NC0000272_Color Compliance Report_20060501

Color Compliance Report
MAY 2006 CANTON MILL
Canton,North Carolina
NPDES No. NC 0000272
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Table of contents
SUMMARY OF THE REPORT II[
1.0 INTRODUCTION 1
1.1 Purpose 1
1.2 Permit Requirement 1
2.o BLUE RIDGE PAPER COLOR REDUCTION INITIATIVES—CURRENT PERMIT TERM 4
2.1 Process Improvements 4
Figure 1—Color Reduction Initiatives Under 2001 NPDES Permit 5
2.1.1 Permit Required Initiatives 6
2.1.2 Additional Initiatives 6
2.2 Color Material Management 8
2.3 Color Treatment 9
2.4 Color Stream Elimination 10
2.5 Current Color Reduction Initiatives 10
2.5.1 Acid Sewer Rerouting 10
2.5.2 Color Process improvement Team 11
2.5.3 Color Reliability Projects it
j.0 EFFLUENT PERFORMANCE OF THE CANTON MILL 12
3.1 Historical and Current Performance 12
Figure 2—Annual Average Effluent Color,Blue Ridge
Paper Canton Mill 1988 Through March 2006 13
Figure 3—Annual Average Effluent Color 1997 through March 2006 14
Figure 4—Production—Normalized Effluent
Color 1997 through March 2006 14
3.2 Significant Color Actions 15
3.3 Benchmarking 15
3.3.1 Cluster Rule 16
3.3.2 Philp and Paper Industry Studies 16
3.3.3 NCASI 16
Just below the
Canton Mill on
the Pigeon Rivet

I
4.o EVALUATION OF CI ILOR IN THE PIGEON RIVER 17
4.1 Stream Monitoring Data 18
Figure 5—Monthly Average Color in the Pigeon River
at Fiberville,January 1977 -March 2006 18
Figure 6—Monthly Average Color in the Pigeon River
at HEPCO,January 1988—March 2006 19
Figure 7—Monthly Average Color in Pigeon River at the North
Carolina/Tennessee Line,January 1988—March 2006 19
4.2 Pigeon River Photographs 20
Figure 8—Pigeon River;Canton,NC to Newport,TN 21
j.D RECREATIONAL,ECONOMIC AND BIOLOGIGAI, HEALTH OF THE PIGEON RIVER 24
6.0 EVALUATION OF COMPLIANCE WITH THE NORTH CAROLINA COLOR STANDARD 25
6.1 North Carolina Color Standard 25
6.2 Analysis of the Standard 26
6.3 Conclusion 29
7.0 RECOMMENDATION 29
APPENDICES
(Included in separate notebook binder)
Appendix A—January 25,2006 Due Date Extension Letter for
Color Variance Report
Appendix B—Copies of Permit Required Reports
October 2003—Analysis of Color Performance, December 2001— August 2003
December 2003—Color Performance Following Highest Certainty Actions
and Evaluation of Reasonable Certainty Actions
March 2004—CRP Color Reduction Technology Assessment
December 2005—Color Performance Following Highest and
Reasonable Certainty
Appendix C—Executive Summary from 2005 Pigeon River Biological
Assessment Report

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Blue Ridge Paper
Products Canton
Mill

Summary of the Report
INTRODUCTION
The Blue Ridge Paper Products Inc. Canton Mill has achieved
extensive water quality improvements at the Canton Mill and
in the Pigeon River. This report documents those achievements,
specifically in the area of color reduction and effluent color
performance.
This report also evaluates stream color levels in the Pigeon River below
the Canton Mill and compliance with the North Carolina narrative water
quality standard for color. The report concludes that color in the ttt
Pigeon River below the Mill complies with all components of
the Color Standard including public health, ecological health,
recreational use, overall water quality and support of designated
uses.
The report is submitted to satisfy the requirements of Part I, Section
A.(8.),Paragraph 10 of the Canton Mill's December 2001 NPDES Permit:
"...the permittee shall submit a report to Division of Water Quality, the
Technology Review Workgroup and the NPDES Committee on the color
reduction efforts as part of the variance review process (Triennial Review of
North Carolina's Water Quality Standards).This report shall also include an
evaluation of color in the Pigeon River at the Fiberville Bridge, and an
evaluation on the feasibility of complying with North Carolina's Color
Standard."
COLOR REDUCTION IN CANTON MILL EFFLUENT
Color is a natural material produced in pulp manufacturing when wood
chips are cooked and the lignins,or glues binding the wood together are
dissolved. Blue Ridge Paper captures, recycles and treats more than 99
percent of the lignins produced in the pulp manufacturing process.
The 2001 Permit outlined three tiers of specific color reduction actions.
The tiers were,"Highest Certainty","Reasonable Certainty"and"Lowest
Certainty." It was the responsibility of the Mill to evaluate these items,
to implement those that were technically,economically and operationally
feasible,and to report the outcome of the evaluation and implementation
to the North Carolina Division of Water Quality ("DWQ"). The Permit

i
I
established effluent color limits and targeted reductions to be achieved
during the.Permit period:Blue Ridge Paper has completed actions
identified in the Permit and achieved the targeted color reductions.
The Highest Certainty and Reasonable Certainty actions were completed
by December 2003.Based on these actions and demonstrated performance
of the Canton Mill,the DWQ in consultation with the EPA Technology
Review Workgroup ("TRW"), lowered the effluent color limit for the
Canton Mill from 48,000 lbs per day to 42,000 lbs per day effective January
2004. In the February 27,2004 permit modification letter,Alan Klimek,
the Director of DWQ noted:
"The Division appreciates the continued progress of Blue Ridge Paper in
improving the quality of your treated effluent and the Pigeon River. We
n' anticipate continued improvement and progress toward the overall goal of this
process:removal of the color variance for Blue Ridge Paper by the expiration
date of the permit."
In addition to the actions above,Blue Ridge Paper has completed a number
of color reduction evaluations and projects not identified or specified in
the Permit.Color in Mill effluent as of May 2006 has been reduced to the
target range of 32,000 to 39,000 lbs per day envisioned in the 2001 Permit.
Since 1988, effluent color has been reduced by greater than 90
percent.
In December 2005,Blue Ridge Paper submitted its report on completion
of color-related action items identified in the Permit. That report
recommended reducing the Mill's effluent limit for color to 39,000 lbs
per day annual average.The DWQ accepted this report on January 25,
2006 and will make a decision on changes to Canton mill color limits
after consultation with members of the TRW during permit renewal.Blue
Ridge Paper believes 39,000 lbs per day is an appropriate annual average
effluent limit.
Blue Ridge Paper participates in color and wastewater treatment
benchmarking studies for the pulp and paper industry. The Mill is a world
leader among Kraft pulp and paper mills in wastewater effluent performance.
The Mill's current level of effluent color performance represents
the best color performance among North American mills and
complies with the North Carolina Color Standard.
Notwithstanding color reduction achievements and best-demonstrated
performance among its industry peers,Blue Ridge Paper remains committed
to the evaluation and implementation of further improvements to reduce
color at the Canton Mill.

