NC0000272_Historic Docs 1996-1997_19970101

ITN OFFICE D:2166 MAY 0 '97 10 :32 No .003 P .01
f L.i dnn Idill
Ihw f 10
Champion
CI-ampinn I nnfimu,I Cnrfwnfion [
May 1, 1997
To: Roy Davis
Fr: Michele Reaves
RE: Purchased Goods and Services I
Year to date purchases for the Canton mill from suppliers in North Carolina,
Tennessee and South Carolina (does not Include wood purchases).
Year to Date -Annualized
NC $27,658,286 $B2,974,858
TN $ 3,586,366 $10,759,098
Sc $ 5,997,542 $17,992,626
Note: "Annualized" numbers ate basest off of the first three months of 1997.
Champion has incurred approximately $40,000,000 in wood purchases from
Western North Carolina. Wood purchase figures from Tennessee sources are
not available at this time.
If you have any questions, I can be reached at 646-2308 or via digital pager
444-3536.
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ENVIRONMENTAL MANAGEMENT COMMISSION
IN THE MATTER OF REQUEST FOR ) AMENDED ORDER
VARIANCE FROM WATER QUALITY ) FOR
STANDARD-BASED EFFLUENT ) MODIFICATION OF COLOR
LIMITATIONS BY CHAMPION ) VARIANCE GRANTED ON
INTERNATIONAL CORPORATION ) JULY 13, 1988
CANTON,NORTH CAROLINA )
THIS MATTER came on to be heard before the NPDES (National Pollutant Discharge
Elimination System) Committee at its scheduled meeting in Raleigh, North Carolina, on
December 11, 1996, on its own motion to amend its order, dated October 9, 1996, for
modification of an existing color variance which was granted to Champion International
Corporation on July 18, 1988.
Upon duly made motion and vote, the NPDES Committee hereby re-adopts its order,
dated October 9, 1996, and further adopts the additional, following Findings of Fact and
Conclusions of Law:
FINDINGS OF FACT
1) On October 17, 1996, the Director of the Division of Water Quality transmitted to
the United States Environmental Protection Agency, for its review, the October 9, 1996, order for
Modification of Color Variance Granted on July 18. 1988,
2) On December 9, 1996, the United States Environmental Protection Agency
advised the Division of Water Quality and the NPDES Committee, by letter from Regional
Administrator John Hankinson to Assistant Secretary Linda Rimer, that the modification of the
color variance with certain more restrictive clarifications to the order is acceptable to the agency.
l —

2
3) The Division of Water Quality and' Cham_ pion International Corporation have
-advised the NYDES:.Committee that;the.changes-proposea`by the United'States hndiiorimental
..
Protection Agency are acceptable.
4) The following changes to the conditions of the modified variance are more
restrictive on the company, and are accepted by the NPDES Committee:
(Words recommended for removal are stricken through and additional wording is
in bold.)
Conditions identified below of the "Ordered" section of the October 9, 1996, order
of the NPDES Committee should be modified to:
CONDITION 211
II. The average daily discharge of true color for each calendar month shall not
exceed '']� 125,434 pounds per day. The average annual effluent true color
loading shall not exceed 124,923 98,168 pounds per day. For the purpose of this
permit/variance only, "pounds of true color" is calculated by the following
equation:
Effluent Flow (mgd) x Effluent True Color Level (Platinum Cobalt Units)x 8.34.
CONDITION 4
4. Champion shall continue to study, evaluate, and pursue and operate color
removal technologies and report its findings to the NPDES Committee and the
Division of Water Quality in accordance with the following schedule:
DATE ACTIVITY
EeatkHgfig
January 1, 1997 The Company will implement a one year Eemmereial
demonstration of full scale bleach filtrate recycling
(1317k") technology on the mill's pine line.
March 1, 1998 In conjunction with the scheduled Triennial Review of N.C.
Water Quality Standards the-Company shall:
1. Submit a status report to the NPDES Committee
on the technical, economic, and operational feasibility of
the BFR' technology, including those analyses prepared
for other permitting agencies concerning its effects on air
emissions.

PPPPP� 3 r
2. Evaluate and report to the NPDES Committee on
the application of end-of-pipe color reduction;technologies
- _- --- - and, additional mini-nization,of-,colar,lones from.the
manufacturing processes and raw material' storage • `'
areas. The evaluation shall include an incremental
color improvement analysis. This analysis will
concentrate 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 and minimization
efforts must look particularly at periods of low river
flow. The report will identify specific economic and
implementation issues associated with the incremental
improvement of color levels expected by installing and
adopting these technologies and minimization efforts at
the mill. The report will also project the expected
additional color reduction for each technology and
in-mill minimization effort evaluated and the maximum
color reduction possible using the identified technology
or action.
3. Champion will evaluate color reduction
strategies for further optimization of BFRTm technology
and report on the feasibility of implementation on the
hardwood line.
3
area
December 1, 1998 Based en the results of the demenstFatien prejeet and the
presented in*14he "' , Champion
will deeide and FepeFt en the desist,.., to fully implement
and operate on a continuing basis the BFRT' technology
on the mill's pineweed line.,
unless the Company can demonstrate to the NPDES
Committee that BFRTm is not a commercially viable
process at this location.
March 1, 2001 Champion will evaluate and report on end-of-pipe color
reduction technologies in conjunction with the Triennial
Review of N.C. Water Quality Standards. The evaluation
shall include ' au incremental color improvement
analysis. This analysis will concentrate 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
must look.particularly at periods of low river flow. The
,t

4
report will identify specific economic and
implementation.issues associated.with the incremental
` irnler vei .ent of color.levels-expected..by,irisi lli^g these-
_.
technologies at the mill. The report will also project the-
expected additional color reduction for each technology
evaluated and the maximum color reduction possible
using the identified technology.
June 1, 2001 Champion will submit a report to the NPDES Committee
and N.C. DEHNR, Division of Water Quality, on the
comparative evaluation of the above collective efforts as
part of the Variance review process (Triennial Review of
North Carolina Water Quality Standards).
CONDITION 5
5. The Division will provide a status summary report on color removal at the
Canton Mill to the NPDES Committee and the Variance Review Committee
within
30 days of the availability of Champion's reports as required above. The
Variance Review Committee, utilizing the information available,will, by July
1, 1998, and July 1, 2001, make recommendations to the NPDES Committee
concerning revisions_ to the color variance. Those recommendations will
include lower limits for the monthly average and annual average color
limitations applicable to the mill due to color removal performance and the
Committee's position on additional revisions needed in the variance to reflect
the application of BFRTm, end-of-the pipe treatment and in-mill color
reduction technologies. Based on the instream color data available at that
time, the Committee will also provide recommendations on the applicability
of any instream color compliance point in N.C. The NPDES Committee will
review the available information, the recommendations of the Variance
Review Committee and the staff recommendations in proposing any changes
to the variance.
CONDITION 6
6. In conjunction with subsequent triennial water quality standards reviews,
the Division will nominate a variance review committee. The NPDES Committee
will have final approval of the selection of this Committee. Committee
membership may consist of Department Staff and individuals considered
authorities on pulp and paper technology or environmental aspects of that industry
from the university or research communities. The'Committee will also include
in its membership a representative of Tennessee's Department of
Environment and Conservation who shall be appointed by the Governor of
Tennessee. That review committee's report and recommendation will be

U `
examined by the NPDES Committee for a decision on the adequacy of the
existing variance. :The NPDES Committee will determine if changes in the
r,m rrj..%rc was mm ted duc to the Y_� ti:reness.of the reatirient systerp or,because
- 1-7 - - -of advances-in color' reduction technologies for this 'type wastewater. . ;All
revisions adopted by the NPDES Committee will required the modification of the
Company's NPDES Discharge Permit,
CONDITION 7
7. The.tvariance;proceeding, and the NPDES Permit Number"NC0000272,
shall ages be subject to reopening in order to modify the color requirements
based upon the following and in association with the required triennial
reviews:
1. a Any breakthrough in color removal technologies. Such breakthroughs
shall be brought to the NPDES Committee for consideration, by
Champion and the Division of Water Quality, as soon as they are
discovered.
2._ An acceptable statistical analysis of effluent color discharge data
demonstrating significantly better color removal performance than
that currently prescribed in the variance and permit.
3. Successful application of end-of-pipe color reduction technology or
in-mill color minimization effort that results in significant and
measurable reduced mass color discharge.
CONCLUSIONS OF LAW
1) On its own motion and prior to the effective date of the October 9, 1996, order for
Modification of Color Variance Granted on July;1'8. 1988, the NPDES Committee may amend its
October 9, 1996, order, to satisfy concerns of the United States Environmental Protection
Agency, to clarify its conditions and to make the conditions more restrictive on Champion
International Corporation.
Based on the re-adopted October 9, 1996, Findings of Fact and Conclusions of Law and
the additional, foregoing Findings of Fact andtConclusions of Law, it is hereby ORDERED that
the previously existing variance from the North' Carolina water quality standard for color as

6
memorialized in the July 13, 1988 Final Decision Ordering Paragraphs, continues in effect as
hereby modified,to.read as follows:'
1. Champion's petition for a variance is granted, pursuant to G.S. 143-215.3(e), as a
variance to water quality based effluent limitations for color.
2. The Division of geine Water Quality2 shall issue NPDES
Permit No. NC0000272, for the Canton Mill, and medif3, draft its provisions to reflect all the
conditions of •' ^ F-b ^^ , +n84 a_^a inn sempreraise rronEc . Fmi this modification,
including the following specific wording.
I. Champion shall take such action as necessary to prevent their
contribution of true color from causing the true color at the North
Carolina/Tennessee State line from exceeding 93 50 true color units at all
flows equal to or exceeding 126 cfs (81.4 MGD, the seven-day, ten-year
low flow level) at the Hepco Gauging Station.
Compliance with this requirement shall be measured through a calculation
a of instream true color levels at the North Carolina/Tennessee state line by
the following equation:
91a=
0.224
Sly_ (W tP4/8.34) +((HEI-WTP. x__).
(-0.224 x LOG(FIE,)+ 0.781)
HE1 x 10
Where:
WTP�=Monthly average Waste Treatment Plant discharge color. (QU3
Calculated as the average of all daily loading values (pounds of true
color per day) for a calendar month.
For ease of reference, the language of the July 13, 1988 Final Decision Ordering
Paragraphs is included verbatim, with the modifications made on October 9, 1996 and by this
Amended Order denoted by overstriking for deletions and bolding for additions.
2 The Division of Environmental Management has been reorganized and NPDES
pemritting is now administered by the Division of Water Quality.

pppppp
7 .
WTPf=Monthly average Waste Treatment Plant discharge flow(mgd).
".r HEf = Monthly. average HEPCO, North Carolina flow, (MGD).' Daily
flow values less than 81.4 mgd shall be entered as 81.4 mgd.
Sly = Monthly average Instream true color at North Carohna/Tennessee
border(state line).
Dl.= Color concentration of all dilution streams (13 C.U.). r
The SL, shall be calculated on a daily asis for each calendar month.
The aveFage.of aay ealendar week (seven days) of ealeulate,7 SL. values
for each month shall not exceed 95 50 true color units. Any exceedance
of SS 50 true color units for this average value shall be considered a
violation of this permit/variance exeept as provided in item M of
1aEt--
II. The average daily discharge of true color for each calendar month
shall not exceed 258,945 125,434 pounds per day. The average annual
effluent true color loading shall not exceed 1'rr2,369 98,168 pounds per
day. For the purpose of this permit/variance only, "pounds of true color"
is calculated by the following equation:
Effluent Flow (mgd) x Effluent True Color Level (Platinum Cobalt Units)
x 8.34.
leading to less than 124,193 peupt per day.
Ill,. IV7 The method of analyses used to measure true color shall be
the procedure referenced in FR 39 430.11(b) (May 29, 1974).
3. The Division of Efwiranmenta4 Management Water Quality shall include review
of this variance as a specific item in its Triennial Water Quality Standards review, as required by
the federal Clean Water Act, and make appropriate recommendations to the NPDES Committee.
4. Champion shall continue to study, and evaluate, pursue and operate color
removal technologies and shall report its findings to the NPDES Committee and the Division of

EavkenmeaW Management Water Quality
r_ �, 7 n , .e _ accordance�ritfi the following schedulc

47
PPP"P7-
9 ..
DATE ACTB=
January 1, 1997 ::The Company will implement a one=year demonstration
of full scale bleach filtrate recycling.(BFRT"') technology
on the mill's pine line.
March 1, 1998 In conjunction with the scheduled Triennial Review of
_ N.C. Water Quality Standards the Company shall:
1. Submit a status report to the NPDES Committee
on the technical,,economic, and operational feasibility of
the BFRTm technology, including those analyses
prepared for other permitting agencies concerning its
effects on air emissions.
2. Evaluate and report to the NPDES Committee
on the application of end-of-pipe color reduction
technologies and additional minimization of color losses
from the manufacturing processes and raw material
storage areas. The evaluation shall include an
incremental color improvement analysis. This analysis
will concentrate 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 and
minimization efforts must look particularly at periods
of low river flow. The report will identify specific
economic and implementation issues associated with the
incremental improvement of color levels expected by
installing and adopting these technologies and
minimization efforts at the mill. The report will also
project the expected additional color reduction for each
technology and in-mill minimization effort evaluated
and the maximum color reduction possible using the
identified technology or action.
3. Champion will evaluate color reduction strategies for
further optimization of BFIff technology and report
on the feasibility'of implementation on the hardwood
line.

10 '
• ' u. .:.f. 1 'f .ef_ ,.. v ' _ •_.._V: r •F' . ,. _ r r:l +. ._ .
December 1, 1998 Based on the results af the d-em—anstr-afien pr-ojeet and
Champion will deeide and report an the deeislan to fully
implement and operate on a continuing basis the BFRT"
technology on the mill's
pineweed line., unless the Company can demonstrate to
the NPDES I Committee that BFR` is not a
commercially viable process at this location.
March 1,2001 Champion will evaluate and report on end-of-pipe color
reduction technologies in conjunction with the Triennial
Review of N.C. Water Quality Standards. The
evaluation shall include an incremental color
improvement analysis. This analysis will concentrate
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 must look particularly at periods of low
river flow. The report will identify specific economic
and implementation issues associated with the
incremental improvement of color levels expected by
installing these technologies at the mill. The report will
also project the expected additional color reduction for
each technology,,, evaluated and the maximum color
reduction possible'using the identified technology.
June 1,2001 Champion will submit a report to the NPDES
Committee and, N.C. DEHNR, Division of Water
Quality, on the'comparative evaluation of the above
collective efforts'as part of the Variance review process
(Triennial Review of North Carolina Water Quality
Standards).
5. The Division will provide a statu 1 s summary report on color removal at the Canton
Mill to the NPDES Committee and the Variance Review Committee allnually, en er be
Ame 30 of eaeh year, within 30 days of the availability of Champions' reports as required
above. The Variance Review Committee, utilizing the information available,will, by July

. 11 •
PPPPP�
1, 1998, and July 1, 2001, make recommendations to the NPDES Committee concerning
revisions io;the coior variance. ' I hose'r6comifiendations vrill:-include lower limits for the
monthly average and annual average color limitations applicable to the mill due to color
removal performance and the Committee's position on additional revisions needed in the
variance to reflect the application of BFRT , end-of-the pipe treatment, and in-mill color
reduction technologies. Based on the instream color data available at that time, the
Committee will also provide recommendations on the applicability of any instream color
compliance point in N.C. The NPDES Committee will review the available information,the
recommendations of the Variance Review Committee and the staff recommendations in
proposing any changes to the variance.
6. Following the rletiea and r
and In conjunction with theft subsequent triennial water quality standards reviews afteF
period, the Division will nominate a variance review
committee. The NPDES Committee will have final approval of the selection of this committee.
Whi 11 Committee membership may corisist of Natuml ReseuFees and Geffh amity
Develepraeat Department Staff and at individuals considered authorities on pulp and
paper technology or environmental aspects of that industry from the university or research
communities.' The Committee will also include in its membership a representative of
Tennessee's Department of Environment and Conservation who shall be appointed by the
Governor of Tennessee. That review committee's report and recommendation will be examined
by the NPDES Committee for a decision on the adequacy of the existing variance. The NPDES
' The Variance Review Committee membership qualifications are changed to provide
greater flexibility in appointments.

