NC0000272_Dissolved Oxygen Above Clyde Doc._20071019

BLUE RIDGE
PAPER PRODUCTS INC.
19 Oct 2007
Roger Edwards
Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Re: Dissolved Oxygen Above Clyde on 10/16/2007
Canton Mill
NPDES NC0000272
Dear Mr. Edwards —
p E C E I V D
OCT 2 2 Zorn
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
As discussed with you on 10/17/2007, the daily average dissolved oxygen (DO) in the Pigeon River
above Clyde on 10/16 was 4.95 mg/l. From our discussion and considering DO meter accuracy,
rounding and significant figures in the Canton Mill permit limits for DO, the Division determines that this
value is in compliance with applicable requirements. The Division also agrees that requirements to
monitor DO at sampling stations DN3 and DN4 below Clyde were not triggered.
Blue Ridge Paper started the Site E (Thickety) oxygen station on the Pigeon River at 2 pm on 10/16. The
decision to start the oxygen station was made after a dissolved oxygen (DO) measurement in the Pigeon
River above Clyde of 4.3 mgfl on the morning of 10/16. This was the first time during the current
exceptional drought that measured DOs above Clyde have dropped to this extent. After starting the
oxygen station, we continued to monitor river DO and obtained a daily average DO reading above Clyde
of 4.95 mg/l for 10/16. The DO measured above Clyde at 10 am on 10/17 was 6.4 mg/1 indicating that
the oxygen station is having a positive effect. The DO above Clyde measured on 10/18 was 6.1 mg/l.
The permit limit for dissolved oxygen above Clyde is a daily minimum not less than 4.0 mg/l and a daily
average not less than 5.0 mg/l. Both permit limits are expressed with one decimal. Under our permit
sampling procedures, we record and report field DO measurements to 2 decimal places. The accuracy of
our field DO meter (Hach HQ30D + LD 101-30 DO probe) is plus or minus 5 percent. Considering the
accuracy of our field DO meter, rounding and the significant digits in the permit limit, the daily average
DO measured at Clyde on 10/16 works out to 5.0 mg/I. Blue Ridge Paper will code DO measurements
above Clyde on 10116 in the October 2007 discharge monitoring report as compliant.
Sincerely —
Paul S. Dickens cc: C. File Water
Manager, Environmental Affairs Internal distribution
828-646-6141
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

MichaelF. Easley, Govemor
January 13, 2003
Mr. David E. Jenkins
Director of Conservation and Public Policy
American Canoe Association
7432 Alban Station Boulevard
Suite B-232
Springfield, Virginia 22150-2311
Mr. VVU Callaway
Executive Director
Tennessee Environmental Council
1700 Hayes Street
Suite 101
Nashville, Tennessee 37203
Re:
Gentlemen:
Natural Resources
Blue Ridge Paper Products, Inc.
NPDES Permit No. NC0000272
William G. Ross Jr., Secrelary
I am in receipt.•ofyour letter, dated November 19, 2002, requestinginformal discussions
to resolve a described dispute over the implementation of the 1997 "Settlement Agreement
Concerning 1996 Water Quality Color Variance and 1996 NPDES Permit (NC0000272) issued
to Champion International Corporation". In the letter you voice various concerns over the
permitting and performance of the Canton Mill, which is now -operated by Blue Ridge Paper
Products, Inc. pursuant to an NPDES permit issued by the State of North Carolina in November
2001.
While I appreciate your concernsand I share your goal of continued and steady
improvement to the water quality in the Pigeon River, I do not agree that the 1997 Settlement
Agreement governs any resolution of these issues. The permit and. variance that were based on
the 1997 Settlement Agreement have now been replaced by the currently -effective permit and
variance which were issued in November 2001.
1601 Mail Service Center, Raleigh, Norlh Carolina 27699-1601
Phone: [phone] FAX: [phone] Internet: www.enr.state.ne.us/FNR/
� tau 4wirvP'/f •nn.tAyn Emw,n•;H.Rr.•ett ita vmymvme oew

ppppp� - -
Page Two
January 13, 2003
Re: Blue Ridge Paper Products, Inc
NPDES Permit No. NC0000272
We concluded in 2001 that the conditions placed in the permit will assure that Blue Ridge
Paper will achieve significant improvements in its color loading discharge to the Pigeon River.
As you will recall, the basic structure of the permit calls for a series of steps to lower the lbs/day
of color based on demonstrated performance and process changes. As the deadlines and
.milestones of the permit are reached, we will learn more about what can be attained and
determine the necessity of continuing the color variance in the next permit period.
I am willing for our Department to meet with you to discuss the mill's performance and
the permitting timelines. If you are amenable to such a meeting, perhaps in the Asheville area, I
will be glad to invite the appropriate officials of the company, the EPA and the Tennessee
agencies and counties. -Please contact Alan lGimek, Director of the Division of Water Quality
(919/733-7015), if you believe such a meeting would be helpful.
Thank you for the letter and thank you for your commitment to environmental protection
and natural resources conservation.
Sincerely,
William G. Ross, Jr. _
Secretary
cc: James Palmer
David.Moreau
Robert Ray
Justin Wilson
Paµl Davis
Iliff McMahan
RoW Dykes
Bob Williams
Alan Kmek
Dan Oakley

Status of Champion, Canton, NC
1997 Settlement Agreement
The following is a status of the elements contained in Champion at Canton, NC 1997 Settlement
Agreement in Paragraphs 32 and 33. Paragraph 32 focused on " Assistance to downstream communities and
community input," while Paragraph 33 focused on, "Ecological assessment of the Pigeon River system and the
Waterville Reservoir." All of the other commitments in the agreement were included in the permit and variance
issued by NC and are reported on by them. Champion sold the Canton mill to Blue Ridge Paper Products (BRPP)
in 1999. BRPP assumed responsibility for the Settlement Agreement as a result of that sale.
- EPA will identify available programs, initiatives, and technical resources within the agency which
may support and further such (recreation, tourism, and other economic opportunities) development
opportunities in Cocke County.
Status; EPA did provide information on the above matters to the County and
followed up with communications on those matters. EPA continues to
provide the County with advice and consultation on a variety of matters.
- EPA will also work closely with TVA on its Quality Communities Initiative, the goal of which is to
develop a long-term economic development strategy for Cocke County and surrounding areas.
Status; This program was initiated in 1997. EPA has both discussed the program
and offered our assistance to the members, but has not been called upon
for specific inputs. We understand that the program is not meeting frequently
at this time.
- N.C. and TN will foster joint planning and public input by establishing a joint Watershed Advisory
Committee.
Status; First committee meeting held on May 25, 2000.
- Champion will establish a facility Community Advisory Committee.
Status; A committee was established by BRPP. The first meeting was held on
February 2, 2000, and the second meeting was held on March 27, 2000.
EPA Region 4
May 25, 2000

EPA will lead, in cooperation with NC and TN, an independent
evaluation of current information on the Pigeon River. Evaluation will
include convening a group of scientists to evaluate existing data, identify
additional data needed, and if necessary, to conduct an ecological
assessment. Also, determine whether any significant ecological or
health risks exist. If so, what if any, steps could be taken to address
those risks.
Status; EPA has contracted with TVA to compile all existing
data into a useable database (this is the first step in
this task). A draft report is expected in May 2000. EPA
will convene a group of scientists to evaluate the data,
when the report is finalized.
EPA Region 4
May 25, 2000

J,„IED sr"eB
-
O o
i�ryf,1 N+01E l�
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION a
ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW
ATLANTA. GEORGIA30303-8909
January 8, 1998
[See Addressed List Attached]
SUBJ: Champion permit Matter
Gentlemen:
RECEIVED
JAN 1 3 1997
LEGAL AFFAIRS
Enclosed is a copy of the final, fully executed Settlement Agreement in the above_ referenced matter.
I would like to take this opportunity to thank each of you with whom I had occasion to
work on this project for the high level of professionalism and courtesy which you brought to this
matter. I thoroughly enjoyed working with each of you and look forward to the opportunity to
do so in the future.
Attachment
Encl.
Sincerely,
Mary J.I11
Associate lligto ttomey
Racyclod/Rorycioble • Primed wlm Vegetable 00 Based bda on 100%Recycled Paper (40%Posiconsumer)

ADDRESS LIST
Barn Turner
Deputy Attorney General
Office of the Attorney General
Cordell Hull Building*. 2nd Floor
425 5th Avenue North
Nashville, TN 37243-0495
Paul E. Davis, Director
Division of Water Pollution Control
TN Department of Environment and Conservation
6th Floor
L & C Annex
401 Church Street
Nashville, TN 37243-1534
Daniel C. Oaklev
Senior Deputy Attomev General
NC Department of Justice
114 West Edenton Street
Suite 311
Raleigh, NC 27602
Forrest R. Westall
Regional Water Quality Supervisor
NC Department of Environment and Natural Resources
Division of Water Quality, Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
BenjaminS. Bilus .
Senior Associate Counsel
Champion International Corporation
One Champion Plaza
Stamford, Connecticutt 06921
David E. Jenkins
Director of Conservation and Public Policy
American Canoe Association, Inc.
7432 Alban Station Boulevard, Suite B-226
SprinofPid_ NIA 22150-2311

John Noel
Pigeon River Coordinator
Tennessee Environmental Council
1700 Haves Street, Suite 101
Nashville. TN' 37203
Honorable James E. Robinson
Mayor. Citv of Newporr
P.O. Box 370
Newport, TN 37822
Mr. Harold Cates
Cocke Countv Executive
Court House Annex. Room 146
360 East Main Street
Newport, TN 37821

_AGREEMENT REGARDING 3996 WATER OII TTTV
COLOR VARIAND RMIT IESUEn
TO Atrvrrns -'T"' mTION T, QQEPORATION
I. INTRODUCTION
1• The United States Environmental Protection Agency
(EPA), the State of North Carolina (North Carolina), the State of
Tennessee (Tennessee), Cocke County, Tennessee (Cocke County),
the City of Newport, Tennessee (Newport), the Tennessee
Environmental Council (TEC), the American Canoe Association
i
(ACA), and Champion International Corporation (Champion) enter
into this Settlement Agreement to resolve the concerns of
Tennessee, Cocke County, Newport, TEC, and ACA with the amended
modified water quality color variance granted by North Carolina
to Champion on December 11, 1996, and approved by EPA on December
�. 26, 1996, and with the NPDES permit issued by North Carolina to
Champion on December 12, 1996. It is also intended that this
Agreement will be the basis for resolution of the contested case
proceeding pending before the North Carolina Office of
Administrative Hearings to which all of the foregoing, except
EPA, are parties.
II. PROCEDURAL HISTORY
2• Champion operates a bleached kraft pulp and paper mill
on the Pigeon River at Canton, North Carolina, and discharges
treated wastewater from its mill operations, domestic wastewater
from the Town of Canton, and leachate from its active landfill
into the river. The Pigeon River below Canton is designated by
North Carolina as a Class C river (secondary recreation, fishing,
`-" aquatic life, including propagation and survival, and wildlife)

and flows from North Carolina northwestwardly into Tennessee.
Under the Federal Water Pollution Control Act (commonly referred
to as the Clean Water Act), 33 U.S.C. § 1251 Q.t seo., and under
North Caroiina's Water and Air Resources Act, N.C. Gen. Stat. §§
143-211 ,et Z_eZ., Champion is required to have an NPDES permit for
-these discharges.
3. Until January 1, 1997, when the permit issued on
December 12, 1996, by the State of North Carolina took effect,
Champion was operating its Canton mill under an NPDES permit
issued by EPA, effective October 25, 1989. EPA issued that
permit after objecting to, and subsequently vetoing, the permit
that North Carolina had issued to Champion in mid-1985_ EPA
vetoed the North Carolina permit on the grounds that it did not
reasonably ensure compliance with Tennessee's narrative water
quality criteria for color. On November 13, 1985, EPA notified
Champion that it had assumed permitting authority for the
Champion permit. North Carolina and Champion challenged EPA's
authority to take over the permit in federal court. In 1987, the
District Court for the Western District of North Carolina
rendered an opinion upholding EPA's permitting authority.
, 648 F.Supp. 1390 (W.D.N.C. 1987). This opinion
was upheld by the Fourth Circuit Court of Appeals in 1988,
Chamn;on �pn 850 F.2d 182 (4th Cir. 1988), and EPA issued its
permit on September 25, 1989. Champion and the Dead Pigeon River
Council appealed the EPA permit. After an administrative hearing.
before EPA Administrative Law Judge Thomas B. Yost, the permit
I
was upheld on February 12, 1992.

4. in 1988, the NPDES Committee -of the North Carolina
I
Environmental Management'Commission granted Champion a variance
from the North Carolina narrative water quality criterion for
color. EPA approved this variance on August 11, 1988.
S. The EPA -issued permit and the North Carolina color
variance have operated together to control the contribution of
effluent color by Champion to the Pigeon River, by the use of a
Predictive model and a color limitation.of 50 true color units on
a monthly average basis at the North Carolina/Tennessee state
line.
6• Champion's EPA -issued permit for the Canton mill (NPDES
Permit No. NC0000272) was set to expire on October 24, 1994. On
March 28, 1994, Champion applied to the North Carolina Department
{ of Environment, Health and Natural Resources (NCDEHNR) for
renewal of this permit. At that time, North Carolina advised
Champion that it believed EPA was the proper permitting agency,
since EPA had assumed control of the facility's permit in the
Previous permit cycle. Champion, therefore, applied to EPA for a
renewal on April 15, 1994. EPA then advised Champion that North
Carolina was, in fact, the proper permitting agency, and Champion
filed its renewal application with North Carolina on November 18,
1994.
7• The 1988 color variance was reviewed by the North
Carolina Environmental Management Commission as a part of its
triennial. revie•;; and w3G continued on May 12, 1993. On November
29, 1994, EPA approved the continued variance.
8• On June 6, 1996, North Carolina conducted a public

hearing in Haywood Count
I v, North Carolina, to consider renewal of
NPDES 'permit No. ZIC0000272 and modifications to the 1988 color
variance. A public comment period extended for thirty (30) days
after the public hearing. The effluent color limitation for the
Canton mill was one of the issues subject to comment.
9• Tennessee provided public comment at the hearing as
well as in writing thereafter through the Tennessee Department of
Environment and Conservation (TDEC) and .the Tennessee Wildlife
Resources Agency (TWRA), Those comments stated that color in the
river in Tennessee was still objectionable, particularly during
the low -flow Period from mid -summer through fall. The comments
further stated that additional conditions needed to be placed on
effluent color to meet the Tennessee narrative water quality
t' criterion for color. ACA members also participated in the public
hearing. TEC provided written comments which also raised
objections to the noticed permit. EPA also provided comments on
the publicly -noticed draft permit by letter, dated July 3., 1996.
TEC and ACA also subsequently submitted additional comments to
EPA expressing concerns regarding the permit and variance.
10. Following the public hearing, North Carolina,
Tennessee, EPA and Champion attempted to resolve the color issue
through several formal and informal mechanisms. Based on the
public record and EPA's comments, a proposed final permit was
prepared on October 1, 1996. The North Carolina NPDES Committee
then modified the 1988 Color variance uil uctober 15, 1996.
11. Discussions among North Carolina, Tennessee and EPA
continued thereafter; additional targets for continued color

reductions and more restrictive mass -based color limits were
Placed in the permit and variance by North Carolina, based on
comments received, and Tennessee was added as a specifically -
named member of the Variance Review Committee, which would
periodically consider the variance conditions. These changes
were documented in the variance modification by a new Amended
Order of the North Carolina NPDES Committee issued on December
11, 1996, and in the permit issued on December 12, 1996.
12- EPA Region 4 supported the December 1996 variance
amendments by letter dated December 9, 1996; and EPA Region 4
subsequently approved the amended color variance modification by
letter dated December 26, 1996.
13- By letter dated December 23, 1996, Tennessee advised
EPA that it considered the permit to be invalidly issued and that
North Carolina had failed to comply with § 402(b)(5) of the Clean
Water Act, 33 U.S.C. § 1342(b)(5). Subsequently, on January 13,
1997, Tennessee filed a contested case petition with the North
Carolina Office of Administrative Hearings challenging the permit
and color variance. Thereafter, Champion, Cocke County, and
Newport were allowed to intervene in the North Carolina contested
case proceeding.
14. In an effort to resolve the color issue without time -
and resource -consuming litigation, North Carolina, Tennessee,
Cocke County, Newport, Champion, and EPA agreed to an informal
negotiation process. The North Carolina contested case
proceeding was stayed during this process until September 26,
1997. On November 21, 1997, TEC and ACA. were also allowed to

intervene in the North Carolina contested case proceeding.
15. The agreements which follow constitute what the
parties
to this Agreement believe to be an appropriate and reasonable
resolution of the pending disputes surrounding the contested
Permit and variance. P.11 parties to this Agreement are committed
to the ultimate achievement of water quality standards in the
Pigeon River, both in North Carolina and in Tennessee. This
Agreement and the modified variance and .the permit resulting
therefrom represent a major step toward that goal. At the same
time, the parties recognize that there is further work to be done
and they are committed to attaining further reductions in color
in the river at the quickest possible pace.
III. TECHNOLOGY MODIFICATIONS
TO THE VARIANCE/PERMIT
�.. 16. The parties hereby agree to the following measures to
achieve additional color reduction over that required in the
permit issued on December 12, 1996 and by the color variance
adopted on December 11, 1996 [hereinafter the December 1996
Permit and variance]. The parties further agree that the
December 1996 permit and variance will be modified [hereinafter
the 1997 Permit and the Revised Variance] to reflect these
requirements and effectuate this Settlement Agreement. Except as
modified by the Settlement Agreement, all other provisions of the
December 1996 permit and variance, including the monitoring and
reopener provisions, will be maintained in the 1997 Permit and
the Revised Variance.

17• The December i996 permit and variance required that
Champion implement a one-year demonstration of full-scale bleach
filtrate recycling (BFR'Y) technology on the mills pine line and
that, as of December 1, 1998, Chamoion implement and operate
BFR" technology on its Dine line, unless Champion could
demonstrate to the NPDES Committee that BFR" was not
commercially viable. Champion has nearly completed the process
of the required demonstration phase of BFR". Based on the
results of the demonstration effort, Champion commits to continue
the full operation of the BFR'" technology on the mills pine
line on a continuing basis, subject to the process set forth in
Paragraph 22.
18. The 1996 permit and variance required Champion to
`.
evaluate the potential for additional minimization of color
losses from the manufacturing processes and raw material storage
areas (i.e. in -mill color minimization; or, spill
Prevention/control measures) that might result in further color
reductions and to report its findings to the NPDES Committee.
Reports were to be submitted by March 1, 1998 and again by June
1, 2001, so that they could be used by the Committee in
conjunction with the required variance review process held every
three years to determine if the variance would be readopted or
made more stringent. As a part of the efforts to resolve the
challenge to the 1996 permit and variance, a Technology Review
Workgroup was fcrmed, cu3neris-d o, experts on the pulp and paper
industry from EPA and representatives of the environmental
agencies for the States of Tennessee and North -Carolina. The

Technology Review Workgroup shall replace the -previously existing
North Carolina Variance Review Committee and shall be maintained
during the life of the 1997 Permit in order to make the
recommendations and determinations 'which this Agreement calls for
such Workgroup to make. The Technology Review Workgroup shall,
at all times, be chaired by EPA and be comprised of three
technical representatives from EPA with expertise on the pulp and
paper industry, two environmental agency -representatives from the
State of Tennessee, and two environmental agency representatives
from the State of North Carolina. The Workgroup shall make
itself available to consult with and provide information to
community representatives at appropriate times. In addition,
consistent with any limitations under law or regulation relating
to confidential business information, copies of all written
reports and recommendations generated pursuant to this Agreement
shall be provided to the parties to the Agreement at least 20
days before any recommendation or determination by the Workgroup
becomes final. The Workgroup shall review any comments or input
received on such documents prior to making its final
recommendations or determinations. Any comments or input
received by the Workgroup shall be made available to all parties
to this Agreement.
19. Working with the Technology Review Workgroup, Champion
has already begun the process of identifying and implementing
Possible prevention and control measures wnich can be Laken to
further reduce color discharges from the mill. Champion commits
to Eurther evaluate mill operation so as to fully identify

opportunities for preventing and controlling measurable black
f
liquor leaks and spills (best management practices - BMPs). This
evaluation will include gathering more extensive and detailed
data on sources of color within the mill to substantially improve
the accuracy of measurements, to improve the mill's existing BMP
Program, and to complete efforts to identify, quantify and
substantially improve the accuracy of a mass balance of sources
of leaks and spills of black liquors, including unmeasured
sources and discharges during periods of fiber line disruption.
Such BMPs include: further upgrading and integrating of sewer
monitoring (e.g., additional flow measurement and sampling
stations to facilitate more comprehensive and daily monitoring of
sources) and automated mill process control systems with
t' operational procedures and management oversight to reduce black
liquor leaks and spills; continuing operator training;
identifying and implementing additional controls for known but
unmeasured sources (e.g., evaporator set, knot rejects bin, etc.)
Of liquor losses; modifying the digester area to facilitate
capturing leaks and spills; diverting clean water discharges; and
capturing and recycling liquors during fiber line disruptions
through detailed scheduling of planned outages and contingency
Planning for unplanned outages. Champion also commits to
thoroughly evaluate additional measures to modify its process
operations and controls to remove or reduce sewer generated
color.
20. Champion agrees to provide a report to the Technology
Review workgroup and the NPDES Committee no later than June 1,

1998. This report will identify a strategy and time line for
I
implementing those color reduction measures identified is
Paragraph 19 until the target effluent limitations in Paragraph
24 are met or ail measures in Paragraph 19 have been fully
implemented. The report will include an explanation of and
rationale for both the implementation strategy and the proposed
time line. The report will also identify those measures which
will be implemented in the event that the effluent limitations
set out in Paragraph 22 are not achieved by the color reduction
measures specified in that paragraph.
21. Four BMPs which have already been identified as having
both a high potential for achieving color reduction and a high
level of implementability are: a) installation of replacement
digester recirculation pumps and a spill collection sump; b)
I
installation of a pine courtyard Parshall flume slide gate; c)
installation of weak black liquor tank containment, and; d)
correction of evaporate set demister clogging, installation of
condensate instrumentation and sampling ports for the evaporator
set, and assurance of continued'dry conveying of knot rejects.
Champion commits to fully implement all four of these BMPs by
June 1, 1998.
22. The 1996 permit and variance required that the annual
average effluent true color loading should not exceed 98,168
lbs/day and that the monthly average true color loading should
not exceed 125,d3d lbs/day. Based on current demonstrated
achievable levels which have resulted from measures that Champion
has already undertaken to reduce color from the mill, the parties

agree that the 1997 Permit and Revised Variance shall provide
that beginning January 1, 1998, the monthly average discharge of
true color from the mill shall not exceed 95,000'lbs/day. Based
on an analysis of the available data from the BFR7" demonstration
Project and the spiil prevention/control measures that have
already been identified by Champion and the Technology Review
Workgroup as being implementable in the near -term, it is
anticipated that full-scale implementation of BFR� on the pine
line combined with the four BMPs identified in Paragraph 21 will
reduce annual average color loading by approximately 40% below
the limits in the December 1996 permit. Therefore, the 1997
Permit and Revised Variance will require that, beginning December
1, 1998, the annual average discharge of true color shall not
{ exceed 60,000 lbs/day and the monthly average true color loading
shall not exceed 69,000 lbs/day. However, if by October 1, 1998,
the Technology Review Workgroup determines, and the NPDES
Committee agrees, that there are overwhelming technical, economic
or operational barriers to Champion's ability to attain the
above -stated color loading limits, the Technology Review
Workgroup shall recommend to the NPDES Committee the alternate
interim limits to become effective December 1, 1998. The
Workgroup shall, at the same time, also recommend to the NPDES
Committee a new effective date for achieving an annual average
color loading limit of 60,000 lbs/day. These recommendations
shall be based on what the Workgroup concludes CLamoion can
reasonably be expected to achieve, giving due consideration to
the demonstrated discharge levels which the mill has, in fact,

achieved and taking into account the evaluations conducted
pursuant to Paragraph 19 and the report submitted by Champion
pursuant to Paragraph 20. Based on the Workgroup's
recommendations, the NPDES Committee will determine the alternate
interim limits to become effective on December 1, 1998, as well
as a new effective date for achieving an annual average color
loading limit of 60,000 lbs/day. The permit will then be
modified in accordance with North Carolina's permitting process
to reflect these determinations.
23. The 1996 permit and variance required Champion to
evaluate color reduction strategies for further optimization of
BFR"` technology and to report on the feasibility of
implementation on the hardwood line. Champion commits to begin
L
implementation of that portion of the BFR technology which
involves the recycling of the Eo stage of the hardwood line by no
later than January 1, 1999. Champion further agrees to provide
an evaluation of that implementation as well as the potential for
full implementation of the BFR"' technology on the mill's
hardwood line to the Technology Review Workgroup and the NPDES
Committee by December 1, 1999. The evaluation will include data
reflecting the color reduction benefit gained from the partial
implementation and a projection of potential color reduction
benefit to be gained from full implementation of the BFR
technology on the hardwood line.
24•. Based on the work that Champion and the Technology
Review Workgroup have already done in the area of in -mill color
r
�` reduction measures, it is anticipated that further color

reductions, beyond those to be obtained by BFR' on the pine line
in combination with the four BMPs identified in Paragraph 21,
could be expected after implementation of the BMPs and measures
to reduce and/or remove sewer generated color identified in
Paragraph 19, and partial BFR"' (i.e., recycle of Eo filtrate) on
the hardwood line_ This combined package of in -mill color
reduction measures (i.e., the four BMPs in Paragraph 21, the
additional BMPs and sewer -generated color.reduction measures
identified in Paragraph 19 as implemented pursuant to Paragraph
20, full implementation of BFR on the pine line, and partial BFR
on the hardwood line) shall hereinafter collectively be referred
to as the Near -Term Package. it is further anticipated that full
implementation of the Near -Term Package could be effectuated by
tr June 1, 2000, resulting in a target color annual average loading
within a range of 48,000-52,000 lbs/day. Champion shall submit
to the Technology Review Workgroup by January 1, 2001, a report
on the feasibility of achieving a target annual average color
loading limit within the range of 48,000-52,000 1bs/day based on
full implementation of the Near -Term Package. This report shall
include all available data necessary to derive the lowest
achievable annual average and monthly color loading limits. By
April 1, 2001, the Technology Review Workgroup shall recommend,
considering the feasibility report submitted by Champion and the
demonstrated performance of the mill, the lowest achievable
annual =.ver -
...ge .inf !nnntht..
-, color loading effluent limitations.
The Workgroup evaluation and recommendation report shall be
submitted to the NPDES Committee and the other pafties to this