COLOR REDUCTION IN THE PIGEON RIVER
Color in the Pigeon River downstream of the Canton Mill has
improved dramatically since 1988 as a result of the collaborative efforts
of Blue Ridge Paper,North Carolina,Tennessee,EPA,local governments
and interested citizens from eastern Tennessee and western North Carolina.
This report includes figures and photographs illustrating color reductions
and the aesthetic quality of the Pigeon River. Stream color in the river
has declined significantly since 1988 and has continued to decline during
the 2001 Permit term (see Figures S, 6 & 7 of the report).
RECRFAIIONAL USE OF THE RIVER
There is a successful commercial rafting industry in the Tennessee portion v
of the Pigeon River below the Walters Dam powerhouse. Recreational
use of the Pigeon River in North Carolina is increasing, but remains
limited by lack of a regular release of water as
occurs in Tennessee. Fishermen at Fiberville are
a frequent sight during spring and summer.
Waterville Lake and flat sections of Pigeon River
below Clyde have become good locations for
small mouth bass fishing. Property values in
Haywood County,including land along the Pigeon
River below the Canton Mill,have increased by
more than forty percent (40%) since 2002.
Property values m
Haywood County
Swimmen and have increased by
often enjoy the mom than 40%
waters of the since 2002
Pigeon River in
Tennessee

BIOLOGICAL ASSESSMENT
All forms of aquatic life in the Pigeon River are healthy. Blue Ridge
Paper,in collaboration with others,is supporting work by the University
ofrennessee to re-introduce non-game fish species into the Pigeon River.
This work began in Tennessee portions of the river in 2001 and expanded
to North Carolina sections in 2003.Monitoring of non-game fish species
re-introduction sites shows good survival and reproduction.During the
summer o£2005,Blue Ridge Paper completed,in cooperation with the
Department of Forestry,Wildli£e and Fisheries at the University ofrennessee,
a biological assessment of the Pigeon River from the Mill into Tennessee.
The study concludes that there is a diverse and healthy aquatic community
in the Pigeon River below the Mill.
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Progress Energy
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Monitoring non- A variety of groups have
game fish species m joined together to support
the Pigeon River the University of
Temessee project to re-
introduce non-game fish
to the Pigeon River

THE NORTH CAROLINA WATER QUALITY STANDARD FOR COLOR
The North Carolina water quality standard for color(the"Color Standard")
is a narrative standard that allows color:
"only(in)such amounts as shall not render the eaters injurious to public
health,secondary recreation,or to aquatic life and udldlife or adversely affect
the palatability offish,aesthetic quality or impair the waters far any designated
uses". 115A NCAC 02B.0211(3)(f))
Compliance with the Color Standard is determined by analysis of its
components.This report demonstrates that color in the Pigeon River
below the Canton Mill complies with the Color Standard as follows:
Public health — Stream water color is not related to public health. V1I
Color in the Pigeon River is not adversely affecting the public health.
Aquatic life and wildlife—The most recent biological assessment of
the Pigeon River was conducted in 2005.This assessment found a diverse
and healthy aquatic community in the Pigeon River below the Mill.
Color in the mill's effluent is not injurious to aquatic life or wildlife.
Palatability of fish—Stream water color is the result of lignin,a natural
material that does not affect the taste of fish.
Secondary Recreation —Current levels of color in the Pigeon River
are not limiting recreational use of the river. Recreational use of the
river in North Carolina is increasing.There is a successful commercial
rafting industry on the Pigeon River in Tennessee.
Aesthetic Quality —The diverse and healthy aquatic community in
the river,significant recreational use of the river and increasing property
values, including land along the river, demonstrate that the aesthetic
quality of the river is not adversely affected or impaired. The aesthetic
component of the Color Standard is met.
Taugenne Darter;
Assessments found
a diverse and
healthy aquatic
community in the
Pigeon P,iwr
below the Mill

Designated Uses —The Pigeon River below Canton is classified as
"Class C waters"in the State of North Carolina. Designated uses for
this classification are:aquatic life propagation and survival,fishing,wildlife,
secondary recreation,and agriculture. All designated uses for the Pigeon
River are supported.
The Blue Ridge Paper Canton Mill has achieved remarkable
reductions in effluent color since 1988 that have continued during
the 2001 Permit term. The reductions in effluent color are
reflected in reduced color levels in the Pigeon River below the
Canton Mill.There is a diverse and healthy aquatic community
in the river below the Mill.The river is being used for secondary
recreation in North Carolina and Tennessee. All designated uses
of the river are supported. At the current level of Canton Mill
v"' effluent color performance, color in the Pigeon River below the
Mill complies with the North Carolina Color Standard.
RECOMMENDATIONS
Blue Ridge Paper remains committed to evaluation and
implementation of further improvements to reduce color at the
Canton Mill and in the Pigeon River.
Based on the Canton Mill's demonstrated performance,Blue Ridge Paper
requests that DWQ reissue the NPDES permit for the Canton Mill with
an annual average effluent color limit of 39,000 Ills per day
Color in the Pigeon River below the Canton Mill complies with the
North Carolina Color Standard. The Color Variance for the Canton Mill
is no longer necessary. Blue Ridge Paper requests that the DWQ discontinue
the Color Variance at the end of the current NPDES Permit term in
November 2006.
Blue Ridge Paper ,;. i `"
terrains committed - T
to further ,.
improvements in y
the Pigeon River t "�
,

1.0 Introduction
1. 1 PURPU�I
This report documents color reduction efforts and effluent color performance
at Blue Ridge Paper Products Inc.Canton Mill (hereinafter"Blue Ridge
Paper,"and the"Canton Mill"or the"Mill"). Color is a natural material
produced in pulp manufacturing when wood chips are cooked and the
lignins, or glues binding the wood together are dissolved. Blue Ridge
Paper captures, recycles and treats more than 99 percent of the lignins
produced in the pulp manufacturing process.
The report also evaluates stream color levels in the Pigeon River below
the Canton Mill and their compliance with the North Carolina narrative I
water quality standard for color (the"Color Standard").The evaluation
concludes that color in the Pigeon River below the Mill complies with
all components of the Color Standard including public health,ecological
health,recreational use, overall water quality and support of designated
uses.
The report consists of the following sections:
• Introduction
• Blue Ridge Paper Color Reduction Initiatives—Current Permit Term
• Effluent Performance of the Canton Mill
• Evaluation of Color in the Pigeon River
• Recreational,Economic and Biological Health of the Pigeon River
• Compliance with the North Carolina Color Standard
• Recommendations
1.2 PERMIT REQUIREMENT
The requirement for this report is set forth in Section A.(8.),Paragraph
10 of the Canton Mill's December 2001 NPDES Permit (the "Permit"
or"2001 Permit"):
"By March 1,2006,the permittee shall submit a report to Division of Water
Quality,the Technology ReviewWorkgroup and the NPDES Committee on
the color reduction efforts as part of the Variance review process (Triennial
Review of North Carolina's Water Quality Standards). This report shall also
include an evaluation of color in the Pigeon River at the Fiberville Bridge,and
an evaluation on the feasibility of complying with North Carolina's Color
Standard."