12
Committee will determine if changes in the variance are warranted due to the effectiveness of the
treatment-system or because of advances-in coloi'reducfion.techuolc giEs fa2.this type wasfewatef. .
All revisions adopted by the NPDES Committee will require the modification of the Company's
State NPDES Discharge Permit.
7. The variance proceeding, and the NPDES Permit No. NC 0000272, shall at-au
times be subject to reopening in order to modify the color requirements based upon ar3y the
following and in association with the required triennial reviews:
1) Any breakthrough in color removal technologies. Such breakthroughs shall be
brought to the NPDES Committee for consideration, by Champion and the Division of
b Water Quality, as soon as they are discovered.
2) An acceptable statistical analysis of effluent color discharge data
demonstrating significantly better color removal performance than that currently
prescribed in the variance and permit.
3) Successful application of end-of-pipe color reduction technology or in-mill
color minimization effort that results in significant and measurable reduced mass
color discharge.
8. This variance shall extend for an indefinite period of time, subject to
consideration of the three-year reviews and the annual repefts. aFA Any modification or
termination based thereon shall be subjected to the public hearing process required by G.S.
143-215.3(e).

pppppp�
13
It is further ORDERED that this Modification of Color Variance shall be effective as of
".The"effective(ia2e ii'Cue re-issueu'T11'i) 5 Perriit^I1u."Ni `0�?OU272`for ihe"i;hitioa-Mill;and the
terms of the previously existing variance shall continue in effect until that time.
NOTICE OF CONTESTED CASE RIGHTS
This Amended Order for Modification of Color Variance Granted on July 13 1988 is
made effective on the effective date of, and is issued in conjunction with, the re-issued NPDES
Permit No. NC0000272 for the Canton Mill. A person aggrieved by this Amended Order may
commence a contested case in accordance with G.S. 143-215.1(e), by filing a petition under G.S.
150B-23 within thirty(30) days after Champion International Company is notified of the NPDES
Permit decision. That date has been established as December 12, 1996; thus any contested case
petitions must be filed with the Office of Administrative Hearings no later than January 13, 1997.
:�; s 4

14
This the' of December, 1996:
m
aniel V. Besse, Chairman
NPDES Committee

ppppp�
15
CERTIFICATE OF SERVICE
This is to certify that I have this day served a copy of the foregoing AMENDED.ORDER
FOR MODIFICATION OF COLOR VARIANCE GRANTED ON DULY 13, 1988 on the parties
listed below by the methods indicated, addressed to each as follows:
William Clarke HAND DELIVERY
Roberts & Stevens
P.O. Box 7647
Asheville,North Carolina 28802
A.Preston Howard,Jr.,Director HAND DELIVERY
Division of Water Quality
N.C.Department of Environment,Health
and Natural Resources
9th floor,Archdale Building
Raleigh,North Carolina 27601-7687
Jennie Odette, Clerk HAND DELIVERY
Environmental Management Commission
N.C.Department of Environment, Health
and Natural Resources
9th floor, Archdale Building
Raleigh,North Carolina 27601-7687
Paul Davis CERTIFIED MAIL
Tennessee Department of Environment RETURN RECEIPT REQUESTED
& Conservation
6th floor, L& C Annex
401 Church Street
Nashville, Tennessee 37243-1534
David McKinney CERTIFIED MAIL
Tennessee Wildlife Resources RETURN RECEIPT REQUESTED
Ellington Agriculture Center
P. 0. Box 40747
Nashville, Tennessee 37204
Gary Davis CERTIFIED MAIL
Tennessee Environmental Council RETURN RECEIPT REQUESTED
1700 Hayes Street, Suite 101
Nashville, Tennessee 37203

16
i�
Mike McGhee CERTIFIED MAIL
TXie:u ,,W er •Zr.w_:e nunt
..,i.o..6Cr of"..�t.:a isiz.._g..i.utaa
100 Alabama Street, SW
Atlanta, Georgia 30303
Barry Turner CERTIFIED MAIL
Deputy Attorney General RETURN RECEIPT REQUESTED
Tennessee Attorney General's Office
450 James Robertson Parkway
Nashville,Tennessee 37243-0495
This the ffi!-day of December, 1996.
MICHAEL F.EASLEY
Attorney General
Daniel C. Oakley
Senior Deputy Attorney General
Environmental Division
P. O. Box 629
Raleigh,North Carolina 27602-0629
919/733-5725
/14287

State of North Carolina
Department of Environment,
Health and Natural Resources •
Division of Water Quality r
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary p E
A. Preston Howard, Jr., P.E., Director
December 19, 1996
John Hankinson> Jr.
Region IV Administrator I'
U.S. Environmental Protection Agency DEC 3 06
100 Alabama Street, S.W.
Atlanta, Georgia 30303 AS WATER UAi ;i-°c
t G;0
SUBJECT: Color Variance
Champion International Corporation
NPDES Permit NC0000272
Haywood County
Dear Mr. Hankinson:
As EPA requested, North Carolina re-evaluated the amendment to the 1988 water
quality standard variance for color issued to the Champion International Corporation
Canton Mill wastewater discharge approved by the NPDES Committee in October of this
year. Modifications to the variance were prepared further reducing the allowable discharge
load of color, explicitly describing the continued color minimization studies required,
strengthening the re-opener condition and specifically establishing that Tennessee would
have representation on the Variance Review Committee. Based upon staffs discussion
with EPA and Champion,the NPDES Committee approved the modifications previously
sent to EPA in draft at their December 10, 1996 meeting.
Enclosed are the documents pertaining to the adoption of the modification. I hereby
request that EPA approve the modified variance. Your prompt consideration of this matter
would be greatly appreciated.
Thank you for all the attention that you and your staff have devoted to this issue. If
you have any questions regarding the variance,you may contact Coleen Sullins of my staff
at 919/733-5083, extension 550.
Sin rely,
A. Preston Howard, Jr., E.
cc: Mike McGhee,Water Management Division Director,EPA Region IV
Harlan Britt,Deputy Director, Division of Water Quality
Steve Tedder, Chief,Water Quality Section
Dan Oakley, Senior Deputy Attorney General,Environmental Division
Forrest Westall,Water Quality Supervisor, Asheville Regional Office
Greg Thorpe. Assistant Chief Water Quality Section, Planning Branch
Colleen Sullins, Supervisor, Pemuts &Engineering Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10%post-consumer paper

ENVIRONMENTAL MANAGEMENT COMMISSION
IN THE MATTER OF REQUEST FOR ) AMENDED ORDER
VARIANCE FROM RATER QUALITY ) FOR
STANDARD-BASED EFFLUENT ) MODIFICATION OF COLOR
LIMITATI4) CHAMPION ) VARIANCE GRANTED ON
INTERNATI CORPORATION ) JULY 13, 1988
CANTON,NO CAROLINA )
THIS MATTER came on to be heard before the NPDES (National Pollutant Discharge
Elimination System) Committee at its scheduled meeting in Raleigh, North Carolina, on
December 11, 1996. on its own motion to amend its order, dated October 9, 1996, for
modification of an existing color variance which was granted to Champion International
Corporation on July 18. 1988.
Upon duly made motion and vote, the NPDES Committee hereby re-adopts its order,
dated October 9, 1996. and further adopts the additional, following Findings of Fact and
Conclusions of Law:
FINDINGS OF FACT
1) On October 17, 1996, the Director of the Division of Water Quality transmitted to
the United States Environmental Protection Agency, for its review, the October 9, 1996, order for
Modification of Color Variance Granted on July 18. 1988,
2) On December 9, 1996, the United States Environmental Protection Agency
advised the Division of Water Quality and the NPDES Committee, by letter from Regional
Administrator John Hankinson to Assistant Secretary Linda Rimer, that the modification of the
color variance with certain more restrictive clarifications to the order is acceptable to the agency.

z
3) The Division of Water Quality and Champion International Corporation have
advised the NPDES Committee that the changes proposed by the United States Environmental
Protection Agency are acceptable.
4) The following changes to the conditions of the modified variance are more
restrictive on the company, and are accepted by the NPDES Committee:
(Words recommended for removal are stricken through and additional wording is
in bold.)
Conditions identified below of the "Ordered" section of the October 9, 1996, order
of the NPDES Committee should be modified to:
CONDITION 2.II
II. The average daily discharge of true color for each calendar month shall not
exceed 132,341 125,434 pounds per day. The average annual effluent true color
loading shall not exceed 124,923 98,168 pounds per day. For the purpose of this
permit/variance only, "pounds of true color" is calculated by the following
equation:
Effluent Flow (mgd) x Effluent True Color Level (Platinum Cobalt Units) x 8.34.
CONDITION 4
4. Champion shall continue to study, evaluate, and pursue and operate color
removal technologies and report its findings to the NPDES Committee and the
Division of Water Quality in accordance with the following schedule:
DATE ACTIVITY
Gentiaeing
January 1, 1997 The Company will implement-a one year Cemmereial
demonstration of full scale bleach filtrate recycling
(BFRTm) technology on the mill's pine line.
March 1, 1998 In conjunction with the scheduled Triennial Review of N.C.
Water Quality Standards the Company shall:
1. Submit a status report to the NPDES Committee
on the technical, economic, and operational feasibility of
the BFRTm technology, including those analyses prepared
for other permitting agencies concerning its effects on air
emissions.

3
2. Evaluate and report to the NPDES Committee on
the application of end-of-pipe color reduction technologies
and additional minimization of color losses from the
manufacturing processes and raw material storage
areas. The evaluation shall include an incremental
color improvement analysis. This analysis will
concentrate 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 and minimization
efforts must look particularly at periods of low river
flow. The report will identify specific economic and
implementation issues associated with the incremental
improvement of color levels expected by installing and
adopting these technologies and minimization efforts at
the mill. The report will also project the expected
additional color reduction for each technology and
in-mill minimization effort evaluated and the maximum
color reduction possible using the identified technology
or action.
3. Champion will evaluate color reduction
strategies for further optimization of BFRTAf technology
and report on the feasibility of implementation on the
hardwood line.
F e and raw fnate:al
storage-
afeas.
December 1, 1998 Based _.. the result_ of the deems'-" `en ; Oad the
presented in the eenelusien of the status i:epeFt, Champion
will deside and . pei4 en the deeision to fully implement
and operate on a continuing basis the BFRTA4 technology
on the mill's pineweed line.,
unless the Company can demonstrate to the NPDES
Committee that BFRT"' is not a commercially viable
process at this location.
March 1, 2001 Champion will evaluate and report on end-of-pipe color
reduction technologies in conjunction with the Triennial
Review of N.C. Water Quality Standards. The evaluation
shall include an incremental color improvement
analysis. This analysis will concentrate 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
must look particularly at periods of low river flow. The

4
report will identify specific economic and
implementation issues associated with the incremental
improvement of color levels expected by installing these
technologies at the mill. The report will also project the
expected additional color reduction for each technology
evaluated and the maximum color reduction possible
using the identified technology.
June 1, 2001 Champion will submit a report to the NPDES Committee
and N.C. DEHNR, Division of Water Quality, on the
comparative evaluation of the above collective efforts as
part of the Variance review process (Triennial Review of
North Carolina Water Quality Standards).
CONDITION 5
5. The Division will provide a status summary report on color removal at the
Canton Mill to the NPDES Committee and the Variance Review Committee
within
30 days of the availability of Champion's reports as required above. The
"Variance Review Committee,utilizing the information available,will, by July
1, 1998, and July 1, 2001, make recommendations to the NPDES Committee
concerning revisions to the color variance. Those recommendations will
include lower limits for the monthly average and annual average color
limitations applicable to the mill due to color removal performance and the
Committee's position on additional revisions needed in the variance to reflect
the application of BFRr", end-of-the pipe treatment and in-mill color
reduction technologies. Based on the instream color data available at that
time, the Committee will also provide recommendations on the applicability
of any instream color compliance point in N.C. The NPDES Committee will
review the available information, the recommendations of the Variance
Review Committee and the staff recommendations in proposing any changes
to the variance.
CONDITION 6
6. In conjunction with subsequent triennial water quality standards reviews,
the Division will nominate a variance review committee. The NPDES Committee
will have final approval of the selection of this Committee. Committee
membership may consist of Department Staff and individuals considered
authorities on pulp and paper technology or environmental aspects of that industry
from the university or research communities. The Committee will-also include
in its membership a representative of Tennessee's Department of
Environment and Conservation who shall be appointed by the Governor of
Tennessee. That review committee's report and recommendation will be

5
examined by the NPDES Committee for a decision on the adequacy of the
existing variance. The NPDES Committee will determine if changes in the
variance are warranted due to the effectiveness of the treatment system or because
of advances in color reduction technologies for this type wastewater. All
revisions adopted by the NPDES Committee will required the modification of the
Company's NPDES Discharge Permit.
CONDITION 7
7. The variance proceeding, and the NPDES Permit Number NC0000272,
shall -�'itimes be subject to reopening in order to modify the color requirements
based upon the following and in association with the required triennial
reviews:
1. a Any breakthrough in color removal technologies. Such breakthroughs
shall be brought to the NPDES Committee for consideration, by
Champion and the Division of Water Quality, as soon as they are
discovered.
2. An acceptable statistical analysis of effluent color discharge data
demonstrating significantly better color removal performance than
that currently prescribed in the variance and permit.
3. Successful application of end-of-pipe color reduction technology or
in-mill color minimization effort that results in significant and
measurable reduced mass color discharge.
CONCLUSIONS OF LAW
1) On its own motion and prior to the effective date of the October 9, 1996, order for
Modification of Color Variance Granted on July 18. 1988.the NPDES Committee may amend its
October 9, 1996, order, to satisfy concerns of the United States Environmental Protection
Agency, to clarify its conditions and to make the conditions more restrictive on Champion
International Corporation.
Based on the re-adopted October 9, 1996, Findings of Fact and Conclusions of Law and
the additional, foregoing Findings of Fact and Conclusions of Law, it is hereby ORDERED that
the previously existing variance from the North Carolina water quality standard for color as

6
memorialized in the July 13, 1988 Final Decision Ordering Paragraphs, continues in effect as
hereby modified,to read as follows:'
1. Champion's petition for a variance is granted, pursuant to G.S. 143-215.3(e), as a
variance to water quality based effluent limitations for color.
2. The Division of MaMagement Water Quality' shall issue NPDES
Permit No. NC0000272, for the Canton Mill, and medify draft its provisions to reflect-all the
conditions of the Fekuafy, 1989 draft EPAeempi:emise NPDEo Ftmk this modification,
including the following specific wording.
I. Champion shall take such action as necessary to prevent their
contribution of true color from causing the true color at the North
Carolina/Tennessee State line from exceeding 95 50 true color units at all
flows equal to or exceeding 126 cfs (81.4 MGD, the seven-day, ten-year
low flow level) at the Hepco Gauging Station.
Compliance with this requirement shall be measured through a calculation
of instream true color levels at the North Carolina/Tennessee state line by
the following equation:
(RE') ,
(-0.224xL0GME,)+ 0.781)
HEf x 10
Where:
WTP,=Monthly average Waste Treatment Plant discharge color. (Q.4.�
Calculated as the average of all daily loading values (pounds of true
color per day) for a calendar month.
' For ease of reference, the language of the July 13, 1988 Final Decision Ordering
Paragraphs is included verbatim, with the modifications made on October 9, 1996 and by this
Amended Order denoted by overstriking for deletions and bolding for additions.
2 The Division of Environmental Management has been reorganized and NPDES
permitting is now administered by the Division of Water Quality.

7
WTPr=Monthly average Waste Treatment Plant discharge flow(mgd).
HEr = Monthly average HEPCO, North Carolina flow (MGD). Daily
flow values less than 81.4 mgd shall be entered as 81.4 mgd.
Sl, = Monthly average Instream true color at North Carolina/Tennessee
border(state line).
D,= Color concentration of all dilution streams (13 C.U.).
The SL, shall be calculated en a daily basis for each calendar month.
The everage e ,... ^_of lend week (seven ,le.,^) e f ealeulaied SL, values
for each month shall not exceed 95 50 true color units. Any exceedance
of SS 50 true color units for this average value shall be considered a
violation of this permit/variance exeept as previded :n item rrr of t ^
1�
II. The average daily discharge of true color for each calendar month
shall not exceed 258,945 125,434 pounds per day. The average annual
effluent true color loading shall not exceed 172,368 98,168 pounds per
day. For the purpose of this permit/variance only, "pounds of true color"
is calculated by the following equation:
Effluent Flow (mgd) x Effluent True Color Level (Platinum Cobalt Units)
x 8.34.
9-1- Champion ea ., reduee the Bail effluent ^lam
a te less than 124,193
II PA The method of analyses used to measure true color shall be
the procedure referenced in FR 39 430.11(b) (May 29, 1974).
3. The Division of gemen Water Quality shall include review
of this variance as a specific item in its Triennial Water Quality Standards review, as required by
the federal Clean Water Act, and make appropriate recommendations to the NPDES Committee.
4. Champion shall continue to study, and evaluate, pursue and operate color
removal technologies and shall report its findings to the NPDES Committee and the Division of

s
Water Quality
b_c- ^—Fi' 39 of eaeh yeaF in accordance with the following schedule:

9
DATE ACTIVITY
January 1, 1997 The Company will implement a one-year demonstration
of full scale bleach filtrate recycling(BFRT'") technology
on the mill's pine line.
March 1, 1998 In conjunction with the scheduled Triennial Review of
N.C.Water Quality Standards the Company shall:
1. Submit a status report to the NPDES Committee
on the technical, economic, and operational feasibility of
the BFRT"' technology, including those analyses
prepared for other permitting agencies concerning its
effects on air emissions.
2. Evaluate and report to the NPDES Committee
on the application of end-of-pipe color reduction
technologies and additional minimization of color losses
from the manufacturing processes and raw material
storage areas. The evaluation shall include an
incremental color improvement analysis. This analysis
will concentrate 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 and
minimization efforts must look particularly at periods
of low river flow. The report will identify specific
economic and implementation issues associated with the
incremental improvement of color levels expected by
installing and adopting these technologies and
minimization efforts at the mill. The report will also
project the expected additional color reduction for each
technology and in-mill minimization effort evaluated
and the maximum color reduction possible using, the
identified technology or action.
3. Champion will evaluate color reduction strategies for "
further optimization of BFRT"' technology.and report
on the feasibility of implementation on the hardwood
line.

10
I;III
December;1, 1998 =.�a 41��a
Champion will fully
implement and operate on a continuing basis the BFRT
technology, f "" ""'";" `"' "' ^^ •on the mill's
pinewood line., unless the Company can demonstrate to
the' NPDES' ,Committee that: BFRT"' is not a
commercially viable process at this location.
March 1,2001 Champion will evaluate and report on end-of-pipe color
reduction technologies in conjunction with the Triennial
Review of N.C. Water Quality Standards. The
evaluation':,,shall , include S; an incremental color
improvement analysis. This analysis will concentrate
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 must look particulirly­at periods of low
river flow.. •The .report„will.;identify-specific economic
and implementation issues associated With ' the
-incremental-improvement"of.color,.leVels ,expected by
installing these technologies-at thill.e m The report will
also project the expected additional•color.reduction for
each technology.�,evaluated and the-'maximum color
reduction possible using the,identified technology. -
June 1,3001, Champion will .submit , a, report„ to,,,the. NPDES
Committee and N.C. DEHNR, Division of Water
Quality, .on• the comparative evaluation,of'the above
collective efforts as part of the,Variance review process
(Triennial,Review,of North Carolina Water Quality
Standar&).
5. The Division will provide'a status summary report on color=removal at the Canton
Mill to tfie NPDES'Committee and the Variance Review Committee apnually, en ofI;PfeFB-
june ^^ of eaeh within'30 days of the adailability'of Champions';reports as required, '
above. The Variance Review,Committee, utilizing the-information available, will, by July

III Champion
�J ampion Internauonai Corporation
December 13, 1996
Ms. Colleen H. Sullins
Supervisor, Stormwater Group
North Carolina Department of Environmental, Health
and Natural Resources
PO Box 27687 [ 0 d D
Raleigh, NC 27611-7687
DEG 3 � 1996
Subject:: Stormwater Permit NCS000105
Champion International pp A ITYSEWON
Canton, NC WAVIRLEVRE010NALOFFICE
Data for 2nd year of permit
Dear Ms. Sullins:
As required in Champion's stormwater permit (page 7, 2.d.) samples analyzed in
accordance with the terms of the permit shall be submitted no later than January
31 for the previous year. Attached is the data for the year of 1996.
The cut off concentration has been met for BOD at No. 3 outfall, COD at
No. 9 outfall , TSS at 5C-17 and 6-10 outfalls and fecal coliform at No. 1
Outfall . These outfalls will be sampled again in the last year of the permit.
If you have questions or need additional information, please call
[phone] or 646-2255.
Sincerely,
LouiestJ William Chapman
Sr. Environmental Engineer CEM Maintenance Technician

Champion Internation ooration
copy: Mr. Roy Davis
North Carolina Department of Environment, Health
and Natural Resources
Water Quality Section
t 59 Woodfin Place
Asheville, NC 28801
Mr. William Manzer
Vice-President-Operations Manager
Champion International Corporation
PO Box C-10
Canton, NC 28716
c:\flj\doc\strwate\monrpt96.doc

