's narrative water quality color standaprd//Only under extreme drought conditions
(below 30Q2/7Q10�fl wswere�mstream•color values reported to exceed the Prestrude
aesthetic threshold of I0 latinum obalfunits (PCU or"color units"), and NC
egu ations do noti consider.aesthetic color standards violated by the permittee when
stt am flows fall'belo�y 30Q2.de`s gin flow.
The reference o,the Prestrude estheti eshold of 100 PCU relates to a study entitled, Color:
Misperceptioxs,About the Aesthetics of River Color, (Dr. A.M. Prestrude, July 1996) (the
"Prestrude Report,). The Prestrude Report suggests that color levels become an aesthetic
problem at 100 PCU: llowever,none of the studies relied upon in the Report are based on
waters that are similar totthe segment of the Pigeon River near Canton. The study of ambient
color levels in the Pres(rude Document included consideration of photographs of the Pigeon
River downstream of the facility discharge which were taken in or about 1988. However,the
amount of color discharge from the facility during that time frame was approximately ten times
the amount that is currently discharged.
3
i-

Ms. Colleen H. Sullins
Director, Division of Water Quality
North Carolina Department of Environment and
Natural Resources
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Dear Ms. Sullins:
On November 23, 2008, we received your submittal foryour review,of a draft National
Pollutant Discharge Elimination System (NPDES)permit`for Blue Ridge, \per Products,
Permit No.NC0000272. We appreciate your efforts to'c tiriue the improvements in the quality
of the Mill's discharges to the Pigeon River throughfhe NPDES permit process and recognize
the tremendous progress made by the Mill over the-last 20 years" We also want o.commend you
for your decision to increase public participation in this,proce s by holding a public meeting on
the draft permit in Tennessee.
We have had many discussions with youz staff during our,review of the draft permit and
resolved a number of issues. To provide morettime for these collabo�five discussions, we
notified you on December 10, 2009, that we'w�ould be taking he fy1190-day period to complete
our review pursuant to Section IV.B.3 of the N,,DES,Meemor_andum of Agreement (MOA) with
North Carolina Division of.et•Quality (DWQ).
/ - E
At this time;w" a Have completed our review'and have remaining concerns with some
provisions of the draft peimit. Based.on our reviev�and consideration of issues raised at the
recent public meeting and heaiing,'we, earear providingspecific objections to the draft permit,
which are explained i&detail below puns ant-to'Section IV.B.3 of the MOA and regulations at
Title 40 Code of Fede'ra1;Regulations,(CFR) §123.44.
Spec" Obiections
Specific Objection 1:: ITechnoloev-Based Color Limits and Compliance Schedule
The draft permit=in6ludes an initial annual average color permit limit of 39,000 #/day and
requires a 37,000 #/day�limit within four years. Although the 2001 current permit required that
DWQ conduct an analysis of mill performance and possible revision of annual average color
loading to a 32,000-39,000 #/day range by March 2006, that revision did not occur. To assess
current performance, EPA developed 95% confidence limits for annual average color loadings
using monthly average data for the period 2006-2009. EPA typically uses this type of statistical
analysis to determine effluent performance and the use of such confidence limits is consistent
with effluent guidelines development. That analysis indicates that the draft permit's annual
average color limits do not fully capture current performance or provide a sufficient incentive for

the mill to continue to improve its performance. These permit provisions are thus not consistent
with the case-by-case Best Professional Judgment requirements of 40 CFR §§ 125.3(c)(2) and
(d)(3). The draft permit is therefore subject to specific objection pursuant to 40 CFR §§
123.44(c)(4), (6), and (7).
To resolve this specific objection, based on the confidence limits cited above,the permit
must require an initial annual average color permit limit of 37,900 #/day. Also,the permit must
require an annual average color limit in the range of 32,000-36,000 #/day at the end of the four-
year compliance schedule. This is consistent with the color range recommended by the
Technology Review Workgroup (TRW) in February 2008. a
Also, for the color compliance schedule cited above,the draft permit requires that the
mill develop an implementation plan for various color reduction effoi ts,and submit annual
reports of progress. However, the permit does not specify a da e certain for submittal of that
plan, nor interim requirements and the dates for their achie ement. Since tlie�compliance
schedule exceeds one year,pursuant to 40 CFR§ 12247(a)(3);tithe complianc&schedule must
include interim requirements and dates for their achievement. The failure to inciude'/the interim
requirements and dates for their achievement is subject,to obj ion pursuant 40 CFR §
123.44(c)(7).