The North Carolina Division of Water Quality ("DWQ"),extended the
March 1,2006 due date to May 31,2006 (See DWQ letter of January 25,
2006 in Appendix A).
The Permit established a series of actions and reports related to color
reduction at the Canton Mill.The Permit also established initial effluent
limits and targeted effluent color reductions based on color reduction
actions and actual performance of the Mill. The initial limits and targets
were:
December 2001 -48,000 Ibs per day (annual average)
December 2003 -40,000 - 42000 Ibs per day (annual average)
March 2006 -32,000 - 39,0001bs per day (annual average)
z
The actions and reports related to color reduction were classified as follows:
"Highest Certainty" action items were projects identified by Blue Ridge
Paper and the EPA Technology Review
Workgroup (TRW) as technically,
economically and operationally feasible.
All of these projects were implemented
during 2002 and 2003. Canton Mill
effluent color performance following
implementation of the Highest
Certainty projects was documented in
the October 2003 Color Report
included in Appendix B to this report.
+' "Reasonable Certainty"action items
were projects identified by the TRW
for possible application at the Canton
- - Mill. Blue Ridge Paper completed
= — evaluation of the Reasonable Certainty
action items during 2002 and 2003.
Results were documented in the
December 2003 Color Report included
in Appendix B. None of the Reasonable
Certainty actions were deemed
Blue Ridge Paper has technically,economically and operationally feasible. However,based on
completed ut mill performance as a result of the implementation of the Hi est
NPDES tegttitememsimprovedp P
cr related to Highest
Certainty.Reasonable Certaintyitems and other initiatives, Blue RidgeP
Paper achieved the
C
Certainty and Lowest targeted annual average color limit of 42,000 lbs per day before December
Certainty actions
2003. DWQ,in consultation with the TRW,revised the NPDES permit
to reflect new annual and monthly limits for color on February 27,2004.

The annual effluent color limit was lowered from 48,000 lbs per day to
42,000 lbs per day effective January 2004.
In the February 27, 2004 permit modification letter,Alan Klimek, the
Director of DWQ noted:
"The Division appreciates the continued progress of Blue Ridge Paper in
improving the quality of your treated effluent and the Pigeon Rivet We
anticipate continued improvement and progress toward the overall goal of this
process:removal of the color variance for Blue Ridge Paper by the expiration
date of the permit."
"Lowest Certainty" action items involved the evaluation of technologies
to treat or eliminate color from the Chloride Removal Process (CRP)
waste stream. Part I, Section A (8.), Paragraph 9 of the NPDES permit 3
identified several specific technologies for evaluation, including land
application, commercial incineration, coagulation / precipitation and
solidification for land disposal. Blue Ridge Paper identified and evaluated
other possible technologies including
ozone and chlorine dioxide bleaching.
However, based on engineering
evaluations and on bench and pilot scale
testing, no Lowest Certainty action
items were found to be technically,
economically and operationally feasible.
The results of the Lowest Certainty
actions were reported in the March
2005 CRP Color Reduction
TechnologyAssessment Report included
in Appendix B.The CRP Report was
originally due in December 2004,but
DWQ granted an extension to April
2005 following floods that affected the
Canton Mill in September 2004.
Blue Ridge Paper has completed
all NPDES requirements related
to Highest Certainty, Reasonable
Certainty and Lowest Certainty
actions for color reduction and has achieved the targeted effluent Blue Ridge Paper
g has achieved the
reductions in the 2001 Permit. In addition, the Canton Mill has targeted color
reductions in the
undertaken, and in some cases, implemented,color reduction initiatives zoos Permit
not specifically identified in the Permit. The December 2005 Color
Report documented these activities and recommended an annual average
color limit of 39,000 lbs per day. DWQ accepted this report on January

25,2006 and will make a decision on changes to Mill effluent color limits
after consultation with members of the Technology Review Workgroup.
Color reduction initiatives during the current Permit term are outlined
in Figure 1 and are summarized in the following section of this report.
More than 35 separate initiatives were undertaken at a direct cost of almost
$6,000,000.Appendix B contains copies of all color reports required under
the Permit.
2.0 Blue Ridge Paper Color Reduction Initiatives
- Current Permit Term
4 Color reduction initiatives during the current Permit term can be grouped
into five categories:
• Process Improvements
• Color Material Management
• Color Treatment
• Color Stream Elimination
• Current Color Initiatives
2.1 PROCESS IMPROVEMENT
Effluent color prevention,rather than treatment,is the primary focus of
Blue Ridge Paper's color reduction efforts.Process improvement initiatives
and evaluations during the current Permit term included:
•The 2001 Bleach Environmental Process Evaluation and Report (the
"Liebergott Report")
• An ozone / chlorine dioxide (ZD) stage evaluation for the hardwood
fiberline
•A second oxygen delignification stage evaluation for the pine fiberline
• Installation of mechanical seals in digester and knotter areas
• Improvements to handle knot rejects
• Improvements to the Bleach Filtrate Recycle (BFR) process
•Evaluation of the use of quaternary screen reject presses on both fiberlines
• Green liquor segregation in the recovery furnace area
•Acid sewer re-routing