STORMWATER DISCHARGE OUTFALL(SDO)
MONITORING REPORT
PERMIT NO.NCS 000105 SAMPLES COLLECTED DURING CALENDAR YEAR: 1996
(all samples collected during a calendar year shall he reported no later than
January 31 of the following year)
FACILITY NAME COUNTY Haywood
PER A SON C01,1,1?CTINC MPLF(S)_ 7 1 am a haom ll PHONE NO.( 704 ) 646-2318
CERTIFIEDLABORATORY(S)_Hydrologic Lab# 47
Lab# (SIGNATURE OF PERMITTEE OR DESIGNEE)
By this signature,I certify that this report is accurate
Part A:Specific Monitoring Requirements complele In the best of my knowledge
Oulfall 'I DatC y tf i MR 501150 W;' i i
No: SamDle`:> .Total p C mom; h 4 e L
Collected Flow a 0. . coed o f�i fo.rtn ":
r` m o/d il/ r a MG a r '1°col• 100
9-2 -96 0,0100 500-0
2 6-4-96 0,3328
3 6-4-96 0,3586 0 460
4 9-2 -96 0 0 23 762.0
5 9-
6 5-6-9
7 5-6-96 0,7308
8 5-6-96 0,0438 176.0,
9 5-6-96 0,0002 0
5B-20 9-2 -96 0,0269 11 .6
6-4 9-2 -96 00034 90 0
Page I of 2
Form MRNCS

Does this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?_yes -.no
(if yes,complete Part Il)
Part It: Vehicle Maintenance Activitv Monitorine Re uirements
Ou/fall Date, : s E. 50050 - 00556:' 00400
01051 38260
No. Sample Total Flow Oil and Grease Lead, Total Detergents pH New Motor Oil
F, Collected <;: @! Rcrnverablel• ' (MBAS)2 Usage
mo/dd/ rrtc�: MG•x m ugn m unit al/mo
No vehicle maintenance activity conducted within any stormwater drainage area
Footnotes:
I Applies only for facilities at which fueling occurs.
2 Detergent monitoring is required only at facilities which conduct vehicle cleaning operations.
\STORM EVENT CHARACTERISTICS:
Dale 5-6-96 Date : 9-a1 �6 Mail Original and one copy to:
0,26
Total Event Precipitation(inches): inches) Attn: Central Files
Event Duration(hours): 7,33 1 .75 hours) DEIINR
Division of Environmental Mgt.
(if morg tlenffe storm event was sampled) P.O. Box 29535
Date Raleigh,NC 27626-0535
Total Event Precipitation(inches): 0.14
Event Duration(hours): 0 25
"I certify,under penally of law,that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person
or persons who manage the system,or those persons directly responsible for gathering the information,the information submitted is,to the best
of my knowledge and belief,true,accurate,and complete. 1 am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
(Signature of Permiltec) (Date)
Page 2 of 2
Form MRNCS

Canton Mill
Box C-t 0
Canton,North Carolina zan e
Champion
Champion International Corporation �jf
December 18, 1996 wqF O
�yEVrE�EPlrq(�
FF�
Mr. Billy Ray Cameron
NC Emergency Response Commission
NC Division of Environmental Management
116 West Jones Street
Admimstratton Building
Raleigh, NC 27603-1335
RE: Release of Sodium Hydroxide on December 17, 1996.
Dear Mr. Cameron:
Champion International is providing written notification of a release 3760 pounds of
sodium hydroxide at the Canton Mill on December 17, 1996 at approximately 1:12 pm
EST. The spill occurred as a result of a check valve cracking upon start up of Brown
Stock Washing System. The material containing sodium hydroxide was contained on a
concrete pad and drained to the mill's NPDES permitted wastewater treatment plant. The
spilled material was neutralized once it entered this system with no adverse impacts to the
treatment system. Additional information concerning the release is attached.
If you need further information, please contact Robert Kahle at [phone].
Sincerely,
T
Robert Kahle Jim Giauque
Advanced Environmental Engineer Advanced Environmental Engineer
Attachment

copy: Mr. Keith Haynes
Environmental Specialist
Division of Environmental Management
Water Quality Section
59 Woodfin Place
Asheville, NC 28802
Mr. Nolan Palmer
Haywood County Emergency Management Commission
2143 Asheville Road
Waynesville, NC 28786

NOTIFICATION REPORT FOR
SPILL/RELEASE
1. Name of Chemical: Sodium Hydroxide
2. Is substance an Extremely Hazardous Substance?: No
3. Caller's Name and Position: Robert Kahle
Advanced Environmental Engineer
4. Company where release occurred: Champion International
Corporation
5. Address of company, including county: 175 Main Street
Canton,NC 28716
Haywood County
6. Media into which release occurred: Concrete, then to mill NPDES
Permitted wastewater treatment plant
7. Quantity released: 3760 pounds
8. Date, Start and Stop of release: 12/17/96
from 1:12pm to 1:26pm EST
9. Causes and sources of release:
Start up of the No. 1 Fiberline Brownstock Washing System resulted in a dilution
pump "hammering'; which caused the adjoining check valve to crack. The pump
draws weak black liquor containing sodium hydroxide from the No. 1 Seal Tank.
The spilled material was contained on concrete and drained via a u-drain to the
mill's wastewater treatment plant where it was neutralized.
10. Action taken to respond to release and status of actions:
The release was stopped by closing a manual valve located inside the building
adjacent to the pump. The wastewater treatment plant personnel were notified.
No adverse impacts on this NPDES-permitted system were identified. Also, there
were no off-site impacts. The check valve was replaced and the area around the r
spill was washed up with a water hose.

11. Other notifications made:
National Response Center; December 18, 1996, 9:00 am EST to Mrs.
Sanchez. Report 9370801
U.S. EPA Region IV Emergency Response Hotline, December 18, 1996,
9:03 am EST
NC Division of Emergency Management; December 18, 1996, 9:07 am
EST to Mr. Keith Haynes
12. Any injuries?: No
13. Name and telephone number of person to contact for further information:
Robert Kahle [phone]
14. Action taken for clean-up:
Area around spill was washed up using a water hose and draining to the
wastewater treatment plant.
15. Does release require written notification under Section 204 of Emergency
Planning and Community Right to Know Act (Title III SARA)?: NO

bxc:
John Bengel
Derric Brown
Bob Cicale
Louie Justus
Bill Manzer
Pete Maxey
Bob Williams

GJCS-fa t ( q ) t��
Tennessee Wildlife Resources Agen
Ellington Agricultural Center
P.O. Box 40747
Nashville, Tennessee 37204
DEC 10 1996
December 7, 1996 WAr
�ECTUAI/TY
Reeistered Mail
Ms. Beverly H. Banister, Acting Chief
Water Permits and Enforcement Branch Q L
Water Management Division 0
U.S. Environmental Protection Agency, Region IV
100 Alabama Street, SW L—O -
17 M
Atlanta, Georgia 30303
WATER ELI MSSECfiON
Mr. Steve Tedder, Chief ti I REGIONAL OFF;CE
Division of Environmental Management
Water Quality Section
P.O. Box 29535
Raleigh, North Carolina 27626-0535
RE: Formal Objection
Draft NPDES Permit and Variance
Champion International Corporation
Canton Mill, No. NC 0000272
Haywood County, NC
Dear Ms. Banister and Mr. Tedder:
On November 13, 1996, the Tennessee Wildlife Resources Agency contacted you by
certified mail to advise you that on November 8, 1996, we received for the first time
a copy of a final draft NPDES permit for Champion's Canton, NC, paper mill. We
requested confirmation that we would have a minimum of thirty (30) days to review
the draft and provide comments. As of this date, we have not had the courtesy of any
return correspondence.
This correspondence is a Formal Objection on behalf of the Tennessee Wildlife
Resources Agency and the Tennessee Wildlife Resources Commission to both the
variance and the final draft NPDES permit as proposed by North Carolina.
1. On June 6, 1996, we provided North Carolina with both oral and written
objections to the proposed variance and draft permit during the public hearing in
Waynesville, NC. As of this date, we have not been notified in writing by North
Carolina of failure or refusal to accept our recommendations or of any rationale

rOR ' ? �.

Ms Beverly Banister
Mr. Steve Tedder
December 7, 1996
Page 2
for such failure or refusal, as required by the Clean Water Act at 402(b)(5). We
incorporate and continue herein our objections, comments and recommendations
of June 6, 1996.
2. Having observed the Pigeon River in Tennessee for the past thirty-six (36) months
under conditions of sustained NPDES permit compliance by Champion, it is
obvious that color in the Pigeon River during summer and fall continues to violate
Tennessee water quality criteria of "...no objectionable color." The 50 True
Color Limit as proposed for the Pigeon River at the TN/NC state line is wholly
inadequate to protect the Tennessee water quality criteria for color during
summer and fall.
3. Recognition by the North Carolina Variance Committee that 50 True Color Units
results in sufficient instream color to require a variance from water quality
standards is conclusive that such color is objectionable. By inclusion of such a
variance into the NPDES permit, North Carolina in fact utilizes the permit as a
vehicle to extend a North Carolina variance to thirty (30) stream miles of waters
of the State of Tennessee, resulting in the continuation of objectionable color in
the Pigeon River.
4. Champion is responsible for contaminated sediments in Waterville Reservoir and
resultant contamination of fish in Tennessee. Champion should be required to
begin the process of understanding the behavior and likely long term impact of
contaminated reservoir sediments on the Tennessee portion of the Pigeon River
5. Both the variance and the draft NPDES permit are devoid of requirement that
Champion further reduce color in the Tennessee portion of the Pigeon River. We
conclude, as did our June 6, 1996 comments, the final draft permit requires no
further advancement in color removal, maintains the Pigeon River in its current
objectionable condition, and is unacceptable.

Ms Beverly Banister
Mr. Steve Tedder
December 7, 1996
Page 3
Please enter this correspondence into the variance/permit record. Your time and
consideration in this matter are greatly appreciated. If you have questions or need
additional information, please contact me at 615n8l 6643.
Sincerely,
G
Aubrey D. McKinney, Chief
Environmental Services Division
cc: Mr. Paul Davis
Mr. Barry Turner

c�
December 16, 1996
Mr. Roy Davis
Asheville Regional Office
Division of Water Quality
Interchange Building
59 Woodfin Place
Asheville,NC 28801
Dear Roy:
As requested, enclosed is a copy of the forthcoming article, "The River and Time: Pigeon's
Toxic Past",to be published in the Forum for Applied Research and Public Policy. Please call
me if you have any questions.
Thanks.
9!9 �� 2 3sso

DEC la '96 05:46 'ERATIONS & EM/IROWIENT SLPPO?T PA
FAX TO: Roy Davis
FROM: Buzz Bryson
SUBJECT: Requested Address
Mick Grecson asked me to send you the attached cover letter we received with the article in the
Forum for Applied Research and Public Policy_ Please call me at(919)362-3551 or Mick at
362-3550 if you have any questions.
Thanks. And Merry Chris n,as
r
r

i
DEC 18 196 05:46 'EP,ATIOIS & E�IR014MENT SLPPORT - P.2
K&Wp ke kf
Ad,yno R.I.wx Hook
■.■. FOR ,M
flute IL'Jya Nufvaal Lakratary U
Mu:rox BussEu
Urvu,veyw RaaQare
£,Rroad,t ava.rl
1N uRRe mGE FOR APPLIED RESEARCH AND PUBLIC POLICY
l i"i,1"rtmnn,1I
LINDA C CAM
Oak Rid,xyia.al rpkyyrvy
AbleRiafnuanl
G11=2 AIPIW
AIW IaW"y kd
RICHARD IL R"I^411SRR
xma" 1py H�VhJ*RM'C
SAND
SANDRAS 6K� November 1, 1996
3 1 Iluiuemly
clrnr.Ltrs emtc -
fr°enaaxm.a rlafgm'y .
NORMAH BERG
Awnlam IEnA dTmr
&°r B`e"B`�">bN-.,k®.fau,;m�a George Oliver
Carolina Power & Light Co,
elAnvavaaooxs Raleigh, NC 27602
rra,.a.d vaf.,r,;ry
lf000tT D.EULfA/lD
cla A1lmmlAaacrRy Dear Dr. Oliver:
BEYPAILY A.OGLER
Jkrtrtayfw�tla Seat°M�iveaairq
B.A,s.c,.ARB lease find an advance
WAS,G.[°a SfNa Enclosed UrtA\ p copy of an article
RAY CLARN that will appear in an upcoming edition of Forum for
awnrtr va Brtvl.Dyal1ty
p.N)I.LIAM CV LDLA'LIKtt [applied Research and Public Policy: "The River and Time:
MamavrAea.f�.a4:n---, pigeon' s Toxic Past, ' by Richard Bartlett.
nORSxr w y>U
Nra,,,,mfa a"rfRrtx
vrR.Ix xaeor AM yDix. I hope you find the article of interest, I also
M.r.7✓R.rrfcr R.rq
Me you would consider pret:laring a brief {250 to 500
ICAIu(.5 Mimh.1IuMriE k
words] -letter-to-the-editor based on the author's ,
9.nA'r,a1C.wnpOOm�Dy&4er observations. For possible publication in a subsequent
RUCHRUMADIInN edition, we need to receive copy by February 13, 1997.
wr1T w mAmYa°yA..emr.a
ApCR-M IL XeCH r
MCA.a` ` I have enclosed a recent edition of Forum for. your
Wh AWhx Na,iaaarretro,aeap review which contains some previously published letters-
IONAMANxN( FS
oahrrai,mrrrrN fdwfma to-the-editor. if you have any questions or would like
IRRIQLN Un( 1tYmnry m
- I additional information, please contact e at
RATxnrnlI.uRsox (423) 974-4251.
rgnnnmc 15�iy,Lxbnny
LO[ILS1.LAxgyxeJrin
A24T9rrfLabda»ra Sincerely,
IE.I.ux MADRweEiM
.AuvrAmnu(bRpn Oaniekchaffer
NAPIERTI=MYNOYBLLR
MUCH rlAsafxl
Rrnc:Marr P"WerF,N:AMrurc Editor-in-Chief
ALLAN G.rumipum 1✓ ''
�,ivw SmN Dai,crsily '
rt wRII.&hA'm�.y DS/Cbg
UAVIrMREILMLtw`'rlaAvawy Enclosures
I:x881ann.nicHmottD
Aaweiun4 NF.ara Uxiueasrmc Lac
JAIM
n.r MA.Il[M
Npp lywv
SMART A.ROSENFIRM
ItrgNmlTWnx.Ia,gIH
d5rur<y'Ire.Le:
R.NEIL SAMPSON
Aana Z&,"AM.Aal e
PRANCPS R SHAMES
G,A R'v{rsiAtiavlfaWnlorp N 6dirfvipl Offim;Energy,EnvGonrneai and Eewwws C; Ier,Tim Uaivr s4 d TLnncasec,Boo Healey Sir.,Suite 311,ftnoxvillS
M ANSON YAN FLEET TN 379964134,Teluphoau(423(9744Z51,Pax(4231 974,8491,a-mail:[e-mail]
fYnw.nimti,m A mriutc
ON.dBR'1'8 Y,nrrE ■ 8usineaa Olflcer Executive 5denees Instltute,1005 Misulu i Avenue,Davcn ort,IA 52803,Tile hone(319 324.4463
.Inaa.,.Rywczfmma iPP P n 1
1'XOAUBI.WILEANxS m
rra Rxr�r Am;,.Armea,mary n Publication oJOah kud'e NrLionaf laboratory and The Univeniy a77krBttuee's Sfarg;EnvirurRnwl and RGtaare[4 Can[rr �3Y
1

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I.
II__
..xussRLL ■ V RU IVp✓J 1�A r
aia,d•1nwN � 12i
N➢hRR WBDf FOR APPLIED RESEARCH AND PUBLIC POLICY
LINDA C G W
DL RmW.AtVi°W 14bW1.V
6N'hma/DuvN
C20MRAIMY
AII/CAy ",,ra
HICIIAROaR JILSRR
Nttlnu Ip.yr R yuaA Mr•Mrc
UNDRS.Rl STS Abd,—wl. November 1, 1996
lln y
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AwYlxe R,nles4 r)Ax
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A1i°ni v.irvulr
IIARYRY BROOKS
ua,�e IA.r,e,;y
HOtnmr D.BuL
crmtnlm,°u,°.s.,Ry
REvMY A.CIGUR
nrt,�s,va,sam 1Ari.°,.iy
B.Km .wvu p copy of an article
tm. GerMA,m.uAAr Enclosed lease find an advance
HAY ClARA that will appear in an upcoming edition of Forum for
c.,rwwRnvic p,mRy
E.WILLIAM L'f,LeltA= Applied Research and Public .Po2jcy. HThe River and Time:
HORRKI Aw1 A W A'NI rrc4'°ryaA"""` Pigeon' s Toxic Past, • by Richard Bartlett.
NU '
11Nwnm/a Mr Nner
SM.I.IAM fulAtHand
ndn,lwinvr la 6x.•a I hope you find the article of interest. I also
adsW.GIL' hope you would consider orenarin a brief {250 to 500
BS W. ILTMIBR
.irR•e Ttlmhw mvirr.N words) 1Ptter-to-the-editor based on the author's
OIUHLEs coaunun
s•rrHrfA cay.�ys,.rti.. observations. For possible publication in a subsequent
xveKn;' �.�N edition, we need to receive copy by February 13, 1997.
M)CNAFL U.HICH r
Nlrnc,l.s. ` I have enclosed a recent edition of Forum for your
dR lr n.NIRS'r �
"°""�•""°°" °� review which contains some previously published letters-
ii;niaiirRnrRmawfirtl, to-the-editor. If you have any questions or would like
LP.LINARI] HYMAN additional information, please contact me at
RATHnvN AURsoN (423). 974-4251.
Y,.na..°eda�ra,ro„Ry
1A11LS .LAx4RHITrp
"M �l/w w°^ Sincerely,
BuBU MAC.Em I➢IM
SwrlAMiu,C41YH° .
TSD NAPI➢N
Ohm 4°lr ffuirT,eT/
TIMERYNOYRLLR
Rud«
n3ucx r,nsRaanxCKI Mu°Lyy„°.I Oanie#1 Schaffer
RAaalc,r PoWMh,dn Mi,u,r Editor-in-Chief
AI G.rUUIPIIM
4�4;iwn.9t,m Ucnr,ily
8 BwUNTOUR r N DS/cbg
URNID HER'HLB Enclosures
JoL A.ke Natianef GEavtvy
CHE312RR nICI1MOIID
4"vsiume W61,.c VnirrNi4,r,/ '
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FRANCES H SRAKrLn
rhv<Hid"`^t",°",/adni'°'I' ■ 6ili,orial Uijce:Energy,EnvirOluueal and Aeaou,cHs CuDley The llnivcrnity uF'hmlB3ce,e0o 1{Lv]Ly Sir.,Suite 311,1CDeravillt
hlAN90N YnN FLRer TN 379964134,7L•lc hoax 4E1 974-4251,Fa: 423 974-8491,a-mail:Ibmm@cera¢w.utk.edu ILn. druGw,l�orut P I ' I I 1
VI I.88h'1'P.wHrrR ■ ewinen office.,Executive Sameas lnstltute,3006 MI,d"ippl Amiuc,Davmpost,1A 52803,7hlephond(3191 324-4403
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,xD Htkr AV,IimlfuAwaurT A Publicarion o(oak RickE National ZaboralnTy and 77Ke University ol7bimrstee's Rwgy,SAvimu tand Re umas Canter