To address this specific objection;+the permit must require the facility to submit an
implementation plan within the first year o'f:'perriit issuance. The permit must also contain a
reopener clause to include interim requirements and•daies-for their achievement as enforceable
r ,
parts of the permit based on the ubmitted impl1\ /tation•p" lan Once the implementation plan
is submitted and reviewed;thepermit should be modified accordingly.
Specific Obie"cfion 2: Effluent Limit for Color: Protection of Water Quality and
Status of Variance to Nariative Color Criterion
The<condrtronshand limits for color ihlhe draft permit are based on the removal of the
variance4o the narrative color standard for the Pigeon River,which was adopted by the State on
October 10, 2001. Thus, the'color effluenflimits, in the State's view, are consistent with the
States water.�quality standard for color/However, the fact sheet or record supporting the draft
permit does,not-adequately support this determination. As background, in the absence of a State
translation of the narrative standard, EPA has historically translated the State's narrative standard
to a numeric standafd of 50 platinum cobalt units (PCU or"color units"), and the State has
adopted a variance from'thhs'standard that was reflected in previous permits for the Blue Ridge
facility. EPA's 50 coibr,units interpretation was based on studies conducted by the National
Council for Air and Stream Improvement, and is consistent with Tennessee's interpretation of a
similar narrative color standard for the segment of the Pigeon River located downstream of the
North Carolina/Tennessee state line. When North Carolina adopted a variance from this standard
in 2001, the terms of that variance included the following:
2

"This variance shall extend for an indefinite period of time, subject to consideration
during the water quality standards triennial reviews. Any modification or termination
based thereon shall be subjected to the public hearing process required by N.C.G.S. 143-
215.3(e)".
Therefore,until the administrative process for removal of the variance is completed, the 2001
variance remains in effect. Nevertheless,the fact sheet indicates that the variance has been
removed and does not provide an explanation as to how the procedural requirements for its
removal have been met. y�
Also, as mentioned above,the actions required in Section< 8 6 the 2001 variance and
the 2001 permit do not appear to have been completed. Thal cction of�the�variance required an
evaluation of mill performance related to color and a recommendation by,Db X of the lowest
achievable annual average and monthly average color load g'effluent limitations for the mill.
This section also required that, if the analysis supported a revision to average an>ival color limits
in the range of 32,000 to 39,000#/day, the revised-limitwas to become effective on-lvlazch 1,
2006. However,the current effective annual average linlatiori for color is 42,000'•#/day.
In addition to not completing th"rocedures for variance,removal, DWQ also did not
include in the fact sheet a defensible scientific rationale for its"determina ion that the draft permit
will ensure compliance with North Carolinats narrative water quality standard for color. The
fact sheet for the draft permit states that the inonthlyrand'annual av,�rage color limits are"in
accordance with the TRW recommendations ',Te' acY sheet also states
51
Based on actual'instream color measured'between 2002-2008, DWQ believes that
complianceawit0he effluentcolor limits established in the 2001 permit were protective
of NC's narrativewater quality color standard�Only under extreme drought conditions
(below 3_QQ2`/7Q W flows were instream,color values reported to exceed the Prestrude
aes1hetic.threshold of 100 platinum obalt units (PCU or"color units"), and NC
regal tions do n'ot�consideraesthetic color standards violated by the permittee when
streaam flows fall below\30Q2 des gn now.
The reference Ito the Prestrude aesthetic threshold of 100 PCU relates to a study entitled, Color:
Misperceptions.About the Aesthetics of River Color, (Dr. A.M. Prestrude,July 1996) (the
"Prestrude Report ). The Prestrude Report suggests that color levels become an aesthetic
problem at 100 PdfI owever, none of the studies relied upon in the Report are based on
waters that are similai��the segment of the Pigeon River near Canton. The study of ambient
color levels in the Prestrude Document included consideration of photographs of the Pigeon
River downstream of the facility discharge which were taken in or about 1988. However, the
amount of color discharge from the facility during that time frame was approximately ten times
the amount that is currently discharged.