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FIGURE I - COLOR REDUCTION INITIATIVES UNDER 200I NPDES PERMIT, BLUE RIDGE PAPER PRODUCTS INC. - CANTON MILL
Color Reduction Initiative / Project 2001 21102 2003 2004 2005 2006 Cost S
I Hrannlat dulyhryt. mN
I t I r4un 11 n.n. ndU o' ('?11111 W I'I.R R,pon) mcl .0 N H
4 U of OIl lu. ('I uille. . SI dl
4 I I s 1 Not .. K on1 ,,Ik I. .c w PHIL 81 c Ibtrrt 1 135,nUu
5 I I I ntr ct t t un,t 1}rqu . c lunuµ a uw
6 Insollanon of Morh.uuc..l Seal. Glr..n ten cr.cµnpantml I I I ! INn,ullll
7 hu nnermun of a m Incm used "I h.udln"PM'anJ I IanlouaJ tanttt Re cep_. I 1'S 500
1 I_1 b I I(1
fl Bleach Filtrate Rcccdc Inge orcutcnt. . 1 1 5.0,100
� ht all I FI rho um I I ht wq r t . . nr _ — { I IIflOt00f)
lu I> t unmt I uudul I. ' utnl ut n l . t .. u t d t amine Sevs t C n T t'I Color a
II I4 ueh ual au g,n u I tolo, tve.A >nuu
12 I Iw.issnoJ I.b..Luc Su S.t,w Ib...n 1 . I tot c.a.phu.v unm and plat uupn n'uu vt. I nti,nuu
13 1Inprovemout.ut,.de rat I'.nC IItOR'.h1T A .ump,to. h,ut. rrntcon' 1 �un.,Ynn
14 White Rut I u..ett. 1 1111 (S uac hclav I*IS It[ aehm., t ( R n. t u.. (See note below)*.. o I bJN
C
16 )nJ n}1.. r t 10 /11 Stat 1 u)I. is't I[)leach lin lab study(Set n ne bs luo)* - Jxx)
C
17 ' .l t �i,b,uihtauun ou I .ne-I h[tads (Sec note below)* cl t n y
Id ()/unc III.I•h.oti 14 et}lut rat, 1.11)pilot ntdIt.(Soe note bel(Iw)` _ _ tenon
19 I'm, 15n.au Kctucvn LwA I me to II)cd Not, I oa c. wd u. l;13
20 MA of l..... I 'A )Sec on I', I` _ m _S,roll
21 Land Apph,.mou..I( Ii boluw)*
w ( o. "I('RI'oav,sutaw (See non
23 Cu..y;ula[u.n/I'rtt tpnam a of('lll'wa.t ttn•am (Sec u t hclutcl* -.. 121I1 )
24 Suhthhnuum h,r I..uJ I h.po.a of ( R l'tsasm.vown (S note [)claw)*
'S I'.uc au,l Il vlwuod l?u t uan )rca ISLINIII
oC C.n,km I .ro.nlr m•at.u. rc ul —m:uu (lice uutc hd„m)` _ I5,110(I
27 1 nal to n ohm) .0 I sia• e t m( r( I0 I ..noon of ('K P,u Juarc full-scale apphcatinn
(tnals ann(I ¢,I dtrr SoI .H flood" ,c note I elo,t)` _ _.. 61,0101)
29 I'emxiJc I'naL on I lanlo of L"(Sec uon below)*_ _ -. A.Ut4I
29 GIe,'n I ¢µmt Sump at I of Cn tlunaaa. _ _ l 11)u000
$. Cli I'on I un I'rrruat I'.[it r(See uom [)t low)* .._... ..._
it I'nustJc lYt,t6 on line 1.0(S a uo.el),I�tm)`_............ ..._....._._... ..... _..,....... ._..........._. ..._...... ...._ � IS lltal
12 Md 31 1.3.IS,nUU
fall Pltruhou(Sev uote be(")* I?uull
i4 Color Protess Improvement Six titymta Team to examine operating mnditious associated with good
color perfomtame. _.
3-9Color Reliabli projects- rotes,and m g onimrin focus to reduce vartabli •of color erfonnance "' 446,1
Completed Prccesa Change/Evaluation Process Evaluation or Change Total S 3.89S,300
Continued Performance Improvement Expected Performance Improvement
• Inittiative detemtined not to be technically, operationally, or economically feasible
N

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2.I.1 PERMIT REQUIRED INITIATIVES
During 2001 through 2003, Blue Ridge Paper focused on process
improvements and color material management as the best opportunities
for color reduction. During this time period,the Canton Mill evaluated
and implemented, where technically, economically and operationally
feasible,the sixteen recommendations from the Liebergott Report. These
sixteen recommendations were identified by the TRW as having the
Highest Certainty for color reduction. In addition, Blue Ridge Paper
contracted with outside professional organizations to perform studies on
Reasonable Certainty actions identified in the permit involving the use
of an ozone / chlorine dioxide (ZD) stage for the hardwood fiberline and
a second oxygen delignification stage for the pine fiberline. Both of these
6 trials were unsuccessful as they did not achieve significant color reduction
and caused problems with pulp quality.
2.L.2 ADDITIONAL INITIATIVES
Blue Ridge Paper evaluated and implemented other color reduction '
initiatives not identified specifically in the Permit. Mechanical seals
were placed on the digester recirculation pumps and knotter feed pumps
on both fiberlines.These seals reduced color by removing clean water
dilution in the digester area sewer.Clean water dilution of color material
prevents its recovery.Less dilution led to more efficient recovery of colored
material in the digester area for return and re-use in the process.The Mill
made improvements on the equipment used to handle fiberline knot
rejects.The knot rejects improvements allow for greater recovery of black
liquor that drains from the rejects. Improvements were also made to the
Bleach Filtrate Recycle (BFR) process,increasing closure rates to reduce
color.These improvements contributed to color reduction by reducing
the amount of overall measured and unaccounted color in the mill sewer
system.
During 2004 and 2005,Blue Ridge Paper continued its focus on process
improvement by evaluating quaternary screen reject presses on both
fiberlines.These presses allow for dewatering of the screen rejects and
recovery of the resulting filtrate. Two presses were installed,one each on
the pine and hardwood fiberlines. However,the presses have experienced
mechanical reliability and vendor support problems,both during trials and
after implementation. In long-term use,it has been difficult to statistically
confirm color reduction in the effluent attributable to the reject presses. ,

In August 2005, the green liquor sump project was completed allowing
for better segregation of green liquor and black liquor in the recovery
furnace area.Green liquor contamination of black liquor prevents recovery
of the black liquor for process reuse.The separate green liquor process
sump has allowed more efficient collection and recovery of black liquor
materials. In December 2005,the mill completed re-routing of the acid
sewer to reduce the creation of sewer generated color in the waste treatment
process.
Finally,Blue Ridge Paper has invested substantial resources and time on
process optimization within each fiberline area.This effort was initiated
by a process improvement team examining the relationship between color
and hardwood brownstock washing during 2004.That project was a success,
and led to formation of a process improvement team looking at the pine 7
and hardwood fiberlines in late 2005.The 2005 process improvement team
examined process-operating parameters associated with periods of good
color performance.This work continues in 2006. The 2004 and 2005
improvement team findings led to an increased understanding
of conditions necessary to minimize effluent color from process
operations.At the end of 2005,the Canton Mill developed several color
reliability projects focused on color control during normal operations and
on the detection and control of color during process upset conditions.
These projects are in the planning stage and are discussed in Section 2.5
of this report.
Blue Ridge paper
evaluated and
implemented other
color reduction
initiatives not
identified
specifically in the
Permit