In the early 20th century,after
a brief period as a mountainous
retreat for some of the nation's
wealthiest families, pulp and pa-
per manufacturing supplanted
tourism as the Pigeon River
basin's primary industry. In fact,
Champion's Fibre Mill was prob-
ably the largest pulp mill in the
world when it became operational
in I908.
If we include purchases of
wood and other locally produced
products used in the manufacture
of pulp and paper, this industry
dominated a region far larger than
the area defined by the basin
WN itself. Meanwhile, the damage
done by the mills' liquid effluent
defined a larger region still, ex-
The River and Time. Carolinng aintoCobout 65 keCoes rnty,Teom Ten-
nessee.
into Cocke County,Ten-
Pigeon's Toxic Past neInt
In the late 19th and early 20th
centuries, cash income was des-
perately needed by the mountain
people of southern Appalachia.
Richard Bartlett is professor emeritus of history at Florida State Expanding families and shrinking
University in Tallahassee, Florida. patrimonies ensured a diminish-
ing agricultural base. As a conse-
quence, cash was scarce, educa-
The 660-square-mile Pi- continuing through the county tion poor, and medical facilities
geon River basin in west- seat of Newport (population inadequate.
ern North Carolina and 7,000), to its junction with the By the early 20th century,
northeastern Tennessee includes a French Broad. Just beyond, the mountain people were in desperate
spectacular gorge, high moun- French Broad River runs into need of a stable economic base.
tains, and lush timber stands.I artificially created Douglas Lake. Enter the pulp and paperindustry.2
North Carolina's Haywood This well-watered, richly for-
County, home to 47,000 people, ested mountainous region would Propensity for Pulp
boastQ.8 peaks rising 6,000 feet seem to be ideal for a flourishing
above ea level. It receives 50 tourism industry. In fact,along a By the turn of the last century,
2`\ inches of rainfall each year that 5-mile stretch through Cocke the exploitation of Appalachia's
help fill several freshwater tribu- County,Tennessee,the river cre- natural resources,especially coal
taries, all but one of which flow ates rolling rapids that spawn and timber,had been progressing
\113`,, into the Pigeon River. some of the nation's best for several decades. Concerns of
From there, the Pigeon River whitewater for rafters, kayakers, the region's few conservationists
flows across the state line into andcanoeists. were muted. In fact, state gov-
Tennessee's,Cocke County. By Until recently, however, the emments either ignored the ex-
the time it reaches the tiny mu- river's usefulness as a recreational ploitation or,more likely,encour-
nicipality of Hartford(population resource has been limited because aged it. Indeed, when the paper
500), the river flows placidly, of the pollution its waters carry. industry expanded at a phenom-
88 FORUM FOR APPLIED RESEARCH AND PUBLIC POLICY/WINTER 1996

a - 4
r
enal pace at the turn of the cen- who needed a steady source of ent carried off by the Pigeon
tury, and pulp and paper entre- pulp for his Champion Coated River.
preneurs cast covetous eyes on the Paper Company in Hamilton, Thomson had settled on Can-
great forests of Southern Appala- Ohio. By 1905, he was actively ton because land was abundant
chia,state governments were there purchasing thousands of acres of and available, as were the pure
to help them exploit the resource. North Carolina timberland. He waters of the Pigeon River. Be-
The behavior of North Caro- also was surveying eastern Ten- yond that, he had already pur-
lina's state government typified nessee for a suitable location for chased thousands of acres of tim-
such cooperation. In 1901,Colo- his proposed mill. ber, which were ready to be cut.
nel S.A. Jones of Waynesville Many still believe that Thomson The Southern Railroad reinforced
secured passage through the faced no opposition in locating his Thomson's choice of Canton by
state's general assembly of an"act pulp mill,but that was not the case. agreeing to haul wood and fiber
to encourage the building of pulp In fact, handed-down stories in and construct necessary trackage
and paper mills and tan- Cocke County,Tennessee,relate at a reasonable cost.
neries in the counties of Haywood how he approached some of the In the 1900 U.S. Census, Can-
and Swain." The act stipulated: county's large landowners for the ton boasted a population of 230
that every corporation, com- purchase of land along the French residents. By 1910, two years
pany,or firm who may expend Broad River for his mill. Though after the mill became operational,
one hundred thousand dollars environmentalism had yet to be the city's population had grown
in establishing a factory to con- bom, these landowners knew of to 1,393.1
vert wood into wood pulp shall the stench and dirtying of the wa- Though Thomson had won the
not be subject to any criminal
prosecution for the pollution ter that would accompany pulp North Carolina legislature's
of any watercourses upon production, and so, as the story blessing, he was not finished
which such factory or factories goes, they refused to sell.4 safeguarding his business. The
are located,and the measure of What little opposition that sur- legislation merely protected his
damages to the owner or own-
ers of lands overwhich the wa- faced, however, was of minor company from injunctions that
ter flows from such factory or consequence in the face of the could halt production; thus
factories shall be confined to overwhelming support and enthu- Champion Fibre was still vul-
actual damages, to be ascer- siasm for the mill. In fact, a bid- nerable to lawsuits.
tained as provided by law. dingwarof sorts began,with vari- To protect himself from legal
The act goes on to say that, in ous localities offering themselves action, Thomson sent his agents
case of a lawsuit, the company to Thomson. The mill could be downriver as far as the mouth of
could file a bond and in so doing located in Cocke County, the Jonathan Creek knocking on
was relieved of any threat"of re- Newport Plain Talk editorialized doors of nearby residents and
straining order or injunction." In in early 1906, "if the people act obtaining their signatures on a
other words,while a lawsuit was promptly. The entire county document"releasing Mr.Thomson
underway,operations could con- would be greatly benefited." and his heirs...from damages on
tinue.' The newspaper, in fact, urged account of the pollution of the
Such favorable legislation the county's Board of Trade to waters of the Pigeon."
came about because rumors were pursue the mill "with all haste Prosperity was on the way to
rife that a paper manufacturer was and energy possible."' Haywood and adjoining counties.
studying the area as a potential In fact, the rumble of prosperity
site for a pulp mill. Indeed,com- Carolina Wins Out reached as far west as Cocke
mon knowledge at the time held County, Tennessee. Lumber
that pulp and paper industrialists At it turned out,Cocke County camps on Champion land em-
or their agents were investigating did notgetthemill;thathonorwent ployed scores of laborers. Inde-
the lay of the land,forests,rivers, to Canton, North Carolina, 60 pendent farmers cut their stands
railroad facilities,and labor force. miles upstream. In fact,all Cocke oftimber to Champion's specifica-
One of the tycoons investigat- County received after the plant tions,and the company paid them
ing the area in 1901 was Peter G. became operational in 1908 was cash for their wood. Employees
Thomson, an Ohio industrialist the colored,foamy,smelly efflu- at the huge mill received steady
BARTLETT: THE RIVER AND TIME: PIGEON'S TOXIC PAST 89

• - r
paychecks,and the pay was good. W. Hooper, who had been born tently below the 50-unit color
Economically and socially as in a cabin overlooking the Pigeon limit required by Tennessee law.
well,the coming of the Champion River,promised to push litigation The water does not smell as bad
mill was a boon for the region. during his term of office (1910- asitdidinthepast,norisittopped
Only the environment suffered, 1914). Despite his pledge, anti- with as much foam.
and in the climate of opinion of pollution legislation never materi- How does it happen that today
1908, the people of Haywood alized. the Pigeon River flows cleaner
County and North Carolina ac- In the pages of the Newport despite decades of Champion's
cepted the stench and the pollu- Plain Talk of April 18, 1912, the denial and recalcitrance? Did the
tion as a suitable trade-off. They sinking of the Titanic took sec- states of North Carolina and/or
were delighted and proud to have and place to a Champion an- Tennessee bring this about? Did
the new industry in their domain. nouncement that the company was a popular uprising of environ-
The Pigeon River System is an making massive changes to cut the mentalists force Champion's
interstate waterway, originating pollution even though the com- hand? Was the federal Environ-
high in the mountains of North pany insisted the effluent was mental Protection Agency(EPA)
Carolina and flowing across the harmless in spite of the stench, instrumental in forcing the clean-
state line into the Volunteer state. the color,and the foam. Regard- ing of the Pigeon River?
Before the Walters' project, less of Champion's claims, the No. In fact, none of these fac-
which dammed the Pigeon and pollution continued.' tors turned the tide. Champion
created Waterville Lake in the late The company litany continued was motivated more by an inter-
1920s,the polluted Pigeon River for decades: The pollution was est in modernizing and boosting
flowed unrestricted into Tennes- nontoxic and harmless; the com- its plant's efficiency than by
see and through the heart of pany was doing everything to cleaning up after itself. Some
Newport. For decades,pollution limit it; and when new technol- observers predicted that the
was so bad that Cocke countians ogy was developed, Champion company's modernization pro-
dubbed the Pigeon the "Black would use these advances to cut gram would cost the region 300
River." the pollution. to 500 jobs. However,as of Feb-
In addition to its offensive Not until 1983, 74 years after ruary 1996, Champion had an-
color,the stench,especially on hot its initial attempt, did Tennessee nounced less than 65 layoffs"
summer days,was almost intoler- mount a strong legal case against Indeed,a cleaner Pigeon River
able,and the foam was sometimes Champion. North Carolina, is little more than a fortuitous
two to three feet thick. Few in- which continues to reap the finan- byproduct of Champion's yen to
dustrialists wanted to establish cial benefits from the pulp mill, update its plant.
factories along such a stream,and sided with Champion and has It is a fact that improved tech-
tourists took one whiff and packed continued to do so. nology aimed at efficiency and
their suitcases. economy in the pulp and paper
Guided by their disgust over Pigeon River Today industry usually results in less
the condition of the Pigeon,Ten- pollution. This is especially true
nesseans voiced their protest. Today, more than 80 years af- at Champion's new oxygen-
Time and again,state representa- ter the mill opened,the waters of delignification process, which
tives,usually from Cocke County the Pigeon flow substantially reduces but does not eliminate
and Newport, introduced bills in cleaner, though still not clean chlorine-derived effluent.
the general assembly imploring enough. The water's brown hue, Scientific investigations have
the attorney general to bring suit measured in color units near the a place in the story because the
against Champion for damages. Tennessee line, differs greatly effluent, long described by the
In 1909, just a year after the from day to day and would differ company as harmless, has been
plant opened,the attorney general from hour to hour if measure- proven extremely toxic. More-
promised to bring suit against ments were taken that often. over, most of the cutting-edge
Champion but failed to do so be- In the past,measurements com- scientific research on pulp and
cause of lack of funds. Ten- monly read as high as 200, but paper mill toxins continues to be
nessee's colorful Governor Ben today they are registering consis- negative. This is especially true
90 FORUM FOR APPLIED RESEARCH AND PUBLIC POLICY/WINTER 1996

of the breakdown of chlorine, a bleaching technology would be will be granted, but all signs are
chemical used heavily in paper used at the Canton mill. Accord- that Champion will continue its
bleaching. ing to the company's news re- efforts to clean the river. Mean-
Throughout this process,envi- lease,the new system,at a cost of while, the future of Haywood
ronmentalists—locally the Pigeon up to $30 million, should further and Cocke counties looks bright.
River Action Group, the Dead clean the Pigeon River.' The climate of opinion con-
Pigeon River Council, the Foun- What of the people of the Pi- cerning uses of the Pigeon River
dation for Global Sustainability, geon River basin? Tourism is has changed, and a new era is be-
and the Izaak Walton League— clearly taking a more important ginning for the people of the Pi-
have maintained a drumbeat of place in the region's psyche,and geon River basin—one in which
protest, some since the mid- certainly in its economy. Tourist economic developmentand envi-
1980s. Yet,there is no proof that shops now line the main street of ronmental protection will proceed
this sustained opposition moti- Waynesville. Folkmoot,an inter- hand in hand.
vated Champion's corporation national dance festival, is held
officials to launch the plant's every summer in Haywood SEEN
modernization scheme. County. There is an annual vin-
When Tennessee began litiga- tage car meet, balloon rallies at NOTES
tion against Champion in 1983, Maggie Valley,and plans for the
the situation had changed drasti- Smoky Mountain Railroad to en- 1. For a fuller discussion of the
cally since the first demand to sue ter Waynesville. issues raised in this essay, see
Richard Bartlett, Troubled Waters:
in 1909. One difference was the Whitewater rafting, always a Champion International and the
stable of rules and regulations to potential tourist attraction, has Pigeon River Controversv (Knox-
which the mill must adhere. When come into its own for two reasons. ville: University ofTennesseePress,
North Carolina ignored its own First, Carolina Power and Light 1995).
regulations by issuing variances, Company, the local utility, now 2. Ronald D. Eller, Miners,
and when there was finally a fed- periodically releases water from Millhands, and Mountaineers:
eral EPA to back up Tennessee's Waterville Dam for the use of Industrialization ofrheAppalachian
assertions, Champion's situation whitewater runners; second, the South, 1880-1930 (Knoxville:
changed. Pigeon is now sufficiently clean University of Tennessee Press,
to support a profitable rafting in- 1982).
Champion Today dustry. 3. State of North Carolina,
As a result, a dozen rafting Sessions Laws, 1901, pp. 917-918.
4. Interview with Charles
Champion officials are facing companies have set up shop, and Moore,formerly executive officerof
a new era in which environmen- more than 30,000 rafters and Cocke County,September 14, 1989.
talism will not go away,in which kayakers enjoy the thrills of the 5. Plain Talk (Newport, TN),
an increasing population needs Pigeon each summer. Champion circa 1906.
more potable water,and in which is playing a role in the region's 6. The Log (House Organ of
scientific discoveries link more tourist boom by sponsoring an Canton Mill), December 16, 1926.
and more carcinogens to chlorine annual whitewater competition. 7. Ben W. Hooper (Edward
and its derivatives. Yet, with barely half the per- Robert Boyce, ed.), The Unwanted
The situation has so changed sonnel it employed during the Boy: The Autobiography of Gover-
that the corporation finally isfac- 1980s, Champion will watch its or Ben W. Hooper (Knoxville:
ing reality—that is, it's finally influence on the economy, soci- University of Tennessee Press,
seeing the light. Instead of being ety, and politics of the region 1963), pp. 6-16.
8. Enterprise Mountaineer
dragged kicking and screaming decline as tourism rises. In fact,its (Waynesville, North Carolina),
into the 21st century, Champion application for anew North Caro- February 23, 1996.
may be taking the lead in ending lina water-release permit in 1996 9. Champion news release,
pulp and paper company pollution. has been met with the usual com- June 14, 1994; Mountaineer, June
An indication of this change plaints: The Pigeon remains pol- 15, 1994; Newport Plain Talk,
occurred in June 1994 when luted, smelly, and discolored. editorial,June 27, 1994.
Champion announced that a new No one doubts that the permit
BARTLETT: THE RIVER AND TIME: PIGEON'S TOXIC PAST 91

Mate of North Caroni .a 1~
Department of Environment,
Health and Natural Resources 1 •
Division of Epidemiology _
James B. Hunt, Jr., Governor r�
Jonathan B. Howes, Secretary 1D E H N FR
Michael Moser, M.D., M.P.H.
December 9, 1996
Mr. Roy Davis D O D
Asheville Regional Office DEC I I
Interchange Building, 14
59 Woodfin Place
Asheville, North Carolina 28801 AHATERtQREGOI NAiCOrFICE
Dear Mr. Davis:
At your request, I have provided a risk assessment based upon my review of the
mercury in fish tissue sample results collected on October 7 and 8 from the North Carolina
section of the Pigeon River (see enclosure). This sampling was conducted in response to
growing concerns over possible mercury bioaccumulation in the Pigeon River.
The mercury levels found in the fish sampled were low and comparable to levels
expected for fish across North Carolina. None of the sixty-five samples exceeded the North
Carolina action level of 1 mg/kg for issuing an advisory. Consumption of the mercury-
containing fish tissue (ranging from 0.02 to 0.54 mg/kg) should not pose a health risk. A fish
consumption advisory, with respect to the mercury levels found, is not warranted. However, the
current fish consumption advisory, due to the presence of elevated dioxin levels in carp and
catfish, should be followed :
"Carp and catfish in the Pigeon River may contain low levels of dioxins and
should not be consumed. Consumption of all other fish species is not considered
to present a health risk and are not affected by this advisory. Swimming, boating,
and other recreational activities present no health risk."
Call me if you have/any questions at 919-715-6429.
c I
air- i• r, Sincerely,
. V w� r� Luanne K. Williams, Pharm.D., Toxicologist
Yh 0 Medical Evaluation and Risk Assessment Branch
t� Occupational and Environmental Epidemiology Section
KW:Ip
Enclosure
P.O. x 27687, aleigh, UP C An Equal Opportunity Affirmative Action Employer
North Carolina 27611-7687 50%recycled/10%post-consumer paper

Stag-North Caroli. ._
epartment of Environment,
ealth and Natural Resources 1 •
Division of Water Quality _
James B. Hunt,Jr., Governor
Jonathan B. Howes, Secretary p E H N R
A, Preston Howard, Jr„ P.E., Director
December 6, 1996
Mr. John J. Prvately
Champion International WWTP Lab.
P.O. Box C-10
Canton, NC 28716
SUBJECT: Additional Parameter Certification
CONDUCTIVITY
Dear Mr. Prvatelv:
The Department of Environment, Health and Natural Resources, in accordance with the provisions
of 15A NCAC 2H .0800, is pleased to certify your laboratory to perform additional analytical
parameter(s).
This chanqe to vour certification is effective December 3, 1996.
Enclosed is an amended certificate that includes the new parameter(s). The same requirements
applying to your present certification are applicable to the new parameter addition(s). Please
review this certificate to insure that your laboratory is certified for all parameters required to
properly meet your certification needs.
Contact us at [phone] if you have questions or need additional information.
Sincerely,
Bernard E. Sims, PhD
Chief, Laboratory Section ` C
BES:iwm Q`�G +'A w
p(O
Enclosure &
cc James W. Meyer �P
William B. Edwards, Jr.
Gary W. Francies
-Ashville Regional Office rR�
Laboratory section,4405 Reedy Creek Road, �I��y.� FAX [phone]
Raleigh,North Carolina 27607-6445 11 , �� An Equal Opportunity/Affirmative Action Employer
Voice 919-733-3908 50%recycles/10%post-consumer paper

Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Lab Name: Champion International WWTP Lab. Certificate Number: 198
Address: P.O.Box C•10 Effective Date: 1/1/96
Canton,NC 28716 Expiration Date: 12/31/98
Date of Last Amendment: 1216196
The above named laboratory,having duly met the requirements of 15A NCAC 21-1.0800,is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANIC
BOD
COD
COLIFORM,FECAL TUBE _
COLOR,PLATINUM COBALT
CONDUCTIVITY
HARDNESS,TOTAL
AMMONIA NITROGEN
pH
.RESIDUE,SETTLEABLE
RESIDUE,TOTAL
RESIDUE,DISSOLVED 180 C
RESIDUE,SUSPENDED
Thic reninrarinn runuime maimm�nu of en onnnnm6ln nunlin,�eo,mngo�rnnmT uen of annrmmd motbndnLvv and<al'mlarmm nednm.anr.nn n•mL,alinn eomnb< I<Mmtndce er.