Agreemenc. If the recommended limits are within the target
r
range, the limits shall become effective on May 1, 2001, by
written notification from the Director of the North Carolina
Division of Water Quality. If the limits determined to be
achievable by the Workgroup are not within the target range, the
Permit shall be modified in accordance with North Carolina's
permitting process to reflect those limits. The Workgroup,s
recommendation of limits under this Paragraph shall take into
account appropriate effluent variability.
25. The 1996 permit and 'variance contain provisions to
limit color in the Pigeon River at the NC -TN state line to a
maximum monthly average of 50 true color units. The new effluent
limitations in this Agreement at Paragraphs 22 and 24 are more
stringent than the provisions in the 1996 permit and variance and
will result in color levels at the state line well below 50 true
color units. It is possible to calculate the monthly flow at the
Hepco gage above which instream color will not exceed 50 true
color units for any specific color discharge from the Champion
facility. Using the 69,00o lbs/day monthly average true color
loading limit anticipated in Paragraph 22 to become effective
December 1, 1998, the flow which will provide for color less than
50 true color units at the Hepco gage is 330 cubic feet per
second (cfs). Therefore, the parties to this Agreement agree
that the scope and magnitude of the 1996 variance will be reduced
in the Revised Variance to proviae t::at: e_feutve December 1,
1998, color in the Pigeon River at the Hepco gage shall be less
�• than 50 true color units whenever monthly average flows are

greater than 330 cfs. The parties to this Agreement further
agree that should alternate interim limits be set pursuant to
Paragraph 22, or when monthly limits are established pursuant to
Paragraph 24, the above variance conditions will be revised in
accordance with the above approach. Using North Carolina's
governing flow criteria (30Q2), historical flow records, and the
December 1, 1998 effluent limits in Paragraph 22, it is expected
that color in the Pigeon River at the Hepco gage will be less
than 50 true color units 91W of the applicable time. Similarly,
using the May 1, 2001 effluent limits in Paragraph 24, it is
expected that color in the Pigeon River at the Hepco gage will be
less than 50 true color units 96% of the applicable time.
Champion agrees to cooperate fully with any periodic independent
monitoring (including activities such as splitting samples)
requested by EPA or the State of North Carolina. In -stream
monitoring data gathered during the 1997 Permit term will be
evaluated at the end of the 1997 Permit term to determine whether
the limits established under the Permit, in fact, attained the
color levels as expressed in the Variance. This information will
be used to develop new requirements for the next permit which
further reduce color levels in the Pigeon River.
26. As Paragraph 25 recognizes, there could still be some
periods of time, corresponding to periods of lower flows in the
river, when color at the Hepco gage might exceed 50 true color
units. Champion agrees to develop a contingency plan for
mitigating the occurrence and degree of these potential
exceedances which correlates measures designed to achieve

mitigation with periods of lowest flow, with -particular attention
being given to periods of higher recreational use in the river.
In developing the plan, Champion shall evaluate anv reasonable
means,-ncluding scheduling of maintenance, intermittent
treatment, and production curtailment, which would achieve
additional color reductions during temporary periods of lower
flows in the river, when color at the Hepco gage might exceed So
true color units. The contingency plan shall be submitted by
December 1, 1998, for review by the Technology Review Workgroup.
Champion agrees to work in good faith with the Workgroup to
resolve any issues which arise during this review in order to
achieve a mutually acceptable plan. By February 1, 1999, the
Technology Review Workgroup will recommend to the NPDES Committee
either approval of or modifications to the plan. The NPDES
Committee will approve the contingency plan, either as submitted
or with the changes the Committee determines are appropriate.
The plan shall become effective upon approval, which shall be no
later than March 1, 1999.
27• Champion commits to, and North Carolina will direct,
the continuing improvement of existing process and related
technologies which could improve the efficiency of all water -
using equipment and operations throughout the mill, with the goal
of meeting North Carolinas water quality standards under the
Clean Water Act without a variance.
1�96 Fc=^it and variance required Champion to
evaluate and report to the NPDES Committee on end -of -pipe color
reduction technologies that could conceivably be implemented at

the mill. The evaluation was to include an incremental color
improvement analysis which concentrated on the technical,
economic, and operational feasibility of the application of these
technologies on a continuous or intermittent basis. The
intermittent application of these technologies was to look
particularly at periods of low river flow. These reports were to
be submitted to the NPDES Committee for its consideration as part
of the water quality standards Triennial Reviews to determine
whether the variance should be readopted or made more stringent.
The reports were to identify specific economic and implementation
issues associated with the incremental improvement of color
levels expected by installing these technologies at the mill.
They were also to project the expected additional color reduction
possible using the identified technology. The first such
evaluation/report, which was due March 1, 1998, has essentially
been completed as a result of the Technology Review Workgroup,s
efforts. A subsequent evaluation/report was to be due March 1,
2001_ Champion agrees to provide this evaluation/report,
together with an updated report on the results of all ongoing and
any additional planned color reduction activities, to the
Technology Review Workgroup and the NPDES Committee March 1,
2001. The Technology Review Workgroup shall evaluate this
combined report and make recommendations to the NPDES Committee
for further color reduction targets for inclusion in the next
NPDES permit.
' 29. The parties agree that the 1997 Permit shall require
that Champion and any successor -in -interest to Champion's

ownership and/or operation of the Canton mill use their best
efforts in good faith to implement the BFR-'A technology, BMPs and
other color reduction measures in accordance with the terms of
this Agreement, and to achieve the effluent limitations required
by and to be determined under this Agreement, as well as the
effluent limitation targets required by Paragraph 24.
30. The 1997 Permit shall also provide that neither
Champion nor any successor -in -interest to Champion's ownership
and/or operation of the Canton mill will increase the mill's
current pulp production capacity during the permit term, unless
this can be done in way that also reduces color loading.
31. Champion's Canton mill already meets or exceeds the
technology requirements of the Pulp and Paper Cluster Rule for
Climits on dioxin. The 1997 Permit shall require that the Canton
mill continue to meet those requirements. All other requirements
of the Cluster Rule, including any monitoring requirements, will
apply to Champion in accordance with timeframes established
pursuant to the Rule.
IV. ASSISTANCE TO DOWNSTREAM COMMUNITIES
AND COMMUNITY INPUT
32. The parties to this Agreement recognize the concerns
Of communities downstream from the Champion mill regarding the
economic impacts that may have resulted from Champion's discharge
over the years. The parties are committed to working with those
downstream communities to assist in the developmerr ^f
recreation, tourism, and other economic opportunities in those
areas. EPA will identify available programs, initiatives, and

technical resources within the Agency which may be available to
support and further such development opportunities in Cocke
County. EPA will also support and work closely with TVA on its
Quality Communities Initiative, a community based effort being
undertaken by _'VA, the coal of which is to develop a long-term
economic development strategy for Cocke County and surrounding
areas. In addition, :forth Carolina and Tennessee will foster
joint planning and public input on decisions affecting the Pigeon
River by establishing a Joint Watershed Advisory Committee and
Champion will establish a facility Community Advisory Committee.
V. ECOLOGICAL ASSESSMENT OF THE PIGEON RIVER
SYSTEM AND THE WATERVILLE RESERVOIR
33. Over the years, a number of studies have been conducted
by various entities on the health of the aquatic biological
community in the Pigeon River and, in particular, analysis of
fish flesh contamination. However, EPA believes that a more
current evaluation of the level of contaminants remaining in the
system and the cverall health of the river and of the Waterville
Reservoir should be undertaken. ,EPA will lead, in cooperation
with North Carolina and Tennessee, an independent evaluation of
current information on the Pigeon River. The evaluation will
include convening a group of scientists to evaluate existing
data, to identify additional data needed, and, if necessary, to
conduct an ecological assessment. EPA agrees to take the lead in
convening the scientific panel. The information gathered from
such an assessment would be used to determine .:hether any
significant ecological or health risks exist, and, if so, what,
if any, steps could and should be taken to address those risks.

VI. ADDITIONAL COVENANTS
AGREEMENTS OF THE PARTIES
��• In consideration of the covenants and agreements made
by the other parties to this Settlement Agreement, North Carolina
covenants and agrees to modify the amended modified color
variance granted to Champion on December 11, 1996, and to revise
NPDES Permit No. IIC0000272 issued to Champion on December 12,
1996. to reflect the requirements found in Section _iII of this
Settlement Agreement. North Carolina agrees that these
modifications to the variance and permit will be made and the
1997 Permit and Revised %rariance incorporating those requirements
will be finalized and will become effective no later than
December 31, 1997. North Carolina agrees that it will not
further modify the 1997 Revised Variance prior to the triennial
review, or further modify the 1997 Permit prior to its expiration
in 2001 except as provided in this Agreement, unless North
Carolina seeks to impose more stringent requirements in the
variance and/or the permit to protect water quality. North
Carolina agrees to conduct public,hearings on Champion's next
NPDES permit renewal application by June or July of 2001 and to
make its decision on reissuance of the NPDES permit, as well as
its decision on extension of or modifications to the color
variance, by October 31, 2001.
35. In consideration of the covenants and agreements made
by the other parties to this Settlement Agreement, Champion
agrees to the modifications to be made by North Carolina to the
r
variance granted it on December 11, 1996, and to the NPDES _permit
issued to it on December 12, 1996. Champion further agrees not

to seek administrative or judicial review of the 1997 Revised
Variance and/or the 1997 Permit as long as they are consistent
with this Agreement. Champion agrees to submit its NPDES permit
renewal application for the Canton mill no later than March 1,
2001.
36. In consideration of the covenants and agreements made
by the other parties to this Settlement Agreement, Tennessee,
Cocke County, Newport, TEC and ACA agree that they will neither
Oppose EPA's approval of the 1997 Revised Variance, nor request
that EPA object to the 1997 Permit. Tennessee, Cocke County,
Newport, TEC and ACA further agree that, they will not seek
administrative or judicial review of the 1997 Revised Variance
and/or the 1997 Permit so long as they are consistent with this
i Agreement. The same parties further agree that they will not
seek to have any change in water quality standards that Tennessee
might make during the life of the 1997 Permit effective against
Champion prior to the next permit term.
37. EPA has reviewed and considered the proposed changes to
the December 12, 1996 permit and the December 11, 1996 variance
called for by this Agreement in accordance with its obligations
under the Clean Water Act. EPA hereby represents that as long as
the 1997 Permit and Revised Variance are consistent with this
Agreement, it will approve the 1997 Revised Variance and will not
object to the 1997 Permit.
38. Tennessee, Cocke County, Newporc, —C, ACA, North
Carolina and Champion agree to enter into an agreed order to
i resolve the North Carolina contested case proceeding, Stare of

�•� t � n
H ?P^d r•�t i a
Pr t No. 97 EHR 0041.
' That
agreed order, which will be filed with the Administrative Hearing
Officer as soon as the 1997 Permit and Revised Variance have both
been issued, :rill incorporate by reference this Settlement
Agreement and will constitute a dismissal with prejudice of the
contested case Petition. The agreed order also will reflect that
North Carolina Senior Administrative Law Judge Fred G. Morrison
is suitable to all parties as a mediator of any disputes that may
arise regarding North Carolinas or Champion's compliance with
this Settlement Agreement. Disputes will be presented to Judge
Morrison if the parties are unable to reach resolution under the
informal dispute resolution procedures specified in Section VII
Of this Settlement Agreement.
VIZ. DISPUTE RESOLUTION
39- North Carolina, Tennessee, Cocke County, Newport, TEC,
ACA and Champion agree that should a dispute arise regarding
compliance with, this Settlement Agreement by any of those
parties, the parties shall first attempt to resolve the dispute
informally, it is the 'intent of the parties that EPA, which is
not a party to the North Carolina contested case proceeding, may
participate so as to facilitate informal dispute resolution if
requested by any Other :arty to do so, and if EPA chooses to do
SO.
40, As a condition precedent to a party bringing any civil
suit for breach of this Settlement Agreement, that party must
first attempt to resolve the purported dispute as expeditiously

as possible within the following framework. All time frames for
informally resoiving disputes may be lengthened by mutual
consent. Each of the parties will designate a representative for
infor al dispute resolution. A party representative claiming
that a dispute has arisen will summarize the dispute in writing,
and circulate the written summary to all other party
representatives within five (5) working days. If the party
representatives fail to resolve the dispute within twenty (20)
working days, the parties agree that any party, except EPA, shall
next seek resolution of the dispute by calling for a formal
mediation, to be conducted by Senior Administrative Law Judge
Fred G. Morrison. Notwithstanding any other provision in
Paragraphs 39 & 40 of this Agreement, if a dispute arises
regarding this Agreement, the parties agree that any party may
make any administrative or judicial filing necessary to avoid the
running of any limitations period for bringing such
administrative or judicial action.
41. All the parties agree that should a dispute arise
regarding any actions EPA is to undertake as part of this
Settlement Agreement, the parties shall attempt to resolve the
dispute informally. All time frames for informally resolving
disputes may be lengthened by mutual consent. Each of the
Parties shall designate a representative for informal dispute
resolution. These representatives may be the same
representatives designated under, paragraph 40, above. A party
representative claiming that a dispute has arisen shall summarize
the dispute in writing, and circulate the written summary to all

other party representati•.as within five (5) working days. The
Party representatives will endeavor to resolve the dispute within
twenty (20) working days. For any such dispute, EPA's party
representative will init`ally be designated by the Region 4
Administrator. If the parties are unable to resolve the dispute
with the Region 4 representative, any party may request that EPA
Headquarters designate a representative for that particular
dispute, and the parties, ;;corking with the EPA representative,
Will have an additional ten (10) working days to resolve the
dispute.
VIII- RESERVATION OF RIGHTS
42- The covenants and agreements set forth in this
Settlement Agreement do not pertain to any matters other than
/ those expressly specified in the Settlement Agreement. All
\ parties reserve,
and this Settlement Agreement is without
Prejudice to, all rights any party,to this Agreement may have
- to this Agreement with respect to all
against any other part
other matters.
IX. EFFECTIVE DATE
43. Each party shall execute the signature page of this
Settlement Agreement and return the executed signature page to
EPA. The Settlement Agreement shall become effective upon EPA's
receipt of executed signature pages from all of the parties.
Upon receipt of all executed signature pages, EPA shall
immediately issue a notice letter ail -
r;.ies st ring the date
on which the Settlement Agreement became effective. The parties
all acknowledge that because this Settlement Agreement is

intended to be the basis for resolution of the North Carolina
j' contested case proceeding, SLatp 2f m
r �
Caron - n=n, ---- -ir -North
-
LQ -, No. EHR C041, Tennessee was required to have the Settlement
Agreement approved through its statutory compromise and
settlement procedure before it executed the Agreement. Under
Tenn. Code Ann. § 20-3-103, the settlement of any litigation to
which Tennessee is a party must be approved by the Attorney
General and Reporter, the Comptroller of the Treasury, and the
Governor. North Carolina was required to have the Settlement
Agreement approved by the Department of Environment and Natural
Resources as the agency responsible for issuing the permit, and
by the NPDES Committee, as the agency responsible for issuing the
variance.
(r
X. AUTHORIZED SIGNATURES
44- Each of the undersigned representatives of the parties
certifies that :.e or she is fully authorized by the party he or
she represents to enter into the terms and conditions of this
Settlement Agreement and to le all g y bind suc1i party to this
Agreement.
IT IS SO AGREED:
UNITED STATES ENVIRONMENTAL: By:
AGENCY
/ . �.
John H. HankinsJr. Date:
Regional Administrator
9

STATE /O1n1F NORTH CAROLINA
By; yne M . Date: Wayne McDevitt
Secretary, DENR
By: .. B e.0,az
Daniel V. Date: 1ZfsOjS)
Besse
Chairman, 14PDES Commit`ee
[$ustel—n
ng to original si dated 12/22/971
SF T
L: B/
P. Wilsonate.ty Governor for Policy
IM
--u r;. luates— —
County Commissioner
te: 4l -
CITY OF dEWPORT, NNESSEE
l ames E. Rob nson Date: Z,2 7
Mayor
TENNESSEE ENVI ONMENTAL COUNCIL
John NoelDate: / _� .. ,� _ •�
Pi eon g ive-r:-Coordinator
SSO IATION
By.
David E. l Date:
JC-nk ns
Director 6f,6onservation
and Publis�policy
CHAMPION 75
PORAT N
By;
Richai '� Date:
Senior Vi rPOrlc,
Preside t,
Environm nt, Health & Safety
�_ [Conforming to original signature dated 12/19/971

Pigeon River Science Panel
Data Review and Recommendations
Prepared for
U.S. EPA — Region 4
61 Forsyth St., SW
Atlanta, GA 30303
Prepared by
Anna Hamilton
Lee Wilson & Associates, Santa Fe, NM
Kay Johnson
Tetra Tech, Inc., Lafayette, CA
Rob Plotnikoff
Washington State Department of Ecology, Olympia, WA
Final Report
2005

i
River Science Panel Review
Executive Summary
Background and Issues
Final
The Pigeon River flows almost 70 miles northeast from its headwaters in North Carolina to its
confluence with the French Broad River in Tennessee. The Pigeon River basin includes several
tributaries and a few urbanized areas. Most of the watershed is forested, with some agricultural
development near the river. The river also supports a significant recreational industry.
In 1908, the Blue Ridge Paper Mill (previously operated by Champion Paper) was established on
the Pigeon River near Canton, North Carolina, at about river mile (RMv1) 64. The paper mill
discharges treated wastewater from mill operations, domestic wastewater from Canton, and
leachate from an active landfill. Other discharges to the river below the mill include several
wastewater treatment plants (WWTPs). Another significant feature along the river is Walters
Dam at RM 39, operated by Progress Energy (formerly Carolina Power & Light Company) for
hydropower generation.
In the past, the mill 'discharge resulted in high loadings of color and biochemical oxygen demand
(BOD), low dissolved oxygen (DO) concentrations, low pH, high bacterial counts, high
conductivity, total suspended solids (TSS) and total dissolved solids (TDS), increased nutrient
loading, increased temperatures, and toxins including dioxin, furan, and chloroform. There is a
history of contested permits, lawsuits, and interventions associated with the mill. The paper
plant began modernizing its facilities and operations in 1990. One notable improvement to the
pulping process was changing from chlorine bleaching to oxygen delignification, which
eliminated further discharge of dioxin.
In 1997, a Settlement Agreement was signed by several government and non-profit organizations
involved in the contested permitting. The Settlement Agreement includes the call for "a current
evaluation of the level of contaminants remaining in the system and the overall health of the river
and the Waterville Reservoir." EPA took this responsibility and convened a Science Panel to
address the following objectives:
Evaluate existing data, including its quality, comparability, pertinence to existing issues,
and completeness.
Identify additional data, if needed to fill existing data gaps, and focus future monitoring
efforts.
Conduct an ecological assessment, if possible, as a summary of existing conditions and a
framework for understanding any remaining concerns.
This report is a result of a short-term, intensive review of existing Pigeon River data, and based
on that, of existing river conditions, conducted by the Science Panel. The Pigeon River Science
Panel selected a limited number of data parameters for review, based on their importance for
assessing ecological conditions within this river system and the availability of data. Assessment
efforts focused on the main stem of the river.

River Science Panel Review
Status of Pigeon River Data
Final
The extant data on the Pigeon River reflects nearly two decades (1983 to 2004) of pollution
studies and permit monitoring. These data are a valuable asset and, despite the diversity of study
objectives and approaches, provide considerable information about this system. Nevertheless,
one of the biggest single deficits of the existing Pigeon River knowledge base is its lack of
continuity. This includes various spatial and temporal discontinuities, as well as lack of
continuity in sampling and analysis methodologies. For example, water quality data were
collected regularly between 1987 and 1998, but only for select sites in North Carolina.
Similarly, benthic macroinvertebrate and fish community data are sporadic. Although benthic
sampling is conducted annually, most stations are not sampled every year, and there are only a
few years in which spatial comparisons above and below the paper mill can be made. Also,
sampling methods and methods of calculating benthic community indices differ between North
Carolina and Tennessee, making it problematic to compare results, even when synoptic sampling
occurred. The most complete temporal record of fish community monitoring is for two
locations in Tennessee, with other locations not sampled in most years. The most complete
spatially synoptic fisheries sampling occurred in 1995.
Toxicant data consist almost entirely of annual monitoring for 2,3,7,8 TCDD & TCDF (dioxin &
furan) in fish tissue, although fish species and sample locations have varied over time. Other
types of toxicants, such as releases from the W WTPs and landfill discharging to the river, have
not been characterized recently.
Condition of the Pigeon River Ecosystem
Major changes in water quality conditions occurred following changes to the paper pulping
process in the early 1990s. Significant improvements occurred in water quality variables
including color and TDS. Total Suspended Solids concentrations below the mill outfall declined
to resemble upstream conditions following 1993. Long-term changes in DO concentrations
below the paper mill were difficult to interpret, due to the limited number of measurements
compared to the typically high short-term variability and complex dynamics of this variable.
Biological responses to the paper mill discharge are evident within the benthic and fish
communities, although substantial improvements over time clearly occurred. In addition to
possible mill effluent effects, benthic community patterns suggest responses to spatial
differences in habitat, and possibly to other inputs (e.g., tributaries, WWTPs, non -point source
runoff). Downstream fish communities show an increasing diversity of native species,
supplemented by a re -introduction program, suggesting there is substantial improvement in
ecological condition of the lower Pigeon River, with the potential for continued recovery.
Following modernization of the mill, dioxin concentrations in all fish species sampled decreased
substantially. Based on these data, the States of North Carolina and Tennessee rescinded
consumption advisories for all fish, except for carp in Waterville Reservoir. The convergence of
two conditions: 1) settling zone for organics, and 2) depositional zone for historic dioxin loads
may promote higher risk of contaminant exposure in the carp population.

River Science Panel Revieiv
Science Panel Recommendations for Future Activities
Final
Integration and Management of Data. Greater utility of existing information and future
comparisons would derive from centralized banking of data, statistical summary and review of
data, and development and maintenance of meta -data. A focused effort should be made to add
biological, water quality, and toxics data collected since 1998 to the existing electronic database.
Future Monitoring Efforts. Future monitoring of water quality and biological communities
should be conducted within the framework of a cooperative monitoring program, to assure
comparability of methods and results, achieve greater spatial coverage of aquatic resources, and
realize greater efficiency and cost savings. An integrated program could address multiple
objectives beneficial to government agencies and regulated businesses. Duplicate data collection
efforts (e.g., fish tissue analyses for dioxins) should be refocused and/or halted.
Periodic synoptic benthic surveys of the river should be conducted. Sampling should include
locations immediately upstream and downstream of the paper mill outfall and extend to the
French Broad River. Methods should be uniform, quantitative, and documented, with
consideration given to adopting the EMAP Wadeable Streams protocols.
Continuous monitoring of DO, temperature, and conductivity should occur below the paper mill
outfall, immediately above the Waterville Reservoir, at the base of the bypassed reach, and at the
mouth of major tributaries.
A 5-year review process is recommended to confirm that dioxin levels in sportfish remain below
levels of health concern. Bottom feeding fish sampling in the reservoir could also be reduced to
a 5-year sampling frequency since dioxin levels have remained relatively stable over at least the
past 5 years. Additional sampling of sediments and other biota could provide important
information on dioxin "sinks" in the river and reservoir.
Sediment Transport Modeling. Mapping the location of contamination in depositional zones
and describing the rate and quantity of sediment transport is necessary to determine risk to
species that are potentially exposed to pollutants.
Detailed Risk Analysis. Additional information is needed to conduct a full ecological risk
analysis, including identifying specific stress sources, defining the contribution of variations in
habitat condition, and defining the areas of greatest exposure. In addition, information is needed
on indicators of organism response besides species presence and abundance, and on contaminant
levels or responses of higher trophic levels. In order to understand the ecological risks posed by
the dioxins remaining in fish and sediments, an evaluation of the potential for accumulation in
predators, such as otter or birds of prey, may need to be conducted.

River Science Panel Review
Table of Contents
Executive Summary
1.0 Introduction.
Final
Page
1.1 Background............................................................................................................1
1.2 Issues.......................................................................................................................2
1.3 Science Panel..........................................................................................................3
2.0 Panel Approach..................................................................................................................3
2.1 Identifying and reviewing available data.............................................................3
2.2 Focus on Selected Analyses...................................................................................4
3.0 Characterization of Available Data .... :.............................................................................
5
3.1
Range and Type of Data........................................................................................5
3.2
Water Quality Data................................................................................................6
3.3
Biological Data.......................................................................................................8
3.3.1 Benthic Macroinvertebrates.........................................................................8
3.3.2 Fish Community Characterizations...........................................................11
3.3.3 Periphyton...................................................................................................13
3.4
Dioxin and Other Toxicological Data.................................................................13
4.0 Characterization of Environmental Condition.............................................................17
4.1
Water Quality Analysis/Evaluation....................................................................17
4.2
Biological Analysis/Evaluation...........................................................................19
4.2.1 Benthic Macroinverlebrates.......................................................................19
4.2.2 Fish Community Characterizations...........................................................20
4.3
Dioxin Evaluation (Human Health Risk)...........................................................23
4.4
Fish Criteria Relative to Current Toxicity Evaluations...................................25
4.5
Integration of "Key" Observations....................................................................27
5.0 Recommendations
............................................................................................................28
5.1
Future Monitoring Efforts..................................................................................28
5.2
Integration and Management of Data................................................................30
5.3
Sediment Transport Modeling............................................................................31
5.4
Detailed Risk Analysis.........................................................................................31
6.0 Literature Reviewed and/or Cited.....
.................................3 2
iv

River Science Panel Review
List of Tables
Final
Table Page
Zones along the Pigeon River mainstem defined for purposes of evaluation of
existing data and of ecological conditions...........................................................................4
Sources of data for water quality evaluation in select reaches of the
PigeonRiver, NC and TN....................................................................................................8
Availability of fish community results (species composition and abundance and IBI)
from TVA in select reaches identified by zones (see Section 2) of the Pigeon River,
NCand TN....................................................................................................................
Average changes in elevation (feet per mile) for defined zones within the mainstem
PigeonRiver, NC and TN......................................................................I...........................20
Species composition and abundance of fishes at various sampling locations along the
Pigeon River, NC and TN, 1995 and 2003........................................................................22
Target list of fish species expected to occur in the Pigeon River, TN...............................24
Acceptable fish tissue concentrations
.26 ,

River Science Panel Review
Figure
Final
List of Figures
Page
Map of Pigeon River features (adapted from CP&L 2002)...............................................36
Map of Pigeon River basin, showing sampling stations with definition of zones (A-H)
alongthe mainstem............................................................................................................37
Temporal and spatial patterns for water Color observations (units) described by
"zones" in the Pigeon River that extend from North Carolina and end in
Tennessee. Data describing Color units and'variance for each year may originate
From one or more stations within each zone. (The error bars represent one standard
Deviation about the mean.)...........................................................................................
4 Temporal and spatial patterns for Total Dissolved Solids (TDS) concentrations
(mg/L) described by "zones" in the Pigeon River that extend from North Carolina
and end in Tennessee. Data describing TDS concentrations and variance for
each year may originate from one or more stations within each zone. (The error bars
represent one standard deviation about the mean.)............................................................39
5 Temporal and spatial patterns for Total Suspended Solids (TSS) concentrations
(mg/L) described by "zones" in the Pigeon River that extend from North Carolina
and end in Tennessee. Data describing TSS concentrations and variance for
each year may originate from one or more stations within each zone. (The error bars
represent one standard deviation about the mean.)............................................................40
6 Annual average stream flow in the Pigeon River near Hepco, NC (USGS gage
403459500), RM 45.1, 1980-2002.....................................................................................41
7 Temporal and spatial patterns for Ammonia (NH3-N) concentrations (mg/L)
described by "zones" in the Pigeon River that extend from North Carolina and end
in Tennessee. Data describing NH3-N concentrations and variance for each year may
originate from one or more stations within each zone. Data collected from zone "e"
in 2004 are represented by a single observation collected from surface water at two
locations in Waterville Reservoir. (The error bars represent one standard deviation
aboutthe mean.) ....................................... .......... ........................................ I ...................... 42
Temporal and spatial patterns for Total Nitrogen (TN) concentrations (mg/L)
described by "zones" in the Pigeon River that extend from North Carolina and end
in Tennessee. Data describing Total Nitrogen concentrations and variance for each
year may originate from one or more stations within each zone. Data collected from
zone "e" in 2004 are represented by a single observation collected from surface
water at two locations in Waterville Reservoir. (The error bars represent one
standard deviation about the mean.)..................................................................................43
vi