i
2.2 COLOR MATERIAL MANAGEMENT '
Color material management initiatives focused on improved detection
and improved segregation and recovery of color material, particularly
during process upsets and outages.These initiatives included:
• 2-hour color testing on Mill wastewater influent to treatment
• 1-hour color testing during maintenance outages and process upsets
• Development of tank draining schedules during outages
• Use of off-line spare clarifier for diversion of color material during
process upsets and outages
• Connecting the pine recovery tank to the hardwood blow tower for
additional capacity to recover color material
8 • Connecting the hardwood recovery tank to pine blow tower for
additional capacity to recover color material
•Additional overflow prevention control on pine brownstock
• Reliability improvements to pine fiberline area sumps
In 2001,the Canton NO began 2-hour color testing of wastewater influent
to detect short-duration elevated concentrations of color materials discharged
to the sewer. The wastewater treatment plant operators collect and analyze
a 2-hour composite sample of wastewater influent for color every two
hours (a total of 12, two-hour samples per day). Color concentrations
above normal are communicated to the Mill for immediate investigation.
Color sampling frequency is increased to 1-hour intervals during planned
maintenance outages to shorten the response time to elevated color events.
Concurrent with 1-hour color monitoring during outages, the Mill
developed formal tank draining schedules for maintenance outages where
only the necessary vessels are emptied for inspection and maintenance.
Process tanks scheduled for maintenance are drained in sequence to
maximize recovery of color material.Also in 2001, the Mill improved
procedures to divert elevated concentrations of color material into an off-
line spare primary clarifier for treatment and later release at a controlled
rate to the wastewater treatment plant.
During 2002 and 2003, the Mill increased its capacity to capture color
material from the hardwood and pine fiberlines.This was accomplished
by adding the capability for each fiberline's spill collection system to be
routed to the other.This way when the spill collection system of one
fiberline is full of color material from an outage or process upset, this
material can be pumped to the other fiberline collection system thus
increasing the effective recovery capacity of each fiberline. In 2003, t

improvements were made to the pine fiberline sumps to improve the
detection and recovery of elevated color material.Finally,during the first
quarter of 2003,new alarms and process control interlocks were implemented
on the pine brownstock system to minimize overflow of high color
materials from process tanks into the mill sewer system.
2.3 COLOR TREATMENT
Although the primary focus of the Canton Mill is color prevention and
reduction through process improvement,the Mill has undertaken studies,
pilot tests and other initiatives aimed at reducing effluent color through
treatment of particular waste streams. These initiatives included:
9
• Ozone treatment of the final effluent
• Ozone treatment of the Hardwood Eo color stream
• Ozone treatment of the CRP color stream
• Coagulation / Precipitation on the CRP color stream
• Chlorine dioxide (C102) treatment of the CRP color stream
• Peroxide treatment of the Hardwood and Pine Eo color streams
• Enzyme treatment of the Hardwood and Pine Eo color streams
• Peroxide and enzyme (TAML) treatment of the Hardwood Eo color
stream
•White Rot fungus trial
• Lime trials on the mill wastewater from CRP
For various reasons,none of these initiatives were technically,economically
or operationally feasible. Some initiatives,such as white rot fungus,appeared
promising in lab scale tests,but failed during full scale trail. Others,such
as color treatment of Eo filtrate or CRP,produced no statistically significant
reduction in Mill effluent color. Others,such as coagulation/ precipitation
and ozone treatment of final effluent,were not feasible due to treatment
chemical cost or solid waste handling issues.

i
2.4 COLOR STREAM ELIMINATION
Color stream elimination is a color prevention approach directed at
elimination or reduction of a color material waste stream inside the Mill.
The successful BFR process that greatly reduces the sewering of color
material in pine pulp mill filtrates is an example.Color stream elimination
initiatives by Blue Ridge Paper during the current permit term focused
on the CRP purge stream and included:
• Land application
• Commercial incineration
• Solidification for landfill disposal
•Applying the CRP stream to the lime pre-coat filter for dewatering
Io and landfill disposal
Based on engineering evaluations,commercial quotes and full scale trials,
none of these alternatives for eliminating the CRP purge stream were
technically, economically and operationally feasible.A more detailed
discussion of these initiatives is included in the CRP Report in Appendix B.
2.5 CURRENT COLOR REDUCTION INITIATIVES
The Canton Mill has seen its greatest success in effluent color reduction
from color prevention and color material management.These approaches
are the focus of current color reduction initiatives discussed in the December
2005 Color Report included in Appendix B.The current status of these
projects is discussed below.
2.5.1 Acid Sewer Rerouting
In the October 2003 Color Report (Appendix B), Blue Ridge Paper
identified sewer-generated color as a significant source of unaccounted
color in the Canton Mill sewer system. Pulp mill effluent color is a pH-
dependent characteristic. Sewer-generated color is created when acid
bleach plant filtrates and other pulp mill wastewaters mix with alkaline
wastes in the Mill's sewer system.This additional color does not diminish
when wastewater pH is adjusted to neutral range. The sewer-generated
color phenomenon is complex and not completely understood by the
pulp and paper industry. Mill sewer color monitoring suggests that
segregating acid bleach plant filtrates from strong alkaline wastewaters
reduces the amount of sewer-generated color. '

As a part of its continuing efforts to reduce color, the Canton Mill
segregated its alkaline and acid wastewater streams in December 2005.
The acid sewer rerouting has been fully operational since January 2006.
With rerouting of the acid sewer,bleach plant acid filtrates are mixed with
other mill wastewaters after neutralization for treatment.As a result,
exposure of these filtrates to strongly alkaline conditions is avoided. The
acid sewer project is configured to allow bleach plant filtrates to mix with
either primary influent or primary effluent wastewater prior to secondary
* treatment.
s
Blue Ridge Paper believes the Acid Sewer Rerouting has a favorable effect
on effluent color by reducing the amount of"sewer generated color"in
the mill sewer system.However,several consecutive quarters of mill sewer
and effluent color data are required before benefits from the acid sewer it
rerouting can be fully quantified.
2.5.2 Color Process Improvement Team
A process improvement team was chartered in September 2005 to examine
the operating conditions associated with periods of lowest color performance.
The team examined process parameters associated with the pine and
hardwood fiberlines with a focus on what conditions, if any, changed
during periods of better color performance. For the time period under
consideration, the team found that improved pulp washing on the pine
fiberline contributed directly to better color performance.The team
identified ways to improve washing including:
• Periodic clearing of scale deposits in the pulp washing showers
• Periodic jetting of the pulp washing shower line
• Design modifications to existing pulp washing shower bars
The hardwood fiberline analysis indicated that better brownstock washing
led to improved color performance.Specific details to implement process
improvement team recommendations are under development.
1.5.3 Color Reliability Projects
Blue Ridge Paper has dedicated resources in 2006 to improve the reliability
of processes that have a demonstrated impact on color performance. These
projects focus on pulp washing efficiency,engineering controls to further
improve early detection of process upsets that may release color,and further
reliability improvements to the BFR process.These projects are scheduled
for completion in 2006.