State of North Carol �
Department of Environment,
Health and Natural Resources •
Division of Water Quality IV
r
James B, Hunt, Jr., Governor r -a
A. Preston Howard, Jr., P.E., Director v " 7
Asheville Regional Office
December 2 , 1996
MXK0iRANDIIM
TO: Steve Tedder, Chief
Water Quality Section
FROM: Roy M. Davis, Regional Supervisor ^�
Division of Water Quality
SUBJECT: Sediment Study
Waterville Reservoir
Carolina Power & Light Company
Haywood County
On September 20, 1996 Keith Haynes, Forrest Westall and I visited
Knoxville, Tennessee to discuss the draft Champion NPDES Permit
with Paul Davis and David McKinney of the State of Tennessee .
The purpose of the meeting was to give us the opportunity to
inform the State of Tennessee how we thought the Division of
Water Quality would respond to comments offered by that State at
our Champion NPDES Permit public hearing. One request made by
Tennessee at the hearing was that Champion be required to study
the fate of dioxin found in the sediment in Waterville Reservoir.
We told Paul and David that we felt we had no legal basis to
include such a requirement in Champion' s discharge permit . We
also told them that Carolina Power and Light Company' s (CP&L)
Federal Energy Regulatory Commission (FERC) order for the
Walter' s Power Complex which includes Waterville Reservoir
requires CP&L to submit to FERC by the last day of 1998 a study
of sediment bound dioxin in Waterville Reservoir and a
recommendation regarding further action, if any, to address
dioxin contaminated sediment in Waterville reservoir. We told
Paul and David that we would approach CP&L to see if they were
willing to listen to what Tennessee might recommend in the way of
a sediment dioxin study.
On November 20, 1996 Keith, Forrest, Bryn Tracy and I met with
Mick Greeson and Phil Lucas of CP&L. At the conclusion of the
Interchange Building,59 Woodfin Place N���C FAX [phone]
Asheville, North Carolina 28801 11 , �r An Equal Opportunity/Affirmative Action Employer
Voice704-251-6208 N 50%recycles/10%post-consumer paper

Steve Tedder
Memorandum
December 2 . 1996 ---- - --
Page Two
meeting Mick was inclined that CP&L would update an earlier
Waterville sediment dioxin study. Without making a commitment,
Mick thought CP&L might be willing to look at the same lake
stations, (approximately twelve in number) , as were looked at in
the earlier study. This would allow comparison from the
standpoint of amount of deposition since the earlier study and
dioxin currently present in the surface sediment . Bryn felt this
is the most useful thing CP&L could do. Mick also felt that CP&L
might be agreeable to sitting around a table with Tennessee and
Champion and receiving their input .
We plan to call such a meeting sometime after the permit/variance
issues are settled. I would want DWQ to know what it would like
CP&L to do when we meet and therefore I will be discussing this
matter with Jimmie Overton.
We had a much better meeting as a result of Bryn Tracy' s
involvement and I very much appreciate his being with us .
xc : Harlan Britt
Jimmie Overton
Bryn Tracy
Trish Macpherson
Forrest Westall
Keith Haynes

wanton Mill
3OX C-t0
,anton.North Carouna 287;E
UUyampion -
ampion Internatlonai Carporanon D
ASHE`� E RE6n��F NICE
December 2, 1996
Mr. Billy Ray Cameron
NC Emergency Response Commission
NC Division of Emergency Management
116 West Jones Street
Administration Building
Raleigh, NC 27603-1335
RE: Release of Sodium Hypochlorite at Champion International Corporation's Canton
Mill on November 26, 1996
Dear Mr. Cameron:
Champion International Corporation is providing written notification of a CERCLA
hazardous substance release at the Canton MID which exceeded the reportable quantity.The
release was discharged from a storage tank to a concrete containment area. It was then
neutralized in the on-site Wastewater Treatment Plant and none of the released material
went off site. The information concerning this release is attached.
Please contact Susanne Koelsch at(704) 646-2381 or Jim Giauque at(704) 646-2028 if
you need additional information.
Sincerely yours,
Susanne Koelsch / ames
A. Giauque
Sr. Environmental Engineer Adv.Environmental En eer
Attachment

Mr. Billy Ray Cameron
December 2, 1996
Page 2
xc:
Mr. Keith Haynes
Environmental Specialist
Division of Environmental Management
Water Quality Section
59 Woodfm Place
Asheville, NC 28801
Mr. William Manzer
Vice-President, Operations Manager
Champion International Corporation
Canton Mill
PO Box C-10
Canton, NC 28716
Mr. Nolan Palmer
Haywood County Emergency Management Commission
2143 Asheville Rd.
Waynesville, NC 28786

NOTIFICATION REPORT FOR
EMERGENCY RELEASE OF HAZARDOUS SUBSTANCE
1. Name of chemical: 16% Sodium Hypochlorite solution.
2. Is substance an Extremely Hazardous Substance?: No
3. Caller's name and position: Susanne Koelsch
Sr. Environmental Engineer
4. Company where release occurred:
Champion International Corporation
5. Address of company, including county: Box C-10
Canton, NC 28716
Haywood County
6. Media into which release occurred:
The sodium hypochlorite solution was released onto a sealed concrete floor inside a
tank farm containment area.
7. Quantity released:
Approximately 8800 lbs of sodium hypochlorite was released.
8. Date and time of release:
The release occurred on November 26, 1996 between approximately 2:55 pm and 3:25
pm.
9. Cause(s) and source of release:
The release occurred shortly after refilling the bulk storage tank when a gate valve on the
tank failed. This resulted in the loss of approximately 75% of the tank volume to the
containment area.
10. Actions taken to respond to release, and status of actions:
An operator went to inspect the tank when an operator in the control room noted
— that rapid drop in tank level was occurring. Because of the nature of the
mechanical failure, the release could not be stopped. The operator checked that the
containment valve was closed in order to keep the release in the containment area.
11. Notifications made:
National Response Center: November 26, 1996 at 4:05 pm to Petty Officer Blanchard-
Report#368769
Mr. John Glance of the Haywood County Commications Department, Emergency
Management at 4:15 pm.
Mr.Keith Haynes of the Water Quality Section of the North Carolina Department
of Environmental Management in Asheville at—4:30 pm.
12. whether any injuries occurred:
No

Notification Report of Emergency Release
of Hazardous Substance
Sodium Hypochlorite
December 2, 1996
Page 2
13. Name and telephone number of person to contact for further
information:
Susanne Koelsch 704-646-2381
14. Action taken for clean-up:
The released sodium hypochlorite was metered to the wastewater treatment plant over the
-course-of the next 30-hours-This sodiutn hypochlorite was treated in the-on-site - -
wastewater treatment plant and none of the released material went off site. There was no
adverse effect on wastewater treatment performance. The concreted area affected by the
spill was washed with water to remove any residual chemical.
15. Does release require written notification under Section 204 of Emergency
Planning and Community Right to Know Act (Title III SARA)?:
No

Agreed to Variance Conditions 11/27/96
��J
(Words recommended for removal are stricken through and additional wording is in bold:)
Conditions identified below of the"Ordered" section of the variance should be modified to: «f.
CONDITION 2.II
II. The average daily discharge of true color for each calendar month shall not exceed
98,16
12s,434 pounds per day. The average annual effluent true color loading shall of excels cal' d by 8
pounds per day. For the purpose of this permit/variance only,-pounds _
the following equation:
Effluent Flow(mgd)x Effluent True Color Level(Platinum Cobalt Units)x 8.34. ;
CONDITION 4
4. Champion shall continue to study,evaluate, and pursue and operate color removal technologies
and report its findings to the NPDES Committee and the Division of Water Quality in accordance with
the following schedule:
DATE ACTIVITY
Continuing Commercial demonstration of bleach filtrate recycling (BFRTM)
March 1,1998 In conjunction with the scheduled Triennial Review of N. C.Water Quality
Standards the Company shall:
1. Submit a status report to the NPDES Committee on the technical,
economic, and operational feasibility of the BFRTM technology, including
those analyses prepared for other permitting agencies concerning its effects on
air emissions.
2. Evaluate and report to the NPDES Committee on the application of end-
of-pipe color reduction technologies and additional minimization of color losses
from the manufacturing processes and raw material storage areas. The
evaluation shall include an incremental color improvement analysis. This
analysis will concentrate 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 and
minimization efforts must look particularly at periods of low river flow. The
report will identify specific economic and implementation issues associated
with the incremental improvement of color levels expected by installing and
adopting these technologies and minimization efforts at the mill. The report
will also project the expected additional color reduction for each technology
and in-mill minimization effort evaluated and the maximum color reduction
possible using the identified technology or action.
Evaluate and-repert-0�truffflzad

December 1,1998
eenelusieft of the ,Champion will Oeidp and repert eft.
- - to iuily impiemeni and operaie'the b Rl.'-tecnnoiogy-as-a eeenaiem
preeess on the mill's pinewood line-,unless the Company can demonstrate to the
NPDES Committee that BFRTM is not a commercially viable process at this
location.
December 1,2000 Champion will evaluate color reduction strategies for further optimization of
BERTM technology and report on the feasibility of implementation on the
hardwood line. '
March 1,2001 Champion will evaluate and report on end-of-pipe color reduction technologies
in conjunction with the Triennial Review of N. C.Water Quality Standards.
The evaluation shall include an incremental color improvement analysis.This
analysis will concentrate 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 must
look particularly at periods of low river flow. The report will identify specific
economic and implementation issues associated with the incremental
improvement of color levels expected by installing these technologies at the
mill. The report will also project the expected additional color reduction for
each technology evaluated and the maximum color reduction possible using the
identified technology.
June 1,2001 Champion will submit a report to the NPDES Committee and N. C.DEHNR,
Division of Water Quality, on the comparative evaluation of the above
collective efforts as part of the Variance review process (Triennial Review of
North Carolina Water Quality Standards).
CONDrnON 5
5. The Division will provide a status summary report on color removal at the Canton Mill to the
NPDES Committee and the Variance Review Committee
Water Quality Standards review within 30 days of the availability of Champion's reports as required
above. The Variance Review Committee,utilizing the information available,will,by July 1,1998
make recommendations to the NPDES Committee concerning revisions to the color variance. Those
recommendations will include lower limits for the monthly average and annual average color
limitations applicable to the mill due to color removal performance and the Committee's position on
additional revisions needed in the variance to reflect the application of BFRTM,end-of-the pipe
treatment and in-mill color reduction technologies. Based on the instream color data available at that
time,the Committee will also provide recommendations on the applicability of any instream color
compliance point in N. C. The NPDES Committee will review the available information,the
recommendations of the Variance Review Committee and the staff recommendations in proposing any
changes to the variance.
CONDITION 6
6. In conjunction with subsequent triennial water quality standards reviews,the Division will
nominate a variance review committee. The NPDES Committee will have final approval of the
selection of this Committee. Committee membership may consist of Department Staff and individuals
considered authorities on pulp and paper technology or environmental aspects of that industry from the
2

university or research communities. The Committee will also include in its membership at least one
representative of Tennessee's Department of Environment and Conservation. That review committee's
report and recommendation will be examined by the NPDES Committee for a decision on the adequacy
.. •f'.tl:_ Tl-- .. DE-5 iC ctculdiie
warranted due to the effectiveness of the treatment system or because of advances in color reduction
technologies for this type wastewater. All revisions adopted by the NPDES Committee will required
the modification of the Company's NPDES Discharge Permit.
CONDITION 7
7. The variance proceeding, and the NPDES Permit Number NC0000272, shall at all-tirne be
subject to reopening in order to modify the color requirements based upon the following and in
association with the required triennial reviews:
1. aAny breakthrough in color removal technologies. Such breakthroughs shall be brought
to the NPDES Committee for consideration,by Champion and the Division of Water Quality,
as soon as they are discovered.
2. An acceptable statistical analysis of effluent color discharge data demonstrating better
color removal performance than that currently prescribed in the variance and permit.
3. Successful application of end-of-pipe color reduction technology or in-mill color
minimization effort that results in significant and measurable reduced mass color discharge.
3

SENT BY:CHAXP10N INTERNATI0NAL;11-26-96 ; 9;18:A11 LEGAL _AFFAIRS CHMPIM' EOHS;n 2/ 3
DRAFT 11/25/96
F. SCHEDULE FOR CONTINUED COLOR MINIMIZATION
Champion shall continue to study, evaluate,and pursue color removal technologies and
shall report its findings to the Division of Water Quality in accordance with the following
schedule:
LATE ACLTMTY
Continuing Commercial demonstration of bleach filtrate recycling(BFRTM)
.Tamrary 1, 1997 The average daily discharge of true color for each month shall not
exceed 125,434 pounds per day, and the average annual effluent
true color loading shall not exceed 98.166 pounds per day.
March 1, 1998 In conjunction with the scheduled Triennial Review of North
Carolina Water Quality gtandardc:
1. Submit a status report to the Variance Review Committee
on the technical, economic and operational feasibility of
the BFRTM technology, including those analyses prepared
for other permitting agencies concerning its offsets on air
emissions.
2. Fvvaluate and report on and-nf-pipe color reduction
technologies and minimization of color losses from
midnul'acttuing processes and raw material storage areas.
The evaluation shall include an incremental color
improvement analysis. The Variance Review Committee
shall be made up of the same types of members as provided
for in the initial variance, with the addition of a
representative of the Tennessee DEC, Division of Water
pollution Cnntml.
June 1, 1998 Based upon the above reports,the Variance Review Committee will
recommend lower limits for monthly average and annual average
discharge of color pounds per day to reasonably reflect the color
reduction achieved by the BFR technology or another in mill or
end-of-plpc Wchaulogy. The Variance Review Committee shall
submit its recommendations to the NPFDES Committee, which will
take final action thereon.

SENT BY:CHAIIIPION INTEMATIONAL;11-26-96 ; 9:18AIM LEGAL AFFAIRS- CHAMPION EOHS;r 3/ 3
December 1, 1998 Champion will implement BFRTu technology on the pine line if'it has
proven io be a fully commercial process.
December 1, 2000 Champion will evaluate color reduction strategies for further
optimization of BFRT"r technology and report on the feasibility of
implementation on the hardwood line.
March 1. 2001 Champion will evaluate and report on crrd-of-pipe wlor reduction
technologies in conjunction with the Triennial Review of N.C. Water
Quality Standards. The evaluation shall include an incremental color
improvement analysis.
A new statistical analysis of effluent data will be completed by the State
as to the demonstrated performance regarding color levels and loadings
which are attainable in the discharge.
June 1, 2001 Champion will submit a report to N,C, DEHNR,Division of Water
Quality,on the comparative evaluation of the above cnllective efforts as
part of the variance review process(Triennial Review)and the NPDES
renewal process.
During the March 1, 1998 and March 1, 2001 Triennial reviews, the State urill review the
instream color data collected at all NC instream color monitoring stations specified in Itcm 1.A
to determine if the variance can be revised to include a maximum instream color level or to
change the point of its application,

Champion International Corporation - Canton, NC
Calculation of Color Limits for the Variance Based on Post CMP Performance
Monthly Average Color Data SE color lbs/day Natural Log
Aug-95 89,795 11.4053
Sep-95 78,026 11.2648
Oct-95 96,786 11.4803
Nov-95 97,637 11 .4890
Dec-95 83,586 11 .3336
Jan-96 101,363 11.5265
Feb-96 96,968 11.4821
Mar-96 77,639 11.2598
Apr-96 70,227 11.1595
May-96 72,694 11 .1940
Jun-96 80,560 11.2968
Jul-96 84,481 11 .3443
Aug-96 71,346 11.1753
Sep-96 90,495 11 .4130
Oct-96 78,689 11 .2733
Average 8/95-10/96 84,686 11 .34
Std dev 8/95-10/96 10,289 0.12
Skew 8/95-10/96 0.21 0.07
8/95 -10/96 99th percentile max mo 108,659 11 .62
8/95-10/96 straight 99th pet max yr 91,607 11.42
Exponent of Nat. log of 99th pet max month 111 ,572
Exponent of Nat. log of 99th pet max yr 91,255
8/l/95-10/31/96 avg daily pulp production 1,320
Post CMP max monthly pulp production 1,484 /
design daily pulp production 1,420
Proposed Color Variance Limits
99th pet Max mo' 1484/1320 Monthly average 125,434
99th pet Max yr ' 1420/1320 Annual Average 98,168
SKK 11/26/96

State of North Carol'„ ,.,
Department of Environment,
alth and Natural Resources 14 •
�1 ivision of Water Quality _
James B. Hunt, Jr., Governor k
inn,rest. 1 B. ! r�Howard,
., . �
A. Preston Howard, Jr., P.E., Director
Asheville Regional Office
November 21, 1996
MR. JOHN PRYATELY
CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX C-10
CANTON, NC 28716
Dear Mr. Pryately:
Your letter dated November 19, 1996 that describes corrective
actions for your analytical procedures has been received and
reviewed. The actions taken are acceptable for your North Carolina
Wastewater/Groundwater laboratory certification. If a future
inspection should reveal that the deviations cited in the
inspection report were not corrected, enforcement actions may be
recommended.
Thank you again for your cooperation. Contact us at (704) -251-
6208 ext . 285 if you have questions .
Sincerely,
Gel
Gary Francies
Laboratory Section
CC : W.B . Edwards, Jr.
James W. Meyer
,�419Mheville Fallillijignal Off'ce
Interchange Building,59 Woodfin Place �Aw C
FAX [phone]
Asheville,North Carolina 28801 An Equal Opportunity/Affirmative Action Employer
Voice 704-251-6208 r 50%recycles/10%post-consumer paper