River Science Panel Review
Figure
Final
List of Figures (continued)
Page
Temporal and spatial patterns for Total Phosphorus (TP) concentrations (mg/L)
described by "zones" in the Pigeon River that extend from North Carolina and end
in Tennessee. Data describing TP concentrations and variance for each year may
originate from one or more stations within each zone. Data collected from zone "e"
in 2004 are represented by a single observation collected from surface water at two
locations in Waterville Reservoir. (The error bars represent one standard deviation
aboutthe mean.).................................................................................................................44
10 Temporal and spatial patterns for Dissolved Oxygen (DO) concentrations (mg/L)
described by "zones" in the Pigeon River that extend from North Carolina and end
in Tennessee. Data describing DO concentrations and variance for each year may
originate from one or more stations within each zone. Data collected from zone "e"
in 2004 are represented by a single observation collected from surface water at two
locations in Waterville Reservoir. (The error bars represent one standard deviation
about the mean.)......
.........45
11 Number of EPT taxa in benthic communities of the Pigeon River in North Carolina
and Tennessee, September 2001 (from CP&L).................................................................46
12 Number of EPT taxa in benthic communities of the Pigeon River in North Carolina
July 2002 (from NCDENR)...............................................................................................46
13 Number of EPT taxa in benthic communities of the Pigeon River in North Carolina
below the Blue Ridge Paper Mill (Zone "d") from 1983-2002.........................................47
14 Fish Index of Biotic Integrity (IBI) for several locations along the Pigeon River,
NC and TN, collected by TVA in 1990 and 1997.............................................................47
15 Number of native species of fishes along the length of the Pigeon River, from above
the paper mile discharge (RM 64.5) to Tannery Island, TN (RM 8.2), 1995....................48
16 Fish Community Index of Biotic Integrity (IBI) at two locations on the lower Pigeon
River, TN, Denton (RM 16.5) and Tannery Island (RM 8.2), 1988-2003 (from
Charles F. Saylor, personal communication, 2005)...........................................................48
17 Number of Native Fish Species collected from the Pigeon River at two locations on the
lower Pigeon River, TN, Denton (RM 16.5) and Tannery Island (RM 8.2), 1988-2003..49
18 TCDD concentrations measured in all fish species sampled at RM 64.5 (non -detects
reported at the detection limit)...........................................................................................49

River Science. Panel Review
List of Figures (continued)
Figure
Final
Page
19
TCDD concentrations measured in three fish species (not including carp) sampled at
RM 64.5 (non -detects reported at the detection limit).......................................................50
20
TCDD concentrations measured in all fish species sampled at RM 59 (non -detects
reported at the detection limit)...........................................................................................50
21
TCDD concentrations measured in all fish species sampled at RM 52,3 (non -detects
reported at the detectionlimit............................................................................................51
22
TCDD concentrations measured in two fish species (not including carp) sampled at
RM 52.3 (non -detects reported at the detection limit).......................................................51
23
TCDD concentrations measured in all fish species sampled at RM 41.5 (non -detects
reported at the detection limit)...........................................................................................52
24
TCDD concentrations measured in five fish species (not including carp) sampled at
RM 41.5, at head of reservoir (non -detects reported at the detection limit)......................52
25
TCDD concentrations measured in all fish species sampled at RM 39, near dam in
reservoir (non -detects reported at the detection limit).......................................................53
26
TCDD concentrations measured in six fish species (not including carp) sampled at
RM 39, near dam in reservoir (non -detects reported at the detection limit)......................53
27
TCDD concentrations measured in six fish species sampled at RM 19 (non -detects
reported at the detection limit............................................................................................54

River Science Panel Review Final
Pigeon River Science Panel
Data Review and Recommendations
1.0 Introduction
The Pigeon River drainage is set in the Blue Ridge Mountain physiographic province and flows
eastward and north to the Tennessee Ridge and Valley province. The headwaters of the Pigeon
River are buried in the steep -sided valleys of the Blue Ridge Mountains where there is a limited
amount of farming and logging. Towns located in the upper drainage are limited in size by the
surrounding geography and by the natural resources in the region.
The lower end of the drainage has wider valleys as it enters the Tennessee Ridge and Valley
ecoregion. Farming interests that include a tomato -growing industry become prevalent and a
burgeoning recreation industry has provided economic growth to the region. Walters Dam
provides white -water rafting opportunities, canoeing, and recreational fishing expeditions in the
lower portion of the drainage and this attracts over eighty -thousand visitors per year. Addressing
past and existing water pollution problems are paramount in this region as the Pigeon River is the
focus for most of the local economy's success.
1.1 Background
The Blue Ridge Paper Mill (previously operated by Champion) is located near Canton, North
Carolina, and discharges to the Pigeon River at approximately river mile (RM) 63.3 (Figure 1).
The mill is located at the transition from a high -gradient reach classified as Class A trout waters,
to a lower -gradient reach with waters classified as cool -water fisheries. Major upstream
tributaries are the east and west forks of the Pigeon River. Major tributaries within North
Carolina below the mill include Richland Creek, Jonathans Creek, and Cataloochee Creek.
At about RM 41.5, the river enters Waterville Reservoir, created by Walters Dam at RM 39, and
operated by Progress Energy (formerly operated by Carolina Power & Light Company [CP&Lj)
for hydropower generation. Water is withdrawn from the lake through a bypass tunnel to the
hydropower facility located near the state line with Tennessee, at about RM 26. The "bypassed"
portion of the Pigeon River, between RM 39 and RM 26, is supplied with flow from tributary
streams and groundwater. The Pigeon River then flows for 26 miles through Tennessee to its
confluence with the French Broad River.
The paper mill discharge includes treated wastewater from mill operations, domestic wastewater
from the town of Canton, and leachate from its active landfill. The mill is permitted to discharge
29.9 million gallons per day (MOD), and the discharge can represent up to 90% of total river
flow below the discharge at low flow. As such, the paper mill is a major discharger on the
Pigeon River. However, there are more than 20 other discharges to the river below the mill
(NCDENR, 2003), including the Waynesville wastewater treatment plant (W WTP) (6 MOD) and
Maggie Valley's W WTP (1 MOD). Erosion and nutrient runoff from agricultural lands within

River Science Panel Review Final
the watershed also influence the river, including cattle and dairy farms (watershed land use
within North Carolina is classified as 14% pasture), and cultivated crops. Still, most of the
watershed within North Carolina is forested (about 84%). Some influence of urbanization comes
from the major towns, including Canton, Waynesville, Lake Junaluska, and Clyde in North
Carolina, and Denton and Newport in Tennessee.
1.2 Issues
A river, whose value to local residents was once based on its native fauna, was changed forever
when the paper mill was established in 1908 (Coombs, 2004). At its inception and for many
subsequent decades, the paper mill discharged pollutants to the river with little restriction. The
mill discharged in North Carolina and was regulated in North Carolina, but river-bome pollutants
traversed the state line into Tennessee. During the ensuing years, pollution issues were protested
by local citizen groups in the State of Tennessee.
Conditions created by the mill discharge that impacted native fauna included high loadings of
color and biochemical oxygen demand (BOD), low dissolved oxygen (DO) concentrations, low
pH, high bacterial counts, high conductivity, total suspended solids (TSS) and total dissolved
solids (TDS), increased nutrient loading, increased temperatures, and toxins including dioxin,
furan, and chloroform. Other aesthetical and environmental issues included foam and odor.
These by-products of the pulping process remained for decades until stronger regulation forced
change. The change was influenced in part by a lawsuit brought against the State of North
Carolina by the State of Tennessee.
An alteration in the pattern of river hydrology and effluent distribution in the lower mainstem of
the river occurred with the establishment of Walters Dam in 1930. To an extent, this structure
blocked pulp mill effluent by filtering sediments and dissolved pollutants along the length of the
Waterville Reservoir. The presence of Walters Dam has helped abate pollution in a portion of
the drainage, but has changed the hydrologic cycle in the lower Pigeon River.
The mill itself started modernizing its operations in about 1990. One notable improvement was
changing from chlorine bleaching to oxygen de-lignification, which eliminated further discharge
of dioxin.
Contested permitting, interventions and associated legal proceedings eventually resulted in a
Settlement Agreement in 1997, signed by all involved parties including several government and
non-profit organizations. An updated operating permit (NPDES) was issued to the pulp mill in
2001 in order to improve quality of its discharge effluent, which, upon reaching the river, would
not cause water quality violations in this Class C water as outlined by North Carolina
environmental law. The paper mill has been and is currently in compliance with all of its
discharge limitations, including consistently passing its required Whole Effluent Toxicity (WET)
tests. A current draft NPDES permit issued by the State of North Carolina outlines a complex set
of rules for effluent quality and considers river discharge a major natural influence on
assimilation capacity of the Pigeon River.

River Science Panel Review
1.3 Science Panel
Final
Numerous ecological studies have been conducted since the 1980s by various entities to
characterize river conditions relative to the mill discharge. These have included the status of
biological communities, and of toxic contaminants. Most of these studies provide data useful for
characterizing river conditions. However, almost all recent sampling is divided among various
entities and provides examples of spatially or temporally limited sampling, and few
comprehensive or synoptic studies. No single entity currently sampling on the Pigeon River is
responsible for synthesizing all recent existing data. Undoubtedly in light of this multiplicative
situation, the 1997 Settlement Agreement includes, among other terms, the call for "a current
evaluation of the level of contaminants remaining in the system and the overall health of the river
and the Waterville Reservoir". EPA took the responsibility for implementing such an
overarching evaluation of current status, and convened a scientific panel to address the following
objectives.
• Evaluate existing data, including its quality, comparability, pertinence to existing issues,
and completeness.
• Identify additional data, if needed to fill existing data gaps, and focus future monitoring
efforts.
• Conduct an ecological assessment, if possible, as a summary of existing conditions and a
framework for understanding any remaining concerns.
2.0 Panel Approach
2.1 Identifying and reviewing available data
Data pertinent to the Pigeon River system have been collected over a relatively long time frame
(at least since the 1980s), by many different entities (e.g., state and federal government agencies,
industries, consulting scientists), and for a variety of objectives. As a result, sources of data tend
to be distributed. In addition, there have been many competing interests and objectives regarding
this river system, and the issues associated with the industrial activities on the river have been
controversial. This generates an ongoing need to fully understand the system and make
maximum use of existing information. An initial effort to address this need and gather existing
information from diverse sources into a unified database was undertaken for EPA Region IV by
Tetra Tech, and is reported in Tetra Tech (2004).
The result of the necessarily limited Tetra Tech effort was a prototype database produced in a
specialized application of Access®, called the Ecological Data Application System (EDAS). The
Pigeon River EDAS database includes much of the existing Pigeon River data for the period
1983-1998. Types and sources of data incorporated into this database are fully described in
Tetra Tech (2004), and specifics regarding availability of data are discussed in this report by
category (water quality, biological data, and toxins).
The EDAS database represented readily accessible data to the Science Panel, and was the source
of information first evaluated. Existing limitations in the database that resulted from

River Science Panel Review Final
circumstances attending its development (e.g., data from some sources could not be made
available to Tetra Tech in a timely manner, much existing biological data were never entered into
any electronic format), became limitations for Science Panel evaluations. Data limitations are
mainly discussed in the body of this report, which include the absence of methods descriptions,
station descriptions, completeness for some data (e.g., types of fish analyzed for dioxins) and
quality information for data that have been incorporated into the database.
Because of the wide variety of data sources and lack of any commonality in application of station
names, the first step was to plot all sampling stations included in the EDAS database using GIS.
The distribution (and clustering) of stations on the resulting map was based on major features
along the river such as: the location of the paper mill discharge, location of the reservoir, and
location of the hydro -generating facility (point of re -introduction of mainstem river water to the
river channel). Zones were identified by grouping sampling stations that were influenced by
similar natural or human disturbances. These zones are shown in Figure 2, and described in
Table 1.
Table 1. Zones along the Pigeon River mainstem defined for purposes of evaluation of
existing data and of ecological conditions.
Zone
River Miles
Description
A
69-65.5
Upper Pigeon R. mainstem, above mill discharge
B
65-64
Immediately above mill discharge
C
62-60
Immediately below mill discharge
D
59-45
Between mill discharge and reservoir
E
43-41.5
Immediately above reservoir
F
38 -26
Bypassed reach
G
26-14
Below hydroelectric facility to near Denton, TN
H
9-7
Mainstem near Tannery Island, TN
Two additional zones were also identified for the reservoir, designated by river mile. These are
located at RM 41.5, at the head of the reservoir, and RM 39, near the reservoir dam.
The next step in data evaluation was to tabulate each parameter of interest by location (zone) and
date in order to assess the extent of data available. Once the extent of available data from the
EDAS database for selected parameters was determined, the potential availability of recent data
was determined by review of hardcopy reports, data sheets, and of individual Excel® files
provided mainly by the Tennessee Wildlife Resources Agency (TWRA) or entered from
hardcopy sources to support analyses by the Science Panel. Hardcopy sources of data are
described in the main body of this report by category (water quality, biological data, and toxins).
2.2 Focus on Selected Analyses
The Science Panels' objectives for evaluating the condition of existing data as well as the
existing condition of the river were approached within specific constraints. The value in
assessing existing data is in defining broadly what has been studied, and where there are
significant gaps in important information. It was therefore not the intent of the Panel to
catalogue all available data and assess its quality. The Science Panel was convened to conduct a

River Science Panel Review Final
short-term, intensive review, including one week of focused effort for orientation, data review
and evaluation, and framing of a report, with approximately two subsequent weeks for
completion of the report. Within this timeframe, and considering any data limitations discovered
during the first week of effort, the Panel took the approach of selecting a limited number of
parameters for review based on importance to the issues within this river system and availability
of data. In addition, the Panel focused assessment efforts on the mainstem of the river. While
there are tributary data available, this increase in scope of assessment was not deemed warranted
to address the Panel's objectives.
3.0 Characterization of Available Data
3.1 Range and Type of Data
Data have been generated from the Pigeon River drainage for more than two decades. Several
agencies and private companies have contributed to this base of information. For example, Blue
Ridge Paper Products and Progress Energy generated over ten years of data as conditions
outlined by operating permits. The following is a list of government and private contributors to
the base of known information included in this analysis:
United States Environmental Protection Agency (U.S. EPA) Region 4
United States Forest Service
United States Geological Survey
U.S. EPA MDSD
U.S. EPA Headquarters
U.S. EPA Environmental Research Laboratory
Tennessee Valley Authority
North Carolina Division of Environment and Natural Resources
North Carolina Environment, Health, and Natural Resources
Tennessee Department of Environmental Quality
Carolina Power and Light (now Progress Energy)
Champion International Corporation (now Blue Ridge Paper Products)
Tennessee Division of Environment and Conservation
Tennessee Wildlife Resources Agency
Period ofRecord. Data examined in this review were collected from between 1983 and 2004.
Water Quality data had been collected from the earlier time period through 1998 with limited
records in 2001 and 2004. Biological information was collected throughout the period of record
(POR), but on a discontinuous basis. The greatest effort in biological characterizations and
evaluation of changes occurred at the lower portion of the drainage in the State of Tennessee.
Accumulation of toxins (e.g., dioxin, furan, chloroform) in fish tissues were collected from 1987
through 2004. Specific dates included in evaluations for this review are reported in detailed
discussions of water quality, biological data, and dioxin including other toxicological data.

River Science Panel Review Final
Format (electronic or hard copy). Data evaluation began with examination of the Tetra Tech
EDAS database. The largest volume of readily available electronic information described water
quality conditions. However, recent water quality information was restricted to hardcopy
reports. Most of the data describing toxicological concentrations in fish tissues and other
compartments of the ecosystem were found in hardcopy reports. Biological descriptions of
benthic macroinvertebrate and fish community evaluations were also found primarily in
hardcopy reports. Hardcopy information was transferred into electronic format and eventually
incorporated into graphical form for further examination. The literature reviewed and relevant
information used for this report are found in Section 6.0 (Literature Reviewed and/or Cited).
3.2 Water Quality Data
Period of Record. Water quality data examined for this review included sporadic records
produced from 1983 through 1987. Following 1987, records were more consistently generated
by Progress Energy (formerly Carolina Power and Light) and by Champion International
Corporation (now Blue Ridge Paper Products). Continuous data at select sites along the
mainstem Pigeon River were available from 1987 to 1998. The longest records for water quality
monitoring were generated by Carolina Power and Light at four locations beginning from above
the town site of Canton, North Carolina to the powerhouse at RM26. Additional water quality
records were obtained from the Tennessee Department of Environment and Conservation in the
lower reaches of the Pigeon River. The sites at Denton and Tannery Island generated information
for 1987 and 1988. Few records exist for water quality at these sites beyond 1988.
Pollution problems originating from pulp mill effluent discharged into the Pigeon River
prompted monitoring designs by both private companies (pulp mill and power generator) to
enable partitioning of pollution effects on water quality and biological communities. The
pollutants were characteristic of two pulping processes (chlorine bleaching prior to 1994 and
presently oxygen de-lignification) and hydrologic modification through operation of a
hydropower dam at approximately River Mile 39 (RM 39). These monitoring sites generated
long-term records that were useful for determining improvements in water quality over the past
decade.
Format (electronic or hard copy). Records through 1998 were, extracted from the EDAS
database and analyzed for increasing/decreasing patterns over the ten year period of record at key
locations of the drainage. Some of the water quality parameters were discontinuous over space
and revealed location of data gaps. A limited amount of recent water quality information (2004)
was extracted from hardcopy reports and was plotted independently from electronically available
data on graphs describing total nitrogen, total phosphorus, dissolved oxygen; ammonia -nitrogen
concentrations, and water temperature. These data were restricted to two locations within the
Waterville Reservoir; near the head (Zone "e") and near the Walters Dam.
Data Ouality Evaluation. The longest period of record for water quality available at any of the
sites is restricted to four locations: immediately above the town site of Canton (effluent outfall),
mainstem Pigeon River before the Waterville Reservoir, below Walters Dam (RM33.0), and at
the powerhouse (RM26.0). This served as the basis for the most complete long -tern evaluations

River Science Panel Review Final
of water quality conditions. Following 1998, data were available at select stations and restricted
to a sub -set of the original variables monitored for the longer term effort.
Water quality sampling data is absent from immediately below the effluent outfall on the Pigeon
River mainstem. The current discharge permit requires extensive monitoring at several locations
below the effluent outfall (Permit No. NC0000272, Forrest Westfall). This is an important
addition to monitoring information for evaluating the output of nutrients on an annual and
seasonal schedule.
Information regarding performance of laboratory analysis was generally unavailable. Therefore,
quality assurance records for batch laboratory analysis of samples were not examined as part of
this review. Factors that affect analysis of water quality data for pattern or trend over longer
time periods are: differences in analytical methods among data sources, sample batch
performance of the instrumentation (e.g., detection limits, bias, data qualifiers), and consistency
in field collection protocols. Quality assurance information was unavailable for the water quality
records contained in the EDAS database and so was assumed to meet standard requirements for
each analyte. The water quality information included in EDAS is located in the U.S. EPA
STORET database and will have data quality designations. The generators for the bulk of the
data analyzed are assumed to have used high quality laboratory analytical services.
Selection ofData for Characterization. Degradation of water quality in the Pigeon River
mainstem was historically related to the Blue Ridge Paper Products mill. A select group of water
quality variables that could be altered by the effluent discharged into the river was monitored
over time. These variables included those with secondary effects to chemical characteristics of
the receiving water like dissolved oxygen or temperature. The remaining primary variables were
selected based on direct influence the pulping process had on water withdrawn from the river and
then returned following treatment of the wastes.
The primary water quality characteristics evaluated in this review were: color, temperature,
dissolved oxygen, total dissolved solids, total suspended solids, total nitrogen, total phosphorus,
and ammonia concentrations (see Table 2). Most of these variables have related monitoring
requirements described in the recent draft discharge permit issued by the State of North Carolina
(Permit No. NC0000272, Forrest Westfall). Those not included in the draft permit were used to
determine changes to ecosystem function in reaches throughout the Pigeon River Basin.

River Science Panel Review
Table 2. Sources of data for water quality evaluation in select reaches of the Pigeon River, NC
and TN.
Final
Sources of Data (Zones) .
Water Quality Variable
Carolina Power and Light
Tennessee Valley
North Carolina WQD
Authority
Temperature
1995-1998 (a); 1987-1998 (e,f,);
1987-1988 (g)
'
Color
1987-1998 (a,e,fg), 2001 (a,e,f)
1983 (b,e,f,g)
1983-1997 (b,d,e)
Dissolved Oxygen
1987-1998 (a,e,f,g); 2001 (a,e,f)
1983 (b,e,f,g); 1994
1983-1997 (b,d,e)
Total Dissolved Solids
1995-1998 (a); 1987-1998
(e,f,g); 2001 (a,e,f)
Total Suspended Solids
1995-1998 (a); 1987-1998 (e,0;
1987-1988 (g); 2001 (a,e,t)
Total Nitrogen
1995-1998 (a); 1987-1998 (e, f ;
1987-1988 (g); 2001 (a,e,t)
Total Phosphorus
1995-1998 (a); 1987-1998 (e,f);
1987-1988 (g); 2001 (a,e,t)
Ammonia
1987-1998 (b,e,f,); 2001 (a,e,t)
3.3 Biological Data
3.3.1 BenthicMacroinvertebrates
Period ofRecord. Various types and/or sources of benthic data have been collected from
different locations in the Pigeon River from 1983 to 2004. Collections were, in general, once per
year, however, there were usually only a few stations sampled in any one year. As a result, there
are only a few years within the period of record (POR) when data were collected at multiple
locations upstream and downstream in the mainstem Pigeon River where a synoptic survey used
comparable methods. '
In North Carolina, benthic community indices are reported most frequently (11 of the 20 years in
the POR) for the Pigeon River just upstream of the Blue Ridge Paper Mill (approximately river
mile (RM) 64.5). The month in which the annual collection occurred varied, but was most often
in July, August, or September. Benthic community indices also were reported relatively
frequently (10 of the 20 years) at a location downstream of the paper mill, at about RM 57.5, and
less frequently (4 of the 20 years) at a third downstream location, at about RM 42.5. Overall,
there were four years (1988, 1994, 1997, 2002) during which benthic community index results
were reported for three locations.

River Science Panel Review Final
It should be noted that within the 1983-2004 POR, some benthic survey results are available for
other locations within the Pigeon River sub -basin, including the east and west forks, and several
tributaries. Typically, sampling was conducted at these locations in one to four years within the
POR, though a few (e.g., Cataloochee Creek) were sampled more frequently. Tributary data
were not evaluated further in this report, as discussed above in Chapter II.
In addition to benthic index results, some benthic community data, listing taxa and relative
abundances, exist for the same three general locations described above (the vicinities of RM
64.5, 57.5, and 42.5), for several years within the 1983-2004 POR. Years in which
taxa/occurrence data exist for all three locations include 1984, 1986, 1988, 1994, and 1997.
In Tennessee, benthic community index and taxa/occurrence data are reported annually for 1998-
2003 for two locations on the Pigeon River mainstem, Denton (about RM 16.5, zone "g") and
Tannery Island (about RM 8.2, zone "h"). The month of collection for each year was usually
July.
Format (electronic or hard cony). Only sporadic portions of existing benthic macroinvertebrate
data are available in electronic format. Some benthic community data (taxa and occurrence)
from the Pigeon River within North Carolina, including the three mainstem locations discussed
above, were available on EPA's STORET system, and were entered into the Pigeon River EDAS
database (Tetra Tech, 2004). A selection of benthic community index data from several
locations in both North Carolina and Tennessee was available on an ArcView GIS project, and
was downloaded from ArcView into Excel format for this review. These included three
mainstem Pigeon River locations in North Carolina and two in Tennessee. More details on this
GIS project and its status in relation to the Pigeon River database can be found in the database
report (Tetra Tech, 2004).
Remaining benthic data exist in hard -copy reports, and on data sheets. Sources include a report
by EA (2001) on river -wide sampling conducted in 2000, a report by Carolina Power & Light
(CP&L, 2002) reporting on sampling conducted in 2001; and a basin -wide assessment report by
North Carolina Department of Environment and Natural Resources (NCDENR) on the French
Broad Basin (2003). Hard -copy data sheets recording benthic taxa/occurrence and community
index results at the Denton and Tannery Island sampling locations on the Pigeon River in
Tennessee were provided by the Tennessee Valley Authority (Charles Saylor, TVA, personal
communication, 2005).
Data Quality Evaluation. Review and comparison of protocols used by different entities to
sample benthic macroinvertebrate communities in the Pigeon River suggest there are potentially
important differences, particularly between North Carolina and Tennessee. Sample collection
differences were discerned in the approach to defining and selecting the distribution of
microhabitat types to be sampled at a station, in how many microhabitat "subsamples" are
composited to create a station sample, and in how the level of sampling effort is defined and
controlled. Although multi -habitat collections generate larger species lists, sampling in riffle
habitat using quantitative collection protocols, or sampling among microhabitats in proportion to
their occurrence at each site, would generate results that have a greater likelihood in detecting
effects from stressors. Sampling standardized based on total activity time at a station is

River Science Panel Review Final
inadequate to assure comparability among sampling locations and dates, if numbers of sub -
samples taken and/or size of areas sampled are not also standardized. These differences can lead
to method -related variation in proportional representation of taxa that could confound
interpretation of spatial patterns.
In addition to the comparability limitations of the benthic sampling, there is an apparent lack of
quantitative habitat data, and/or existing habitat characterization results were not consistently
documented and reported. As a result, it is difficult to separate stressor effects on benthic
communities below the paper mill (habitat vs. contaminant concentrations). This in part
contributes to the conclusion that a comprehensive eco-risk assessment is not possible with the
current status of available benthic community characterizations and supporting habitat data.
In addition, the methods used to calculate community indices differ between North Carolina and
Tennessee. North Carolina uses a state -specific index called Biotic Integrity (BI), which is
tailored to the communities and levels of taxonomic identification used in North Carolina. In
Tennessee, the index used is called the Index of Biotic Integrity (IBI), but may also be slightly
altered from. the national standard. The indices are likely appropriate to their local applications,
and provide internally consistent results; but are likely to introduce unaccountable variation if
results from similar collection dates are combined in order to do river -wide (i.e., across -state)
evaluations.
Although North Carolina clearly generated benthic community taxa and relative abundance data
for each sample, these results were not made available in hard copy (or electronically). These
would have been useful for an ecological assessment, both for direct comparison to other
sampled locations, and for evaluation of index results that otherwise differed between agencies.
Other data quality problems were encountered in the course of tabulating various sources of
benthic data by station and date for evaluation:
• While there are several locations along the mainstem of the Pigeon River that are
sampled for benthic macroinvertebrates, few locations are actually sampled in any one
year. As a result, there are only a few years over the period of record (1983-2004) for
which reasonable spatial analyses could be conducted (assuming methods provided
comparable results).
• There are no stations sampled on a regular basis that are immediately downstream of the
paper mill discharge. The commonly sampled location (RM 57.5) is about 5 miles
downstream of the discharge. While this might not create a serious impediment to
evaluating plant effects and recovery over time if the spatial -temporal data set were
complete and fully comparable along the length of the river, given that the data set is
incomplete, an additional station proximal to the discharge would help support the
objective of conducting an ecological assessment and characterizing environmental
effects and possible recovery.
• Much of the existing benthic data are not entered into electronic format, and the
opportunity has not been provided for these results to be reviewed and entered into the
Pigeon River database.

River Science Panel Review
Final
Data that are on the electronic database suffer from taxonomic comparability problems
and errors, which were encountered through efforts to tabulate community data for spatial
comparisons. Although originally entered into STORET (see Tetra Tech, 2004), many
instances were found of similar taxa entered with different codes, or with different levels
of taxonomic detail, so that the same taxon occurred at more than one location, but did
not come up in the database as being comparable across those locations. In addition,
there were several errors encountered, which based on experience, can typically only be
discovered and corrected through a process of data tabulation and statistical summary and
review. These included a genus or species being listed under an incorrect higher
taxonomic category, and the same species being listed under multiple higher categories.
Selection of Data for Characterization. Benthic data availability is relatively deficient, despite
seemingly regular collections made by various entities in North Carolina and Tennessee.
Selection of benthic community results for evaluation was constrained by comparability of
results, by limited availability of years with broad spatial distributions of results, and by the
practicality of having recent results only in hard copy. The focus for evaluating benthic
community indices and taxa/occurrence data was on recent results for years in which all three
locations (the vicinities of RM 64.5, 57.5, and 42.5) on the mainstem Pigeon River in North
Carolina above and below the paper mill were sampled in the same month. Calculated indices
were compared only within a single collecting agency's results, without compiling results across
collections.
3.3.2 Fish Community Characterizations
Period of Record. Fish community monitoring in the Pigeon River has been conducted mainly
by the TVA for the period 1988-2004. Table 3 summarizes the availability of fish species
composition and abundance data and Index of Biotic Integrity (IBI) results by location along the
Pigeon River mainstem. Collections were made once per year (month of collection not specified
in the database). Results are available from twelve locations along the mainstem from just above
the Blue Ridge Paper Mill to the mouth (at its confluence with the French Broad). The most
complete temporal records for the period 1988-2004 are available from two sampling locations
in the Tennessee portion of the Pigeon River, at Denton and Tannery Island (Zones "g" & "h").
Sporadic collections were made at other mainstem locations by TVA, including locations in the
North Carolina above and below the Mill. There are only a few years from 1988-2004 in which
spatial comparisons for the entire mainstem can be made. The most complete suite of station
locations sampled synoptically within the basin was from 1995.
Fish community results (metrics only) are available from NCDENR only from tributaries above
the reservoir for the period 1993-2002. No fisheries data from the Pigeon River mainstem are
available from NCDENR.
There also is information available regarding fish re -introductions as part of the Pigeon River
Recovery Project; participating agencies include TDEC, TVA, TWRA, USGS, NCWRC, BRPP,
CFI, and UTK. The period of record for these re -introductions is 1996-2003. There are
associated snorkel survey results for re -introduced species from 2001-2004.