3

Further,the document also states, "From a perception standpoint,therefore, it is readily
accepted that the general population can differentiate between colors differing by approximately
50 color units. While this difference is capable of scientific quantification,more refined studies
are required to focus on what level of perceived color is objectionable in natural environments."
Thus,the Prestrude Report does not purport to establish a one-size fits all color standard that can
be applied to different environments. EPA agrees with the Report's suggestion that more
refined, site-specific studies would be useful to determine how the narrative standard
should be interpreted or applied to specific natural environments such as,the Pigeon River near
Canton.t
The terms of the 2001 variance allowed a monthly aveerage limitT 55,000 Wday,which
was selected based on actual performance of color treatment aad removal'technologies that were
identified in an earlier review by the TRW. In other words thisvalue was s lected based on the
p .,.. :.
ability of the facility to meet the limit by installing and operating color treatment and/or removal
technologies, rather than factors related to instream,water quality.
���
The monthly average color limit proposed in thdiaft ,e - t%is 52,000#/day; however,
the fact sheet does not clearly indicate whether this limit is basd on what can be achieved
through application of available technologies or on protection of water quality. Due to the
absence of a numeric interpretation of the arraf ve color standard by the State, it is not clear
whether the State has determined that the monthlylimit of 55,000# day,,i.e., "the effluent color
limits established in the 2001 permit,"or the monthly,average of 52`000 Wday, as proposed in
the current draft permit, is needed to meet theNnarrativ color olor standard. Using the 30Q2 flow of
the Pigeon River of 89.9 ca�lo'feet per second al 6anton, and assuming that the background
color level of the Pigeon,River is 11PCU,the current draft permit allows for a color level
downstream of the discharge of 11.4 PCU, and the previous 2001 monthly average permit limit of
55,000 4/day allowed an instream color level of 120i96U. The absence of a specific numeric
interpretation of-the State's`na�rrative•col ro standard and the ambiguity of the statements made in
the fact sheefmake tt difficult cult to�determi at-what PCU level the State believes ambient
conditio4 would be'&n Went with'the narrative color standard. Thus,the effluent limits in the
draft etmit would resultin instrearn col�o}'levels that exceed both the"Prestrude aesthetic
threshold,ofNI00 platinum cobalt units�and EPA's historical use of 50 PCU as a numeric:
translation of the State's narrative standard. However,the fact sheet also does not adequately
explain how P14�PCU will mply with the State's narrative color standard.
The Tennessee Department of Environment and Conservation reviewed the studies summarized in the Prestrude
Report and concluded that the appropriate interpretation of its narrative color standard requires that the increase of
ambient color levels in the Hiwassee River should be limited to an increment of 50 color units over levels measured
above the Bowater paper facility outfall.
4

The fact sheet states:
NC has generally viewed color as primarily an aesthetic issue, and the interpretation of
color as an aesthetic impact is subjective. Similar to odor issues,the number of
complaints received serves as one means to gage public perception of color impact. The
NC DWQ regional office in Asheville has received only one color complaint in recent
years.
This appears to be the State's justification for the determination that the draft permit will ensure
compliance with the state's narrative color standard and a variance ismo-longer necessary.
However,while the presence or absence of complaints may be relevant, EPA does not find the
counting of complaints to be a sufficiently structured process fq establishing a state water
quality standard. EPA is not aware that the State has notified the puBlie'that the frequency of
complaints is a factor that is used in the State's interpretation oor application.of the narrative color
standard. 4
As noted above,EPA has historically interpret'Morth Carolina's narrative color
standard for the Pigeon River to be 50 PCU. The rationaie,provide`din the fact sheet does not
establish a scientifically defensible basis for the State's interpz tation of the narrative standard or
its conclusion that the limits in the draft'permit implement the State's water quality requirements
for color, as established in 15A North Carolina-Administrative Code (NCAC)2B.0211(3)(f) and
15A NCAC 2B.0206(a)(4).