Division of Water Quality
V�✓/ Biological Assessment Group
VNovember 21, 1996
MEMORANDUM
To: Roy Davis
Regional Supervisor, ARO Q t5
Through: Jimmie Overt 1 2 s
Trish MacPhe Cain RAL OFfiCE
Wp1ER
From: Mark Hale I,/ AStl�l E
Subject: Results of DWQ Fish Tissue Mercury Assessment
Pigeon River, October 1996
The following are results of the DWQ Environmental Sciences Branch assessment of mercury
levels in fish collected from the Pigeon River during October 7 and 8, 1996. DWQ personnel
conducted the study to examine mercury concentrations in fish from the North Carolina section of
the Pigeon(above Canton to Walters Lake). The survey was conducted at the request of the
Asheville Regional Office in response to growing concerns over possible mercury
bioaccumulation in the Pigeon system below Canton.
Sixty fish samples were collected from five stations along the Pigeon River during the study. The
following stations stretched from just above Canton and the Champion mill discharge, to Walters
Lake (see map).
1] Below NC 215 Bridge above Canton(at the high school)
2] SR 1513 above Clyde at river mile 59.0
31 Old Rt. 209 at river mile 52.3
41 SR 1364 at Ferguson Bridge,river mile 48.2
51 Walters Lake, river mile 39-40
Fish were collected via backpack and boat-mounted electrofishing units. Piscivores,insectivores,
and/or omnivores were collected at each station, wrapped individually in foil,bagged, and
transported on dry ice back to the ESB laboratory for processing. Field identifications of all fish
were confirmed in the laboratory.
All fish samples were processed at the ESB laboratory on October 11, 1996 and delivered to the
DWQ chemistry lab for analysis of total mercury. Split samples were also prepared and shipped to
Quanterra Environmental Services for analysis at the request of Champion Paper personnel.
Samples sent for analysis included individual and composited fish.
DWQ results show all fish from all stations contained total mercury levels below the EPA and
FDA limits of 0.6 ppm and 1.0 ppm respectively. Mercury concentrations ranged from 0.02 ppm
in insectivores and omnivores, to 0.54 ppm in a largemouth bass collected above Canton(see
attached statistical summaries). Piscivores such as bass are expected to contain higher levels of
mercury due to their longevity and trophic level. All total mercury results were comparable to
"background" levels expected for fish across North Carolina.
V

s
November 21, 1996
Page 2
Results from split sample analyses by Quanterra correlate well with DWQ data. Quanterra results
were consistently higher than results generated by the DWQ lab,but were considered to be well
within the same range(see enclosed Champion Paper fax,Table 1). All Quanterra results were
lower than the FDA limit of 1.0, and only one result for the aforementioned bass collected above
Canton exceeded the EPA screening value of 0.60 ppm. The average of DWQ and Quanterra
results for the bass equals 0.59 ppm,just under the EPA screening value. Mercury levels
approaching the EPA value are not uncommon in older, larger bass in systems across the state.
Individual sample results from both labs remained under current FDA criteria. The current EPA
screening value of 0.60 ppm was exceeded by only one individual Quanterra result. All mean
mercury results for species and station from both labs were less than EPA and FDA limits.
Mercury results from both labs reflect levels that would be encountered in fish from NC waters
not subject to excessive discharges or impacts.
cc: Steve Tedder
Forrest Westall,ARO
Keith Haynes, ARO
Susan Wilson, NPDES Group
Luanne Williams, Envir. Epidemiology Section

Pigeon River Fish Tissue Stations
NCDWQ Mercury Assessment
October 1996
WaAn UM Mfar&Uke
ra
Greo Walters Lake
�k
(38.1) creek
P (42- )
New Hepea Bridge
'\FLOW Ferguson Bridge (48.2)
JmaCarrs
creek
Old Rt. 209 (52.3) Above Clyde (59.0)
YiUWall Canton,HC
(633)
WayneW4 A; a d Cryde,NC Below 215 Bridge
WWTP creek Above Canton
(54.8)

Mercury in Fish Tissue Pigeon River
NCDWQ, October 1996
(Results are expressed as ppm)
Station and Species Mean Count Minimum Maximum
Total,All species and stations 0.11 60 0.02 0.54
Pigeon River at Canton,Bass 0.42 3 0.34 0.54
Pigeon River at Canton,Hogsucker 0.06 2 0.02 0.10
Pigeon River at Canton,Redbreast 0.15 4 0.05 0.26
Pigeon River at Canton,Rock Bass 0.24 3 0.08 0.45
Pigeon River at Canton,Warmouth 0.31 1 0.31 0.31
Pigeon River at SR-1513,Blue ill 0.04 2 0.03 0.05
Pigeon River at SR-1513,Carp 0.09 3 0.08 0.09
Pigeon River at SR-1513,Bass 0.10 2 0.07 0.13
Pigeon River at SR-1513,Redbreast 0.04 3 0.04 0.05
Pigeon River at SR-1513,Rock Bass 0.03 1 0.03 0.03
Pigeon River at SR-1513,SmaUmouth 0.07 1 0.07 0.07
Pigeon River at SR-1513,Warmouth 0.09 1 0.09 0.09
Pigeon River at SR-1513,White Sucker 0.05 2 0.02 0.08
Pigeon River at NC-209,Carp 0.08 3 0.08 0.08
Pigeon River at NC-209,Bass 0.18 3 0.07 0.25
Pigeon River at NC-209,Redbreast 0.06 5 0.05 0.07
Pigeon River at NC-209,Smallmouth 0.09 1 0.09 0.09
Pigeon River dwnstrm of Ferguson Bridge,Redbreast 0.02 3 0.02 0.03
Pigeon River dwnstrm of Ferguson Bridge,Rock Bass 0.03 1 0.03 0.03
Pigeon River dwnstrm of Ferguson Bridge,Smallmouth 0.04 1 0.04 0.04
Walters Lake,Bluegill 0.05 6 0.04 0.07
Walters Lake,Crappie 0.08 3 0.06 0.10
Walters Lake,Bass 1 0.071 61 0.041 0.10

. y �
Mercury in Fish Tissue: DWQ Results Pigeon River-October 1996
DATE SAMPLED DESCRIPTION SPECIES LENGTH(cm) WEIGHT(g) SAMPLE TYPE Hg (mg/Kg)
1018/96 Pigeon River at Canton NHS 22.6 136 FC2 0.1
1018/96 Pigeon Riverat Canton NHS 23.4 128.5 FC2 <0.02
1018/96 Pigeon River at Canton RKB 14.5 54 FC2 0.08
10/8f96 Pipeon River at Canton RKB 17.9 93 F 0.45
10/8/96 Pigeon River at Canton RKB 20 136 F 0.2
10/8196 Pigeon River at Canton W 17.5 99 F 0.31
10/8196 Pigeon River at Canton LMB 26.9 268 F 0.38
10/8196 Pigeon River at Canton LMB 38 892 F 0.34
10/8196 Pigeon River at Canton RBS 17.5 100 FC2 0.12
10/8196 Pigeon River at Canton RBS 16.4 87.5 FC2 0.05
10/8196 Pigeon River at Canton RBS 22.3 55.3 FC3 0.18
10/8/96 Pi eon River at Canton RBS 16.2 72.6 FC3 0.26
10/8/96 Pigeon River at Canton LMB 44.7 2129 F 0.54
10/7/96 Pi eon River at SR-1513 C 60.3 2937 F 0.09
10/7196 Pigeon River at SR-1513 C 54.7 2435 F 0.09
10/7/96 Pi eon River at SR-1513 C 51.8 2085 F 0.08
1017196 Pigeon River at SR-1513 RKB 18 116 F 0.03
10/7/96 Pigeon River at SR-1513 SMB 25 186 F 0.07
IOM96 Pigeon River at SR-1513 LMB 36.4 749 F 0.13
10n196 Pigeon River at SR-1513 LMB 34 545 F 0.07
10n196 Pigeon River at SR-1513 W 17.9 115 F 0.09
10/7/96 Pigeon River at SR-1513 BGS 19.2 164 F 0.03
10n196 Pigeon River at SR-1513 BGS 19.5 - 142 F 0.05
10n196 Pigeon River at SR-1513 RBS 18 111.3 FC3 0.04
10n196 Pigeon River at SR-1513 RBS 15.9 66.2 FC4 0.04
10/7/96 Pi eon River at SR-1513 RBS 15 56.5 FC4 0.05
10n196 Pigeon River at SR-1513 WSU 26.6 224 F 0.02
10n196 Pigeon River at SR-1513 WSU 37.9 663 F 0.08
10/7/96 Pigeon River at NC-209 SMB 27 269 F 0.09
10n196 Pigeon River at NC-209 RBS 18.1 119 FC2 0.07
10/7196 Pigeon River at NC-209 RBS 17.6 114 FC2 0.05
10/7/96 Pigeon River at NC-209 RBS 17 98 FC2 0.06
10/7196 Pigeon River at NC-209 RBS 18.3 129 FC2 0.06
10M96 Pi eon River at NC-209 RBS 17.8 13.3 FC2 0.05
10n196 Pi eon River at NC-209 LMB 43.7 1367 F 0.25
10n196 Pi eon River at NC-209 LMB 36.8 746 F 0.21
10n196 Pigeon River at NC-209 LMB 24.6 189 F 0.07
1017/96 Pigeon River at NC-209 C 52 1891 F 0.08
10M96 Pigeon River at NC-209 C 49.2 1786 F 0.08
1017/96 Pigeon River at NC-209 C 42.8 1020 F 0.08
10M96 Pigeon River dwns=ofFerguson Brid eSMB 22.6 235 F 0.04
10n196 Pi eon River tl n trm of Ferguson Bridge RKB 16.3 82 F 0.03
1017196 Pigeon River dwnstrm ofFerguson BrideRBS 19.4 190 F 0.02
10/7/96 Pigeon River dwnstrm ofFerguson BrideRBS 16.9 94 FC4 0.03
10n196 Pigeon River dwmtrm ofFer uson BrideRBS 14.6 65.2 FC4 0.02
10/8196 Walters Cake BKS 22.3 174 F 0.09
10/8196 Walters Lake BKS 21.5 141 F 0.06
10/8/96 Walters Lake BKS 22.2 145 F 0.1
10/8/96 Walters Lake BGS 18 117 FC2 0.04
10/8196 Walters lake BGS 18 123 F 0.07
10/8196 Walters Lake BGS 19.3 139 F 0.05
10/8196 Walters Lake BGS 19.4 129 F 0.06
1018/96 Walters Lake BGS 19.6 161 F 0.04
10/8196 Walters Lake BGS 16.4 87 FC3 0.04
1018196 Walters Lake LMB 30.8 404 F 0.1
1018/96 Walters Lake LMB 29.3 381 F 0.1
1018/96 Walters Lake LMB 28.7 359 F 0.07
10/8/96 Walters lake LMB 29 333 F 0.07
10/8196 Walters Iake LMB 24 186 IF 0.06
10/8/96 JIValters Lake ILMB 21.5 1 130 IF 0.04

i
CHRMPION EOHS I 04-646-6892 NOY V, - `5 15 :36 N0 .009 P .02
TABLE 1: Results from NCDEHNR Fish Tissue Analysis for Pigeon River Mercury Assessment
Fish tissue collected on 1017/96 and 10/8196
quantarra NCDEHNR
Pigeon River Sample Fish Total Hg Total Hg
Sample Site Mile ID Species ID m m
Canton Upstream 64.5 96-300 N. Hogsucker 0.18 0.1 {f
Canton Upstream 64.5 96-301 N.Hogsucker 0.18 <0.02 t
Canton Upstream 64.5 9B-302 Rook Bass 0.13 0.08
Canton Upstream 64.5 98-303 Rook Base 0.56 0.45 j
Canton Upstream 64.5 96-304 Rock Bass 0.28 0.2
Canton Upstream 64.5 96-305 Warmouth 0.42 0.31
Canton Upstream 64.5 96-305 Largemouth Bass 0.43 0.3B
Canton Upstream 64.5 96.307 Largemouth Bass 0.40 0.34
Canton Upstream 64.5 95-306 Redbreast 0.23 0.12
Canton Upstream 64.5 96-300 Redbreast 0.089 0.05
Canton Upstream 64.5 96-310 Redbreast 0.14 0.18
Canton Upstream 64.5 96-311 Redbreast 0.41 0.26
Canton Upstream 64.5 1 96-313 Largemouth Bass 0.64 0.54 t
t
Above Clyde(SR 1513) 59.0 95.350 Carp 0.077 0.09
Above Clyde(SR 1513) 59.0 96-351 Carp 0.085 0,09
Above Clyde(SR 1513) 59.0 96-352 Carp 0.086 0.08
Above Clyde(SR 1513) 59.0 95.354 Rock Bass ND 0.03
Above Clyde(SR 1613) 69.0 96-365 Smallmouth Bass 0.080 0.07
Above Clyde(SR 1513) 59.0 96-366 Largemouth Bass 0.16 0.13
Above.Clyde(SR 1513) 59.0 96.357 Largemouth Bass 0.092 0.07
Above Clyde(SR 1513) 59.0 96-359 Warmouth 0.13 0.09
Above Clyde(SR 1513) 59.0 96-360 Bluegill 0,044 0.03 3
Above Clyde(SR 1613) 59.0 96-351 Bluegill 0.083 0.05 ;)
Above Clyde(SR 1513) 59.0 90-362 Redbreast 0.073 0.04 y
Above Clyde(SR 1513) 59.0 96-363 Redbreast 0,081 0.04
Above Clyde(SR 1613) 59.0 96-364 Redbreast 0.084 0.05 '
Above Clyde(SR 1513) 59.0 96-365 White Sucker 0.099 0.02
Above Clyde SR 1513 59.0 1 96-366 White Sucker ND 0.08
Old NO Route 209 52.3 96.337 Smallmouth Bass 0.12 0.09
Old NO Route 209 62.3 96.338 Redbreast 0.080 0.07
Old NO Route 209 52.3 90-339 Redbreast 0.020 0.05
Old NO Route 200 52.3 96-340 Redbreast 0.096 0.08
Old NO Route 209 52.3 96.341 Redbreast 0.10 0.08
Old NC Route 209 52.3 96.342 Redbreast 0.076 0.05
Old NO Route 209 52.3 98.343 Largemouth Bass 0.25 0.25
Old NO Route 209 52.3 95-346 Largemouth Bass 0.26 0.21
Old NO Route 209 52.3 96.346 Largemouth Bass 0.087 0.07
Old NO Route 209 52.3 95.347 Carp 0.060 0.08
Old NC Route 209 62.3 98-346 Carp 0.057 0.08
Old NO Route 209 52.3 96-349 Carp 0.080 0.08
Ferguson Bridge 48.2 96-314 Smallmouth Bass 0.084 0.04
Ferguson Bridge 4B,2 95-316 Rock Bass 0.076 0.03
Ferguson Bridge 48.2 96.317 Redbreast 0.050 0.02
Ferguson Bridge 48.2 96-318 Redbreast 0.087 0.03
Ferguson Bride 48.2 96.319 Redbreast 0.047 0.02
Page 1 CMS1116196

6AMPLON EOHS 1 '04-646-6892 NOV 13'---6 15 :36 N0 .009 P .03
TABLE 1: Results from NCDEHNR Fish Tissue Analysis for Pigeon River Mercury Assessment
Fish tissue collected on 10/7/96 and 1018/96
Quanterra NCDEHNR
Pigeon River Sample Fish Total Hg Total Hg
Sam le Site Mile ID Spades ID (Dom) m
Walters lake NA 96-320 Crappie 0.17 0.09
Walters Lake NA 96-321 Crappie 0.18 0.08
Walters Lake NA 96-322 Crappie 0.13 0.1
Walters Lake NA 96-323 Bluegill 0.097 0.04
Walters Lake NA 96-32d Bluagill 0.083 0.07
Walters Lake NA 96-325 Bluegill 0.16 0.05
Walters Lake NA 96-326 Bluegill 0.12 0.06
Walters Lake NA 96-327 Bluegill 0.14 0.04
Walters Lako NA 96.328 Bluegill 0.11 0.04
Walters Lake NA 98-330 Largemouth Bass 0.16 0.1
Walters Lake NA 96-332 Largemouth Bass 0.21 0.1
Walters Lake NA 96.333 Largemouth Bass 0.15 0.07
Walters Lake NA 96.334 Largemouth Bass 0.16 0.07
Walters Lake NA 96.335 Largemouth Bass 0.12 0.05
Walters Lake NA 1 96.336 1 Largarnouth Bass 0.12 0.04
ND=Not Detectable at 0.040 ppm Reporting Limit
NA=Not Applicable
The FDA fish consumption standard fo methyl mercury is 1 ppm
Page 2 CMS11/8/a8

State of North Carolina IT a
Department of Environment,
ealth and Natural Resources 4 •
Ozjvision of Water Quality
� mes B. Hunt, Jr., Governor
natha B. Howes, Secretary Preston Howard, Jr., P.E., Director
Asheville Regional Office
November 13, 1996
MR. JOHN PRYATELY
CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX C-10
CANTON, NC 28716
Dear Mr. Pryately:
We evaluated results from your analysis of the wastewater/groundwater laboratory
certification sample(s) received on November 12, 1996. The information from this
evaluation is summarized below:
Value True Acceptable
Parameter Reported Value Range Performance
Conductivity,umhos/cm 398.2 398 368-435 Acceptable
Acceptable result: No further action is required.
Contact us at (704) 251-6208 ext. 285 if you have questions concerning this matter.
Sincerely,
Gary Francies
Laboratory Section
cc: W.B. Edwards, Jr.
James W. Meyer
Asheville Regional Office
Interchange Building,59 Woodfin Place MAXAn
FAX [phone]
Asheville,North Carolina 28801 Equal Opportunity/Affirmative Action Employer
Voice 704-251Voice 704-251-6208�50%recycles/10%post-consumer paperrecycles/10%post-consumer paper

(� Stage of North Environment,
to
artment of Environment,
�1 ealth and Natural Resources •
Division of Water Quality James B. Hunt, Jr., Governorya
Jonathan B. Howes, Secretary p E H N fR
A. Preston Howard, Jr., P.E., Director
Asheville Regional Office
October 31, 1996
MR. JOHN PRYATELY
CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX C-10
CANTON, NC 28716
Dear Mr. Pryately:
Enclosed for your use are certification materials as follows:
( ) Certification Regulation ( ) Federal Register
( ) Application ( ) List of Certified Labs.
(X) Please complete and return the enclosed checklist(s)
(X) Other
Also enclosed is an invoice. DO NOT submit fess until an acceptable value has been reported on the evaluation
sample.
Evaluation Samples
( ) ROD Metals. Group I ( ) Total Phosphorus ( ) Purgeables 601
< ) COD ( ) Regular Level ( ) Orthophosphate ( ) Purgeables 602
( ) Chloride ( ) Lou Level ( ) Oil 8 Grease ( ) Aerolien 603
( ) Chlorine Metals. Group II ( ) pH ( ) Phenols 604
( ) Color PC ( ) Regular Level ( ) Phenols ( ) Renzidines 605
( ) Color ADMI ( ) Low Level ( ) Res. Total ( ) Phthalates 606
(X) Conductivity ( ) Barium ( ) Res. Dissolved 180°C ( ) Nitrosamines 607
( ) Cyanide ( ) Mercury ( ) Res. Suspended ( ) Pesticides 608
( ) Fluoride ( ) Ammonia Nitrogen ( ) Sulfate ( ) PCB 608
( ) Hardness ( ) T. Kjeldahl Nitrogen ( ) TOC ( ) Nitroaromatics 609
( ) MBAs ( ) NO? + N0.� Nitrogen ( ) Turbidity ( ) PAH 610
( ) Nitrate Nitrogen ( ) Others ( ) Hal oethers 611
( ) Chi Hydrocarbons 612
( ) Purgeable Organics 624
( ) SN/A Organics 625
C ) Herbicides
( ) EDB - EPA 504
Sample Tvce ( ) TPH
( ) Required Samples (X) Initial Samples ( ) Recertification Samples
( ) Samples for your use only - No report needed
( ) Replacement Ampules
Please contact us at 704-251-6208 Ext. 285 if you have questions or need
additional information.
Sincerely,
Gary F7ancies
Laboratory Section
cc: W.B. Edwards, Jr.
James W. Meyer
Interchange Building,59 Woodfin Place NV
y.■ FAX [phone]
Asheville,North Carolina 28801 r■tl An Equal Opportunity/Affirmative Action Employer
Voice 704-251-6208 I7!TFYT7Twj?FT77 50%recycles/10%post-consumer paper