River Science Panel Revieiv
Table 3. Availability of fish community results (species composition and abundance
and IBI) from TVA in select reaches identified by zones (see Section 2) of the
Pi£eon River. NC and TN.
River Mile
Zone Place Name
Years
64.5
b
90, 95, 97, 03
63
c
95
59
d
95
55.5
d
90,.95, 97, 02
54.5
d
95
52.3
d
95
48.5
d
95
42.6
e
95, 97, 00, 03
24.9
9
95
19.3
9
90,95
16.5
(Denton)
Annually 88-03
8.2
h Tanner Island
Annually 88-04
Final
Formal (electronic or hart! copy). Aside from fish tissue concentrations of dioxin, no fisheries
data were available on the EDAS database established by Tetra Tech (2004). This was because
very little biological data had been entered into a formal electronic format, mainly EPA's
STORET, by the monitoring agencies, and no "informal" electronic data (e.g., in Excel files)
were made available to Tetra Tech during the period of database development.
During the week of the Science Panel meeting, several Excel files of fisheries results from TVA
were e-mailed to Tetra Tech from EPA Region 4 for use by the Panel. As a result, most of the
data listed in Table 3 could be summarized electronically.
Data Quality Evaluation. Spatially comprehensive data that would be useful for evaluating
effects of the paper mill and changes in those effects over time are available for a limited number
of years. For the most extreme example, fish collections are available from immediately below
the mill discharge (zone c) for only one year (1995). Results are available from further below
the discharge, but above the reservoir (one location) for four years (see Table 3). In addition,
these data represent the time period after the paper mill began significant process improvements.
Data prior to 1990 are not available from locations proximal to the mill discharge.
When river -wide fisheries data were available, the taxonomic and calculated community index
results were comparable among stations, since all the mainstem data available were collected by
the same agency (TVA). Thus, the problem of having river -wide data collected during only a
few years was not as severe as for the benthic community collections, where methods differences
between agencies in collection protocols and index calculations prevented direct comparisons of
data collected in the NC and TN reaches of the river. However, no methods descriptions were
associated with the data, no quality assurance/quality control efforts associated with entry of data
into a database were performed, and the data were received "at the last minute." In addition, it
should be noted that the State of North Carolina calculates its fisheries IBI index differently from
the IBI index used by TVA (NCDENR, 2004). Should there be a need to evaluate NCDENR

River Science Panel Review
Final
results from Pigeon River tributaries, comparisons to locations sampled by TVA would be
problematic.
Results of snorkel surveys conducted as part of the Pigeon River Recovery Project (searching for
tagged re -introduced fish) are available only in hard copy.
Selection of Data for Characterization. Fisheries data reviewed to characterize conditions in the
Pigeon River were limited to the TVA results. Fish species and abundance data (community
composition) were compared only for two years (1995 and 2003) for which river -wide
collections were available. Community index (IBI) results were compared at four locations
along the river (RM 64.5, 55.4, 16.5 and 8.2) for the earliest year available from these locations
(1990) and a later year (1997) to characterize improvements due to upgrades in mill operations.
Temporal trends in fish community metrics, which might also be expected to reflect
improvements in river conditions, were reviewed for Denton and Tannery Island in Tennessee.
3.3.3 Periphyton
Periphyton communities were not evaluated by the Science Panel. No periphyton data are
available electronically, and no recent periphyton data are available at all, even in hard copy.
The Pigeon River ecological study conducted by EA. Engineering, Science and Technology in
1987 (EA, 1988) represents the only substantial information on periphyton. Several interesting
conclusions arise from the EA (1988) study, showing possible benefits to including periphyton
studies in a monitoring program in this river system. But it must also be noted that this study
was conducted prior to the extensive facility and process improvements implemented by the
paper mill.
3.4 Dioxin and Other Toxicological Data
Toxicological data available for the Pigeon River consist primarily of dioxin analyses of fish
tissues. As early as 1987 the USEPA identified the characterization of dioxins in fish tissue from
the Pigeon River as a priority health issue because of dioxin production associated with the
bleach kraft paper pulping process. Fish accumulate dioxin, expressed either as the most toxic
constituent 2,3,7,8-Tetrachlorodibenzodioxin (TCDD) or as the combination of dioxin and furan
isomers as Toxic Equivalencies [TEQs] in tissues. Also, fish (rock bass, carp, and white
suckers) collected from the Pigeon River (as part of the USEPA National Chemical Residues in
Fish Study in 1987 and 1988) had dioxin concentrations ranging up to 75.7 parts per trillion
(ppt). Although dioxin concentrations in sportfish were below the Food and Drug Administration
(FDA) criterion of 25 ppt, the elevated concentrations in the bottom feeding species indicated
that additional evaluations were necessary. Studies of dioxin levels in fish tissue have been
ongoing since that time.
Evaluations of other toxicants potentially present in fish have been conducted infrequently and in
limited locations. Sampling has been conducted for dioxin and other toxicants in sediment,
surface water, and groundwater, but only at a few locations and timeframes. The data available
for these environmental media, therefore, are described separately below.
13

River Science Panel Review Final
Period of Record. Fish tissues were initially analyzed for dioxins/furans in 1987 by the USEPA.
Subsequently, fish tissues have been analyzed at least annually for dioxins/furans between 1990
and 2003. For the most part, sampling has been conducted by the two groups noted below,
supplemented by studies conducted by the USEPA and the States of North Carolina and
Tennessee.
• Champion Paper International (now Blue Ridge Paper Products, Inc.) collected fish and
analyzed tissues for dioxins/furans annually every summer (generally August) at six or
more locations along the river, including two locations within Waterville Reservoir.
Carolina Power and Light Company (CP&L) (now Progress Energy) collected fish and
analyzed tissues for dioxins/ftirans annually every winter (November) at a minimum of
two locations between 1991-2003. Prior to 2000, sampling was conducted at several
locations along the river, while after 2000 sampling was limited to two stations in
Waterville Reservoir.
Format (electronic or hard copy). Fish tissue analytical results are presented in electronic form
in the EDAS database developed for the Pigeon River by Tetra Tech (2004). Data are available
in electronic format for samples collected between 1990 and 1998. Dioxin concentrations are
provided in terms of the individual dioxin and furans analytical results as well as separate
determinations of the TEQs for each sample.
An additional electronic dataset (in Excel) was generated in support of this report, using the
summary of dioxin results presented in the Blue Ridge Paper Company's (2004) report for fish
tissue analyzed from 1990 to 2004. In addition to providing current levels of dioxins in fish, this
dataset also provided the dioxin/furan concentrations in fish fillets of individual fish species. To
be consistent with the reporting provided by Blue Ridge Paper, only the 2,3,7,8-TCDD
concentrations were used to -demonstrate changes in concentrations over time. TEQ levels are
available in the report, but were not entered into the electronic file.
Five reports available only in hardcopy provided detailed information on the dioxin/furan
concentrations in fish tissue, in addition to key sets of supporting data, such as fish species, fish
length, analytical method, and laboratory quality assurance/quality control data. These reports
are listed below:
1. USEPA. 1987. "Assessment of Dioxin Contamination of Water, Sediment and Fish in
the Pigeon River System (A Synoptic Survey)" [December 1988]
2. Tennessee Department of Environment and Conservation "Dioxin Levels in Pigeon_
River Fish 1996 —2002"
3. Blue Ridge Paper Products Inc. 2003. "Results of 2003 Dioxin Monitoring in Fish
Tissue."
4. Blue Ridge Paper Products Inc. 2004. "Results of 2004 Dioxin Monitoring in Fish
Tissue."

River Science Panel Review
Final
5. Progress Energy (formerly Carolina Power and Light). 2003. "Dioxin and Furan
Concentrations in the Axial Muscle Tissue of Fish from Waterville Lake, November
2003."
Data Ouality Evaluation. The datasets available to evaluate human health risks for the Pigeon
River consisted almost entirely of data on 2,3,7,8 TCDD & TCDF (dioxin & furan) in fish tissue.
Although dioxins/furans are highly toxic and bioaccumulative, the lack of nearly all other types
of toxicant data by default limits the data evaluation to dioxins only. This data gap is important
because there are other potential sources of toxicant releases to the river, such as the W WTPs at
Waynesville and Maggie and the landfill at Canton. Since WWTPs routinely monitor effluent
releases, these data may be available to supplement the analyses conducted for dioxins, but were
not available to the Science Panel.
Based on a review of the available hardcopy reports, dioxin analyses have consistently been
conducted with EPA Method 8290, although by differing labs. In a short-term review, it was not
possible to determine whether QA/QC analyses have been conducted for all of the available data
or whether the QA/QC analyses have identified any problems with the reported data. This type
of analysis is critical to determining whether all of the data are useable in a risk assessment.
However, since these data have been collected in response to regulatory requirements, it was
assumed for purposes of this report that the data quality was sufficient to evaluate current
conditions of dioxins in fish in the river and reservoir.
The electronic dataset developed by Tetra Tech (2004) provides both dioxin/furan analyses and
TEQs for fish tissue. However, no data were provided on the fish species sampled, so it was not
possible to determine whether the sampling data are from sportfish or other, possibly less
desirable fish. Further, without this information it is difficult to determine whether dioxins are
accumulating within the foodchain (i.e., determining whether higher levels of dioxins are found
in predatory fish relative to herbivores or omnivores). Additionally, it was not clear if the TEQ
data reported in the electronic database were for the same fish or composites of fish as reported
for the individual isomers. Further, the types of fish tissues (fillets or whole body) analyzed
were not provided in electronic form. Thus, the electronic database (as downloaded from
STORET) was considered incomplete because it was lacking these highly important factors that
are necessary to evaluate dioxin levels in fish. Based on this determination, the Blue Ridge
Paper (2004) data summary of dioxin analyses of fish tissue for 1990 to 2004 were used for this
report.
Almost the entire electronic dataset available for dioxins in fish tissue consists of data reported
by Blue Ridge (formerly Champion Paper). However, based on a review of the "Dioxin and
Furan Concentrations in the Axial Muscle Tissue of Fish from Walters Lake" (Progress Energy
2004), CP&L has apparently also collected fish on a regular basis along the river and in the
reservoir. These data appear supported by detailed fish collection information, laboratory data
reports, QA/QC analyses, and comparisons with data collected by Blue Ridge. These data,
therefore, would be highly valuable if they were integrated into the electronic database.

River Science Panel Review Final
The most recent data available for dioxin concentrations in fish are only those for tissue analyses
of selected bottom -feeding fish, particularly carp. Apparently, fish sampling for carp has
continued because North Carolina still has a fish consumption advisory for this group of fish in
the Waterville Reservoir. Sportfish analyses were halted in 2000 when North Carolina rescinded
the fish consumption advisory for the Pigeon River. Also, although North Carolina and
Tennessee have different criteria for establishing and/or rescinding fish consumption advisories
and Tennessee criteria are lower for dioxins, recent sampling of fish has not occurred in
Tennessee. This lack of data continuity, except for carp in Waterville Reservoir, also limits the
analyses of toxicants in the river.
As part of the 1988 USEPA study of surface water, groundwater, and sediments along the Pigeon
River (as described below), fish were also collected at RM 64.5 and RM58 and analyzed for
dioxins and furans with results that were consistent with those collected as part of the National
Chemical Residue in Fish Study, discussed above.
Groundwater and surface water sampling was conducted in 1988 at the time that dioxins were
found to be health concerns in fish. Private drinking water wells were sampled because of
concerns about recharge of groundwater by the Pigeon River. Samples were analyzed for
dioxin/furans, polychlorinated biphenyls (PCBs), chlorinated pesticides, and selected inorganics.
Water in the river was sampled at RM 39, 40, 41.25, 41.5, 42, 45.5, and 64.5. Ten drinking
water wells were sampled in the vicinity of Hartford, TN. Results of these analyses found:
• No dioxins/furans were detected in drinking water.
• No other organics were detected in drinking water.
• Dioxins/furans were not detected in river or reservoir surface water.
• Chloroform was detected in the river water above the reservoir, in reservoir water, and
below the reservoir near Hartford, TN, with a maximum concentration of 2 µg/l in
reservoir water.
• Trace metal concentrations indicated no apparent environmental concern (USEPA, 1988).
Sediments were also sampled along four transects in the reservoir. Results of these analyses
found:
• Dioxin was detected in sediments with estimated concentrations of 0.34 to 0.64 ppt near
the dam and at a measurable concentration of 13 ppt at the upper part of the reservoir
where the river enters the reservoir.
• The only measurable concentration of dioxin in sediments was found at this upper portion
of the reservoir.
• No pesticides, PCBs, and only trace levels of toluene were detected in sediments.
16

River Science Panel Revieiv
Final
Selection of Data for Characterization. The data reported by Blue Ridge Paper were
selected for characterization of the Pigeon River dioxin analyses of fish tissue in this report
because:
• Data reported for individual fish species were available in electronic (Excel) format.
• Sampling stations are located along much of the river proximal to the station groupings
established by the Science Panel for evaluation of the mainstem of the Pigeon River (i.e.,
in groups b, d, reservoir, g, and h; or above the paper plant, below the paper plant, two
stations within the reservoir, and two groups below Walters Dam).
• This dataset included the most recent analyses of fish tissue (i.e., analysis of fish tissue
through 2004).
• Based on comparison of dioxin results presented by Progress Energy, TCDD analyses
conducted by Blue Ridge (2004) of the same fish species collected in Waterville
Reservoir appear to be generally similar to those reported by Blue Ridge Paper. For
example, the mean concentrations of 2,3,7,8-TCDD reported for common carp in
Waterville Reservoir between 1997 to 2003 by Blue Ridge Paper and Progress Energy
ranged from 2.6 to 7.7 picogram/gram (pg/g) and 2.3 to 5.2 pg/g, respectively.
It should be recognized that a statistical analysis comparing these two datasets was not possible
and there may be other factors, such as fish length, age, or overall health that could affect the
data analyzed for this report.
4.0 Characterization of Environmental Condition
4.1 Water Quality Analysis/Evaluation
Major changes in water quality conditions occurred following the renovation to an improved
pulping process between 1990 and 1994. Significant changes in water quality variables
including color and total dissolved solids (TDS) were observed in years following the
improvements (Figures 3 & 4). Total Suspended Solids (TSS) concentrations below the effluent
outfall declined to resemble upstream reference conditions following 1993 (Figure 5). These
improvements to water quality directly addressed beneficial uses for surface waters in North
Carolina and Tennessee like recreational contact and protection of aquatic life.
Water quality can be characterized within three major areas of the river in North Carolina: above
the town of Canton (above the effluent outfall), below the effluent outfall to the mouth of the
reservoir, and the bypass reach (absent of any flow from the Pigeon River). There are several
streams tributary to the Pigeon River in each of these areas that have a minor influence on water
quality in the areas above Waterville Lake. The changes in water quality are dominated by the
mill effluent characteristics in the middle area of the drainage while the bypass reach is supplied
with flow from tributary streams and groundwater (although groundwater studies are lacking in
this area). The tributaries contributing the majority of the flow to the bypass reach have a major
influence on water quality characteristics. This area is absent from the effects of the pulp mill
effluent releases.

River Science Panel Review Final
Several drought years were embedded within the period of record analyzed in this review. The
drought years included 1998 through 2002 where stream flows were continuously below medians
calculated from historical United States Geological Service (USGS) monitoring records (Figure
6), Persistent low flows can reduce the area of useable habitat by fish species and act as a
concentrating factor for several of the chemical analytes. Both conditions increase the risk of
exposure in fish and benthic macroinvertebrate communities to contaminants entrained in
sediment and water.
Increases in ammonia (NH3-N) concentrations and total dissolved solids (TDS) occurred during
the drought years 1998-2002 in the Pigeon River below the effluent discharge point (Figures 7
and 4). Concentrations of total nitrogen (TN) and total phosphorus (TP) at Zone "e", at the head
of Waterville Lake were double those recorded from Pigeon River above the town of Canton
(Figures 8 and 9). These concentrations are likely the result of increased relative contribution of
effluent content in the river during drought conditions. However, both TN and TP remain at
lower, constant post-1994 concentrations at the monitoring point near the head of Waterville
Lake.
Current ammonia concentrations (2004) at RM 41.5 (prior to Laurel Branch) in Waterville Lake
are eight times higher than those measured in 2001 at the last river site in Pigeon River before
entering the lake (EA, 2004). It appears that this area of Waterville Lake receives a large load of
depositional material and may have high rates of organic decomposition. Organic loads may
originate from aquatic macrophyte beds (Zone "d"), which may form broken mats that are
deposited in the upper shallow lake area. The macrophyte bed growth may be influenced by a
combination of mill effluent organics and those concentrations originating from tributaries
upstream of this section. Organic concentrations originating from mill effluent are twice the
concentration as that found upstream of the effluent outfall in Canton. Non -point sources of
pollution from the tributaries are likely contributors to the nutrient concentrations reaching the
macrophyte beds. An oxygen demand in sediments, resulting in a reducing environment, may
promote the higher concentrations of ammonia -nitrogen observed in this portion of the lake.
This may explain the increase in ammonia concentration that is several times higher than in
upstream Zone "e".
Dissolved oxygen concentrations are slightly lower below the effluent outfall in Zone "d" and at
the head of the reservoir (Zone "e") (Figure 10). On average, dissolved oxygen concentrations
are 1 mg/L lower at stations below the mill effluent outfall. However, the variation in dissolved
oxygen concentrations is greater at these sites and may result in periodic risks to aquatic life.
The unknown risks are the duration of dissolved oxygen sags and the time of year they occur as
extreme conditions.
Dissolved oxygen concentrations also increased during the drought years in the by-pass reach
(below Walters Dam). Drought conditions are characterized by low water levels in the channel,
exposure to increased radiant heat (degree days), and greater nutrient availability. This may have
stimulated photosynthetic activity and an increase in dissolved oxygen concentrations throughout
the bypassed reach. It should be noted that drought years are also characterized by reduced
runoff, which tends to reduce non -point source inputs of nutrients. In some locales along,the
18

River Science Panel Revieiv Final
river, this may also play a role. Diel measurements of dissolved oxygen concentrations would
identify drought condition effects by characterizing fluctuations in this indicator.
"Color" measurements in the river downstream of the mill and upstream of the reservoir did not
change before or during the drought years (Figure 3). It appears the treatment of mill effluents
for this water quality characteristic, despite hydrologic variation, has been successful. Color of
the river has changed dramatically from 1988 to the present where measurements have remained
routinely constant and within discharge permit guidelines at various stages of the hydrograph.
Water quality conditions are affected by concentrations of pollutants when in a reducing
environment. Liberation of contaminants adsorbed to fine sediments occurs when pH declines as
a result of oxygen, depletion from decaying organics or other processes.
4.2 Biological Analysis/Evaluation
4.2.1 Benthic Macroinvertebrates
Relatively recent (2001) benthic data collected by CP&L show a decline in number of sensitive
Ephemeroptera-Plecoptera-Trichoptera (mayflies-stoneflies-caddisflies, EPT) taxa below the
mill (RM 42.5) compared to upstream (RM 64.5), with recovery downstream in the bypass
portion of the river (Figure 11). Data from NCDENR in 2002 shows a more substantial decline
in EPT taxa below the mill (RM 57.5, Zone "d") compared to upstream (RN 64.5, Zone "b"),
with only a partial recovery near the reservoir (RM 41.5, Zone "e") (Figure 12). This evidence
shows that the benthic community is responding to stressors in the reach between the paper mill
discharge and the reservoir. Contributors to such stress could include the paper mill discharge,
erosion and non -point source runoff of nutrients from pastures that border the river in this reach,
inputs from the Waynesville WWTP via Richland Creek, and various possible habitat
differences.
Characterization of this pattern must be tempered with consideration of temporal patterns, and of
confounding spatial influences of habitat condition. Although effects on the benthic community
remain apparent in the data, over time, there has been noticeable improvement in condition.
Figure 13 shows the number of EPT taxa downstream of the mill near RM 57.5 (Zone "d") from
1983-2002. Between the mid- to late 1980s and the early to mid-1990s, there was a noticeable
increase in EPT taxa (although no data are available for the 1990-91 period, when improvements
in mill operations were initiated). This suggests that historic effects of the mill discharge on
benthic communities have been ameliorated to some degree following improvements in mill
operating conditions.
Another trend in these results is that in the most recent years, 1999 and 2002, there again are
declines in EPT taxa. These are drought years (see Figure 6 showing annual average flow at the
USGS gage located at RM 45.1), and it is possible that the substantially reduced river flows may
have negatively impacted the benthic communities. This could occur through reduced
availability of habitat due to low flows, or possibly through other associated changes, such as in
nutrient concentrations, productivity and food availability, conductivity, and/or other water

River Science Panel Review
Final
quality characteristics. Thus temporal patterns of improvement are confounded by temporal
variation in other environmental conditions, such as stream flow.
Benthic habitat characteristics also are expected to influence spatial differences in benthic
species composition and abundance. For example, gradient of the river changes along the
mainstem, with the upstream reference areas (Zones a and b) and the downstream reach in
Tennessee (Zones g and h) at a higher gradient (about -4 to -6 feet/mile, see Table 4) than the
area below the mill discharge and above the reservoir (Zones c and d, from -1 to about -4
feet/mile). Other variations benthic habitat conditions may also exist. At least a portion of the
area downstream of the mill defined as Zone d apparently has less abundant riffle habitat, more
unconsolidated bottom sediments, and in some areas, more bedrock than river reaches just
upstream of the mill discharge and reaches downstream of the reservoir (EA, 2004). NCDENR
(2003) describes a portion of this reach as having reduced riffle habitats and prolific weed
growth. In addition, Richland Creek joins the mainstem near the beginning of this section (about
RM 55); flow from this creek includes discharge from the Waynesville WWTP. It appears that
the reach defined as Zone d, which is usually the only location downstream of the mill discharge
sampled for benthos,, may have substantial differences in benthic habitat conditions compared to
the upstream reference area. Habitat characteristics are not consistently characterized (even in a
semi -quantitative manner) and reported. Thus, it is not possible with existing data to partition
possible ongoing or varying mill effects from such habitat influences.
In the same vein, similarities seen between benthic community characteristics at the location
upstream of the paper mill outfall and within the bypass reach (CP&L results referenced above)
may be related to habitat similarities, e.g., a return to higher -gradient stream conditions and more
abundant riffle habitat, or may reflect lower concentration of pollutants. A reliable conclusion
regarding any persistent effect on benthic communities in the reach below the mill or the
expected extent of recovery cannot be made.
Table 4. Average changes in elevation (feet per mile) for defined zones within
the mainstem Pigeon River, NC and TN.
Zone
River Miles
Gradient
A
69-66
-5.33
B
66-65
-5.0 '
C
62-60
-4.0
D
59-45
-1.07
E
43-41.5
n/a
F
39-26
-19.9 -
G
26-14
-6.33
H
1 9-7
-4.5
4.2.2 Fish Community Characterizations
As was found for the benthic community, recent fish community status based on the Index of
Biotic Integrity (IBI) shows a depression below the paper mill discharge (see Figure 14 for
1997). Community "integrity" goes from good at the upstream reference and downstream
locations, to fair at RM 55.4, about 9 miles downstream of the discharge. Similar results from

River Science Panel Review Final
1990, shown in the same graph, indicate that at that time, before plant improvements were
implemented, fish community integrity below the paper mill was very poor, and continued to be
poor throughout the remainder of the river. This suggests that conditions for the fish community
had improved substantially by 1997, an expectation consistent with the fact that the paper mill
implemented several process changes and treatment improvements over the period 1990-94. The
comparison also suggests that by 1997, the downstream extent of mill discharge effects on fishes
had diminished compared to that observed in 1990.
Examination of spatial trends in number of native fish species (as another available community
metric) in 1995, when 11 locations along the mainstem of the river were sampled for fish
synoptically, shows a similar decline immediately below the paper mill discharge at RM 63
(Figure 15). While there is some variation, this fish metric remains lower than the upstream
reference through RM 24.9, below the bypass.
Downstream of this location, at three locations sampled in the Tennessee portion of the river, the
number of native species is much higher than at the reference site upstream of the paper mill.
This suggests probable fish community differences between the downstream (Tennessee) and
upstream reference locations that may not be captured in the IBI. For example, green darters
appear to occur upstream but not downstream, while the gizzard shad are abundant at the
downstream stations, but not upstream (see Table 5, showing species abundances by station for
1995 and 2003). It might be beneficial to evaluate fish community similarities between stations
using a multivariate approach such as cluster analysis, to understand whether there are gradients
in community composition that may be responding to habitat gradients. Remembering that the
study area from upstream of the paper mill in North Carolina to the mouth of the Pigeon River in
Tennessee extends over two main physiographic provinces (the Blue Ridge and the Ridge and
Valley, changing at about RM 17), and has progressive influences from watershed drainages and
tributary inputs, such a gradient in community composition would be expected, and would
impact expectations for community composition in the reach of the river between the mill and
the reservoir. As was discussed for the benthic community evaluation, it can be difficult to
define expected community composition in the absence of the paper mill impacts, how much
recovery could be expected as those impacts are reduced, and to partition the influence of other
existing habitat conditions, including other impacts such as sewage treatment discharges or
agricultural runoff.
Temporal trends in fish IBIS at the most downstream locations sampled (Denton and Tannery
Island, TN, RM 16.5 and 8.2, respectively) support the evidence for positive fish community
responses to improvements in the paper mill operations. Figure 16 shows a notable increase in
community condition between the 1988-90 period, prior to mill modernization, and the 1994-
2003 period. As discussed previously, there are substantial variations in the fish IBIS within the
1994-2003 period that may reflect diverse environmental and habitat influences, possibly
including drought effects (see for example, the results for 1999).
21