3.0 Effluent Performance of the Canton Mill
The history of Canton Mill color performance and improvement are
important to understanding compliance with the North Carolina Color
Standard discussed in Section 6.0 of this report.
3.I HISTORICAL AND CURRENT PERFORMANCE
Figure 2 illustrates annual average effluent true color discharge in 1000
Ibs per day from the Canton Mill from 1988 through 2005. Year-to-date
information through March 2006 is included.
cz
The effluent color discharge from the Canton Mill in 1988 averaged
380,000 lbs per day. In 1990, the Mill announced the Canton Mill
Modernization Project (the "Modernization Project"), a $300 million
dollar project to modernize the Canton Mill and improve effluent
performance.The Modernization Project,which began in 1990 and was
completed in 1994,converted the Mill to elemental chlorine free (ECF)
bleaching and installed new and modified fiberlines for manufacture of
hardwood and pine bleached Kraft pulp.The Modernization Project also
included extensive process water reuse and recycling.As a result of the
Modernization,effluent color in 1994 was reduced by 80 percent compared
to the 1988 baseline year. Wastewater discharge decreased by approximately
20 million gallons per day (mgd).
The Canton Mill continued to reduce color after the Modernization.
Black liquor loss controls were implemented in the mid-1990s in anticipation
of EPA's Cluster Rule for Pulp and Paper.The Bleach Filtrate RecyclingTM
(BFR) project in 1998 and 1999 yielded an additional 15,000 to 20,000
Ibs per day of effluent color reduction. By the end of 1999,the Canton
Mill had reduced wastewater effluent color by 330,000 lbs per day or
approximately 89 percent from 1988 levels.
Figures 3 and 4 illustrate Canton Mill effluent color performance from `
1997 through March of 2006. Blue Ridge Paper Products Inc.became
the owner of the Canton Mill in May 1999 when the employees with
help from the KPS Special Situations Fund purchased the mill from
Champion.
NPDES Permits issued by North Carolina in 1997 and 2001 included
specific color reduction measures and requirements to evaluate and
implement other technologies to reduce color if technically,operationally

Figure 2 -ANNUAL AVERAGE EFFLUENT COLOR
Blue Ridge Paper Canton Mill, 1988 thru Mar 2006
r 450
400 380
a 350 333
301 307
c" 300
e TL50 243
0 200
0 150 120
7 100 76 78 83 62
w48 w41 43 43 41 45 40 39
W 500 _ _J Jam_ 13
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006
YTD
Canton Mill has
reduced color by
greater than 909%
and economically feasible.The effluent color reduction achieved under
the 1997 and 2001 Permits is documented in Figures 3 and 4.A number
of the technologies included in the 2001 Permit were selected by the
TRW based on its evaluation of the Liebergott Report, a study of the
Canton Mill conducted by Norm Liebergott and Lewis Shackford,through
a unique partnership between Blue Ridge Paper and Clean Water for
North Carolina.
Figures 3 and 4 demonstrate that Blue Ridge Paper achieved continued
effluent color reductions during a period of great economic change in
the pulp and paper industry and related production volumes changes at
the Canton Mill.The overall reduction in wastewater effluent color
between 2005 and the pre-modernization baseline year of 1988
is greater than ninety percent (90%).

Figure 3 - ANNUAL AVERAGE EFFLUENT COLOR
Blue Ridge Paper Canton Mill, 1997 thru Mar 2006
80
N 70 -- 62 BFR & Cluster Rule - Color Improvement
a 60
0 50 ---- 45 43 4" 41 45 4Q 39 - ------
- 40 36--—
0
U 30
c 20
m
10
w 0
14 1997 1998 1999 2000 2001 2002 2003 2004' 2005 2006
TYD
Recycling and pollution
prevention technology are the
focus of Blue Ridge Papers'
Color reduction efforts
Figure 4 - PRODUCTION-NORMALIZED EFFLUENT COLOR
Blue Ridge Paper Canton Mill,1997 thru Mar 2006
60
a BFR&Cluster Rule BMPs
CO 50 46•7 Color Improvement Projects
0
Q 40 35.6
o. 33.9 32.5 33.2
31 2 30.8
` 30
0 eii s
0 24.9
a 20
10
1997 1998 1999 2000 2001 2002 2003 2004' 2005 2006
TYD
The Canton Mill wastewater
efiluent performance is among
the best of Kraft pulp and
paper mills in the world

3.2 SIGNIFICANT COLOR ACTIONS
As a result of continuous efforts to reduce color, the Canton Mill has
achieved the targeted color reductions envisioned in the 2001 Permit. Of
the many color improvement initiatives evaluated and implemented at
Canton Mill,the following are essential to historical and current effluent
color performance:
•Canton Mill Modernization—OD 100TM process-oxygen delignification,
elemental chlorine free bleaching and enhanced fiberline brown stock
washing
• Bleach Filtate RecyclingTM — BFR with minerals removal process
(MRP) and chlorine removal process (CRP)
IS
• Mechanical seals on pumps in digester and knotter areas to minimize
clear water dilution of color materials that prevents efficient recovery
• Daily mill sewer color monitoring with planning and enhanced sewer
monitoring for color control during outages
• Interconnection of process spill sumps and equipment to increase
recovery of color material during process upsets and outages
• Segregation of black liquor from green and white liquor to avoid
contamination that prevents recovery of black liquor materials
• Segregation of bleach plant acid filtrates from high pH conditions in
mill sewers to reduce sewer generated color
3.3 BENCHMARKING
As part of its color reduction effort,the Canton Mill participates in color
and wastewater treatment benchmarking studies for the pulp and paper
industry. There are three primary benchmarks:
• EPA Cluster Rule
• Pulp and Paper Industry Studies
• NCASI

3.3.1 Cluster Rule
The EPA Cluster Rule (40 CFR 430, Subpart B) establishes minimum
performance standards for treated wastewater effluent from Kraft pulp and
paper mills. The Canton Mill's 2005 overall wastewater effluent performance
is less than twenty percent (20%) of allowable discharges under the EPA
Cluster Rule.While the Cluster Rule does not establish effluent standards
for color,it includes minimum performance standards for control of black
liquor materials.The performance of the Canton Mill for black liquor loss
control far exceeds these minimum regulatory requirements.
3.3.2 Pulp and Paper Industry Studies
16
EKONO, Inc. is a consulting company specializing in benchmarking
studies for the pulp and paper industry. Based on information from a
recent EKONO report(Environmental Performance,Regulations and Technologies
in the Pulp and Paper Industry,August 2005),the Canton Mill wastewater
effluent performance is among the best of Kraft pulp and paper mills in
the world. Canton Mill color performance is among the best of North
American mills with a similar mix of hardwood and pine pulp production.
Of mills achieving effluent color control primarily through in-process
means (color prevention),the Blue Ridge Paper Canton Mill is the best
of the best.
3.3.3 NCASI
The National Council for Air and Stream Improvement (NCASI) is the
environmental research organization for the pulp and paper industry.
NCASI periodically sponsors technical conferences on effluent color.
Blue Ridge Paper is an active participant in these conferences and has
presented technical papers and other information about the Canton Mill.
In January 2006, NCASI,Blue Ridge Paper and other pulp and paper
mills sponsored a literature review and benchmarking study on color
reduction technologies applicable to Kraft pulp and paper mills. The last
such study was conducted by NCASI in 1995. The contractor selected
for the NCASI study was EKONO,Inc.
The NCASI color review and performance study (Review of Color Control
Technologies and Their Applicability to Modern Kraft Pulp Mill Wastewaters,
Final Draft May 2006) will be formally published and available in the late
summer and fall of 2006.There are several conclusions drawn from the