State of North C l on
Department of Environment,
Health and Natural Resources ` 0
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B: Howes, Secretary H N
A. Preston Howard, Jr., P.E., Director
October 17, 1996 OCT 2 9
10
WATcc c tdAL OFFICE
Mr. John Hankinson, Jr. pSHE`1ILLE• F�•
Region IV Administrator
U.S. Environmental Protection Agency
_ 100 Alabama Street, S.W.
Atlanta, Georgia 30303
SUBJECT: Color Variance
Champion International Corporation
NPDES Permit NC0000272
Haywood County
Dear Mr. Hankinson;
As I am sure you are aware,North Carolina recently has reviewed Champion International
Corporstior's Canton Mill variance for color. The color variance was originally granted to Champion
International Corporation in July 1988 and later approved by the United States Environmental Protection
Agency (USEPA).
The color variance, as approved by the USEPA, required that the Division of Water Quality(DWQ)
review the color variance for Champion International Corporation during the state's Triennial Review of
Water Quality Standards (required by the Clean Water Act), and make appropriate recommendations to the
NPDES Committee (a committee of the state's Environmental Management Commission, our rulemaking
and policy making board). The variance more specifically required that, during the Triennial Review period,
following the completion and startup of the Canton Mill's modernization project,the Division nominate a
Variance Review Committee (VR Committee).
The VR Committee was charged with developing a report with recommendations on the adequacy of
the existing variance and presenting these recommendations to the NPDES Committee. The NPDES
Committee was then to decide if the variance should be changed based on available color removal
technologies for this type of wastewater or effectiveness of the color removal system at the Canton Mill.
Any revisions to the variance adopted by the NPDES Committee would require modification of the NPDES
permit for this facility.
The modernization of the Canton Mill was completed in 1994. On February 8, 1996, the VR
Committee proposed modifications to the color variance and recommended that the NPDES Committee send
these proposed modifications to public hearing. On March 13, 1996, the NPDES Committee voted to send
the proposed modifications to the color variance to public hearing. The Hearing Officer's recommendation
from the June 6, 1996 public hearing was taken back to the NPDES Committee to consider for final
approval at their October 9, 1996 meeting.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10%post-consumer paper

a r -iP
The NPDES Committee adopted the hearing officer s recommendations,with one modification, at
their October 9, 1996 meeting. Enclosed are the documents pertinent to the adoption of the modified
variance. I hereby request that the USEPA review the enclosed documents and approve the modified
variance accordingly. _
The NPDES permit is scheduled to be issued in early November with the approved variance
incorporated into the permit. Your prompt consideration of this matter would be greatly appreciated by the
Division. If you have questions regarding the variance,you may contact Coleen Sullins or Greg Thorpe of
my staff at (919)_733.5083, ext. 550 and 557, respectively.
Sincerely,
A. Preston Howard, Jr., P.E.
cc: Harlan Britt,Deputy Director, Division of Water Quality
Steve W. Tedder, Chief,Water Quality Section
Dan Oak1g Senior jDeputy Attorney General,Environmental Division
F_orres`i_Westall Water Qualrty Stipet sorfAs'h6W16Regional O ce
Greg Thorpe,Assistant Chief Water Qualtty Section, Planning Branch
Coleen Sullins,Supervisor, Permits &Engineering Unit

State of North Carolina
MICHAEL F. EASLEY Department of Justice
A7r0kNEY GENERAL P.O. BOX 629 Reply to:Daniel C.Oakley
RALEIGH Environmental Division
27602-0629 [phone](Phone)
[phone] (Fax)
October 15, 1996
Mr. John Hankinson, Jr.
Region IV Administrator
U.S. Environmental Protection Agency
100 Alabama Street, SW
Atlanta, Georgia 30303
Re: Modification of Color Variance;
Champion International Corporation, Canton Mill
Dear Mr. Hankinson:
Under the provisions of a Color Variance granted to Champion International Corporation,
for its Canton Mill, on July 13, 1988, and GS. 143-215.3(e), the North Carolina Environmental
Management Commission, acting through its NPDES Committee, has modified the terms of the
existing variance. The order providing for the modifications is attached for your reference.
The modification process was undertaken in accordance with established North Carolina
law and procedure, and will effect changes in the Color Variance contemporaneously with the
effective date of re-issued NPDES Permit No.NC 0000272
Please advise if you require any further information.
Very truly yours,
4 Li If. opt
Daniel C. Oakley
Senior Deputy Attorney General
DCO/dw
cc: Preston Howard
Andy Vanore
John McArthur
attachment
/13517
r An Equal Opportunity/Affirmative Action Employer ���

ENVIRONMENTAL MANAGEMENT COMMISSION
RECEIVE ®
OCT 1 5 1996
IN THE MATTER OF REQUEST FOR ) EDNi r: i I7AL MANAGE,`�I
VARIANCE FROM WATER QUALITY
STANDARD-BASED EFFLUENT ) MODIFICATION OF COLOR
LIMITATIONS BY CHAMPION ) VARIANCE GRANTED
INTERNATIONAL CORPORATION, ) ON JULY 13, 1988
CANTON,NORTH CAROLINA )
THIS MATTER came on to be heard before the NPDES (National Pollutant Discharge
Elimination System) Committee of the North Carolina Environmental Management Commission
at its scheduled meeting in New Bern, North Carolina, on October 9, 1996, pursuant to the
NPDES Committee's proposal to modify an existing color variance granted to Champion
International Corporation on July 13, 1988.
Upon duly made motion and vote, the NPDES Committee hereby adopts the following
Findings of Fact and Conclusions of Law:
FINDINGS OF FACT
1. Pursuant to a request for variance, dated January 12, 1988, submitted by
Champion International Corporation C'Champion"), the NPDES (National Pollutant Discharge
Elimination) Committee of the North Carolina Environmental Management Commission granted
Champion a variance from the North Carolina water quality standard for color, as that standard is
interpreted by the U.S. Environmental Protection Agency. The variance was memorialized in the
NPDES Committee's Final Decision, dated July 13, 1988.
2. Pursuant to Ordering Paragraph 6 of its Final Decision, the NPDES Committee
established a Variance Review Committee to review the Canton Mill's proposed modernization
a

2
program and to recommend any changes to the existing variance. As stated in Ordering
Paragraph 6 of its Final Decision,-.the NPDES Committee is charged with determining "if
changes in the variance are warranted due to the effectiveness of the treatment system or because
of advances in color reduction technologies for this type wastewater."
3. The Variance Review Committee convened three times, and presented the results
of its review and consideration of Champion's effluent color discharge to the NPDES Committee
at its March 13, 1996, meeting in Raleigh,North Carolina.
4. The Variance Review Committee made several recommendations to modify the
existing variance to the NPDES Committee, through a verbal presentation at the March 13, 1996,
meeting, and through memoranda dated March 7, 1996, from Greg Thorpe ("Review of Proposed
Modifications to Champion's Canton Mill Color Variance by the NPDES Committee"), and
March 6, 1996, from Dennis C. Loflin ("Consideration of Proposed Modifications to Champion
International Corporation's Color Variance for the Canton Mill NPDES Permit"), which are
incorporated herein by reference.
5. Based on a consideration of the Variance Review Committee's reports and
recommendations, the NPDES Committee voted to propose modifications to the existing
variance, and directed its staff to carry out the public notice, comment and hearing process
required by G.S. 143-215.3(e) and Ordering Paragraph 8 of its July 13, 1988, Final Decision.
6. A public hearing was conducted by Mr. Harlan Britt, appointed as hearing officer
for the NPDES Committee and for the contemporaneous NPDES permitting process, on June 6,
1996. in Haywood County,North Carolina.

3 Y
7. The hearing officer made several recommendations to modify the existing
variance to the NPDES Committee, through .a verbal presentation at the October 9, 1996,
meeting, and through a memorandum dated October 2, 1996, which is incorporated herein by
reference.
8. Modification of the variance as recommended by the Variance Review Committee
«ill not result in any discharge of waste that would endanger human health or safety. The
variance for color is to allow discharge of wastewater at levels that will prevent Champion's
contribution to the true color from causing the true color at the North Carolina/Tennessee State
line to exceed 50 true color units at all flows equal to or greater than 126 efs at the Hepco
Gauging Station. The substance being discharged, for which the variance is sought, is not
bioaccumulative. The color does not, at the volumes and levels involved here, present a risk of
indirect or direct human impact or broad environmental damage. The waters are not water
supply. Therefore, the discharge will not endanger human health or safety.
9. Reduction of color discharge by application of best available technology is still
not economically reasonable and results in serious hardship without equal or greater benefit to
d and thorough study and evaluation of color removal technologies was
the public. A detaile
performed and reported in Champion's 1995 and 1996 Color Removal Technoloev Reports
submitted to Division as rcquired by the existing color variance.
10. Champion has now completed its mill modernization project which re-configured
its facility as an oxygen delignification, 100% chlorine dioxide substitution (OD-100) bleach
mill. The project resulted in limited color reduction in its effluent discharge. The end-of-pipe
technologies considered in 1988 and updated for the 1996 review established: a) standard

4
water/wastewater separation technology (lime, alum, or polymer) has not been applied in a
similar fashion, b) these technologies would result in high capital and operating costs at the mill,
c) color reduction on this type of waste, using these type .technologies has no operational
efficiency "track record" (effective under normal paper mill production variations, and consistent
and reproducible color removal), and d) the process color removal effectiveness of OD-100 may
present other in-process reduction opportunities that have not yet been realized.
11. A schedule for continued color minimization is necessary. Members of the
public, EPA and the State of Tennessee commented that the variance document proposed in the
public notice did not include any milestones for continued color reduction. Therefore, the
schedule contained in the Ordering Paragraph 4, infra, is established.
12. In review of the color data, including the short time since the re-configured mill
became fully operational, it is determined that a more restrictive limitation should apply for
color. Therefore, the more restrictive monthly and annual average color limitations contained in
the Ordering Paragraph 2, infra, are established.
13. Based on the continued development of color discharge information from the
reconfigured mill, Champion is required to statistically evaluate its monthly average color
discharge,-its annual average color discharge, and the performance of the state line color model.
These evaluation processes are to be ongoing and the results of the evaluations are required to be
reported to the Division of Water Quality prior to each water quality standards triennial review
period. The results of these evaluation processes shall be utilized by the Division and the next
Variance Review Committee to make recommendations to the NPDES Committee on future

5
revisions to the variance. Champion shall follow the Color Data Variance Review Requirements
proposed by the staff and the hearing officer, in reporting these evaluations.
14. As provided in Findings of Fact#8, supra, Champion is also required to take such
actions as necessary to prevent their contribution of true color from exceeding 50 true color units
at the North Carolina/Tennessee state line at all flows equal to or greater than 126 cfs at the
Hepco Gauging Station. Furthermore, the method by which compliance is determined shall
continue to be the color predictive model.
CONCLUSIONS OF LAW
1. Pursuant to the Ordering Paragraph 6 of the July 18, 1988, Final Decision, the
NPDES Committee has reviewed the existing variance following the Champion Canton Mill
modernization program.
2. The previously existing variance from the North Carolina water quality standard
for color, memorialized in the NPDES Committee's Final Decision, dated July 18, 1998, remains
in effect except as specifically modified herein.
3. Based on the effectiveness of the treatment system subsequent to the Canton Mill .
modernization project and due to the potential for improvements in color reductions by use of
bleach filtrate recycling (BFR'), changes to the variance are warranted.
Based on the foregoing Findings of Fact and Conclusions of Law, it is hereby ORDERED
that the previously existing variance from the North Carolina water quality standard for color as
memorialized in the July 13, 1988 Final Decision Ordering Paragraphs, continues in effect as
hereby modified, to read as follows:'
For ease of reference, the language of the July 13, 1988 Final Decision Ordering
Paragraphs is included verbatim, with the modifications denoted by overstriking for deletions

1. Champion's petition for a variance is granted, pursuant to G.S. 143-214.3(e), as a
variance to water quality based effluent limitations for color.
2. The Division ofEavireFffneaW Manageme Water Quality' shall issue NPDES
Permit No. NC0000272. for the Canton Mill, and mediy draft its provisions to reflect all the
conditions of the Fe1F1a15", 1988 draft EPA eeme-emise 'TD^—.� pen ak this modification,
including the following specific wording.
I. Champion shall take such action as necessary to prevent their
contribution of true color from causing the true color at the North
Carolina/Tennessee State line from exceeding 95 SO true color units at all
flows equal to or exceeding 126 cfs (81.4 MGD, the seven-day, ten-year
low flow level) at the Hepco Gauging Station.
Compliance with this requirement shall be measured through a calculation
of instream true color levels at the North Carolina/Tennessee state line by
the following equation:
Sl,6--
�^_�o(RE d
Sl,_ (W�CP. /8.34) + (M WIPfjx_pil
(-0.224 x LOG(HE,)+ 0.781)
HE,x 10
Where:
WTP,= Monthly average Waste Treatment Plant discharge color. L)'
Calculated as the average of all daily loading values (pounds of true
color per day) for a calendar month.
WTPr= Monthly average Waste Treatment Plant discharge flow(mgd).
HEf = Monthly average HEPCO, North Carolina flow (MGD). Daily
flow values less than 81.4 mgd shall be entered as 81.4 mgd.
and bolding for additions.
'- The Division of Environmental Management has been reorganized and NPDES
permitting is now administered by the Division of Water Quality.

7
Sly = Monthly average Instream true color at North Carolina/Tennessee
border (state line).
D,= Color concentration of all dilution streams (13 C.U.).
a":, basi., for each calendar The SLR shall be calculated --� month.
�t SLR values
The Fany i si ( ,.e.. ,a", F 11
for each month shall not exceed 85 50 true color units. Any exceedance
of 95 50 true color units for this average value shall be considered a
violation of this permit/variance
II. The average daily discharge of true color for each calendar month
shall not exceed 298,945 132,341 pounds per day. The average annual
effluent true color loading shall not exceed 172,369 124,923 pounds per
day. For the purpose of this permit/variance only,-"pounds of true color"
is calculated by the following equation:
Effluent Flow (mgd) x Effluent True Color Level (platinum Cobalt Units)
x 8.34.
114
,ess _ j,4 19cI p a
III. PIL The method of analyses used to measure true color shall be
the procedure referenced in FR 39 430.11(b) (May 29, 1974).
3. The Division of 4;;nagejRentWater Quality shall include review
of this variance as a specific item in its Triennial Water Quality Standards review, as required by
the federal Clean Water Act, and make appropriate recommendations to the NPDES Committee.
4. Champion shall continue to study, and evaluate and pursue color removal
technologies and shall report its findings to the Division of
"l .4a ag eat Water
. in
accordance with the following schedule:

DATE ACTIVITY
Continuing Commercial demonstration of bleach filtrate
recycling (BFRT")
March 1, 1998 In conjunction with the scheduled Triennial
Review of N.C.Water Quality Standards:
1. Submit a status report on the technical,
economic, and operational feasibility of
BFR7 technology, including those
analyses prepared for other permitting
agencies concerning its effects on air
emissions.
2. Evaluate.and report on end-of-pipe color
reduction technologies.
3. Evaluate and report on minimization of
color losses from manufacturing process
and from raw material storage areas.
December 1, 1998 Based on the results of the demonstration project
and the conclusion of the status report.
Champion will decide and report on the decision
to operate BFRT" technology as a fully
commercial process on the pinewood line.
December 1, 2000 Champion will evaluate color reduction
strategies for further optimization of BFR7
technology and report on the feasibility of
implementation on the hardwood line.
March 1, 2001 Champion will evaluate and report on
end-of-pipe color reduction technologies in
conjunction with the Triennial Review of N.C.
Water Quality Standards.
June 1, 2001 Champion will submit a report to N.C. DEHNR,
Division,of Water Quality, on the comparative
evaluation of the above collective efforts as part
of the variance review process (Triennial Review
of North Carolina Water Quality Standards).

8 9
5. The Division will provide a status summary report on color removal at the Canton
Mill to the NPDES Committee
„ eH er, c _e June 3n c,.ae. . .,- prior to completion
,
of the Triennial Water Quality Standards review.
5A. Based on the continued development of color discharge information from the
reconfigured mill, Champion will statistically evaluate its monthly average color discharge,
its annual average color discharge, and the performance of the state line color model. This
evaluation process shall be ongoing and the results of the evaluation shall be reported to
the Division prior to each triennial review period referenced in this variance. The results
of this evaluation process will be utilized by the Division and the Variance Review
Committee to make recommendations to the NPDES Committee on revisions to the
variance. Champion shall follow the Color Data Variance Review Requirements proposed
by the staff and the hearing officer in reporting these evaluations.
6. Fegewing the ee npletien Gantan -
and In conjunction with ;�e—€rrst subsequent triennial water quality standards reviews a€teF
r v ;,.lle,. .t rie , the Division will nominate a variance review
- -
' committee. The NPDES Committee will have final approval of the selection of this committee.
Whirl; will Committee membership may consist of NattffE4 D
pe*ekTmei3; Department Staff and at least twe individuals considered authorities on pulp and
paper technology or environmental aspects of that industry from the university or research
communities.' That review committee's report and recommendation will be examined by the
NPDES Committee for a decision on the adequacy of the existing variance. The NPDES
31 The Variance Review Committee membership qualifications are changed to provide
greater flexibility in appointments.

10
Committee will determine if changes in the variance are warranted due to the effectiveness of the
treatment system or because of advances in color reduction technologies for this type wastewater.
All revisions adopted by the NPDES Committee will require the modification of the Company's
State NPDES Discharge Permit.
7. The variance proceeding, and the NPDES Permit No. NC 0000272, shall at all
times be subject to reopening in order to modify the color requirements based upon any
breakthrough in color removal technologies. Such breakthroughs shall be brought to the NPDES
Committee for consideration, by Champion and the Division of Em-ireFmeatal `T.,nage.. ee
Water Quality, as soon as they are discovered.
- S. This variance shall extend for an indefinite period of time, subject to
consideration of the three-year reviews . and Any modification or
termination based thereon shall be subjected to the public hearing process required by G.S.
143-2153(e).
It is further ORDERED that this Modification of Color Variance shall be effective as of
the effective date of the re-issued NPDES Permit No. NC 0000272 for the Canton Mill, and the
terms of the previously existing variance shall continue in effect until that time.