River Science Panel Review
Final
Table 5. Species composition and abundance of fishes at various sampling locations along the Pigeon River,
NC and TN, 1995 and 2003.
Sum of Individuals
Year MILE OT
1995
64.5
63
59155.5'. 54.5 52.3 48.2 42.6 24.9 19.3
8.2
1995 Total
2003
20M Total
Grand Total
SCIENTIFIC_NAME
COMMON NAME
64.SC 55.5:. 42.61 16.5 8.2
AtnblO liter ru eshis
Rock bass
78
13
81
3!
6
3
1
8
2
122
671
2:
:-
53
18
140
262
Antialoplites witestris<5 in.
ROrk bass <5 in.
I
1
1
1
1.
1
1
Ameums brunneus
Snail bullhead
1:
1
11
1
t
1
1
Ameums naiads
Yellowbrllhead
I.
I
11.
1
1
2
2
Ameumanebl4osus
Bro'.vnbullhead
1
I
1
71
7
7
Aplodinotus grunniens
Freshwater dmm
1
1
2
1
3
I.
1
4
2
6
9
Camposloma anomalum
Central sloneroller
30
1
831
174
7
68
40
3
249
1991
111
1210
459
Camposloma oligolepis
LaMescale stoneroller
I
1
e
147
67
222
I
1
1 104
153
257
479
Carassius aumtus
Goldfish
2
31
19.
11
4
39
1
1
39
Caralodes mroo
River-carpsuaer
i
I
1
1
1
{
i
3
3
4
Ca odes cyprnus
lQuillibeck
1
I
I
1
L
I
t
I I
Catostomus ammersoni
White sucker
I
4
6
12
4
1
24
31
1
3
27
Conn. baildi
Mottled sculpim
33
1
1
33
151
1
15
a
Callus carolinae
Banded scut in
I
1
63
69
31
163
1
1
33
49
82
245
C tinella galactura
Whilstail shiner
B
2
161
35,
15
16
22
3
53
32
53
256
1611
10
61
155
346
678
934
Gypninellas ilo tera
$ otlin shiner
I
1
2
2
L
1
1
4
246
250
252
CPR=mmio
comlrron carp
6
141
20
17
16
13
17
103
1
It
W-
1
9
16
119
Dorosoma cepedianum
Ginald shall
1
1
23
156
90
269
1
1
'
83
120
203
472
Etheastoma blennloides
Greenslade darter
41
1
1
1
29
44
10
125
281
11
+
38
149
216
341
E8leostoma chlorobranNlum
Greenish tlaner
63
1
11
64
1821
1
182
266
Etheostpma Mllneatum
Redline darter
I
1
1
31
414
446
1
1
1
190
885
ION
1530
Etheostoma simoterum
Snubnose darter
1
1
21
13
34
I
1
1
27
41
68
102
Etheostoma zonate
BaMeddarter
i
I
I.
1
t
1
1
1
Hyland le orris sips.
Hybrid sunfish
1
I
1
1
6
1
9
1
1
1
1
10
Hypentelium nigncans
NoMem hag sucker
37
18
671
50;
58
49
54
74
19
137
42
605
91
B:
225
33
52
124
729
Ir31th om on bdellium
ONO larrioney
I
1
1
1
I
i
I
1
1
Iclanyonny,on castandus
Chestruftlaunpray
I
I
I
1
12
3
5
5
Iclalums punctatus
Channel catfish
_
I
1
4
4
1
3.
22'
2.
5
32
36
Idineus bubalus
Boni buffalo
1
1
3
16
19
1
1
3
13
16
35
Imobusnier
Blaabullalo
I
1
1
1
1
1
4
4
5
Lepamis auntus
Redbreast sunfish
29
77 1191 IV, 132
177
112
18
5
12
26
899
1741
47,
25.
26
39
311
1210
Leomis ryanellus
Green sunfish
13
71
21
6
1
9
38
21
11
11
3
7
45
Le orris gulosus
Warmouth
11
I
1
t.
I
1
Lepomis ma=nInus
Sluegll
11
3''
4
1
33
6
1
5
54
11
1
2'
3
15
21
75
Lucius camogenis
Warsainlshiner
32
61
1
38
2101
2,
5
217
255
Micaptelus dolomleu
Smallmauth bass
- 3
2
31
Z
3
11
1
40
24
11
100
71
11
111.
73
9
lot
201
cro Mitents undUatus
S fled bass
1
1
3
1
8
12
1
1
5
2
71
19
Micro lerus salmoides
Largemouth bass
2
2
11
41
11
8
3
14
2
47
11
2
3''
3
9
56
Moronechrysops
Whits bass
1
1
3
3
1
J
1
3
Momstoma anisurum
Silverredhotse
I
1
1
1
L
I
1
1'
4
5
6
Momstoma cadnatum
Riverremlorse
I
I.
I
1
1
2
2
4
4
Momstoma du uesnel
Black redhorse
8
5
t
1
2
1
1
]
24
37
1
22I
15
10
86
115
Mcutostorna endinnurund
Golden redhorse
1
1
10
10
1
1
1
8
8
18
Noamis micro ogon
Rivercdub
147
3
23l
11
3
177
1031
Z
1B;
123
300
Notemigonus crysoleums
Golden shiner
I:
11
1
1
I
1
1
hl.00Iai. amblo s
Miefremul,
1
1
1
4
51
1
1
1
51
8
57
62
Nobolois photogenis
Silvershiner
1
1
6
15
21
1
1
30
127
157
176
Noocpis robeflus
Rosyfaw shiner
1
I
I
I
1
4
122
126
126
Nonopis rubri omus
Saffron shiner
3
1
1
3
171
1
1
17
26
Notro iss ectrunculus
Mihorshiner
Its
1
t
18
341
1
1
1
3a
52
NobO is alescous
Telescope shiner
t
1
3
3
1
1
76
9
85
BB
Oncoth ntllusm kiss
RainboWboul
C
1
3
3
6
1
1
6
Percina auranliam
Tangenne darter
28
1
1
1
29
41
1
t
4
33
Peroina caprodes
LO perrll
1
1
27
41
79
147
1
1
1
3
30
33
180
Petcua eMdes
Gilldarter
t
I
I
1
i
5
5
5
Fornephales pronnelas
FaOead minnow
I.
I
f
1
1
1
1
1
Pomozs annulads
While Mrsid.
I
I
I
I I
1
:B
2
10
10
Pornams nigromaculatus
Black onappl.
11
9;
30
11
6
2
59
I
3:
3!
6
65
Pylodtlisolivads
F1aNead camsh
I
I
1
1
t{
1
2
6
RNnitldhys abatulus
Blacknose dam
I
I
1=1MM
1
i
I
1
Rhunaths mdannAm
Longnose dace
11
11
1
19
1
1
1
1
1
20
Salmo bona
Brown Iroul
2
1
1
d943
3
11
1
1
1
4
Sszostedion anadense
Sauget
1
1
2
1
I
I
1.
1
3
Stizastedion vitreum
walleye
I
1
3
1
1
1
1,
4
5
8
Grand Total
504
144 354[ 3621 308 377
4544
1259L lull 146i1042 ZbUZI
buoul
9594

River Science Panel Review Final
A target list of species expected to occur in Tennessee was developed (Charles F. Saylor,
personal communication, 2005) to help provide a basis for expectations of community recovery
and effectiveness of re -introduction programs. Table 6 provides that list, showing fish species
that have occurred since 1988, before improvements to the paper mill were implemented; species
that have only occurred since 1991, after those mill improvements were initiated; and species
that should occur, but have not yet been observed. This summary suggests that there has been
natural re-establishment of native fish species from surrounding source populations. The
progressive increase in native fish species at Denton and Tannery Island, TN from 1988 through
2003 (Figure 17) supports this, although it must be noted that since 1996, species recovery has
been augmented by artificial re -introductions of native species, transferred from nearby river
basins as part of the Pigeon River Recovey Project. Between the 1988-91 period and the 1994-
2003 period, there has been an increase on the average of 10 native species (from 15 to 25) at
Denton, and of 16 species (from 17 to 33) at Tannery Island. These observations suggest there is
substantial improvement in ecological condition of the lower Pigeon River, supporting both
natural and artificial re -introductions of fish species, with the potential for continued recovery.
4.3 Dioxin Evaluation (Human Health Risk)
Following modernization of the mill, dioxin concentrations in all fish species sampled over
several years decreased substantially, as can be observed in both sportfish and bottom feeding
fish samples collected from 1992 to 2000 (see Figures 18 to 27). Based on these data, in 2000,
the State of North Carolina rescinded the fish consumption advisory for sportfish in the Pigeon
River and Waterville Reservoir. Sampling continued thereafter for only bottom feeding fish.
Thus, the most complete dataset for dioxins in fish tissue is for bottom feeding fish collected
from 1990 to 2004.
Prior to 1990, fish consumption advisories were issued by the States of North Carolina and
Tennessee. These advisories recommended no consumption of fish from the Pigeon River or
Waterville Lake. The criteria used to establish the fish consumption advisories were as follows:
North Carolina
• Dioxin concentrations below 5 ppt = no advisory
• Dioxin concentrations between 5 and 10 ppt = no consumption by pregnant women and
children and no more than 1.2 pounds per month for others
• Dioxin concentrations between 10 and 20 ppt = Limit consumption to 0.5 pound per
month
• Dioxin concentrations about 20 ppt = no consumption recommended
Based on these criteria and dioxin concentrations observed in fish in 1988, North Carolina
recommended that no fish be consumed from the Pigeon River or the Waterville reservoir.
Tennessee
Based on a posting criterion of 5 ppt, in April 1989, the State of Tennessee issued a "do not
consume" advisory for all fish in the Pigeon River (TDEC 2002) from the Walters Dam (state
border) to the French Broad River.

River Science Panel Review
Table 6. Target list of fish species expected to occur in the Pigeon River, TN.
STATUS OF
FISH SPECIES OCCURRENCE IN THE PIGEON
RIVER,
TENNESSEE
name
Scientific name
Occur 1988-
Present
Occur my
>1991
Should
Ohio lam rey
Ichthyomyzon bdellium
XChestnut
lamprey
Ichthyomyzonwstneus
X
jMayHavoCommon
Am brook lamprey
Lampetra appendix
Lake sturgeon
Acl enser tulvescens
Paddlefish
Polyodon spathula
Spotted gar
Le isosteus occulatus
X
Longnose gar
Lepisosteus osseus
X
Moone a
Hiodon tergisus
Gizzard shad
Oarosoma cepedianum
X
Threadfin shad
Oorosoma petenense
X
Central stoneroller
Campostoma anomalum
X
Goldfish
Carassius auratus
x
Whitetail shiner
Cyprinella galactura
X
Spotfin chub.
Cy rinella monarha
x
Spatfin shiner
Cy rinella sp8optera
X
Common carp
Cyprinus carpio
X
Blotched chub
Erimystax insignia
x
Striped shiner
Luxilus chrysocephalus
x
Warpaint shiner
Luxilus wccogenis
x
Golden shiner
Notenugonus crysoluews
X
River chub
Nocontis micropogon
x
Bigeye chub
Notropis ambleps
X
Tennessee shiner
Nortopis leuciodus
X
Silver shiner
Notropis photagenis
x
Rosyface shiner
Notropis rubellus
X
Saffron shiner
Notropis rubric oceus
x
Sand shiner
Notropis stramineus
x
Minarshiner
Notropis spectrunculus
X
Telescope shiner
Notropis telescopus _
X
Mimic shiner
Notropis volucellus
X
Bullhead minnow
Pimephales vigtlax
x
Faflips minnow
Phenawbius crassilabmm
x
Stargazing minnow
Phenawbius uranops
X
Blacknose dace
Rhinichthys atratulus
X
Longnose dace
Rhinichthys cataractae
X
River Carpsucker
Ca lodes carpio
X
Quillback
Carpiodes cyprinus
X
r
Highfin carpsucker
Carplodes velifer
X
White sucker
Catostomus commersoni
X
Blue sucker
cyceptus elon atus
X
Northern hog sucker
Hypentelium nigricans
x
Smallmouth buffalo
Icbobus bubalus
X
Black buffalo
Ictiobus niger
X
Silver redhorse
Moxosloma anisurum
X
River redhorse
Moxestama carinatum
x
Black redhorse
MOXoStOma duquesnei
X
Golden redhorse
Moxostoma erythrurum
x
Shorthead redhorse
Moxastoma macrolepidotum
X
Yellow bullhead
Amelunus natalis
X
Brown bullhead
Ameiurus nebulosus
X
Channel catfish
Ictalurus punctatus
X
Mountain madtom
Noturus eleutheros
X
Flathead cefsh
Pylodlcfis olivaris
X
Northern studfish
Fundulus catenatus
X
Muskellunge
Esox masquinongy
X
Rainbow trout
Onwrhynchus mykiss
X
Banded sculpin
Coitus carclinae
X
White bass
Morone chrysops
X
Rock bass
Ambloplites rupeshis
X
Redbreast sunfish
Le orris auritus
x
Green sunfish
Lepomis ryanellus
x
Wannouth
Lepomis gulosus
X
Bluegill
Le arms macrochirus
x
Smallmouth bass
Microptems dolomieu
X
S otted bass
Microptems pundulatus
X
Lergertwuth bass
Micro leis salmoides
X
White crap le
Pomoxis annulans
1 X
Final

River Science Panel Review Final
Following the modernization of the paper production process, dioxin concentrations in river fish
tissue dropped substantially (see Figures 20 to 23, 25 and 27). In 1996, Tennessee downgraded
the consumption advisory to a "precautionary advisory" for only three fish species (redbreast
sunfish, carp, and catfish) because of reduced dioxin concentrations. By 2002, dioxin
concentrations in both game and rough fish in the Tennessee portion of the Pigeon River dropped
to levels consistently below 1 ppt (see Figure 27), except for catfish, which were reportedly
(TDEC 2002) consistently below 2 ppt. Based on these observations, the fish in the Pigeon
River were considered safe to eat at normal consumption rates. This was considered by the State
of Tennessee (TDEC 2002) to be consistent with the dropping of fish consumption prohibitions
in the North Carolina portions of the river in 2001. Essentially, the reduction in dioxin/furan
concentrations in fish resulted in the dropping of fish consumption advisories for all species in
the river.
Concentrations of dioxin/ftran generally continued to decline in tissues from fish collected both
above and below stream reaches surrounding the pulp mill outfall. A slight increase in dioxin
concentrations in sportfish, such as redbreast sunfish and black crappie, was observed in the
timeframe of 1998 to 2000. Generally the same level of increase occurred in TCDD
concentrations in several different species of fish collected at river mile 52.3 and 59 (RM52.3
and RM59) downstream of the outfall and at river mile 64.5 (RM64.5) above the outfall (see
Figures 18 to 22). Sportfish sampling was halted in 2000, thus it is not possible to determine
concentration trends in this group of fish after 2000.
Nevertheless, analyses are available for bottom feeders, such as common carp, collected at some
of the same sample locations as those where sportfish were collected. These data also show an
increase in dioxins in the pre-2000 years, followed by a decrease after 2000 (see Figures 21 and
27). These data suggest that dioxin concentrations may also have decreased in sportfish and
some other factor, such as the drought that occurred at about this time, may have affected all fish
in the river
Currently the only fish consumption advisory is for carp in the Waterville Lake. Dioxin
concentrations in carp have remained relatively stable over the past decade (see Figures 23 and
25).
4.4 Fish Criteria Relative to Current Toxicity Evaluations
The USEPA is reassessing dioxin toxicity. Although not yet published in -final form, the State of
Tennessee (TDEC 2002) is evaluating the potential impacts on fish posting criteria. The re-
evaluated posting criterion for dioxin has been computed to be 1.2 ppt. However, until the
USEPA reassessment is complete, the legal requirement remains at 5 ppt.
To put this criterion into perspective, Table 7, below, shows the fish tissue concentrations that
would be acceptable using the protocol established by the USEPA (1999) for "Establishing Fish
Consumption Advisories." Using standard default assumptions[ for fish consumption rates,
including an average fish meal size of 8 ounces (0.227 kg), a target risk of 10-5, and a cancer
Other assumptions included in the calculations include an adult body weight of 70 kg, a time -averaging period of 1
month, and a 70-year lifetime.

River Science Panel Review Final
slope factor of 1.56 x 105 per mg/kg/day, the following range of fish tissue concentrations could
be consumed, depending on the number of meals consumed per month.
Table 7. Acceptable fish tissue concentrations
Fish Meals per Month
Dioxin TEQ Concentration t
8
>0.052 — 0.077
4
>0.077 - 0.15
2
>0.21— 0.31
1
0.31 — 0.62
Based on these analyses, the posting or rescinding of fish consumption advisories are consistent
with current approaches to evaluating fish consumption and assuming fish from the Pigeon River
are consumed for approximately one meal per month. That is, available data show that dioxins
in sportfish remained lower than criteria (for one fish meal per month) identified as potential
health concerns for about 5 years prior to lifting of the fish consumption advisories. Also, based
on recent data (Blue Ridge 2004), bottom feeding fish such as channel catfish and flathead
catfish are also below potential levels of concern, while common carp exceed these levels of
potential health concern. Of note, however, is that after the substantial decrease of dioxin
concentrations in fish in the early to mid-1990s, dioxin concentrations in common carp have
retrained within the same relative range (see Figures 2 and 3). This pattern is particularly
striking for fish collected at the upper end of the reservoir (i.e., RM 41.5) (Figure 3).
Altogether, these evaluations demonstrate that modernization of the paper production process at
the Blue Ridge Paper facility at Canton has resulted in substantial reduction in the amount of
dioxin available for accumulation by fish in the Pigeon River. Since dioxin is known to sorb to
particulates, the most likely source of dioxins that remain in the system are those sorbed to
sediments deposited either in the river or reservoir prior to the plant modifications. Dioxin can
persist in the environment for decades (WHO 1997).
Based on the fish tissue analyses, it also appears that the main location where dioxins in
sediments are accessible to fish are those deposited near the dam of the reservoir (RM 39).
Further, since dioxin has remained at relatively steady state concentrations in common carp
sampled at this location and the other station (RM 41.5) in the reservoir over the past 10 years,
there appears to be a persistent source of exposure to dioxin -associated sediments in the
reservoir. Understanding of the dynamics of sediment deposition and re -suspension in the
reservoir is therefore key to determining the potential long-term health risks associated with
dioxins that were released to the Pigeon River.
Key Questions:
Are the dioxins "capped" (entombed) in sediments or are they periodically or frequently
contacted by target species like carp?
• Over the past ten years dioxin concentrations have not changed dramatically in carp
in the reservoir, although the same size fish have generally been sampled. This
suggests that fish are exposed to a renewed source of dioxins, at least at low levels, on
a regular basis.

River Science Panel Review
Final
• Does reservoir turn -over or other water circulatory processes contribute to sediment -
associated dioxin re -suspension?
2. What is unique about Waterville reservoir, where dioxin concentrations remain at higher
concentrations in carp than at upstream locations? Is this the only depositional area
where sediments remain with accessible dioxins?
3. Is there a relationship of dioxin concentrations in fish with those in sediments?
• Is there habitat -specific mediation of contaminant accumulation in fish (e.g., do
common carp "consume" sediments as part of their feeding behavior)?
• Are carp attracted to areas where there is deposition of detrital material from the
upper reaches of the river and thereby contact disturbed sediments that contain
dioxins?
• Are there other fate or chemical partitioning aspects that could explain sediment -fish
dynamics and the transfer of dioxins from sediments to fish or other biota?
4. Are there correlations between dioxin concentrations and major disturbances (e.g., large-
scale climatic events, such as hurricanes)? For example, low flow in the river (based on
annual monitoring plots) may have affected dioxin concentrations in 2000 to 2002
because of drought conditions.
4.5 Integration of "Key" Observations
1. Biological responses to the paper mill discharge are still evident within the benthic and
fisheries communities, although substantial improvements over time are evident.
Spatially synoptic biological collections, uniformity of methods, and quantitative habitat
sampling would support more accurate interpretation of the major stressors, and of
expectations for further improvement.
2. The Pigeon River has two significant "biological zones", upstream of Walters Dam and
the remainder of the river below the dam that includes the bypass reach and reach where
Pigeon River water is reintroduced back to the main channel (below the powerhouse).
Elevation and geographical isolation by the dam emphasize the influence these factors
have on biological communities (McKinney, personal communication). Reference
comparisons should consider these two zones when evaluating biological information
generated in future projects or monitoring programs. Also, transition from the "Blue
Ridge Mountains" to the "Tennessee Ridge and Valley", the powerhouse at about
RM17.0, may present some influence on ordering of biological communities. .
3. Common carp collected from the reservoir have the highest concentration of dioxin in
fish tissue. Carp are omnivorous and consume both plant and animal material that settles
out where the river meets the reservoir. The convergence of two conditions: 1) settling
zone for organics, and 2) depositional zone for historic dioxin loads and continuing
residence may promote higher risk of contaminant exposure in the carp population. In
addition, entrainment of dioxin or other contaminants in detrital material from upstream
sources may be consumed by carp at locations within the reservoir.
27

River Science Panel Review
Final
4. Re -distribution of suspended organic materials is mediated by flow. The fate of
depositional materials and of contaminated sediments is transient depending on
characteristics of the hydrologic year. Migratory behavior of certain fishes will reflect
the distribution of contaminated sediments and eventual risk to their survival throughout
the life stages.
5.0 Recommendations
The Science Panel pursued the objective of assessing the current status of the Pigeon River
system, given the limitations of existing ecological information on the river system. This process
led to some perception of the deficits in scope of existing information, relative to the main issues
that pertain to this river system. As the logical adjunct to this, the Panel has formulated
recommendations intended to address some of these deficits. In general, the Panel recognizes
strong justification for specific continued monitoring, for additional directed efforts to improve
and centralize the Pigeon River database, and for studies that would support more comprehensive
ecological and human exposure risk assessments, including sediment transport modeling and
some additional field studies.
5.1 Future Monitoring Efforts
• Discharge Monitoring Report (DMR) information would be helpful for determining nutrient
concentrations likely to reach the Pigeon River.
• Flow monitoring at several locations along the reach below the effluent outfall are necessary.
Flow levels mediate the timing and severity of water pollution conditions. Suspended
materials are released from the water column at locations downstream when flows are higher.
High flows may reduce the concentration of toxic contaminants and risk of exposure to biota.
At present, there are active USGS gages "near Canton" ("at Canton", RM 64.1, was
discontinued in 1984), near Hepco (RM 45.1), near Waterville, and at Newport (RM 7.8).
Effects of flow on water quality condition was not examined in this evaluation primarily due
to time constraints. A more thorough evaluation of water quality at different hydrologic
stages may be possible with existing data.
• It is recommended that periodic synoptic benthic surveys be conducted, to include the river
from immediately upstream of the paper mill outfall to Tennessee. Sampling should include
the river immediately below the mill discharge, and should reflect habitat types
longitudinally. Methods should be uniform, quantitative, and documented. It is suggested
that consideration be given to adopting the EMAP Wadeable Streams protocols. Continued
but refined examination of the benthic macroinvertebrate community has value in the context
of the Pigeon River system for several reasons.
— Due to their variety of life habits, close association with the substrate as well as the
water column, and relatively long life cycles, benthic community conditions
integrate multiple lines of evidence for identifying pollution source and effects.
— Benthic community status provides a direct measurement of in -stream effects from
pollution sources and/or habitat degradation (disturbance).

River Science Panel Review
Final
— Further evaluation of critical biological communities will be valuable in
identification the range of existing system stressors, including non -point sources of
pollution from tributaries.
All future monitoring of biological communities should be conducted within the framework
of a cooperative monitoring program. An integrated program could be beneficial in three
ways: greater spatial coverage of aquatic resource conditions, cost savings, and ability to
address multiple objectives that would be beneficial to government agencies and regulated
businesses. The historical data was generated by multiple monitoring efforts and addressed
specific objectives. The data produced could have been more useful had additional site
locations been established or multiple monitoring efforts combined to enable isolation of
known pollution sources. The drawback for establishing a monitoring consortium is an
administrative process that slows progress in decision -making. This is outweighed by the
long-term benefit of having comparable data that can be used to measure spatial extent of
pollution effects and trends at key locations in the drainage.
A comprehensive or cooperative monitoring program should incorporate a hierarchical
design that addresses multiple objectives. Small spatial scale questions can be answered with
a monitoring strategy that generates data using a near -field design and adjusting sampling
intensity based on response characteristics of the pollutant or variable of concern. If the
focus is characterization of bacteriological contamination, frequent collection of samples is
recommended at each site in order to adequately describe the variability inherent in this type
of data. Other variables like TSS (total suspended solids) are more conservative and not
biologically interactive and, therefore, result in repeated measures that do not vary broadly,
except when an obvious source for degradation is identified.
• Additional monitoring effort is necessary at the mouth of major tributaries along the Pigeon
River. The period of record for single tributary sites is sufficiently short that pollution type
and intensity is not easily identified. Also, the effects on pollution characteristics at various
stages of the hydrograph are not apparent.
• Continuous monitoring of dissolved oxygen concentrations, as well as temperature and
conductivity, should occur below the pulp mill effluent outfall, immediately above the
Waterville Reservoir on the Pigeon River, and at the base of the bypassed reach. Diel
variation in dissolved oxygen concentrations should be measured to determine the duration
and severity of dissolved oxygen depression and effects to aquatic communities. This would
enable identification of source for dissolved oxygen alteration (human & natural) at these
critical points along the drainage.
• A 5-year review process is recommended to confirm that dioxin levels in sportfish remain
below levels of health concern throughout the river system.
• Bottom feeding fish sampling in the lake could also be reduced to a 5-year sampling
frequency since concentrations have remained relatively stable over at least the past 5 years
and dioxin is likely to persist for decades. The reduced fish sampling effort could provide
the opportunity to investigate other components of the river system, including sediment -
associated dioxin levels or other toxicants, if significant point sources, such as the W WTPs,
or non -point sources, such as cattle grazing, are identified.

River Science Panel Review
Final
• Additional sampling of sediments and other biota could provide important information on the
remaining "sinks" of dioxin in the river and reservoir, in order to understand the dynamics of
the static dioxin levels observed in carp in the reservoir.
• Index modifications from NC are consistent within their own regulatory system, but diverge
from other broadly used indexes for evaluation of benthic communities. NC analytical tools
should be applied to full length of Pigeon River sites (including the Tennessee portion).
• More "reference" information is required, either in -Basin or out -of -Basin, in order to set
expectations. Results of EPA's EMAP sampling in the region may be useful in capturing
expectations for specific settings found throughout the Pigeon River Basin.
5.2 Integration and Management of Data
Data management is a key component of any large-scale and long-term monitoring program.
Data accessibility is the primary need from the monitoring effort and reflects the program's
success. Aggregating data allows presentation in a web -based application where users have
continual accessibility and an environment in which users can serve themselves.
One of the biggest single deficits of the existing Pigeon River knowledge base is its lack of
continuity. Though a variety of "gaps" in existing data have been identified by the Science
Panel, it is also clear that much greater utility of existing information would derive from
centralized banking of data, statistical summary and review of data, and development and
maintenance of meta -data. Tetra Tech has done an excellentjob establishing a prototype
database (Tetra Tech, 2004) containing much of the existing historic data through 1998. The
Science Panel concurs that a focused future effort to add recent elements to that database,
including biological, water quality, and toxicological data collected by numerous entities,
would be a requisite adjunct to proposed future monitoring. It would support a more
complete assessment of current conditions, and form a basis to which future results can be
compared. Some specific recommendations include:
- State and facility datasets should be combined in one database.
- Consistent sampling locations (by RM) should be applied to all data. This should
be correlated directly with water quality and benthic sampling locations to ensure
that co -located data can be recognized.
- Fish and benthic species data should be provided.
- Dioxin and furan isomers should be provided and linked to the TEQs calculated for
individual fish species (or individual composites).
Duplicate data collection efforts (e.g., fish tissue analyses by Blue Ridge and Progress
Energy) should be modified and/or halted, with efforts re -directed at understanding the fate
and dynamics of dioxins in sediments, fish in Waterville Reservoir, or other biota found in
this habitat.