NCASI study pertinent to this report.
• Each pulp and paper mill is unique with respect to its technical
approaches and success with color reduction.There is no "one size
fits all solution".
• There are several common elements to successful color reduction
among the mills with best color performance. These include elemental
chlorine free bleaching with oxygen delignification,black liquor loss
control,pulp washing efficiency,frequent mill sewer monitoring and
advance planning for color control during process upsets and outages.
• Some technical approaches to effluent color reduction exclude other
approaches. In the case of the Canton Mill,the investment in OD100, 17
BFR,and black liquor loss control reduced effluent color to the point
that improvements from other potential process modifications and
color treatment technologies are marginal.
• Based on benchmarking and literature review studies and the Mill's
current level of effluent color performance,the Canton Mill continues
to be the leader in effluent color and control among integrated bleached
( Kraft pulp and paper mills.
4.0 Evaluation of Color in the Pigeon River
Blue Ridge Paper conducts routine stream sampling along the Pigeon
River from Canton to the North Carolina /Tennessee Line ("NC /TN
Line"). Blue Ridge Paper also supports the maintenance of United States
Geological Survey stream flow gauging stations at Canton and HEPCO.
Stream color samples have been collected at HEPCO and at the NC /
TN Line since 1988. The HEPCO sampling station is the HEPCO Bridge
on Fines Creek Road, Exit 15 off 1-40 in the Pigeon River Gorge.
HEPCO Bridge is 20.7 river miles below the Canton Mill.The NC /
TN Line sampling station is Brown's Bridge at Waterville,Exit 451 off I-
40 in the Pigeon River Gorge. Brown's Bridge is 38.6 river miles below
the Canton Mill. Stream color samples have been collected at Fiberville
since 1997.The Fiberville sampling station is the Highway 215 Bridge
immediately downstream of the Canton Mill.

4.1 STREAM MONITORING DATA
Stream monitoring data allow an evaluation of color in the Pigeon River
from Canton,North Carolina into Tennessee. Monthly average in-stream
true color expressed in platinum cobalt (PtCo) color units is presented
in Figures 5,6 and 7 for Fiberville,HEPCO and the NC /TN Line.The
color test methods are specified in the Canton Mill's 2001 NPDES Permit.
Stream monitoring data for color presented in Figures 5, 6 and 7 were
determined by spectrophotometer using NCASI method 253 (1971) as
modified by NCASI Method 71.01 (1999).
Fiquw 5-MONTNLy AVERAGETRUE COLOR IN TNF.PIGEON RIVER AT FIBERVILLE
January 1997 thmugh Mamh 2006
225
200
175
150
m
125
0
c 100
U
m
75
50 -
25
0
1` 1` h O tl 0 g p OI O O ry N N f1 q MI tl tl Np
Figures 6 and 7 illustrate the dramatic and continuous reduction of color
in the Pigeon River since 1998 as result of the Canton Mill Modernization
and color improvement projects undertaken during the 1997 and 2001
NPDES Permit terms. Monthly average color at HEPCO during the
current Permit term beginning December 2001 has averaged 24 true color
units. Monthly average color at the NC /TN line during the current
Permit term has averaged 17 true color units.

[]..
FIgUI¢6-MONTHLY AVERAGE TRUE COLOR IN THE PIGEON RIVER AT 11L_PCO
January 1988 through Match 2006
350
325 _-
300
275
250
m 225
C 200
.7
`0 175
V 150
125
~ 100
75 — —
50
— — 19
—
0
9 N V d N N m
01 N T m P 01 Of P N N A N P m 01 PY_ Q mi . m 4 4 -3 4 4 4
m m W m m W m W m m m m m lC m N m W
Figure 5 data for Fiberville illustrate continuous reduction of color in the
Pigeon River immediately downstream of the Canton NO.During the
last three years beginning December 2002, monthly average color at
Fiberville has been 31 true color units with a median of 29 true color
units.Periods of higher than average color in Figure 5 correspond with
periods of low stream flow. At the current level of Canton Mill effluent
color performance, true color at Fiberville will be 50 color units or less
whenever stream flow at Canton is greater than 120 million gallons per
day (mgd)•
Figum 7-MONIAI.Y AVERAGE TRUE COLOR IN THE PIGEON RIVER
AT THE NORTH CAROLINA/TENNESSEE LINE
225 -- 1988 t1muA March 2006
200
150
m
7 125
`m
p 100
U
m
75
r
50 L ik
25
0
0 N O 01 O O N N OI NI ,R 4 49
T N
er ap ap epmq� am W mmm �j � yim m, 4' ?101 ?' ?' 444444 _ 999

¢? PIGEON RIVER PHOTOGRAPHS
The following are photographs taken May 1, 2006 from downstream of
the Canton Mill.Figure 8 is a schematic of the Pigeon River from above
Canton,NC to Newport,TN and shows the locations of the photographs.
Photo I—Pigeon p
River at Fibemlle
downstream of
Canton Mill
20
r
4'
Now 2—Pigeon
Riverat Thickety, -
2 miles dos nn
of Canton Mill i l�

Figure 8
PIGEON RIVER CANTON, NC TO NEWPORT,TN
• French Broad
Newport, Rrper
TN(RM
O
{4
2I
r4 �1
�S
o Bluf&on,TN �46
OR
H=ford,TN &
r,%. e U
i
��iers
UL L b hl-1111?
v° o p�
3` 00 %00
�sscc x qS 3 W4 h
p y9' (� Phuc.3
�Z 010 ry
Y
S
�� r b' Mill Ontfall
L l,
OC 1 OJ clY& •cmt..
�� GS
Asa
North
- :Mlles

r
? .
1
i
� � Y
� rae�tiR'ft •yiY-� •.

Phom 5—Browns
Bridge near NC/TN
line
23
Photo 6—Pigeon
River near
Hartford,TN
a
- " Phow 7—Pigeon
- * - River at Tannery
Island above
Newport,TN

i
5.0 Recreational, Economic and Biological Health of
the Pigeon River
There is a successful commercial rafting industry in the Tennessee portion
of the Pigeon River below the Walters Dam powerhouse.Recreational
use of the Pigeon River in North Carolina is increasing, but remains
limited by lack of a regular release of water as occurs in Tennessee.
Fishermen in Fiberville below the Canton Mill are a frequent sight during
spring and summer. Waterville Lake and flat sections of Pigeon River
below Clyde have become good locations for small mouth bass fishing.
Property values in Haywood County, including land along the Pigeon
River below the Mill have increased by more than forty percent (40%)
since 2002.
24 Blue Ridge Paper and others are supporting.work by the University of
Tennessee to re-introduce non-game fish species into the Pigeon River.
This work began in Tennessee portions of the river in 2001 and was
expanded to North Carolina sections in 2003.Monitoring of non-game
fish species re-introduction sites shows good survival and reproduction.
During the summer of 2005,Blue Ridge Paper completed,in cooperation
with the Department of Forestry,Wildlife and Fisheries at the University
ofFennessee,a biological assessment of the Pigeon River from the Canton
Mill into Tennessee. This assessment found a diverse and healthy
aquatic community present in the Pigeon River below the Mill.
Measures of biological health in the river during 2005 continue to maintain
or improve from previous biological assessments conducted in 1995 and
2000.The executive summary from the 2005 Biological Assessment Report
for the Pigeon River is included in Appendix C.