In summary,EPA is concerned that tbe\State`has insufficient record support for the
conclusion that the effluenflunits•and conditions f6r color proposed in the draft permit are
protective of NC's narrative water quality color standard. The fact sheet's discussion of the basis
of the color conditions,and limitations does not establish that the draft permit will comply with
the narrative color standard at all flows equal to or greater than the applicable instream flow, i.e.,
30Q2 flow, as established ih,its,water gality-stand'ards. Therefore, the draft permit does not
comply with requirements at 40�CFR§122:44(d)(1)(vii)(A) and is subject to objection under 40
CFR §123A4(c)(8).
To ziddress this specific oble onthe State must revise the terms of the variance from the
m waterquaityNorth CarolA ;standardfor color for the Pigeon River to reflect the proposed
permit conditions and limits for color as referenced in Specific Objection 1 above. The
information necessary,to support a variance determination appears to have already been
developed by the f icility.id6brijunction with the TRW. Accordingly,EPA commits to timely
review and act on a request to revise and extend the variance upon the formal submittal of a
proposed variance revision by DWQ.
2 EPA notes that,based on comments during the public meeting and hearing,there are citizens who believe there is a
basis to complain about ambient color in the Pigeon River.
5

V ,
Recommendation For Site-Specific Study
In order to create a better record for any future effort to reinterpret the narrative color
standard, and ensure that authorized discharges are protective of the narrative standard, EPA
recommends the addition of a condition in the draft permit requiring the permiee to provide
funding for an independent study of color levels in the North Carolina segment of the Pigeon
River, or a segment of a watershed that is reasonably similar to the physical characteristics of the
Pigeon River downstream of the mill. The study should focus on the aspects of the State's
narrative color standard that are relevant to conditions and limits in the permit, and should
address assessment of color levels in ambient waters of the Pigeon Riv r(orother watershed(s),
as specified above) when those levels are in the range of 50 to 120`PCU. The permit could also
include a reopener clause to implement the conclusions of the tudy,if warranted.
EPA believes that an independent,'unbiased site-specif c`study wound*be useful to
determine how the State's narrative color standard should be interpreted or app)ied to the Pigeon
River near Canton. Such a study would be valuable'in addressing uncertainties<r lating..to the
narrative standard for color because many site-specific factors ifluence the ove all perception of
an individual stream setting and the level of protection needed fora stream or watershed.
Evaluation of the Pigeon River downstream of the Blue Ridge�mill is even more critical for
setting regulatory targets, given the coldr-levels in the river d'the public interest in the present
permitting process for the Blue Ridge facility.
The study should be conducted with �.biase�b"servers, fob; xample by using college
students (as was done in some of the studies performed byPrestrude). The results of the study
could be used by the State p adaddress other issues related to the application of the North Carolina
narrative color standard;s h aas,whether it woui`d,be more appropriate to establish a regulatory
requirement for thejrver'solely based on a specifictcolor concentration, or as an increment over
"background" color levels o alsdsuggest that EP�Y be involved in the review and approval of
the framework of-the plan for�conducting the-study prior to initiation.
S ecifi Objection 3: Tem erature Variance
R g ding temperafnte,.the permit implements a Clean Water Act(CWA) § 316(a)
variance by.requiring: 1) an%nstream monthly average of 32' C during July-September; 2) an
instream monthly,average o�29° C during the rest of the year; and 3) downstream values not to
exceed upstreain,values by more than a monthly average of 13.9' C. ("Delta T") Compliance
With these three co'ndfigns is assessed 0.4 miles downstream from the discharge at Fiberville
Bridge.
To obtain such a variance, an applicant is required by Section 316(a) and applicable
regulations at 40 CFR Part 125, Subpart H, to demonstrate that the proposed variance assures
the protection and propagation of a balanced, indigenous population of shellfish, fish, and
wildlife in and on the body of water into which the discharge is made("BIP"). The information
submitted with the draft permit is not sufficient to make the required demonstration. This
concern is heightened by a North Carolina Wildlife Resources Commission report indicating
that a September 2007 fish kill in the Pigeon River was, in part, due to elevated temperature. As
6

a result of the absence of a sufficient demonstration that the variance assures protection of a
BIP, the draft permit is subject to objection under 40 CFR §123.44(c)(7).