Pigeon River Science Panel Review Final Report
5.3 Sediment Transport Modeling
Sediment movement in reaches of this drainage describes fate and intensity of contaminant
problems from historic operation of the pulp mill. Mapping the location of the contamination
in depositional zones and describing the rate and quantity of transport of sediments will
provide enough information to adequately describe risk to species that are potentially
exposed to pollutants. Identification of these zones will also provide insight into areas likely
to place humans or other higher predators (e.g., river otters) at risk from bioaccumulation of
the toxins.
• Sediment modeling would provide insight into the processes occurring at the entrance to the
reservoir and relative to deeper areas of the reservoir, where dioxin "entombment' may be
occurring.
• Sediment modeling may be important in understanding the potential for transport of dioxins
on sediments into reaches of the river below the dam should water quality indicate that river
water can be released to the previously dewatered section.
5.4 Detailed Risk Analysis
A full ecological risk analysis could not be conducted by the Science Panel, due mainly to
limitations in existing data. Specifically, there generally is insufficient information to identify
specific stress sources, to define the contribution of variations in habitat condition, or to define
the areas of greatest exposure. Note that even with regard to the paper mill, recent biological
collections are usually conducted miles downstream of the discharge. In addition, there.is no
information on indicators of organism response outside of a limited sequence of species
occurrence/abundance data, and limited fish tissue contaminant concentrations. Also, there is no
information on contaminant levels or responses of higher trophic levels.
• The available water quality data provided enough insight for identifying general areas of
historic impairments in the drainage. However, isolating the specific sources for stressors
suspected of occurring along the Pigeon River was not possible unless obvious effluent
discharges were known. Integration of observations is possible if monitoring sites are
placed above and below many of the obvious disturbance indicators (e.g., nuisance
aquatic macrophyte growth), and would support adequate evaluation of effects from the
pulp mill and hydropower project.
• Habitat zones that accumulate contaminants should be identified and mapped, and more
carefully examined for biological and water quality characteristics. These sites should
also be monitored over the long -tern so that changes in level of contamination or in
spatial extent can be used to indicate the likelihood of target species contact. Target
species are fish and macroinvertebrates that had historically occupied this drainage and
were identified by examining current geographical range and preferred habitat; they
should include those re -introduced species as described in the Pigeon River Recovery
Project (PRRP) (Southeastern Fishes Council, 2003).
• Setting achievable goals for water quality, habitat availability, and biological integrity
should be a high priority. Some of these categories will require more recent knowledge
31

River Science Panel Review
Final
of community conditions, estimates for areal extent of select habitats, and thorough
understanding for expectations of chemical conditions throughout the Pigeon River
Basin. Goals may be aligned with criteria for water quality, biology, or needs for specific
habitat that supports critical life stages of fish or other species. In some cases, analytical
tools like biotic indexes or predictive models would be helpful in evaluating
environmental conditions.
In order to understand the ecological risks posed by the dioxins remaining in fish and
sediments, an evaluation of the potential for accumulation in predators, such as otter or
birds of prey, may need to be conducted. This evaluation would be feasible if the
available data are developed into a fully integrated database containing dioxin and other
toxicant data, and water quality data supplemented by habitat descriptions and species
found in each reach of the river.
6.0 Literature Reviewed and/or Cited
Reports
Burr, J. 2004. Macroinvertebrate Assessment Report. A six -page fax (subject Pigeon
Benthos) sent to David McKinney by Jonathan Burr, of TWRA, listing Tennessee Core
Metrics and Taxa Lists.
2. CP&L, Environmental Services Section. 2002. Walters Hydroelectric Plant, FERC
Project No. 432, 2001 Water Quality and Biotic Indices Studies of the Pigeon River at the
Walters Hydroelectric Plant: Appendix A Requirements and Historical overview.
EA Engineering, Science, and Technology, Inc. 1988. Synoptic Survey of Physical and
Biological Condition of the Pigeon River in the Vicinity of Champion International's
Canton Mill. EA Report CHI75K. Prepared for International Corporation, Stamford
Connecticut. 373pgs.
4. EA Engineering, Science, and Technology, Inc. 2001. A Study of the Aquatic Resources
of the Pigeon River during 2000. Prepared for Blue Ridge Paper Products, Inc., Canton,
NC. EA Project 13715.02.
5. EA Engineering, Science, and Technology, Inc. 2004. Results of 2003 Dioxin
Monitoring in Fish Tissue. Prepared for Blue Ridge Paper Products, Inc. January.
6. EA Engineering, Science, and Technology, Inc. 2004. Results of 2004 Dioxin
Monitoring in Fish Tissue. Prepared for Blue Ridge Paper Products, Inc. December.
Hudson, R.G. and E. Gee. (1996). The Acute Effects of Pigeon River Water on
Freshwater Juvenile Mussels. Prepared for Tennessee Wildlife Resources Agency. June
26-July 4. 22pgs.
16

River Science Panel Revieiv
Final
Progress Energy Carolinas, Inc. 2004. Dioxin and Furan Concentrations in the Axial
Muscle Tissue of Fish from Walters Lake, November 2003. Walters Hydroelectric Plant
Federal Energy Regulatory Commission Project No. 409. Environmental Services
Section.
9. State of North Carolina. Department of Environment and Natural Resources. 1996.
Settlement Agreement Regarding 1996 Water Quality Color Variance and 1996 NPDES
Permit Issued to Champion International Corporation.
10. State of North Carolina, Department of Environment and Natural Resources, Division of
Water Quality. 2003. Basin -wide Assessment Report — French Broad River Basin, June
2003. Pages 65 to 80 and pages 165 to 191.
11. Stober, Q.J. 1989. Pigeon River Dioxin Study: Proposal to Assess Fate and Transport
and Ecological Risk. January 1989. USEPA Region IV, Athens, GA.
12. Tetra Tech, Inc. 2004. Pigeon River Watershed Data Evaluation. Prepared for USEPA
Region IV, September.
13. Tiernan, T.O, D.J. Wagel, G.F. VanNess, J.G. Solch, J.H. Garrett, and F. Rukunda. 1997.
Annual Report for the First Year of the Project (November 1, 1996 — June 30, 1997):
Determination ofNonpoint-Source Pesticides and Related Bioaccumulative Pollutants in
Fish, Mussel and Other Aquatic Animal Tissues. Prepared for the Environmental
Services Division of the Tennessee Wildlife Resources Agency. December 1997. 12pgs.
14. U.S. Environmental Protection Agency, Region IV. 1988. Assessment of Dioxin
Contamination of Water, Sediment and Fish in the Pigeon River System (A Synoptic
Study). November 15.
15. U.S. Environmental Protection Agency. 1999. Polychlorinated Dibenzo-p-dioxins and
Related Compounds Update: Impact on Fish Advisories. EPA-823-F-99-015. Office of
Water.
16. World Health Organization (WHO). 1997. Exposure and Human Health Reassessment
of 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) and Related Compounds: Part II Health
Assessment of 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD) and Related Compounds.
Scientific and popular literature
Adams, S.M., W.D. Crumby, M.S. Greeley, Jr., L.R. Shugart, and C.F. Saylor. 1992.
Response of Fish Populations and Communities to Pulp Mill Effluents: a Holistic
Assessment. Ecotoxicology and Environmental Safety 24: 347-360.

River Science Panel Review
Final
2. Adams, S.M. and M.S. Greeley, Jr. 1996. Establishing possible links between aquatic
ecosystem health and human health: an integrated approach. Pages 91-102. in. R.T. Di
Giulio (editor) Interconnections Between Human and Ecosystem Health. Chapman &
Hall, London, England.
Adams, S.M., K.D. Ham, M.S. Greeley, R.F. LeHew, D.E. Hinton, and C.F. Saylor.
1996. Downstream gradients in bioindicator responses: point source contaminant effects
on fish health. Can. J. Fish. Aquat. Sci. 53: 2177-2187.
4. Adriaens, P., Q. Fu, and D. Grbic-Galic. 1995. Bioavailability and Transformation of
Highly Chlorinated Dibenzo-p-dioxins and Dibenzofurans in Anaerobic Soils and
Sediments. Environmental Science and Technology 29(9): 2252-2260.
Adriaens, P., A.L. Barkovskii, M. Lynam, J. Damborsky, and M. Kuty. 1996.
Polychlorinated dibenzop-dioxins in anaerobic soils and sediments. Pages 51-64, in
W.J.G.M. Peijnenburg and J. Damborsky (editors). Biodegradability Prediction, Kluwer
Academic Publishers, Netherlands.
Adriaens, P., P.R. Chang, and A.L. Barkovskii. 1996. Dechlorination of PCDD/F by
organic and inorganic electron transfer molecules in reduced environments.
Chemosphere. 32(3): 433-441.
7. Albrecht, I.D. and P. Adriaens. 1997. Evaluating the Fate of Dioxins in Reduced
Sediments: Evidence for Natural Reductive Dechlorination Processes. Pages 405-408 in
H. Verochevtard and W. Vestnoete (editors). International Symposium for
Environmental Biotechnology. (ISEB). Technological Institute, Antwerp, Belgium.
Barkovskii, A. and P. Adriaens. 1995. Biological and Abiotic Dechlorination of Highly
Chlorinated Dioxins in Bi-phasic Microcosms. Bioremediation of Recalcitrant Organics
3(7): 73-82.
Barkovskii, A.L. and P. Adams. 1996. Microbial Declorination of Historically Present
and Freshly Spiked Chlorinated Dioxins and Diversity of Dioxin-Dechlorinating
Populations. Applied and Environmental Microbiology 62(12): 4556-4562.
10. Coombs, J.A. 2004. Pigeon River Revival. Wildlife in North Carolina Magazine.
December 2004: 27-29.
11. Manuel, J. 1993. The Pigeon Flies Again. Canoe Magazine, August 1993.
Permits
State of North Carolina, Department of Environment and Natural Resources, Division of
Water Quality. 2004. Permit to Discharge Wastewater Under the National Pollution
Discharge Elimination System. Granted to the Blue Ridge Paper Products Inc., Canton
Mill Wastewater Treatment Plant, Canton, NC.
34

River Science Panel Review Final
Meetings
1. Pigeon River Recovery Project (PRRP) Meeting. 2005. TDEC-WPC Knoxville Office,
January 19.
35

River Science Panel Review
Final
Powerfquse ,•-•-TN .•-.�
B=- , • ,
-•' ♦Q ' Gwnmro0 Crook
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Figure I. Map of Pigeon River features (adapted from CP&L 2002).

Science Panel Review
Appalachian Ridges and Valleys
1901
A River Miles
A Canton (Papermill)
Rivers
n/ Rivers
/�,/ Tributaries
~State Line "
0 HUC Boundaries(11 digit) W*E
Waterbodies "5
INS]
Mountains
20 0 20 Miles
Figure 2. Map of Pigeon River basin, showing sampling stations with
definition of zones (A-H) along the mainstem.
Final

Pigeon River Science Panel Review Final
a b d
U 400 —
(j
2M
0
1993 1999 2004 1982 1988 1993 1999 2004
ar ImgY®r S9i bgYear
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40
200 ...�
1982 1988 1993 1999 20
az ME
h
Sm frog Y®r
9
400
200
0
1982 1989 1993 199
3
SamMg Year Sv Mg
14 '
Figure 3. Temporal and spatial patterns for water Color observations (units) described by
"zones" in the Pigeon River that extend from North Carolina and end in Tennessee. Data
describing Color units and variance for each year may originate from one or more stations
within each zone. (The error bars represent one standard deviation about the mean.)

J
1
River Science Panel Review
III
Sampling Year
f
Sampling Year
D4
04
e
loot
E 801
N
9_
6 601
V)
a
m
0 401
N
N_
O0 201
H
D
1986 1992 1998 2004
Sampling Year
9
Sampling Year
74
Final
Figure 4. Temporal and spatial patterns for Total Dissolved Solids (TDS) concentrations (mg/L)
described by "zones" in the Pigeon River that extend from North Carolina and end in Tennessee.
Data describing TDS concentrations and variance for each year may originate from one or more
stations within each zone. (The error bars represent one standard deviation about the mean.)

r
River Science Panel Review
a
J
Sampling Year
f
100
04
J
E 80
y
U
-Con 60
9
N
a
m 40
a
N
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m 20
f-
O
61 1 •• I I•• I I • 1
1986 1992 1998 2004
Sampling Year
e
1998 2004
Sampling Year
9
Sampling Year
M
Figure 5. Temporal and spatial patterns for Total Suspended Solids (TSS) concentrations
(mg/L) described by "zones" in the Pigeon River that extend from North Carolina and end in
Tennessee. Data describing TSS concentrations and variance for each year may originate from
one or more stations within each zone. (The error bars represent one standard deviation about
the mean.)
Final

River Science Panel Review
700
600
500
400
N
`u
306
200
100
Final
1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
Figure 6. Annual average stream flow in the Pigeon River near Hepco, NC (USGS gage # 03459500), RM
45.1, 1980-2002.

J
E
E
Z
m
0
0
E
E
J
m
E
z
m
G
E
E
River Science Panel Review
a
Sampling Year
f
Sampling Year
M
04
J
m
E
Z
m
c
E
E
E
e
1986 1992 1998 2004
Sampling Year
9
1.000
0.800
J
m
E 0.600
z
m
E 0.400
E
0.200
0.000 �
1986
1992 1998 2004
Sampling Year
Figure 7. Temporal and spatial patterns for Ammonia (NH3-N) concentrations
(ni described by "zones" in the Pigeon River that extend from North Carolina
and end in Tennessee. Data describing NH3-N concentrations and variance for each
year may originate from one or more stations within each zone. Data collected from
zone "e" in 2004 are represented by a single observation collected from surface
water at two locations in Waterville Reservoir. (The error bars represent one
standard deviation about the mean.)
Final

e
River Science Panel Review
­986 1992 1998 2004
Sampling Year
f
6.000
6.000
J
E 4.000
c
w
0 3.000
a
z
2.000
F
1.000
0 000
J
m
E
C
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2
O
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O
F
e
1986 1992 1998 2004
Sampling Year
9
6.000
5.000
J
E 4.000
w
0 3.000
z
m 2.000
' o
H
1.000
0 000
1986 1992 1998 2004 1986 1992 1998 2004
Sampling Year Sampling Year
Figure 8. Temporal and spatial patterns for Total Nitrogen (TN) concentrations (mg/L)
described by "zones" in the Pigeon River that extend from North Carolina and end in
Tennessee. Data describing Total Nitrogen concentrations and variance for each year may
originate from one or more stations within each zone. Data collected from zone "e" in 2004 are
represented by a single observation collected from surface water at two locations in Waterville
Reservoir. (The error bars represent one standard deviation about the mean.)
L
Final
43

J
J
River Science Panel Revieiv
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a
Sampling Year
f
A
J
E
E
J
e
1986 1992 1998
Sampling Year
9
2004
Final
1986 1992 1998 2004 1986 1992 1998 2004
Sampling Year Sampling Year
Figure 9. Temporal and spatial patterns for Total Phosphorus (TP) concentrations (mg/L)
described by "zones" in the Pigeon River that extend from North Carolina and end in
Tennessee. Data describing TP concentrations and variance for each year may originate from
one or more stations within each zone. Data collected from zone "e in 2004 are represented by
a single observation collected from surface water at two locations in Waterville Reservoir.
(The error bars represent one standard deviation about the mean.)
44

Pigeon River Science Panel Review
a
,5.0
a
= 100 =
5.0 o
a o
00
1998 1992 1998 2009
S.Wlhg Y®r
e
Iq
E
0
O
2
Sa Iing Y®r
E
O
18
Sanpling Ym
I
Sa ling Year
9
Sv ling Y®r
Figure 10. Temporal and spatial patterns for Dissolved Oxygen (DO) concentrations (mg/L)
described by "zones" in the Pigeon River that extend from North Carolina and end in
Tennessee. Data describing DO concentrations and variance for each year may originate from
one or more stations within each zone. Data collected from zone "e" in 2004 are represented by
a single observation collected from surface water at two locations in Waterville Reservoir.
(The error bars represent one standard deviation about the mean.)
Final
M

30
25
20
t-
w 15
tt
10
5
River Science Panel Review Final
65.5 42.5 32 26
River Mlle
Figure 11. Number of EPT taxa in benthic communities of the Pigeon River in North Carolina
and Tennessee, September 2001 (from CP&L).
40
35
30
25
w 20
u
15
10
5
64.5 57.5 41.5
River Mile
Figure 12. Number of EPT taxa in benthic communities of the Pigeon River in North Carolina,
July 2002 (from NCDENR)

30
25
20
10
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River Science Panel Review
Final
1
1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
Figure 13. Number of EPT taxa in benthic communities of the Pigeon River in North Carolina below
the Blue Ridge Paper Mill (Zone "d") from 1983-2002.
60 ._... _... ... .. __
Ekellent
54
Good
48 r
I
42
Fair
36 :. ...
N
N
v0
0i 30---W"'-
°1 Poor
24
Very Poor
18
12
6
0
8.2 16.5 55.4 64.5
Sampling Stations by River Mile Canton
Figure 14. Fish Index of Biotic Integrity (IBI) for several locations along the Pigeon River, NC and
TN, collected by TVA in 1990 and 1997. -
■ 1990
❑ 1997
47

35
30
25
n
= 20
a
`s 15
a
E
10
5
0
60
54
48
c 30
24
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River Science Panel Revieu,
Final
64.5 63 59 55.5 54.5 48.2 42.6 24.9 19.3 16.5 8.2
River Mile
Figure 15. Number of native species of fishes along the length of the Pigeon River, from above the
paper mile discharge (RM 64.5) to Tannery Island, TN (RM 8.2), 1995.
12
88 89 90 91 92 93 94 95 96 97 9B 99 00 01 02 03
Years
Figure 16. Fish Community Index of Biotic Integrity (IBI) at two locations on the lower Pigeon
River, TN, Denton (RM 16.5) and Tannery Island (RM 8.2), 1988-2003 (from Charles F. Saylor,
personal communication, 2005).
48

Sum of CDD (p9rg)
40
35
w 30
U
O
U
25
u
a
N
L 20
N
LL
m
A
Z 15
O
`a
E
i 10
5
0
River Science Pane( Review
Final
.. Champion ... .....
40
35
w 30
U
O
U
25
u
a
N
L 20
N
LL
m
A
Z 15
O
`a
E
i 10
5
0
River Science Pane( Review
Final
.. Champion ... .....
Modernization -
4
k
F
i
�v
4
❑ Denton
■Tannery
88 89 90 91 ^ 92 93 94 95 96 97 98 99 00 01 02 03
Years
Figure 17. Number of Native Fish Species collected from the Pigeon River at two locations on the
lower Pigeon River, TN, Denton (RM 16.5) and Tannery Island (RM 8.2), 1988-2003.
Stelidn (NI)L� RiveMile 64.5 �"
1.6
1.4
1.2
1
0.8
0.6
0.4
0.2
0
Species
+0lackredhorse
—B—Commonc
—O Redbreast ery sunfish
5< Rockbass
1990 1991 1992 1993 1904 1995 1996 1997 199E 1999 2000 2001 2002 20M 20M
Year. ® . m Approximate median ofdelection limits
for TCDD in all species (1990-2003)
Figure 18. TCDD concentrations measured in all fish species sampled at RM 64.5 (non -detects
reported at the detection limit).
49

r f �
Pigeon River. Science Panel Review Final Report
1.6
1.4
12
1
0.8
0.6
0.4
0.2
0
�ti—Black reohorse
f Redbreaslsun5sh
,Rockbass
1990 1991 1992 1993 1994 1995 '1996 1997 1998 1999 2000 2001 2002 2003 2004
Year .: Approximate median ofdcicction limits
far TCDD in all species (1990-2003)
Figure 19. TCDD concentrations measured in three fish species (not including carp) sampled at
RM 64.5 (non -detects reported at the detection limit).
�Stedon (I An�Rivabile 59 (=
25
20
15
10
5
0
19M im 1992 1993 1994 1995 1996 1997 19M 1999 2W0 2001 2002 2003 2004
Year.;.
Figure 20. TCDD concentrations measured in all fish species sampled at RM 59 (non -detects
reported at the detection limit).
Species
t Charnel catfish
- Cwmoncaip
-h Redbreaslsw6sh
50

f r e
4.5
4
3.5
3
25
2
1.5
River Science Panel Review
Final
SPecres �,-
Btuetpil
— Canmoncarp
—c—Recbmastsuffsh
0.5
1990 1991 1992 1993 1999 1995 19% 1997 1998 1999 2000 2001 2002 20M 2009
yeaA Appmzimate median of detection limits
JbrTCDD in all species (1990-2003)
Figure 21. TCDD concentrations measured in all fish species sampled at RM 52.3 (non -detects
reported at the detection limit).
I
2.
�Bluegill
FfRedbreastsunfish
0.
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000
Approximate median of detection limits
for TCDD in all species (1990-2003)
Figure 22. TCDD concentrations measured in two fish species (not including carp) sampled
at RM 52.3 (non -detects reported at the detection limit).

i r' a
Pigeon River Science Panel Review
Statian (Npl:: Ri--I 41.5S=Ii
35
30
25
20
15
10
5
0
1990 1991 1992 19M 1994 1995 19% 1997 1998 1999 2000 2001 2002 2003 2004
year'.
Figure 23. 'TCDD concentrations measured in all fish species sampled at RM 41.5 (non -detects
reported at the detection limit).
Station (a10 t� Rivehfle41.5t=�
sumo( 2,j 8-TCDD (pgrg)
3
2.5
2-
0. 5
0
Final
Spedes `
+Bmckcrapple
— Bluegil
—rl—Channcicatlish
—tFCommon carp
—it Fladheadcatish
— Largemouth bass
species
0 Blackcrapple
——Blucgil
—a—Channalca7sh
—x--Flatheadcatish
— Largemomh bass
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
year', Approximate median of dctecdon limits
for TCDD in all species (1990-2003)
Figure 24. TCDD concentrations measured in five fish species (not including carp) sampled
at RM 41.5, at head of reservoir (non -detects reported at the detection limit).
52

f 1 ^ f
Pigeon River Science Panel Review Final Report
Station, (Alp .- Rir'e1Ml 39
70
60
50
40
30
20
10
0
1990 1991 1992 1993 1994 1995 19M 1997 1996 1999 2000 2001 2002 2003 2W4
' Yeah
Figure 25. TCDD concentrations measured in all fish species sampled at RM 39, near dam in
reservoir (non -detects reported at the detection limit).
Staiion (api=. Riveifvile a9 P3
Spedes.
+Black crappie
tBluegi4
—h—Channel cat ish
—1E—Common wry
—>t—Flatheaoeatish
'Largemouth bass
1.e .p
1.6 .. -
1.4
1.2
2.. Black crappie
crappie
�r Chamelcagish
it --Flativeadeatfish
0.6 .. - -io--latgemculhbass
0.6 • e S
:a.... m -.. s:r. .....--n. nw c-. .�. ... • srn • ..v.... .w n e. m. e
0.2
0 '
1990 1991 1992 1993 MA 1995 19M 1997 19M 1999 2000 2001 20D2 2003 20D4
year m Appmzimatemedianofde(muoulimits
forTCDD in all species (1990-2003)
Figure 26. TCDD concentrations measured in six fish species (not including carp) sampled at
RM 39, near dam in reservoir (non -detects reported at the detection limit).
53

Pigeon River Science Panel Review
Station (PII) , Riierldlel 19,
0.7
0.6 a `
� t
0.5
0.4
0.3
02
Final
Species
Black reahorse
—n— Redbreast sunfish
A Rockbass
—x—Smallmouth bass
—x Smallmouth buffalo
�Spnttedbass
0.1 JAM
0
1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
Year I Approximate median ofdetection limits
for TCDD in all species (1990-2003)
Figure 27. TCDD concentrations measured in six fish species sampled at RM 19 (non -detects
reported at the detection limit).
54

F��
BLUE RIDGE
PAPER PRODUCTS INC.
February 23, 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 6167
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Attn: Central Files
Re: NPDES NO. NC0000272
Best Management Practices 2005 Annual Report
Blue Ridge Paper Products, Inc.
Canton, NC
Please find attached two copies of the data summary of Best Management Practices (BMP)
daily monitoring for Blue Ridge Paper Product's Inc., Canton Mill. This submission is required
by Special Condition A.(6.) Best Management Practices, Section E4 and Section F1, of the
mill's NPDES Permit No. NC0000272.
The Canton Mill's BMP Plan specifies that investigative action will be performed when the
Primary Influent Lower Action Level of 70,322 Ibs/day of True Color is exceeded for two
consecutive days. Investigative action was conducted for the three Lower Action Level
exceedances in 2005, listed below:
Date Primary Influent Color
22-Jan-05 74,548
23-Jan-05 124,216
20-Aug-05 70,340
21-Aug-05 138,804
10-Oct-05 131,324
11-Oct-05 73,399
The Canton Mill's BMP Plan specifies that investigative and corrective action will be performed
when the Primary Influent Upper Action Level of 78,609 Ibs/day of True Color is exceeded for
two consecutive days. The Canton mill did not trigger this requirement in 2005.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

23 February 2006, Page 2
The Canton Mill's BMP Plan specifies that immediate investigative and corrective action will be
performed when the Primary Influent Out -of -Control Level of 92,734 Ibs/day of True Color is
exceeded for one day. Investigative and corrective actions were conducted for the eight Out -of -
Control Level exceedances in 2005, listed below.
Date Primary Influent Color
13-Jan-05
102,195
23-Jan-05
124,216
11-May-05
144,254
28-Jun-05
273,059
21-Aug-05
138,804
04-Oct-05
166,786
10-Oct-05
131,324
03-Nov-05
101,464
A table of the BMP Action Level exceedances and corresponding corrective actions is attached.
There were no action level exceedances that resulted in disruptions to the Wastewater
Treatment Plant.
Please call us if you have any questions or concerns regarding this information.
Sincerely,
Glenn Rogers
Water Compliance Coordinator
828-646-2874
[e-mail]
Paul Dickens
Manager, Environmental Affairs
828-646-6141
[e-mail]
Attachment: 2005 BMP Action Level Exceedances and Corrective Action
cc:
Mr. D. Keith Haynes (w/ attachments)
Environmental Specialist
North Carolina Department of Environment
& Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

23 February 2006, Page 3
Internal Distribution:
C. File —Water
BMP Notebook
B. Williams
D. Brown
B.Shanahan
J. Clary
J. Pryately
Environmental. Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 9 828-646-2000
Raising Your Expectations

2005 BMP Action Level Exceedances and Corresponding Corrective Actions
NPDES No. NC 0000272
Blue Ridge Paper Products, Inc.
Canton, NC
Dates
Primary Influent Color
BMP/Non-BMP
Event and Corrective Action
Both Recovery Furnaces were forced down due to operational problems. No. 11 recovery
cyclones plugged requiring washing. With both furnaces down for extended period, West
GB Evaporators were shut down. Concentrated black liquor from cyclone wash and from
GB boilout was captured for recovery. Rinse water from the GB boilout and cyclone wash
contributed to elevated color as the spill collection system was full and the rinse water had
13-Jan-05
102,195
BMP
to be sewered. There was no detrimental impact on the Wastewater Treatment Plant.
An unplanned outage on #10 Recovery boiler led to storage of black liquor. A steam
purge line on the transfer line to the storage area was open in order to drain for freeze
protection. An operator failed to close the drain valve which resulted in black liquor flowing
back through the steam purge and draining to containment and the sewer. In addition, the
22-Jan-05
74,548
CRP filtrate return pump failed on 1/23 causing the fitrate tank to overflow to the sewer.
23-Jan-05
124,216
BMP
Leak on the steam purge line and the CRP purge pump were fixed.
The evaporator feed pump tripped out which allowed the hardwood weak black liquor tank
to overflow. During the overflow, the DCS controller was down for repair. Therefore, no
alarm was given to notify the operators of the situation. Once the overflow was
discovered, the wastewater treatment plant was notified and the release was diverted to
the off-line spare clarifier for later treatment at a non -disruptive rate. In addition, an
interlock stop was put in the tank control logic to prevent sending material into the tank in
11-May-05
144,254
BMP
the event of another pump failure.
BMP 2005 Report Data, BMP Summary Page 1 of 2 Printed 2/22/2006