6.0 Evaluation of Compliance with the North Carolina
Color Standard
This section examines current conditions of stream color in the Pigeon
River below the Canton Mill and compliance with the North Carolina
water quality standard for color.
6.1 NORTH CAROLINA COLOR STANDARD
The North Carolina water quality standard for color (Color Standard) is
a narrative standard set forth in Title 15A,North Carolina Administrative
Code,Subchapter 213,subparagraph.0211 as follows:
15A NCAC 2B.0211 Fresh Surface Water Quality Standards 29
for Class C Waters
General. The water quality standards for all fresh surface waters
are the basic standards applicable to Class C waters. ...
(1) Best Usage of Waters. Aquatic life propagation and maintenance of
biological integrity (including fishing and fish),secondary recreation,
agricultural and any other usage except for primary recreation or as a
source of water supply for drinking water, culinary or food processing
purposes; ...
(3) Quality standards applicable to all fresh surface waters:
(f} 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 offish,
aesthetic quality or impair the waters for any designated
uses ...
North Carolina has never established a numeric stream color standard.
No river or stream in the state has a numeric standard for color,and for
streams where color is regulated,numeric discharge standards are applied
on a site-specific basis (for example,Clark Creek tributary to South Fork
Catawba River).The only way to determine compliance with the Color
Standard is to consider its components.

6.2 ANALYSIS OF THE STANDARD
The North Carolina Color Standard has six components:
• Public health
•Aquatic life and wildlife
• Palatability of fish
• Secondary recreation
•Aesthetic quality
• Designated uses
An analysis of these components follows:
26 Public Health - Stream water color is not related to public health,and
stream water color in the Pigeon River is not affecting public health. The
ecological health of the Pigeon River has improved dramatically since
1988 and is continuing to improve.
Aquatic Life and Wildlife - The Pigeon River has been sampled
emcnsively for fish and macroinvertebrates since 1987.The most recent
biological assessment was conducted in 2005.There is a diverse and healthy
aquatic community in the Pigeon River below the Mill.
Since 1997 the Canton Mill wastewater effluent has been subjected to
EPA Whole Effluent Toxicity testing using a very pollutant sensitive
indicator species (Ceriodaphnia). The mill has passed all of these tests at
90 to 100% effluent concentration. Based on more than eight years of
this testing and the diverse and healthy aquatic community in the river,
color in the river is not injurious to aquatic life.
Pigeon River at Clyde
x fir

i
Finally,NCASI has summarized research on the biological impacts of color
in streams receiving pulp mill effluents (NCASI Special Report 94-07, Human
Perception and Biological Impacts of Kraft Mill Effluent Color,June 1994). This
NCASI work indicates that stream color concentrations below 100 color
units have no effect on the health of aquatic organisms.Color levels in the
Pigeon River downstream of the Canton Mill are consistently well below
this 100 color unit threshold.
Color in the mill's effluent is not injurious to aquatic life or wildlife.
Palatability of Fish - Stream water color is a result of lignin, a natural
material that does not affect the taste of fish. Color is not a parameter
associated with fish palatability.
27
Secondary Recreation -As discussed in Section 5.0,recreational use of
the Pigeon River in North Carolina is increasing. There is a successful
commercial rafting industry in Tennessee. Color is not impeding recreational
use of the river.
Aesthetic Quality -An examination
of water quality standards for color in
the 27 states in EPA Regions 1-5
showed that 22 of the states relied on
a narrative standard similar to North
Carolina.Most of those states have not
adopted any numeric interpretation 4
of their color standard.
For the Pigeon River, no numeric
interpretation of the narrative color
standard has been established by the "� •e
state of North Carolina.Fifty (50) units
of true color, measured in platinum
cobalt units and used for the Canton
Mill Color Variance, is EPA's .y ;1
interpretation of the North Carolina
standard. In choosing 50 color units,
it is believed that EPA relied on
information derived from a 1975 NCASI Study.This study focused on There is a
susf
perception of color concentration changes detectable to human observers coC e i
rommercial
in streams receiving pulp mill effluents (NCASI Technical Bulletin No. 283, aCring indnury
in Tennessee
A Study to Define Changes in Pulpmill Effluent-Contributed Color in Receiving
Waters Detectable to Human Observers, December 197.5).

1
Perception of stream color is subjective and varies due to environmental
factors including light conditions, water depth, bottom visibility and
contrast, water turbidly,position of the observer and land uses adjacent
to the stream. Perception of change in color is not an objective standard
and should not be the single factor used to assess compliance with the
aesthetic component of the Color Standard.
The aesthetic quality of the Pigeon River is best measured by actual use
of the river,the ecological health of the river and property values in the
surrounding community. Recreational use of the river in North Carolina
New home is increasing. There is a successful commercial rafting industry in the
construction on the Tennessee portion of the river. There is a diverse and healthy aquatic
Pigeon River below
Clyde community in the Pigeon River,reflecting dramatic improvements since
1988. Property values in Haywood
County, including land along the
Pigeon River below the Canton Mill,
have increased by more than forty
percent(401/6) since 2002. These factors
demonstrate that the aesthetic quality
of the Pigeon River is not adversely
affected or impaired. The aesthetic
i component of the Color Standard
is met.
r
Designated Uses— The Pigeon River
.. r
is classified as"Class C waters"in the
State of North Carolina. Designated
uses for this classification are: aquatic
life propagation and survival,fishing,
wildlife, secondary recreation, and
' agriculture.As documented in this
report all designated uses for the
Pigeon River are supported.
Biological sampling of
the Pigeon River in
2005

6.3 CONCLUSION
The Blue Ridge Paper Canton Mill has achieved remarkable reductions
in effluent color since 1988 that have continued during the 2001 Permit
term.The reductions in effluent color are reflected in reduced color levels
in the Pigeon River below the Canton Mill. There is a diverse and healthy
aquatic community in the river below the Mill. The river is being used
for secondary recreation in North Carolina and Tennessee.All designated
uses of the river are supported.At the current level of Canton Mill effluent
color performance, color in the Pigeon River below the Mill complies
with the North Carolina Color Standard.
Blue Ridge Paper remains committed to efforts and initiatives
to further reduce effluent color as these technologies and actions
become technically, operationally and economically feasible for zq
the Canton Mill.
7.0 Recommendation
Based on the Canton Mill's demonstrated performance,Blue Ridge Paper
requests that DWQ reissue the NPDES permit for the Canton Mill with
an annual average effluent color limit of 39,000 lbs per day.
Color in the Pigeon River below the Canton Mill complies with
the North Carolina Color Standard.The Color Variance for the
Canton Mill is no longer necessary. Blue Ridge Paper requests
that the DWQ discontinue the Color Variance at the end of the
current NPDES Permit term in November 2006.