To resolve this objection, the permit must require completion of an updated study that
includes thermal modeling and demonstrates the protectiveness of the proposed variance;the
updated study should meet the parameters outlined in the enclosure to this letter. Further, in the
interim period before an adequate study is completed, a reduction in the Delta T limit should be
included in the permit to provide additional assurance that the BIP is protected. The current
Delta T limit was based on mill operating conditions prior to the modernization project
completed in the early 1990's, which included the installation of a mechanical draft cooling
tower. Based on daily temperature data taken at the Fiberville Bridge (River Mile 62.9) and the
Canton mill (River Mile 63.8) during January 2005 to December'2009,,EPA determined average
Delta T values for warm months (April through October) and cool months(November through
March). The 95th percentile values for average Delta T for the'warm and.:cool periods were
7.4° C. (13.28- F.) and 8.2' C. (14.69*F.),respectivelyAPA believes the average Delta T value
of 8.2° C. will be appropriate for all times of the year and could be adjusted pending the results
of the thermal modeling to be completed as part;ofthe Section 3'1.6(a) updated study:"Lastly, the
permit should require the mill to monitor and report the dail4y/m aziinum and monthly average
effluent temperatures.
Specific Objection 4: Absence of0ailwMaximum Dio in Limit and Fish Tissue
Monitoring
The draft permit contains a monthly average'diox t,-however, it does not include a
daily maximum limit, as re"-
daily ri ed,by 40 CFR Part-122.45(d)Q1)`�The draft permit is therefore
subject to objection pursuant to 40 CFR §123.44'(c)(7). To address this specific objection, the
permit must contain�a daily maximum dioxin limitt•.\That limit may be set at a level equal to the
monthly average limit. i
Ahso„the draft permit contains a new wprovis on that fish tissue monitoring for dioxin will
cease after'2009, unless-DWQ determines that a public health hazard exists. EPA routinely uses
ambient fish tissue dioxin.monitonngto determine whether water column impairment is
occur ni g,and whether reasonable poten ial to exceed a state's numeric dioxin criterion exists.
The fish tissue levels indicating,water column impairment are typically well below the levels at
which fish ad4isories are typically adopted. Based on North Carolina's dioxin numeric criterion
of 0.005 parts pet-quadrillion(ppq), the associated fish tissue value indicating impairment would
be approximately 0:025'pai�s per trillion(ppt). Out of the last five years of fish tissue data
collected by the facilityle els of dioxin detected in common carp at Station 4A in upper
Waterville Lake have been 1.1-1.3 ppt, with two years having estimated concentrations reported.
Assuming a linear relationship between water column concentrations and fish tissue
levels, these fish tissue concentrations would indicate a water column concentration in the range
of 0.22-0.26 ppq, thus exceeding the state's numeric criterion. In this case, direct measurement
of dioxin in fish tissue shows evidence of accumulation;reliance on effluent sampling alone
using method detection limits that cannot measure dioxin at the level of the state numeric
criterion does not.
7

V _ .
As a result, the removal of the dioxin fish tissue monitoring requirement as proposed in
the draft permit does not ensure that sufficient data is generated to adequately represent the
monitored activity, as required by 40 CFR §§ 122.410)(1) and 122.48(a)-(c). Requiring
monitoring in the event of a public health hazard is not adequate to determine if water quality
standards are being met. The lack of such data also does not allow for a complete evaluation of
the reasonable potential to exceed state water quality criteria as required by 40 CFR §
122.44(d)(1). Accordingly, the draft permit is subject to objection pursuant to 40 CFR §§
123.44(c)(5) and (7). To address this specific objection, the permit must require that the facility
conduct monitoring of fish tissue for dioxin(as was done in 2009) in the.first, third, and fifth
years of the term of this permit using a detection level that is as sensitrvc'as�possible. After
examining recent data, EPA is concerned that previous monitoring may have used a detection
level that was not as sensitive as it could have been. Annual incQbring:does not appear to be
needed since fish tissue levels have shown minor changes in recent years`,,
Specific Obiection 5: Absence of Turbidity Momt ring
EPA has previously requested that the State specif cally document in the permit fact sheet
the manner in which reasonable potential to exceed NortliCarolina=s,Class C criterion for
turbidity was evaluated ("the receiving water shall not excee880 Nephelometric Turbidity Units
in streams not designated as trout waters").,To the extent that sufficient data to make that
evaluation were not available, we further requested that specific.m°onit�ng to obtain the
information be required by the permit. The de"raff,.peimit and fact sheet:did not address these
concerns. `" mm
Therefore, the draftpermit,does not ensure'that the discharges authorized under the
permit are protective of North Carolina's numeric°criterion for turbidity. The lack of such data
does not allow for a�complete evaluation of the reasonable potential to exceed the state water
quality numeric criterio°cited above,.as required by,40 CFR § 122.44(d)(1), and as a result, the
draft permit does-not include effluent_limits`that.may be necessary to protect water quality. The
draft pe �s therefoie subject.to`objectio under 40 CFR §§ 123.44(c)(5), (7), and (8).