20-Aug-05
10-Oct-05
70,340
166.786
131,324
F-M"
During start-up of #11 Recovery Boiler and following an upper furnace wash and cyclone
wash the black liquor heater secondary drain valve was inadvertantly left open, draining
black ligour to the sewer. The problem was not immediately identified due to the location
of the drain line discharge which was difficult to see. The secondary liquor heater drain
was re-routed to a point that is more visible and accessible. This will facilitate better
idantifinstinn of inorooer valve position during start-up inspections in the future.
An unanticipated total mill power outage due to a Progress Energy transformer explosion
led to unavoidable loss of material to the in -mill sewer system. The mill's extensive sump
system was able to collect most of the material. After spill collection systems were at
capacity, sporadic overflows of these systems occurred on 8120 and 8/21. Whenever
possible, material was diverted to the off-line spare clarifier for later treatment at a non -
This elevated color resulted from a planned outage that involved maintenance on the
Hardwood Fiberline and #11 Recovery Boiler. Due to the extended nature of this outage,
not all material could be recovered. There was no detrimental impact on the Wastewater
Treatment Plant as material was diverted to the off-line spare clarifier for later treatment at
#19 digester developed two tube ruptures at approximately 0200 the morning of 10/10.
The loss of material was such that it contaminated the boiler feedwater system.
Therefore, mill personnel had to divert the contaminated feedwater to the mill sewer
system the morning of 10/10. There was no detrimental impact on the Wastewater
Treatment Plant as material was diverted to the off-line spare clarifier for later treatment
n nnn-disruptive rate.
2
BMP 2005 Report Data, BMPage of 2 Printed 2/22/2006P Summary '

o�oF wArF,�Qc
l ®En
>_ y
O <
Mr. Paul Dickens, Manager
Environmental Affairs
Blue Ridge Paper Products, Inc.
175 Main Street, P.O. Box 4000
Canton, North Carolina 28716
Dear Mr. Dickens:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
'--- - - - Division of Water Quality
January 25, 2006
JAN �O�o
i
I- -
Subject: Color Report/316a Report
Extension Request
Blue Ridge Paper — Canton Mill
NPDES Permit No. NC0000272
Haywood County
The Division of Water Quality (Division) has reviewed your report entitled "Effluent Color
Performance Following Highest Certainty and Reasonable Certainty Actions". The Division commends
Blue Ridge Paper Products' efforts on reducing color in the effluent.
The Division has also reviewed your request (dated January 12,2006) for an extension of the Part I,
Condition A.(8). Paragraph 10 stipulation (Color Variance Report) of the subject NPDES permit.
According to condition A (8.) Paragraph 8 of your permit, the new effluent color limit shall be established
based on the submitted statistical analysis report via recommendation to the NPDES Committee by
February 1, 2006.
Due to high flow conditions in the Pigeon River during the summer of 2005, it is our understanding
that the field work for the 316a study was delayed. This information is necessary for the completion of
the Color Variance Report. Therefore, the Division is willing to extend the due date of the subject report
and the 316a Study Report, until May 31, 2006. This date coincides with the date of the NPDES Permit
Renewal Application. It should be noted that this date extension does not change any other compliance
date requirements of the Permit.
The Division will conduct consultations with the members of the Technology Review Workgroup
(TRW) during renewal of the permit to set a color limit that is acceptable to the TRW members.
If you have any questions concerning this issue, please contact Sergei Chemikov at telephone number
[phone], extension 594, or Mr. Roger Edwards, or Mr. Keith Haynes of our Asheville Regional
Office at 828-2964500.
Sincerely,
mj--�
Alan Klimek, P.E.
Cc: Central Files
NPDES Files
Asheville Regional Office, Surface Water Protection
Roosevelt Childress, EPA Region IV
Don Anderson, US EPA, Office of Water, Office of Science and Technology (4301 T), 1200 Pennsylvania
Avenue, NW, Washington, DC 20460
N. C. Division of Water Quality 1 NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.encstate.nc.us
Phone: (919) 733-M
fax: [phone]
DENR Customer Service Center: 1 800 623-7748

BLUE RIDGE
PAPER PRODUCTS INC.
5 December 2005
Ms. Michele Phillips
Division of Water Quality
Certified Mail
Return Receipt Requested
7099 3220 0007 0371 594m
F e,^ — —T" 54,uk
North Carolina Department of Environm
and Natural Resources --tv K . n
1617 Mail Service Center (/�
Raleigh, NC 27699-1617
Subject: Notice of Incomplete Discharge Monitoring Report
NPDES Permit No. NC0000272
Blue Ridge Paper Products Inc.
Canton, North Carolina
Deaf: Ms. Phillips:
DEC 1 2 2005
In response to the letter dated October 17, 2005 from the Division of Water Quality (see
enclosure), Blue Ridge has submitted all the requested information with its October 2005
Discharge Monitoring Report (DMR). You will notice that the parameter codes and missing
flow information have now been corrected per your office's request.
L•lll
Blue Ridge regrets the.late submission of the corrections to your office, however, the letter dated
October 17, 2005 was originally sent to the wrong address and was not received by this office
until November 15, 2005. By taking the necessary steps to correct these issues with the DMR
and submitting copies to your office, Blue Ridge has complied with your request and considers
this matter closed.
If you have any questions, please don't hesitate to contact us.
Sincerely,
J. Glenn Rogers Paul S. Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2381 828-646-6141
[e-mail] [e-mail]
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations 4.

Ms. Michele Phillips, NC DENR DWQ
5 December 2005, Page 2
Enclosure: October 17, 2005 Letter from DWQ
cc: Keith Haynes
Environmental Specialist
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Internal Distribution:
C. File Water
J. Pryately
L. Cooper
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

W AT F,7Q I'lichael F. Easley, Governor
���➢ - Winiain G. Ross Jr., Secretary
r North Carolina Department of Environment and Natural Resources
a s —I ..
A]= W. Klimek, P. E. Director
Division of Water Quality
Date: October 17. 2005
Derric Brown WPa.� n 0�resa
1329 Howell Mill Road
Waynesville, NC 28786
Subject: Notice of Incomplete Discharge Monitoring Report
Dear Permittee:
The purpose of this letter is to call your attention to problems with the recent submittal of the Discharge
Monitoring Report (DMR) from your facility. As you may know, the data recorded on your DMR is keyed
into the Division's database. Our.data entry staff has informed me of problems with your recent DMR
submittal. Until these problems have been corrected, your DMR will be considered incomplete. Please
see the attached form along with a copy of the problem DMR for details regarding the DMR's deficiency.
Incomplete or illegible DMRs affect our staff's ability to provide a timely and effective evaluation of DMR
submittals. Please be aware that until the Division receives a corrected DMR, you may be considered
noncompliant with your NPDES permit and 15A NCAC 02B .0506, and you may be subject to further
enforcement action. Please take the necessary steps to correct the problems and submit two copies of the
amended DMR within fifteen (15) days of the date of this letter to the following address:
Attention: Michele Phillips
Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Future DMR submittals with the same or similar problems will be unacceptable. If you have any questions
about the proper completion of DMRs, please contact Michele Phillips at 919-733-5083 Ext. 225. Thank
you for your assistance in this matter.
Sincerely,
�¢J>/Alan W. Klimek, P.E.
cc: Asheville Regional Office /VJ(
Central Files
NO ortnhCarolina
Xmiro!!Y
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Phone: [phone] Customer Service
Internet: hllpl/h2o.em.stale.oc.us 512 N. Salisbury St. Raleigh, NC 27604 Fax! [phone] l-M-623-6748
An Equal Opportunity/Affirmative Action Employer

9off6e of Incomplete Discharge Monitoring Report
D 6 X7
Permit Number.
Facility: Bdw�I�AIA&-cP(Q y45 14-1G.
County ftu U&f)rL-
DNMMonth and Year. %A&Zt
Q
The Division of Water Quality deems the aforementioned DMR as incomplete due to the
followingreason(s): (Please seethe highlighted areas on the attached DM.Rjor details.)
❑ The written values are, illegible.
❑ The Average, Maximum, and/or the Minimum data points have been omitted.
❑ The Units of Measure have been omitted or are incorrect.
❑ The DNa Parameter Codes have been omitted-
.2.U.
2,U. 1-1:1-1
�Zs /V-)I
06�

BLUE RIDGE
PAPER PRODUCTS INC.
4 January 2006
D. Keith Haynes
Environmental Specialist
North Carolina Department of Environment
And Natural Resources
Division of Water Quality
2090 US Highway 70
Swannanoa, NC 28778
Subject: NPDES NC0000272
2005 Annual Average Color
Blue Ridge Paper Products, Inc.
Canton, NC
Dear Mr. Haynes -
JAN - 6 2006
CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 5948
This letter and attachment document the 2005 average annual color discharge from the Blue
Ridge Paper Products, Inc. mill in Canton, North Carolina. The average secondary effluent
color discharge for the calendar period 1 Jan 2005 through 31 Dec 2005 was 39,103 ibs/day.
The attachment provides daily wastewater discharge flows and color from the mill during 2005.
Sincerely,
� A�```�
J. Glenn Rogers
Water Compliance Coordinator
828-646-2874
[e-mail]
Paul S. Dickens
Manager, Environmental Affairs
828-646-6141
[e-mail]
Attachment: Daily flow and color discharge for 2005
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Keith Haynes, NC DENR DWQ
5 Jan 2005, Page 2
Distribution
C File - Water
L. Cooper
J. Pryately
B. Shanahan
D. Brown
J. Clary
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

2005 Discharge Color Data
NPDES Permit No. NC0000272
Blue Ridge Paper Products, Inc.
Canton, NC
Date
Flow
m d
Color
Ibs/da
l/l/2005
25.42
50,881
1/2/2005
25.5
46,787
1/3/2005
25.2
45,817
1/4/2005
'25.01
32,330
1/5/2005
25.51
24,254
1/6/2005
26.11
34,841
1/7/2005
24.64
38,067
1/8/2005
24.35
38,179
1/9/2005
24.96
39,135
1/10/2005
24.82
42,228
1/11/2005
25.14
36.901
1/12/2005
24.37
33,536
1/13/2005
28.9
48,205
1/14/2005
27.99
47,621
1/15/2005
26.02
35,155
1/16/2005
25.75
35,864
1/17/2005
25.26
41,502
1/18/2005
24.95
40,368
1/19/2005
24.68
46,930
1/20/2005
23.89
43,435
1/21/2005
27.73
49,260
1/22/2005
26.29
43,632
1/23/2005
24.99
51,479
1/24/2005
24.85
54,299
1/25/2005
24.95
35,374
1/26/2005
25.66
29,533
1/27/2005
25.2
34,468
1/28/2005
25.26
35,392
1/29/2005
25.62
29,487
1/30/2005
25.6
31,599
1/31/2005
25.95
47,613
2/1/2005
24.95
37,871
2/212005
24.86
34,210
213/2005
26.04
34,313
2/4/2005
25.33
42,673
2/5/2005
25.81
42,836
2/6/2005
26.09
40,907
2!7/2005
27.03
55,681
2/8/2005
27.3
57,376
2/9/2005
26.23
60,815
2/10/2005
25.97
70,608
2/11/2005
24.8
49,226
2/12/2005
24.41
52,320
2/13/2005
24.52
43,353
2114/2005
24.79
45,398
2/15/2005
24.49
39,420
2/16/2005
25.26
42,976
2/17/2005
25.45
52,851
2/18/2005
23.93
50,094
2/19/2005
23.06
40,580
2/20/2005
25.42
48,125
2/21/2005
27.27
46,851
2/22/2005
26.11
42,898
2/23/2005
24.99
39,808
2/24/2005
26.23
62,565
2/25/2005
24.2
36,329
2/26/2005
27
39,181
2/27/2005
24.5
38,414
2/28/2005
25.26
38,342
Subtotal Ibs 2,53 192
Date
Flow
m d
Color
Ibs/da
3/l/2005
23.21
30,391
3/2/2005
23.07
25,975
3/3/2005
22.26
26,919
3/4/2005
22.51
37,171
3/5/2005
24.7
38,934
3/6/2005
24.53
36,415
3/7/2005
25.49
38,053
3/8/2005
26.54
32,316
3/9/2005
24.18
32,669
3/10/2005
24.09
34,155
3/11/2005
25.57
33,268
3/12/2005
23.88
37,840
3/13/2005
23.26
38,992
3/14/2005
23.14
39,176
3/15/2005
23.29
36,711
3/16/2005
23.27
32,022
3/17/2005
23.26
32,202
3/18/2005
22.35
29,824
3/19/2005
23.27
32,216
3/20/2005
24.04
34.485
3/21/2005
24.22
29.491
3/22/2005
24
35,829
3/23/2005
23.89
31,480
3/24/2005
23.93
44,106
3/25/2005
24.64
38,634
3/26/2005
25.21
36,163
3/27/2005
26.01
35,142
3/28/2005
27.11
34,367
3/29/2005
25.92
37,398
3/30/2005
25.63
63,485
3/31/2005
25.78
40,206
4/l/2005
25.96
33,992
4/2/2005
26.87
37.200
4/3/2005
25.26
39,816
4/4/2005
25.87
61,275
4/5/2005
23.03
62,615
4/6/2005
24.63
29,169
477/2005
25.35
25,793
4/8/2005
27.53
22,501
4/9/2005
28.06
25,976
4/10/2005
26.81
54,110
4/11/2005
25.85
38.590
4/12/2005
26.78
38,639
4/13/2005
24.61
34,071
4/14/2005
24.74
33,219
4/15/2005
23.84
43,344
4/16/2005
23.45
35,594
4/17/2005
23.38
33,928
4/18/2005
23.71
39,153
4/19/2005
23.64
29,574
4/20/2005
22.94
26,402
4/21/2005
23.47
28,187
4/22/2005
24.51
28,822
4/23/2005
24.85
27,357
4/24/2005
23.84
26,046
4/25/2005
23.15
33,980
4/26/2005
23.64
34,897
4/27/2005
23.32
33,452
4/28/2005
24.75
33.026
4/29/2005
24.59
36.709
4/30/2005
24.36
32,506
Subtotal Ibs 2,165,9781
Date
Flow
m d
Color
Ibs/da
5/l/2005
23.43
32,242
5/2/2005
24.54
42,161
5/3/2005
24.61
37,355
5/4/2005
24.58
34,440
5/5/2005
24.68
57,221
5/6/2005
24.44
43,823
5/7/2005
24.36
35,960
5/8/2005
24.8
35,989
5/9/2005
25.38
34,290
5/110/2005
26.43
27,774
5/11/2005
24.09
28.328
5/12/2005
24.96
52,458
5/13/2005
25.29
47,246
5/14/2005
23.95
33,557
5/15/2005
24.54
48,505
5/16/2005
24.38
40,259
5/17/2005
24.44
41,785
5/18/2005
24.37
48,779
5/19/2005
25.92
36,966
5/20/2005
28.31
38,721
5/21/2005
25.96
27,496
5/22/2005
24.73
28,050
5/23/2005
24.35
40,413
5/24/2005
24.54
46,663
5/25/2005
23.2
40,052
5/26/2005
22.34
35,959
5/27/2005
23.23
38,360
5/28/2005
23.05
29,989
5/29/2005
23.76
29,724
5/30/2005
23.81
27,801
5/31/2005
24.11
36,194
6/1/2005
26.72
41,449
6/2/2005
25.97
31,189
6/3/2005
25.73
23,390
6/4/2005
26.26
57,599
6/5/2005
24.98
34,792
6/6/2005.
25.84
41,162
6/7/2005
25.02
35,682
6/8/2005
25.03
33,609
6/9/2005
25.72
29,602
6/10/2005
25.42
29,256
6/11/2005
24.81
25,864
6/12/2005
26.65
27,116
6/13/2005
27.05
35,419
6/14/2005
24.59
39,786
6/15/2005
23.96
38,766
6/16/2005
27.28
43,000
6/17/2005
25.56
45,405
6/18/2005
25.18
45,780
6/19/2005
25.69
44,565
5/20/2005
24.41
38,680
5/21/2005
23.86
37,013
6/22/2005
23.52
39,428
6/23/2005
23.77
35,684
5/24/2005
24.05
42,522
5/25/2005
24.46
41,819
5/26/2005
25.41
44,927
5/27/2005
27.06
45,813
5/28/2005
27.77
44,004
"0/29/2005
26.51
83,131
3/30/2005
24.44
54,626
Subtotal Ibs 2,389.637
2005colorcalc, 2005 Daily Color data Pagel of 2 Printed 1/4/2006

2005 Discharge Color Data, continued
NPDES Permit No. NC0000272
Date
Flow
m d
Color
Ibs/da
7/1/2005
25.12
46,090
7/2/2005
24.14
53,352
7/3/2005
26.34
43,935
7/4/2005
26.28
43,616
7/5/2005
25.24
34,312
7/6/2005
25.13
37,935
7(7/2005
29.48
43,764
7/8/2005
27.75
38,418
7/9/2005
26.48
41,298
7/10/2005
24.88
46,065
7/11/2005
26.22
47,890
7/12/2005
25.86
45,291
7/13/2005
25.8
45,186
7/14/2005
25.63
45,743
7/15/2005
25.84
51,290
7/16/2005
23.78
38,872
7/17/2005
23.88
31,865
7/18/2005
24.09
35,360
7/19/2005
25.47
41,422
7/20/2005
26.71
40,765
7/21/2005
26.56
40,758
712PJ2005
24.29
33,020
7/23/2005
22.87
30,899
7/24/2005
22.81
35,954
7/25/2005
23.76
36,857
7/26/2005
24.93
41,999
7/27/2005
25.56
57,556
7/28/2005
26.22
41,986
7/29/2005
26.06
41,729
7/30/2005
25.95
41,120
7/31/2005
25.29
35,856
8/1/2005
24.37
26,015
8/2/2005
24.81
31,244
8/3/2005
25.61
38,873
8/4/2005
24.36
38,195
8/5/2005
24.89
37,572
8/6/2005
24.85
31,916
8/7/2005
27.35
31,706
8/8/2005
27.41
33,833
819/2005
26.76
23,657
8/10/2005
26.11
33,535
8/11/2005
24.32
35,901
8/12/2005
24.47
38,367
8/13/2005
25.32
47,302
8/14/2005
24.81
57,316
8/15/2005
25.36
46,108
8/16/2005
25.97
44,184
8/17/2005
24.05
37,708
8/18/2005
30.8
53,429
8/19/2005
28.04
70,156
8/20/2005
26.69
54,313
8/21/2005
20.396
66,680
8/22/2005
27.9
90,515
8/23/2005
28.59
75,824
8/24/2005
26.81
50,980
8/25/2005
26.13
52,084
8/26/2005
25.5
48,914
8/27/2005
25.36
50,761
8/28/2005
25.61
43,785
8/29/2005
26.43
50,257
8/30/2005
31.12
45,160
8/31/2005
27.29
34,823
Subtotal Ibs 2,71 318
Total color discharge, Ibs 14,272,574
Date
Flow
m d
Color
Ibs/da
9/1/2005
24.99
30,429
9/2/2005
24.75
36,123
9/3/2005
23.62
27,382
9/4/2005
24.36
25,598
9/5/2005
25.44
26,733
9/6/2005
25.71
22,300
9/7/2005
26.19
26,211
9/8/2005
26.16
28,363
9/9/2005
26.32
34,682
9/10/2005
25.1
24,701
9/11/2005
26.15
44.054
9/12/2005
25.36
36,801
9/13/2005
24.01
27.834
9/14/2005
24.54
29,062
9/15/2005
25.34
31,278
9/16/2005
26.56
36,992
9/17/2005
24.91
34,279
9/18/2005
25
26,271
9/19/2005
26.24
27.674
9/20/2005
27.71
38.825
9/21/2005
26.06
33,470
9/22/2005
27.03
31,560
9/23/2005
25.96
30,744
9/24/2005
25.81
38,961
9/25/2005
26.31
39,058
9/26/2005
26.68
41,387
9/27/2005
26.05
39,106
9/28/2005
25.74
30,054
9/29/2005
26.5
35,362
9/30/2005
25.73
41,630
10/1/2005
27.87
46,952
10/2/2005
26.76
37,717
1002005
26.3
29,831
10/4/2005
22.47
48,724
10/5/2005
27.07
88,499
10/6/2005
26.75
33,241
10/7/2005
27.61
31,777
10/8/2005
27.97
45,954
10/9/2005
27.9
42,349
10/10/2005
26.07
60,879
10/11/2005
28.95
71,226
10/12/2005
27.45
40,292
10/13/2005
27.03
28,855
10/14/2005
27.34
25,538
10/15/2005
27.37
42,001
10/16/2005
26.09
36,120
10/17/2005
26.59
36,812
10/18/2005
22.37
36,194
10/19/2005
28.52
44,241
10/20/2005
28.69
37,327
10/21/2005
29.84
32,601
10/22/2005
27.02
31.098
10/23/2005
26.2
37,583
10/24/2005
26.54
38,514
10/25/2005
27.07
34,090
10/26/2005
26.49
40,209
10/27/2005
26.06
35,209
10/28/2005
26.21
33,663
10/29/2005
26.57
39,001
10/30/2005
26.88
41,922
10/31/2005
27.35
42,198
Subtotal Ibs 2.247 442
Days in 2005 365
2005colorcalc, 2005 Daily Color data Page2 of 2
Date
Flow
m d
Color
Ibs/da
11/1/2005
25.58
45,441
11/2/2005
26.39
29,272
11/3/2005
27.65
74,715
11/4/2005
26.73
62,420
11/5/2005
27.11
43,411
11/6/2005
27.11
33,010
11/7/2005
27.38
35,166
11/8/2005
27.36
37,422
11/9/2005
28.04
33,675
11/10/2005
27.7
30,956
11/11/2005
27.49
27,053
11/12/2005
27.46
24,276
11/13/2005
27.44
33,183
11/14/2005
27.17
53,477
11/15/2005
27.46
41,223
11/16/2005
27.05
33,388
11/17/2005
27.28
41,863
11/18/2005
26.78
43,106
11/19/2005
27.12
34,153
11/20/2005
27.07
30,478
11/21/2006
28.64
37,262
11/22/2005
27.36
31,946
11/23/2005
27.78
37,996
11/24/2005
27.74
31,927
11/25/2005
26.34
33,391
11/26/2005
26.56
37,657
11/27/2005
28.26
37,474
11/28/2005
27.57
26,212
11/29/2005
29.93
41,936
11/30/2005
26.3
39,482
12/1/2005
26.37
36,288
12/2/2005
26.37
47,944
12/3/2005
26.86
43,010
12/4/2005
27.39
38,834
12/5/2005
28.16
32,410
12/6/2005
27
34,678
12/7/2005
26.26
37,888
12/8/2005
26.07
38,267
12/9/2005
27.62
26,260
12/10/2005
26.54
30,324
12/11/2005
26.45
37,721
12/12/2005
26.51
35,596
12/13/2005
26.23
37,626
12/14/2005
25.74
33,489
12/15/2005
29.86
37,853
12/16/2005
27.95
29,837
12/17/2005
26.14
27,469
12/18/2005
25.47
39,935
12/19/2005
25.81
37,024
12/20/2005
25.57
37,106
12/21/2005
24.9
23,259
12/22/2005
26.44
17,420
12/23/2005
26.98
32,627
12/24/2005
27.01
28,834
12/25/2005
26.78
37,745
12/26/2005
26.37
34,748
12/27/2005
25.81
48,002
12/28/2005
26.17
43,870
1PJ29/2005
26
39,465
12/30/2005
25.4
32,623
12/31/2005
24.99
26,886
Subtotal Ibs 2.2 007
Annual Average Color, Ibs/day 39,103
Printed 1/4/2006

BLUE RIDGE
PAPER PRODUCTS INC.
30 November 2005
Mr. Alan W. Klimek, P.E.
Director
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Certified Mail
Return Receipt Requested
7099 3220 0007 0371 5900
DEC - 1
Subject: Effluent Color Performance Following Highest Certainty and Reasonable
Certainty Actions
NPDES Permit No. NC0000272
Blue Ridge Paper Products Inc.
Canton, North Carolina
Dear Mr. Klimek:
Enclosed are two (2) copies of the subject report in accordance with Part I, Condition A.(8.),
Paragraph 8 of the December 2001 NPDES permit. With this report Blue Ridge Paper has
completed Highest Certainty, Reasonable Certainty, and Lowest Certainty actions for color
reduction identified in the NPDES permit. The report also documents on -going mill -identified
color reduction initiatives. 0
The Blue Ridge Paper Canton Mill is committed to continued color performance improvement
and recommends an annual average secondary effluent true color limit of 39,000 pounds per day
and a monthly average true color effluent limit of 52,000 pounds per day. Based on recent color
performance and color -related projects underway, we believe that these limits are technically,
economically and operationally feasible.
Please contact us if you have any questions.
Sincerely,
Paul S. Dickens Robert V. Williams
Manager, Environmental Affairs Director, Regulatory Affairs
828-646-6141 828-646-2033
[e-mail] [e-mail]
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

Mr. Alan W. Klimek, NC DENR DWQ
30 November 2005, Page 2
Enclosure: Effluent Color Performance Following Highest Certainty and Reasonable
Certainty Actions
cc: (w/ encl): Dave A. Goodrich
Environmental Supervisor
Point Source Branch
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Roger Edwards
Surface Water Protection Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Keith Haynes
Environmental Specialist
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Don Anderson
US Environmental Protection Agency
Office of Water
Office of Science and Technology (4301 T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Sergei Chemikov
Environmental Engineer I
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

Mr. Alan W. Klimek, NC DENR DWQ
30 November 2005, Page 3
Internal Distribution:
C. File Water
Engr File — NPDES Color Reports
B. Shanahan
J. Clary
M. Ferguson
K. Hennessy
D. Brown
R. Medford
C. Dowdle
D. Cherry
J. Pryately
L. Cooper
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BLUE MIDGE
PAPER PRODUCTS INC.
Blue Ridge Paper Products Inc.
Canton Mi11, Canton, North Carolina
NPDES No. NC 0000272
Effluent Color Performance Following
Highest Certainty ana Reasonable Certainty
Actions
Update on Mill -Identified Color Reduction Initiatives
December 2005

December 2005 Effluent Color Report, BRPP Canton Mill
Page i
Executive Summary
This report documents the ability of the Blue Ridge Paper Products Inc., Canton Mill to attain
annual average and monthly average color limits following Highest Certainty and Reasonable
Certainty actions identified in the December 2001 NPDES permit. The report is submitted to
satisfy requirements of Part I, Section A.(8.), Paragraph 8 of the permit.
"...By December 1, 2005, the permittee shall submit, as related to implementation of the
process improvements evaluated according to Paragraph 7, a statistical analysis of Blue
Ridge Paper's effluent quality performance. This report shall include a statistical
analysis of the Blue Ridge Paper's monthly average and annual average color discharge,
mill performance as related to color, and all available data necessary to derive the
lowest achievable annual average and monthly average color loading limits...."
Based on the Canton Mill's performance from December 2003 through September 2005 and the
mill's continued commitment to color improvement, Blue Ridge Paper believes that an annual
average secondary effluent true color limit of 39,000 pounds per day and a monthly average
secondary effluent true color limit of 52,000 pounds per day are technically, economically and
operationally feasible.
Dec 2005 Color Report Final.doc

December 2005 Effluent Color Report, BRPP Canton Mill
Page ii
Table of Contents
ExecutiveSummary......................................................................................................................... i
Introduction..................................................................................................................................... 1
Purpose........................................................................................:............................................... 1
PermitRequirement.................................................................................................................... 1
Previous Color Limits, Evaluations and Reports........................................................................ 1
Blue Ridge Paper Color Reduction Initiatives................................................................................ 2
Hardwood Fiberline Six Sigma Team......................................................................................... 2
Pine Brown Recovery Transfer Line.......................................................................................... 3
Milkof Lime............................................................................................................................... 3
Pine and Hardwood Quaternary Screen Rejects Press................................................................ 3
GreenLiquor Sump..................................................................................................................... 4
AcidSewer Rerouting................................................................................................................. 4
Color Process Improvement Six Sigma Team............................................................................ 5
ColorReliability Projects............................................................................................................ 5
Statistical Analysis of Color Data ..............................................
Summary and Recommendation.
...I .................... 5
..................................... 6
Attachment I: Color Reduction Initiatives Under 2001 NPDES Permit, December 2005
Dec 2005 Color Report Final.doc