ZTo address this specific objec tion;fhe permit must require that the facility conduct
�
downstrstr
eam turbidity monitoring at Fiberville Bridge at a minimum frequency of twice per
month dung the April-October timeframe for a minimum of one year. Such monitoring must
not occur witfiin 72 hours of a rain event. The permit must also contain a specific reopener to
enable DWQ to add an appropriate turbidity limit if reasonable potential to exceed the State's
numeric criterion is found•to'exist. Based on North Carolina's numeric criterion, upstream data
are not needed and sh j d not be used to assess reasonable potential.
Specific Objection 6: Absence of Effluent Hardness Monitoring To Evaluate Zinc
Toxicity
The draft permit requires quarterly zinc monitoring because DWQ determined that
reasonable potential exists to exceed North Carolina's action level of 50 ug/l (based on an
assumed hardness of 50 mg/1). We are aware of a low upstream hardness value of 7.6 mg/l.
Because zinc toxicity increases at lower hardness values, any future evaluation of effluent zinc
8

data without concurrent effluent hardness monitoring cannot adequately assess reasonable
potential to exceed the action level.
Without concurrent effluent hardness measurements, the draft permit does not ensure that
sufficient data is generated to adequately represent the monitored activity, as required by 40 CFR
§§ 122.410)(1) and 122.48(a)-(c). Further,without such data,the draft permit does not allow for
a complete evaluation of the reasonable potential to exceed the hardness-based state water
quality numeric criterion for zinc, as required by 40 CFR § 122.44(d)(1), and as a result,the draft
permit does not include effluent limits that may be necessary to protect water quality. The draft
permit is therefore subject to objection under 40 CFR §§ 123.44(c)(5),,(7),and (8). To address
this objection,the permit must be revised to include a requirement for quarterly effluent hardness
monitoring concurrent with the quarterly zinc monitoring. F"/
Additional Comment Regarding AOX Limits
EPA also has the following comment regardin"g the draft permit limits\for,,a sorbable
organic halides (AOX), which reflect a 39% increaase jun,Ioadings from the 2001 ,pepr ff The
DWQ presentation at the recent public hearing and meeti gindicated that the facility is#2 in the
world in terms of AOX removal. Our analysis of recent AOX<ffluent data confirms the
facility's performance—the typical discharge is less than 300#lday as a monthly average. Based
on that performance, we recommend that`the AOX limits in thet2001 permit be retained.
Additional Comment Regarding TRW
The TRW has his oileally'performed a valuabl l assessing color reduction
efforts at the mill and vding recommendations to DWQ. We recommend that the permit
include a provision�eun"ng that theI RW will assess color reduction technologies and provide
recommendations to DWQat the�end,of this is�next pe/mut term.
To "ddressth�e )ie�cific bleotions, T askthat you redraft the permit and submit a proposed
permit anda revised faCt''sheet to`EPA for review under the provisions-of Section III.B.6 of the
MO t I� C so ask that yoU submit a sui aiy of the public comments that have been received
and )'s esponse to them.\In ac r ance with Section IV.B.7 of the MOA and 40 CFR
§123.44, within,ninety (90) days of your receipt of this letter, DWQ or another interested person
may request that a,public hearing be held,pursuant to 40 CFR §123.44(e). If no public hearing
is held, and DWQ does not 3esubmit a proposed permit that has been revised to meet our specific
objections within nine,(90) calendar days of receipt of this letter, exclusive authority to issue
the permit passes to EPA/for one permit term. Any requests for a hearing on the objections and
the procedure for resolving any objection shall be governed by 40 CFR §123.44, as provided in
Section IV.B.7 of the MOA.
9

If you have any questions,please have your staff contact Mr. Marshall Hyatt at 404-562-
9304.
Sincerely,
James D. Giattina
Director
Water Protection Division
Enclosure
cc: The Honorable Phil Roe \\\
Dane A. Griswold,Blue Ridge Paper Produc Inc.
John S. Curry, Esq.,North Carolina Environmental jVlanage`ment Commission
Jeffrey V. Morse,North Carolina Environmental Management Commission
Paul E. Davis, Tennessee Department,of Environment and,Conservation
David McKinney,Tennessee Wildlife Re'sourcey��`\
l
10

Section 316(a) Report and the Study Plan for the Subsequent Permit
Evergreen may use existing data in completing its study and may incorporate the
existence of such data into the monitoring program plan design; however, the existing data needs
to be evaluated and presented in the context of a BIP definition that the existing record does not
adequately provide.
Section 316(a) of the CWA contains the term"BIP"but does,iiotlefine it. However, 40
C.F.R. § 125.71(c) defines the term"balanced, indigenous community" as:
"A biotic community typically characterized by diversity, the c pacity to sustain itself
through cyclic seasonal changes, presence of neces`ssry food chaih,species and by a lack
of domination by pollution tolerant species. Such conmunity ma},in lude historically
non-native species introduced in connection with a program of wildlife''nianag went and
species whose presence or abundance resultsfiom substantial, irreversible,environmental
modifications. Normally,however, such a commuu'nity4ill not include species whose
presence is attributable to the introduction of pollutahttgthat will be eliminated by
compliance by all sources with section 301(b)(2) of�he Act: and may not include species
whose presence or abundance is atttib'ixtable to alternative effluent limitations imposed
pursuant to section 316(a)."
The Environmental Appeals Board stated in'its decision m In Re Dominion Energy
Brayton Point, LLC, 12 E�iromnental Appeals'D cision(E�A`D.) 490 (2006)("Brayton Point"),
"this definition clearlyenvisionsa consideration\of more than the population of organisms
currently inhabiting;t 64atter body.)In this vein,although it permits inclusion of certain
`historically non-native species' thatare currently present, it explicitly excludes certain currently
present species whose presence,or"abunda`rice is attributable to avoidable pollution or previously-
granted section 3I6(a)'variances..
Page 557 of the Brayton Point E:A D. goes on to further state that a BIP "can be the
indigenous population that existed pr%oi o the impacts of pollutants,not solely the current
populations of organisms. }l
To the question of how ape ittee should identify a BIP in an area that has been altered
s
by impacts from an extsttng'thermal discharge,the Brayton Point E.A.D.points out that it may
J nj
be appropriate to use a°=nearby water body unaffected by the existing thermal discharge as a
reference area. Examination of an appropriate reference area may be applicable in this case.
The definition of"balanced, indigenous community" at 40 C.F.R. § 125.71(c) contains
several key elements. To be consistent with the regulations, each of these key elements should
be specifically addressed in the demonstration, and the Lake Norman Maintenance Monitoring
Plan should be designed to generate information relevant to these elements. Those elements
include: (1) "a population typically characterized by diversity at all tropic levels;" (2) "the
'`Balanced,indigenous community'and BIP are equivalent terms.
11

capacity to sustain itself through cyclic seasonal changes;" (3) "presence of necessary food chain
species;" (4) "non-domination of pollution-tolerant species;" and (5) "indigenous." Each of
these elements is discussed in more detail below:
1. "A population typically characterized by diversity at all tropic levels" means that all of the
major tropic levels present in the unaffected portion of the water body should be present in the
heat affected portions. EPA recognizes that community structure differences will occur,
however,the number of species represented in each tropic level in the unaffected portions should
be reasonably similar in the heat affected portions of the water body. Sampling and analysis of
fish and invertebrate communities should be done such that the majorftropiclevels are identified
and represented by reasonably similar species distributions. Also, e study plan should be
expanded to include some observations of wildlife (i.e., water fowl;mammals, amphibians, etc.)