December 2005 Effluent Color Report, BRPP Canton Mill
Page 1
Introduction
Purpose
This report documents the ability of the Blue Ridge Paper Products Inc., Canton Mill to attain
annual average and monthly average color limits following Highest Certainty and Reasonable
Certainty actions identified in the December 2001 NPDES permit. The report also documents
recent mill -identified color reduction initiatives.
Permit Requirement
The requirement of the 2001 NPDES permit for this report is specified in Section A.(8.),
Paragraph 8:
"By December 1, 2005, the permittee shall submit, as related to implementation of the
process improvements evaluated according to Paragraph 7, a statistical analysis of Blue
Ridge Paper's effluent quality performance. This report shall include a statistical
analysis of the Blue Ridge Paper's monthly average and annual average color discharge,
mill performance as related to color, and all available data necessary to derive the
lowest achievable annual average and monthly average color loading limits.
By February 1, 2006, the Division of Water Quality (in consultation with the Technology
Review Workgroup) shall recommend to the NPDES Committee, considering the
statistical analysis report submitted by the permittee and the demonstrated performance
of the mill, the lowest achievable average and monthly average color loading effluent
limitations. If the limits determined to be achievable are within or below the range of
32, 000 to 39, 000 lbs per day as an annual average, the limits shall become effective
March 1, 2006, by written notification from the Director. If the limits determined to be
achievable by the Division of Water Quality (in consultation with the Technology Review
Workgroup) are above, the target range, the Permit shall be modified in accordance with
North Carolina's permitting process to reflect those limits. "
Previous Color Limits, Evaluations and Reports
Effluent color limits in Part I, Section A (8), Paragraph 2 of the December 2001 NDPES are as
follows:
"The average annual discharge of true color for each calendar month shall not exceed
48,000 pounds per day. The monthly average effluent true color loading shall not exceed
55,000 pounds per day. For the purpose of this permit/variance only, `pounds of true
color' is calculated by the following equation:
Eff cent flow (mgd) x Effluent True Color ([ppm, siclPlatinum Cobalt Units) x 8.34"
The 2001 NPDES permit also established a series of actions and reports related to color
reduction at the Blue Ridge Paper Canton Mill. "Highest Certainty" actions were projects
Dec 2005 Color Report Final.doc

December 2005 Effluent Color Report, BRPP Canton Mill
Page 2
identified by Blue Ridge Paper and the Technology Review Workgroup (TRW) as technically,
economically and operationally feasible. 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 required under Part I,
Section A (8), Paragraph 5 of the NPDES permit.
"Reasonable Certainty" actions were projects identified by the TRW with possible application to
the Canton Mill. Blue Ridge Paper completed evaluation of the technical, economic and
operational feasibility of Reasonable Certainty actions during 2002 and 2003. Results were
documented in the December 2003 Color Report required under Part I, Section A (8), Paragraph
7 of the NPDES permit. None of the Reasonable Certainty actions were deemed feasible.
However, based on mill performance with Highest Certainty actions and other initiatives, Blue
Ridge Paper recommended an annual average color limit of 42,000 pounds per day. In addition,
the Mill voluntarily accepted a reduced monthly average color limit of 52,000 pounds per day.
The Division of Water Quality (DWQ) revised the NPDES permit for these limits on February
27, 2004.
"Lowest Certainty" actions involve possible technologies to treat or eliminate the Chloride
Removal Process (CRP) wastestream. Part I, Section A (8), Paragraph 9 of the NPDES permit
specified several specific technologies for evaluation including land application, commercial
incineration, coagulation / precipitation and solidification for land disposal. Blue Ridge Paper
identified and evaluated several other possible technologies including ozone and chlorine dioxide
bleaching. However, based on engineering evaluation and/or bench and pilot scale testing, no
feasible Lowest Certainty actions were found. These results were reported in the March 2005
CRP Color Reduction Technology Assessment Report. The CRP Report was originally due in
December 2004, but the DWQ granted a 3-month extension following floods that affected the
Canton Mill in September 2004. I
Blue Ridge Paper Color Reduction Initiatives
Attachment I outlines major color reduction initiatives at the Blue Ridge Paper Canton Mill
under the 2001 NPDES permit. As of December 2005, Blue Ridge Paper has completed
NPDES requirements related to Highest Certainty, Reasonable Certainty and Lowest Certainty
actions for color reduction. The Canton Mill has undertaken other color initiatives beyond those
specified in the NPDES permit. These are included in Attachment I. Mill -identified color
projects not included in previous permit -required color reports are documented in sections
below.
Hardwood Fiberline Six Sigma Team
The October and December 2003 Color Reports identified hardwood frberline washing as a
statistically significant contributor to secondary effluent color. A Six Sigma team was chartered
in spring of 2004 to evaluate opportunities to decrease hardwood color through improved
hardwood brownstock washing and process control. The team looked at process procedures,
Dec 2005 Color Report Final.doc

December 2005 Effluent Color Report, BRPP Canton Mill
Page 3
operating practices and process control parameters to understand their effect on process
reliability and color. A new operating strategy was implemented including new performance
metrics and tracking. The team also identified opportunities to improve brown stock washing
through shower bar adjustments and replacements. New design shower bars were recently
installed on the Number 1 Hardwood Brownstock Washer. A performance evaluation of the new
shower bar design is underway. Shower bar replacements on additional fiberline washers may
be considered during 2006.
Pine Brown Recovery Transfer Line
This project was introduced in the December 2003 Color Report. The Pine Brown Recovery
Transfer Line was completed during the Spring 2004 semi-annual outage. The project provided
a transfer pipeline between the Pine Brown Spill Tank and the Hardwood Blow Tower. The
transfer pipeline increases the effective recovery volume of the Pine Brown Spill System by
allowing excess color materials from the pine fiberline to be pumped into the hardwood fiberline
for recovery. This extra recovery volume is used during maintenance outages and other events to
improve overall capture and recovery of color materials that otherwise would not be reclaimed.
The estimated annual average secondary effluent color reduction from the Pine Brown Recovery
Transfer line is 500 pounds per day.
Milk of Lime
This project was included in the May 2004 Supplement to the December 2003 Color Report.
During Spring of 2004, Blue Ridge Paper conducted a full-scale trial on the color reduction
effect of adding a continuous slurry of hydrated lime to the mill sewer system prior to
wastewater treatment. This "milk of lime" provides calcium, which in bench scale studies was
effective in removing brown color. Milk of lime addition produced a reduction in primary
influent color. However, there was no statistically significant reduction in secondary effluent
color associated with milk of lime. hi addition, milk of lime addition has adverse effects on
sludge dewatering and wastewater sludge volume. Based on the dose rate and cost, milk of lime
is not an economically or operationally feasible technology for color reduction.
Pine and Hardwood Quaternary Screen Rejects Press
This project was introduced in the December 2003 Color Report and was implemented during
2004. The Pine and Hardwood Screening Systems follow brownstock washing and remove
shives and undigested pulp from brownstock fiber before bleaching. The screen reject flow
includes a sizable volume of filtrate that contains dissolved color materials. The Quaternary
Screen Reject Presses allow separation of the rejects and filtrate so that color materials in the
filtrate can be reclaimed. During summer of 2004, Blue Ridge Paper worked with a specialty
equipment vendor to fabricate, install and test prototype mechanical screw presses on the reject
drains for the hardwood and pine quaternary screens. After pressing, the reject filtrates are
returned to brownstock filtrate tanks. The dewatered rejects are burned in the Canton Mill bark
Dec 2005 Color Report Final.doc

December 2005 Effluent Color Report, BRPP Canton Mill
Page 4
boiler. The prototype screw presses were successful, and permanent units were purchased and
installed in the fall of 2004.
Based on monitoring during trials of the Quaternary Screen Reject Presses, color reduction is
approximately 1000 pounds per day. Blue Ridge Paper is working with the equipment
manufacturer to improve reliability and uptime for the Quaternary Screen Reject Presses. The
Blue Ridge Paper installation on the quaternary screen rejects is the first application of its kind
for screw press equipment.
Green Liquor Sump
This Green Liquor Sump project was introduced in the May 2004 Supplement to the December
2003 Color Report. The project was completed in August 2005. The Green Liquor sump allows
segregation of green liquor from black liquor recovery sumps in the recovery furnace area. This
segregation is important to in -mill color control because green liquor contamination of black
liquor materials prevents their capture and recovery. The green liquor is corrosive to evaporators
and other chemical recovery cycle equipment.
The estimated annual average secondary effluent color reduction from the Green Liquor Sump is
500 pounds per day.
Acid Sewer Rerouting
As documented in the October 2003 Color Report, unaccounted color has become a larger
percentage of mill sewer color as Blue Ridge Paper has successfully reduced brown color
discharges to wastewater treatment. Unaccounted color is calculated as the difference between
measured primary influent color in pounds per day and the sum of color measured in mull sewers
upstream of wastewater treatment. Unaccounted color is primarily the result of sewer -generated
color that occurs when acid bleach plant filtrates are exposed to alkaline conditions in the mill
sewer and primary clarifiers. Sewer generated color consists of dissolved color materials and is
not effectively removed by filtration and conventional coagulation and precipitation technology.
The current acid sewer at the Blue Ridge Paper Canton Mill mixes with the alkaline mill sewer at
the 4A manhole upstream of primary treatment. This configuration creates conditions that may
contribute to sewer generated color. To minimize the creation of sewer generated color, it is
desirable to keep acid bleach plant filtrates away from alkaline pH conditions.
A project was engineered during early 2005 to reroute acid bleach filtrates directly to the primary
clarifiers downstream of initial pH adjustment for the alkaline mill sewer. With rerouting, the
acid filtrates will see a neutral pH range of 6 to 9 when mixed with other mill wastewaters for
treatment. The design allows the bleach plant filtrates to mix with either primary influent or
primary effluent wastewater prior to secondary treatment. The Acid Sewer Project was
constructed during summer and fall of 2005 and will go into full operation in early 2006. Startup
testing is scheduled for December 2005.
Dec 2005 Color Report Final.doc

December 2005 Effluent Color Report, BRPP Canton Mill
Page 5
Blue Ridge Paper believes the Acid Sewer Project will achieve reduction in sewer generated
color. The reduction in secondary effluent color, however, is difficult to predict. The Acid
Sewer Project is a full-scale trial in terms of secondary effluent color reduction.
Color Process Improvement Six Sigma Team
As a result of color reduction projects implemented under the 2001 NPDES permit, secondary
effluent color from the Blue Ridge Paper Canton Mill for the period January through September
2005 averaged 39,465 pounds per day. This average includes several months of color
performance in the range of 32,000 to 38,000 pounds per day and several months of color
performance in the range of 41,000 to 46,000 pounds per day. This variability in monthly color
performance is a result of maintenance outages and normal process variability. Reducing the
variability of color performance is the next color reduction challenge for the Blue Ridge Paper.
A Six Sigma Team was chartered in September 2005 to examine the primary operating
conditions associated with periods of lowest color performance.
Color Reliability Projects
In addition to the Color Process Improvement Team, Blue Ridge Paper will dedicate capital in
2006 to improve the reliability of processes that have a demonstrated impact on color
performance. These capital projects will focus on pulp washing efficiency, engineering controls
to improve early detection of process upsets that may release color, and further mechanical
reliability improvements to the Bleach Filtrate Recyclinem (BFR) process. Engineering design
of the Color Reliability Projects is underway with implementation planned during the first half of
2006. The 2006 Color Reliability Projects are included in Attachment I. 1
Statistical Analysis of Color Data
The average daily secondary effluent true color from the Blue Ridge Paper Canton Mill for the
period December 2003 through September 2005 - excluding the period of mill outage and restart
in September and October 2004 due to Hurricanes Frances and Ivan — is 39,548 pounds per day.
The upper 95 percent confidence interval for the average of this period is 40,280 pounds per day.
The average monthly secondary effluent color for the period December 2003 through September
2005 — excluding the flood -affected months - is 39,545 pounds per day. The upper 95 percent
confidence interval for monthly average color is 41,350 pounds per day. The maximum monthly
average color during this period occurred in August 2005 at 45,842 pounds per day. If the
flood -affected months of September and October 2004 are included, the maximum monthly
average color occurred in October 2004 at 59,539 pounds per day.
Dec 2005 Color Report Final.doc

December 2005 Effluent Color Report, BRPP Canton Mill
Page 6
Summary and Recommendation
Blue Ridge Paper Products Inc. has completed Highest Certainty, Reasonable Certainty and
Lowest Certainty actions for color reduction identified in the December 2001 NPDES permit.
The mill has also identified, evaluated and implemented other initiatives for color reduction.
Several of these mill -identified projects are underway and will be completed during 2006.
The Blue Ridge Paper Canton Mill is committed to continued color performance improvement .
and recommends an annual average secondary effluent true color limit of 39,000 pounds per day
and a monthly average true color effluent limit of 52,000 pounds per day. Based on recent color
performance and color -related projects underway, we believe that these limits are technically,
economically and operationally feasible.
Dec 2005 Color Report Final.doc

Attachment I - Color Reduction Initiatives Under 2001 NPDES Permit, December 2005 Update
Blue Ridge Paper Products Inc. - Canton Mill
Color Reduction Measure
------------►
-------------
- ''
------------►
------------►
------------►
-----------♦
-----------*
------------
-------------
-------------
-------------
--------------
-------------
--------------
-----------
-------------
_____________
204
2004
2006
1
2-Hour Color Testing
2
Lieber out Recommendations Implemented
- _.
------------
------------
------------
-------------10
--------------
--------------
--------------
------------
-----------
-----------
______________
..
...
►_
--------'-
--------------
--------------
______________
_
►
---
____________�
..
..
a
„
,
3
Use of Off-line Clarifier for Spill Diversion
4
Hwd Brown Recovery Tank Line to Pine Blow Tower
5
1-Hour color testing before and during maintenance outages
6
Installation of Mechanical Seals clean water segregation)
7
Ira rovement of equipment used for handling Pine and Hardwood Knot Rejects
8
S 1.5MM spent on Bleach Filtrate Recycle Improvements
9
1 Installed Pine Brownstock Control Logic improvements
10
Determined multiple contributors and interaction effects causing Sewer Generated Color
I I
Bench -scale sewer -generated color work
------------
--------------
-------------
-------------
--------------
----------
______________
12
Hardwood Fiberline Six Sigma Team for process optimization and color improvements
13
Improvements made to Pine Brownstock sumps for better recovery
14
White Rot Fungus Trial - growth efforts unsuccessful, may revisit in future
IS
Pine Brown Recovery Tank Line to Hwd Blow Tower
16
Milk of Lime Trial not successful, no statistically significant SE color reduction
17
Pine and Hardwood Quaternary Screen Rejects Press (eliminate quaternary screen rejects
discharge to sewer, recover filtrate and chives
18
Trial to confirm and size system for C102 de-colorization of CRP/evaluate full-scale
application (trials completed after Sep 04 floods, not economically, technically or
operationally feasible
19
20
Green Liquor Sump at recovery furnaces (implementation delayed by Sep 2004 floods,
completed Aug 2005►
Acid Sewer Rerouting - improved segregation of bleach plant filtrates from akaline
wastewaters to reduce sewer generated color
21
Color Process Improvement Six Sigma Team to examine operating conditions associated
with good color performance
22
2006 Color Reliability Projects - Pulp Washing Improvements (shower replacements and
re -bleach internal recyclepump)------------
23
2006 Color Reliability Projects - BRF Mechanical Improvements (MRP fiber detection and
prevention)
24
2006 Color Reliability Projects - Recovery Process Improvements (piping changes and
instrumentation)---'
25
2006 Color Reliability Projects - Color Monitoring Improvement (relocated and reddndant
instrumentation
-""'
- Completed Process Change / Evaluation Process Evaluation or Change
NNNNM Continued Performance Improvement awnumm Expected Performance Improvement

s,
BLUE RIDGE
PAPER PRODUCTS INC.
February 24, 2006
Mr. D. Keith Haynes
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
2090 U.S. Highway 70
Swannanoa, NC 28778
FEB
J f� 7 2
I
2006
L
SEC ioN
� ,NPL
OFPICE�
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 6150
Re: NPDES NO. NC0000272
Certification in Lieu of Monitoring for Chloroform — Process Parameter Exceedance
Blue Ridge Paper Products, Inc.
Canton, NC
In accordance with NPDES Permit No. NC0000272 and 40 CFR 430.02(f)(6)(i)(A), Blue Ridge
Paper Products is hereby notifying the Division of Water Quality (DWQ) of a process parameter
exceedance on the pine fiberline that occurred on January 30, 2006. As approved by the DWQ on
August 16, 2005 Blue Ridge monitors certain process parameters (pH of the first C102 bleaching
stage, kappa factor of the first CI02 bleaching stage, and total bleach line C102 application rate)
for its certification in lieu of monitoring for chloroform. In this case, the maximum allowable kappa
factor of the first C102 stage for the pine fiberline was exceeded on January 30, 2006 (see
Attachment 1).
In accordance with 40 CFR 430.02(f)(6)(i)(B), Blue Ridge Paper Products is demonstrating
compliance with the applicable chloroform standard by submitting the results of one sample taken
from the pine fiberline effluent on February 6, 2006 (see Attachment II). Given that the results of
the sample are well below permitted limits, Blue Ridge has resumed process monitoring in lieu of
monitoring for chloroform as allowed for by NPDES Permit No. NC0000272.
Blue Ridge has remained well below permitted limits for daily maximum and monthly average
chloroform limitations required by NPDES permit No. NC0000272 and remains committed to
continuous improvement in effluent quality. If you have any questions please don't hesitate to call.
Sincerely,
M��
J. Glenn Rogers
Water Compliance Coordinator
828-646-2874
roqerq@blueridqel)aper.com
John J. Pryately
Wastewater Supervisor & Operator in Charge
828-646-6720
pryati @blueridaepaper.com
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

24 February 2006, Page 2
Attachment I: Process Parameter Tracking Sheet
Attachment II: Results Of Chloroform Testing
Internal Distribution:
C. File —Water
B. Shanahan
J. Clary
P. Dickens
D. Brown
C. Dowdle
L. Cooper
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

ATTACHMENT I: PROCESS PARAMETER TRACKING SHEET

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ATTACHMENT II: RESULTS OF CHLOROFORM TESTING

Date:
Bleach Filtrate Chloroform Calculations
1/30/2006
HW D-1 HW Eo
Flow in mgd
Concentration in mgA
Lbs/day
HW Total Pine D-1 Pine Eo Pine D-2 Pine Total
0.292839 0.000026 0.554264 0.847129
I
0.038 0.026 0.033
8.34 8.34 8.34
0.0928 0.0000 0.1525 0.2454

aceAnalytical®
www.pacelabs.com.
February 17. 2006
Mr. John Pryately
Blue Ridge Paper Products, Inc
P.O. Box 4000
175 Main Street
Canton. NC 28716
RE: Lab Project Number: 92112825
Client Project ID: Chloroforms
Dear Mr. Pryately:
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC28078
Phone: [phone]
Fax [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC28804
Phone., 828.254.7176
Fax: [phone]
Enclosed are the analytical results for sample(s) received by the laboratory on February 7, 2006. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Si
[e-mail]
Project Manager
Enclosures
Asheville Certification IDs
NO Wastewater 40
NO Drinking Water 37712
SC 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSISCharlotte
s
NOW stewaericatio12
t
This report shall not be reproduced, except in full,
NO Drinking Water
37706
without the written consent of Pace Analytical Services, Inc.
SC
99006
" °"°"°
FL NELAP
E87627

ace Analytical
www.pacelabs.com
I
Lab Sample No: 926620378
Client Sample ID: PINE 111-COMP
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone., 828.254.7176
Fax: [phone]
Lab Project Number: 92112825
Client Project ID: Chloroforms
Project Sample Number: 92112825-001 Date Collected: 02/06/06 02:15
Matrix: Water Date Received: 02/07/05 12:08
Parameters
Results
Units
Report Limit . Analyzed
By
CAS No. Qual RegLmt
GUMS Volatiles
Volatile GUMS by 624
Method: EPA
624
Chloroform
38.
ug/l
5.0 02/16/06
12:39
DLK
67-66-3
Toluene-d8 (S)
96
%
02/16/06
12:39
DLK
2037-26-5
4-Bromofluorobenzene (S)
94
X
02/16/06
12:39
DLK
460-00-4 1
Dibromofluoromethane (S)
101
X
02/16/06
12:39
DLK
1868-53.7
Date: 02/17/06
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC 99030
FL NELAP E87648
Page: 1 of a
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
99006
FL NELAP
E87627

Analytical
www.pacelabs.com '
Lab Sample No: 926620386
Client Sample ID: PINE EO-COMP-
Pace Analytical Services, Inc.
9800KinceyAvenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax.- 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC28804
Phone: [phone]
Fax: [phone]
Lab Project Number: 92112825
Client Project ID: Chloroforms
Project Sample Number: 92112825-002 Date Collected: 02/06/06 02:10
Matrix: Water Date Received: 02/07/06 12:08
Parameters
Results
Units
Report Limit Analyzed
By
CAS No. Dual ReaLmt
GUMS Volatiles
Volatile GUMS by 624
Method: EPA
624
Chloroform
26.
ug/l
5.0 02/16/06
13:19
DLK
67-66-3
Toluene-d8 (S).
98
X
02/16/06
13:19
OLK
2037-26-5
4-Bromoflu6robenzene (S)
96
X
02/16/06
13:19
DLK
460-00-4
Dibromofluoromethane (S)
38
%
02/16/06
13:19
DLK
1868-53-7 1.2
Date: 02/17/06
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water
37712
SC 990309030 without the written consent of Pace Analytical Services, Inc.
FL NELAP E87648 "
Page: 2 of 9
Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627

aceAnalXical°
www.pacelabs.com
Lab Sample No: 926620394
Client Sample ID: PINE D2-COMP.
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone., 704.675.9092
Fax., 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC28804
Phone., 828.254.7176
Fax, 828.252.4618
Lab Project Number: 92112825
Client Project ID: Chloroforms
Project Sample Number: 92112825-003 Date Collected: 02/06/06 02:05
Matrix: Water Date Received: 02/07/06 12:08
Parameters
Results
Units
Report Limit Analyzed
By
CAS No. Qual ReaLmt
GUMS Volatiles
Volatile GUMS by 624
Method: EPA
624
Chloroform
33.
ug/l
5.0 02/16/06
12:59
DLK
67-66-3
Toluene-d8 (S)-
98
%
02/16/06
12:59
DLK
2037-26-5
4-Bromofluoro6enzene (S)
99
%
02/16/06
12:59
DLK
460-00-4 1
Dibromofluoromethane (S)
102
%
02/16/06
12:59
DLK
1868-53.7
Date: 02/17/06
Asheville Certification IDs
NC Wastewater 40
NC Drinking Water 37712
SC 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
Y CCCOM
Page: 3 of e
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
99006
FL NELAP
E87627

aceAnalytical
www.pacelabs.com
Lab Sample No: 926620402
Client Sample ID: TRIP BLANK -COMP
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC28804
Phone: [phone]
Fax.- 828.252.4618
Lab Project Number: 92112825
Client Project ID: Chloroforms
Project Sample Number: 92112825-004 Date Collected: 02/06/06 02:00
Matrix: Water Date Received: 02/07/06 12:08
Parameters
Results
Units
Report Limit
Analyzed
By
CAS No. Qual RegLmt
GUMS Volatiles
Volatile GUMS by-624
Method: EPA
624
Chloroform
ND
ug/l
5.0
02/16/06
12:00
DLK
67-66-3
Toluene-d8 (S)
101
%
02/16/06
12:00
DLK
2037-26-5
4-Bromoflu6robenzene (S)
98
%
02/16/06
12:00
DLK
460-00-4 1
Dibromofluoromethane (S)
102
%
02/16/06
12:00
DLK
1868-53-7
Date: 02/17/06
sheville Certification IDs
NC Wastewater 40
NC Drinking Water 37712
Sc 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
`N p 1LCp„Q'
Page: 4 of 8
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
99006
FL NELAP
E87627

aceAnalytical
www. pacelahs. com
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Hunters ville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax: [phone]
I Lab Project Number: 92112825
Client Project ID: Chloroforms
PARAMETER FOOTNOTES
Method 9071E modified to use ASE.
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
(S) Surrogate
Ell Sample was received by the laboratory without acid preservation as recommended by the US EPA.
[21 Low surrogate recovery was confirmed as a matrix effect by a second analysis.
Date: 02/17/06
sheville Certification IDs
NC Wastewater
40
NC Drinking Water
37712
SC
99030
FL NELAP
E87648
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
Page: 5 of 8
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
•99006
FL NELAP
E87627

ace Analytical
www.pacelabs.com
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC28078
Phone: [phone]
Fax., 704.875.9091
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
2225Riverside Drive
Asheville, NC28804
Phone: [phone]
Fax.- 828.252.4618
Lab Project Number: 92112825
Client Project ID: Chloroforms
QC Batch: 149847 Analysis Method: EPA 624
QC Batch Method: EPA 624 Analysis Description: Volatile GC/MS by 624
Associated Lab Samples: 926620378 926620386 926620394 926620402
METHOD BLANK:, 926651084
Associated.Lab Samples:
926620378
926620386
926620394 926620402
Blank
Reporting
Parameter
Units
Result
Limit Footnotes
Chloroform
ug/1
NO
5.0
Toluene-d8 (S)
X
99
-
4-Bromofluorobenzene (S)
%
97
Dibromofluoromethane (S)
X
112
LABORATORY CONTROL SAMPLE: 926651092
Parameter
)Chloroform
Toluene-d8 (S)
4-Bromofluorobenzene (S)
Dibromofluoromethane (S)
MATRIX SPIKE: 926651118
Parameter
Chloroform
Toluene-d8 (S)
4-Bromofluorobenzene (S)
Dibromofluoromethane (S)
SAMPLE DUPLICATE: 926651100
Spike LCS
Units Conc. Result
ug/1 20.00 23.16
926626565
Units Result
ug/1 2.818
Parameter Units
Chloroform ug/l
Date: 02/17/06
Asheville Certification IDs
NC Wastewater 40
NC Drinking Water 37712
SC 99030
FL NELAP E87648
LCS
X Rec Footnotes
116
99
101
104
Spike
MS MS
Conc.
Result X Rec Footnotes
20.00
27.12 122
101
92
92
926620386 OUP
Result Result RPD Footnotes
26.00 26.00 0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
`O •��CC py�'
Page: 6 of e
Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627

Ira
ce Analytical
i www.pacelahs.conr
SAMPLE DUPLICATE: 926651100
Parameter Units
Toluene-d8 (S) X
4-Bromofluorobenzene (S) X
Dibromofluoromethane (S) X
Bate: 02/17/06
Asheville CertificationlDs
NO Wastewater
40
NO Drinking Water
37712
SC
99030
FL NELAP
E87648
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NO 28078
Phone: [phone]
Fax: [phone]
QUALITY CONTROL DATA
926620386 OUP
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NO 28804
Phone: [phone]
Fax.' 828.252.4618
Lab Project Number: 92112825
Client Project ID: Chloroforms
Result Result RPD Footnotes
98 96
96 98
38 36 1,2
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except In full,
without the written consent of Pace Analytical Services, Inc.
Page: 7 of 8
Charlotte Certification IDs
NO Wastewater 12
NO Drinking Water 37706
SC 99006
FL NELAP E87627

aceAnalytical
www.pacelabs.com
I
DATA PARAMETER
Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 100
Huntersville, NC 28078
Phone., 704.875.9092
Fax., 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC28804
Phone., 828.254.7176
Fax., 828.252.4618
Lab Project Number: 92112825
Client Project ID: Chloroforms
Consistent with EPA guidelines,`unrounded concentrations are displayed and have been used to calculate % Rec and RPD values.
LCS(D) Laboratory Control Sample (Duplicate)
MS(0) Matrix Spike (Duplicate)
DUP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit'
RPD Relative Percent Difference
(S) Surrogate
Ill Low surrogate recovery was confirmed as a matrix effect by a second analysis.
[2] Sample was received by the laboratory without acid preservation as recommended by the US EPA.
Date: 02/17/06
Asheville Certification IDs
REPORT OF LABORATORY ANALYSIS
NC Wastewater
40
This report shall not be reproduced, except In full,
NC Drinking Water
37712
without the written consent of Pace Analytical Services, Inc.
SC
990309030
FL NELAP
E87648
.«"" 04
e nnf
Page: 8 of 8
Charlotte Certification Ills
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627