both upstream and immediately downstream of the discharge po nt that may be impacted by the
thermal discharge. �
2. "The capacity to sustain itself through cyclic seasonal changes"means that any,additional
thermal stress will not cause significant communiy-instability during times of naural�extremes
in environmental conditions. Community data should be collllebttehuring normal s asonal
extremes as well as during optimal seasonal conditions. Datasshould be compared between heat
affected and unaffected portions of the receiving water body-to account.for normal community
changes corresponding with a change in season: _<
3. "Presence of necessary food chain specieebthe nec pary food webs remain intact
a _. .
so that communities will be sustaining. We believe
that exhaustive food web studies are not
d,
necessary provided that inveiRe rab te, fish and wildlife commli6itres are otherwise healthy, i.e.,
represented by sufficiently high species diversity°+and abundance (appropriate for that portion of
.the receiving water�body), or the identifipic�levels and sustaining through normal seasonal
changes.
4. ."Non-dominate no ofDollution-t-oolleer species that in the case of a thermal effluent,
community assemblages.ili heat affected portions of the lake dominated by heat tolerant species
NI
do mot/onstitute a BIP."EP)grecognizes°that because all species have varying levels of thermal
tolerance; communities in tthe;heat 4cfeed portions of the water body may possess altered
assemblages;An terms of species present and abundance. All community data should be
collected, analy ed�and presented to clearly demonstrate that affected communities have not
shifted to primanly heat tolerant assemblages.
5. "Indi eg nous"has I yen further clarified in the regulations: "Such a community may include
historically non-native species introduced in connection with a program of wildlife management
and species whose presence or abundance results from substantial, irreversible environmental
modifications. Normally,however, such a community will not include species whose presence is
attributable to the introduction of pollutants that will be eliminated by compliance by all sources
with section 301(b)(2) of the Act: and may not include species whose presence or abundance is
attributable to alternative effluent limitations imposed pursuant to section 316(a)." EPA
recognizes that non-indigenous species are present in most aquatic systems in the United States.
All community data should be analyzed and presented to demonstrate that community
12

assemblages in the heat affected portions of the receiving water body are not significantly
different from non-affected communities with regard to the number of non-indigenous species in
the assemblages.
In addition to the foregoing components of the BIP definition, the study plan should also
include provisions for the identification of RIS (e.g., a list of threatened, endangered,thermally
sensitive, or commercially or recreationally valuable species in
up- and down-stream of the study area), as contemplated in 40 C.F.R. § 125.72(b). 40 C.F.R. §
125.71(b) defines RIS as "species which are representative, in terms of their biological needs, of
a balanced, indigenous community of shellfish, fish and wildlife in the bodyof water into which
a discharge of heat is made."
The following EPA comments should be specifically ad6re ed.i the study plan prior to
Evergreen commencing sampling during the term of thenext NP.DES permit. The plan should:
a) include available information on wildlife in the lake areas based o
communications with North Carolma,s Wildlife Management Agency. See
item 1 above. `
b) include a diagram depicting the thermal plume under the worst case scenario
and address the presence or abs n e of a zone of pass ge for which fish can
travel around the thermal plume'_' ^K
e) provide information of which fishicollectecl are either%heat-sensitive or
nuisance spec es:See item 4 above'
d) provide adist of anylake f pecies that are endangered or threaten in accordance with
federal and state regulations.
e) analyz-e a`ndpresent data to cleaily�demonstrate that affected communities
h ve inlide`;recent data or information on benthic macroinvertebrates. See item 1
above not shifted'to primarily
--heat tolerant assemblages
�g)4 analyze and present all data to demonstrate that community assemblages in the heat
affected portions of the receiving water body are not significantly different from non-
affected communities with regard to the number of non-indigenous species in the
assemblagys,_aannd'
h) include a thermal modeling study based on historical effluent temperatures and
operating conditions to determine appropriate permit limits for temperature.
In order to ensure that Evergreen's future study plan for the Pigeon River is adequate to
demonstrate that the Canton Mill should get continuance of a Section 316(a) variance during the
term of its next NPDES permit, EPA requests the opportunity to review a draft 316(a)plan prior
to Evergreen commencing the study.
13