• y
. I1
This the day of October, 1996.
`/icy} •//, ,� , � ,`;i
Daniel V. Besse;Chairman
NPDES Committee

12
CERTIFICATE OF SERVICE
This is to certify that I have this day served a copy of the foregoing MODIFICATION OF
COLOR VARIANCE GRANTED ON JULY 13, 1988 on the parties listed below by the
methods indicated, addressed to each as follows:
William Clarke U.S. MAIL
Roberts & Stevens
Suite 900
One W. Park Square
Asheville,North Carolina 28802
A. Preston Howard, Jr., Director HAND DELIVERY
Division of Water Quality
N.C. Department of Environment, Health
and Natural Resources
9th floor, Archdale Building
Raleigh,North Carolina 27601-7687
Jennie Odette, Clerk HAND DELIVERY
Environmental Management Commission
N.C. Department of Environment, Health
and Natural Resources
9th floor, Archdale Building
Raleigh,North Carolina 27601-7687
Paul Davis U.S. MAIL
Tennessee Department of Environment
& Conservation
6th floor, L & C Annex
401 Church Street
Nashville, Tennessee 37243-1534
David McKinney U.S. MAIL
Tennessee Wildlife Resources
Ellington Agriculture Center
P. 0. Box 40747
Nashville, Tennessee 37204
Gary Davis U.S. MAIL
Tennessee Environmental Council
1700 Hayes Street. Suite 101
Nashville, Tennessee 37203

13
Mike McGhee U.S. MAIL
Director of Water Management
100 Alabama Street, SW
Atlanta; Georgia 30303
This the 15th day of October, 1996.
MICHAEL F. EASLEY
Attorney General
/13=_-4
Daniel C. Oakley
Senior Deputy Attorney General
Environmental Division
P. O. Box 629
Raleigh,North Carolina 27602-0629
919/733-5725

Box C-10
• Canton,North Carobw—116
UChampion
Champion International Corporation D
0
November 19, 1996 NOV 2 f► Q
Mr. James W. Meyer ASHfVr�R �A(r)Y
4405 Reedy Creek Road �EGrpNp[OF f
Raleigh, North Carolina 27607-6445
Dear Mr. Meyer:
This la".: r is Lkc r ceponse to your latter dated November 6. 1996, regarding deviations
cited from the laboratory certification maintenance inspection of October 2, 1996.
Deviation: Color- Values less than the established minimum reporting level were
reported.
Comments: This occurs at the Big Creek sampling site using the spectrophotometric
procedure. The minimum reporting level has been established at 10 C.U.
Correction: All spectrophotometric river color tests that produce a result less than the
minimum detection limit of 10 C.U. are now reported as less than 10, (<10).
Deviation: Ammonia Nitrogen - The meter being used, an Orion 940, does not calibrate
a straight line curve when a multiple point calibration is used.
Comments: If each segment of the curve is not checked, a linear regression Calculation
may be done to establish a straight line curve. Other options would be to do a two
point calibration or use the spectrophotometric procedure.
Correction: A two point Calibration is now being used and verified with a mid-range QC
standard.
Deviation: Ammonia Nitrogen - The value obtained on the mid-range QC standard was
often not acceptable.
Comments: When the mid-range standard varies by more than + or- 10%, the analysis
is out of control. The analysis must be terminated and the problem corrected.
Correction: If the mid-range QC standard is out of range, the cause of the out of range
standard is determined, corrections made, the instrument recalibrated, and the mid-
range QC standard rerun. Samples will not be run until the mid-range QC standard is
in range.

Deviation: Fecal Colifomt - The water bath thermometer is calibrated quarterly, but it is
not documented.
Comments: Supporting records shall be maintained as evidence that these practices
are being carried out.
Correction: A traceable thermometer is now being used in the water bath eliminating
the need to calibrate quarterly. The traceability documentation is on hand for
inspection.
Deviation: Fecal Coliforn - The calibration of the pH meter used to check the media
was not documented.
Comments: Supporting records shall be maintained as evidence that these practices
are being carried out.
Correction: The pH meter is being calibrated with the calibration documented each time
media is prepared.
Deviation: Fecal Coliform - The Town of Canton effluent sample was not dechlorinated.
Comments: All chlorinated samples must be dechlorinated at the time of sample
collection.
Correction: The Town of Canton effluent sample collection bottle now has sodium
thiosutfate added to remove any possible chlorine residual, when the sample is
collected.
If you have any questions, comments, or need additional information please contact me
at 704-646-6720.
Sincerely,
John Pryately
Laboratory Supervisor
cc: Derric Brown, Mike Cody, Joe Deschene,
Gary Francies, Keith Haynes, Bill Manzer

State rt Environment,North i
Department of Environment,
Health and Natural Resources •
Division of Water Quality
James B. Hunt,Jr., Governor
Jonathan B. Howes, Secretary p E H N R.
A. Preston Howard,Jr„ P.E., Director
Asheville Regional Office
DIVISION OF WATER QUALITY
November 20, 1996
Mr. Derric Brown
Champion Canton Mill
Post Office Box C-10
Canton, North Carolina 28716
Subject: Sampling Results
Performance Audit Inspection
Champion Canton Mill
NPDES Permit No. NC0000272
Haywood County
'Dear Mr. Brown:
Attached are the remaining laboratory analyses results, for the
samples collected during the Performance Audit Inspection conducted on
October 2, 1996.
If you have any questions or comments, please do not hesitate to
contact me at 251-6208 .
Fnre
Ith Ha
ynonmental Specialist
Enclosure
cc: Roger Pfaff, EPA
Interchange Building,59 Woodfin Place NOCAn Equal FAX [phone]
Asheville,North Carolina 28801 Opportunity/Affirmative Action Employer
Voice 704-251-6208 50%recycles/10%post-consumer paper

DIVISION OF ENVIRONMENTAL MANAGEMENT _
- CArmisOy L.banlop Report/1Yala Quality ,. I.b Numbs 6W5818
W� SAAIPLETYPE Dme Recei,ed: IWJAK
COUNTY HAYWOOD PRIORITY - Tame Recei.N: 9:I0ARI
RISER BASIN: AhI01ENT QA STREAM .\�' EmUENT Raeleed By 1Imw
REPORT TO , ARO R,ai.o.1 Once O COMPLIANCE CHAINOFCUSTODY I LAKE, INFLUENT
Other : EMERGENCYESTUAR\' ❑ Om R,,.c: TM
COLLECTORISI r IIAITJFS � Ume R,poned: II/JN6
E armed ROD Be.,: Sution Lisbon:CHAMPION -
Seed: C6ladnated: Reinulo:
5lalianR _ D.C.Depin('T/mm/ddl Data End D7'Imm/dd) Ti.,Bepin Time End Depth-Dhl.OD,D851 V.I.,TJ'pe-A,II,L Cnmpmlle-T,5• Snmple TSye
0043272 Mimi caw /
BOD310 mg4. CLloride940 mpL X NHJu N610 6.0 mpL X LI-Lithium 1132 450 u,JL
COD IFagh 340 ma/L Chi a TA 32217 uFL X TKN an N 623 6.6 mg1L X Mg.hbgnmium9 5.8 .,L
COD Lav]J3 mP/L CRI.:Ccar322D9 ug/L X NO2 plot NO3 u N 630 0.01 ro'L X hin-man'sear,III B50 uVL
CRIi10ociAr FeW31616 /IOOmI Ph.,h,,l..32213 uFA. P:Totalas P663 mg/L X Na Sdium 929 390 mg/L
Colifam:hlFTeW31504 /IOGmll X Color.True 10 ISO e.u. POla P 70307 m,L X Anaic:Tml COD 131rWL
Calif:tube Fed 31615 /IOOmI Col.:(9Hl aJ pH. C.U. P:DirsolvedIts PW mA X Se-Sclaium 1147 6x uao.
Colifatm:F.IStrop J167J /IUUmI Col.:PH 7.6 92 c.0 K-Poucsium mgA. X Ito-hlacury 1190 col ugfL
Rmiduc:ToW5OO mg/L Cyanide 720 mVL X Cd.Ctdtoium 1027 e2.O uA Be Borium ug/L
Volatile 303 mgA. ricc,lde 951 mgA. X Ur '.mium:Tmsi 1034 e25 ug)L O.a.chl.ine Peckides
Fixed 51D - mg/L Fameldehyde71180 mWL 1XI
Co-Copar l0/2 6.6 uSIL Orgcaopho.haus Peaticida
Residue:Suspended 530 mg/L 0.ase Coal Oil,336 .,/L Ni-Nickel 1057 e10 ugR.
Volatile 535 .,/L HCodnas Tmd 900 .;M1 Pb-Led IDS e10 uVL Add llabicides — -
FixedSJO .,L Spairic Cpd.95 uhlhoicm5 Z -Zinc 1092 36 vg•L
{:, I pH JDJ unh. hIBAS 39260 Ce A. V.VJndima "WIL BveMeulnlCAddE .bl,Oalanics .
Acidity to pH 4.5 436 .,UL Ph.1.32730 ugh. A,Sit,or 1077 e5.0 ugA. TWI Diesel Range
Aciditymp7laJJJS m.i Su11Coe9J5 .,'L AI-Aluminum 1103 B70 ug/1.
ADdlnitytopHIJJ15 m�A. Sulfide 745 mg A. Br B,glliun 1012� e10 ug/L Pmpable O.mi.(VOA bonle,eQd)
ANA - Alkalinimlo,HJJJ1D -A 0o.n Cg-C.16.916 7B mg1l. TFIl Gasolia Range
TOC610 mp/L Co-Ccb,lt ID37 e50 co& TPNJBMX G.R.RCoge - -
- Turbidity l6 NTU Wif.Tout Tube •II00 mU X jFe,l.IW3 550 '4. Ph7lopl.kaon -
' COMMENTS: 'I _. .. ._. . . , ' .. .... _....— ..: .. .... .
U uuL
Nov 15 ice: 1�
17.TER OUP:LIT-i SEM ON
ASFIEVILLE REGIMAL OFFICE '

DIVISION OF ENVIRON ENTAL MANAGEMENT WATER QUALITY FIE...,-LAB FORM (DM1) O For Lab Use ONLY
COUNTY C� Q 0 Lab Number:
PRIORITY SAMPLE TYPE Date Received• & a6 TIme:Q
RIVER BASIN yy\ 4 . ^❑ ❑ ❑REPORT T CdRd FRO MRO RRO WORO WIRO WS O TS AMBIENT Qp STREAM EFFLUENT Reed by: N/ From: Bus ourie nd Del
AT BM A
Other 'COMPLIANCE ❑ CHAIN ❑ LAKE ❑ INFLUENT DATA ENTRY BY: CK:
OF CUSTODY
Shipped by: Bu Staff, Other, ❑EMERGENCY ❑ESTUARY DATE REPORTED:
COLLECTOR(S): S
Estimated Boo Range:0.5/5-23/25-65/40-130 or 100 plus STATION LOCATION:
Seed: Yes ❑ No Chlorinated: Yes❑ No❑ REMARKS:
Stat� Q Date Begin (yy/rem/dal) Time Begin Dats End Time End I Depth DM DB­DBM Value Type Composite Stipple Type
O d 'QU c ( 'a '�;Q A H L T'�B G GNXX
1 BOD5 310 m2/1 Chloride 940 mg/I NH3 as N 610 m9A LI4.Ithlum 1132 00/1
COD High 340 mg/1 Chi a:Trl 32217 u /1 TKN as N 625
2 g arg/I Mgi4a0nes1um 927 mgA
3 COD Low 335 mg/1 Chi a: Corr 32209 USA NO2 plus NO3 as N 630 mgA Mn-Mangeneae 1055 ORA
4 Colllorm:MF Feeai 31616 /IOOmI Phaophytin a 32213 ug/I P:Torsi as P 665 orp/I I>< Na•Sodlum 929 mgA
5 Colllorm:ME TO 31504 /100mI 4 Color:True 80 Pt-Co PO4 as P 70507 mgA ArserdmToml 1002 m1A
6 Colllorm:Tube Fecal 3I615 /100mi COIor:(PH ) 83 ADMI P.Dlssolvd as P 666 ma/1 Se•Selenlum I147 agA
7 Calif..;Fecal Strap 31673 /100m1 Color:pH 7.6 82 ADMI Hg-Me.mv 71900 USA
S Residue:Total 500 mg/I Cyanide 720 mg/I Cdfsdmlum 1027 u9A Ora anochlodne Pesticides
9 Volatile 505 m9/1 Fluoride 951 mg/I C,-Chromium:Total 1034 agA Omeoupt Fhorus Pwdd-d.
10 Fixed 310 mg/I Formaldehyde 71880 mg/I CuCoppm 1042 og/1
11 Residue:Suspended 530 me/1 Grease and Oils 556 mg/I NI-Nickell 1067 u#A Acid Hmbkides
12 Volatile 535 me/1 Hardrress Total 900 m9/1 Pb•Lud 1051 ORA
13 Fl:ed 540 mg/1 SpecRic Cold.95 uMhos/am2 2n-21nc 1092 egA BOW Neutral Extractable Organics
14 PH 403 unite MBAS 38260 mg/1 Acid Extractable Organics
15 Acidity to pH 4.5 136 mg/I Phenols 32730 ug/I A Ilver 1077
ugA
16 Acidity to PH 6.3 435 mg/I Sulfate 945 mall AI-Aluminum 1105 uVI Purr eable Organics(VOA battle re0'd)
17 Alkalinity to PH 8.3 415 mg/1 Sulfide 743 mg/I Be4lerYlllum 1012 ORA
18 Alkalinity to pH 4.5 110 mg/I Catalcium 916 RWA
19 TOC 680 mgA Co-Cobalt 1037 ugA
20 Turbidity 76 NTU X Fe-Iron 1045 USA Minuplankton
Sampling Point■ Conductance at 25 C Water Temperature C D.O.mg/l PH Alkalinity Acidity Air Tempemmre 10
PH 8.3 PH 4.5 pit 4.5 pit 8.3
2 94 10 300 1. 400 1. 827A4 431 82243 182242 20
Sslinily 8 Precipillon UNdey) Cloud Cover X Wind Direction Well) Strearn Flow Severity Turbidity Severity Wind Velocity MA4 Stream Depth IL St eaam Width IL
480 45 32 % 1351 1350 35 [earr
4 4
DM1Aistdsed 10/86

DIVISION OF ENVIRONMENTAL MANAGEMENT
Chemblry L.boratory Repo"/Water Qusiy Lab Numbm : 6WS818
ElSAMPLETYPE D.Re«iud: Iw4M
COUNTY XAYWOOD PRIORITY Time Rttd,d: 9:I0AM
RIPER BASIN: AMBIENT QA STREAM Eleceiv EFFLUENT Red By HMW
REPORT TO ARO Regional ODin X❑ COMPLIANCE CHAIN OF(,USTODY I LAKE ❑ INFLUENT
OOer : EMERGENCY ESTUARY a Dora Releazed TNT
COLLF.CTORIS): HAYNES Unm RcPnned 11u;M,
Eellm.ted ROD Range: Stallon Localloe:CHAMPION
S,d: CM1lorinaed: Remnkr.
S..6.ox D.le Beeln lyylmmfed) Data E.d U]'/mm/dd) Time Begin Time End Deplb-DRI,DO.DBM 3'alae Typa-A,H.L Ctua,"tsT,5, Sample Type
OOfl2)2 %TOOT o800
BOD 310 mg/L Cf,Wde 940 mu/L X NH3 w N 610 5.0- myiL X Li-Lithium 1132 150 ug/L
COD High 340 mg/L CM.:Tri 32217 .,L X TKN an N 625 6.8 mg/L X 61g-klagxdum 9 5.8 mglL
COD Low 335 me/L CH a:Car 322W ug/L X NO2 plan NO3 a N 6" 0A1 mg/L X MP-Manemmw 10 R50 ug/L
Colifoml:klF Fecal 31616 /100ml Pheoph5ma 32213 ug/L PTolal.a P665 mWL X Na Adlum929 380 mg/L
CPU. MFTad31501 /IWmI X Col,True 80 360 POI as P)O30] mVL X AramicTaal 1002 13 ug/L
Colifmm luba Fad31615 /100ml Colo,(PH)83 PH. au. P:DissohNas P666 mg/L X Se-Selenium lla] <5.0 ug/L
Colifi Fwal Sim 11673 IIOOmI Cola:PH 7,6 82 pu K-POlwdom mg/L X 118-6lmcury]I% <0.2 ue/L
Residue.Tuml 500 mg/L Cyanide 720 mWL X Cd.Cadmium 1027 <2 0 uglL Be euium ug2
Volui1e505 mg/L Fluoride 951 PTWL X Cl{lromium.Total 1034 <25 ug/L Orgumchlai:m Pnikides
Fixed 510 rng/L Famald6yde7I8W mg/L X Cu-Copya 1012 66 ug/L pgumphwphorus Peairidea
Residua.Suspended$30 m4/1, Gmaa and Oils 5% mg/L X Ni-Nickel 1057 <10 uglL
\'nlmik 535 mg/L Hadneu Tmal Opp mmi X Pb-Land 1051 <10 ug4. A6dllabicides
Fi.ad 540 n:g L Spaific Cund.95 uMluo'cm2 X Zn-Ziw 1092 36 ua-L
PH KU uni¢ MBAS 38260 mg/L VA'anadium ug/L 92wMeuoal&Acid Extrwtable Organics
Acidily to PH 45436 nm,L Phgm,632730 ug/L X Ag-Sihm 1017 <5.0 ,1, 11-11 Diewl Range
Acidi.�to pH 83435 ."'1 Su11ue915 mgQ. X AT Aluminum 1105 870 ug1
Alblinily to PIT 8.3 4I3 mg;L Sulfide 745 mg/L X Ba,8 Ilium 1012 <10 aY uga. Pmgeable Oreanica(VOA bonle.epol
Alkalinity to PH 4 5 t 10 mg/L Boron X Ca.Calcium 916 TO m'L TPH Gasoline Ran e
TOC 650 m&fL X Co-C96all 1037 <50 'l- TPH/BTEX Gaoline Range
m Tbidily]6 NTU Collform Tmal Tube '/MOO mp X Fa Iron 105 560 uRL Pbcmnlankwn
COMMENTS:
D �
NOV 996 I
WATtR C'"'PLITY SECTION
_i- -.INNAL OFFICE

CHAMPION EDHS D:704-646-6892 NOV " " "96 8:20 No .001 P .01
IF/IAX
FAX COVER SHEET
ENVIRONMENTAL, OCCUPATIONAL,
HEALTH AND SAFETY.
CHAMPION INTERNATIONAL CORP.
CANTON MILL
TO: K�t't n e S
FROM: Susanne, K0t.15 � 1,
DATE: 1 1 \I i l 4
NUMBER OF PAGES:
(INCLUDING COVER)
NOTE:
e.
e q.jes 1p.
COL1/ , �. / F A4
vc_Sfluhs or fr b)erns
SENDERS PHONE NUMBER: [phone]
FAIL NUMBEA:[phone]
FAX PROBLEMS: (704) 64"700 D
4w Ov �
asH�TfR � O
f

N. C . DEPA: 4ENT OF ENVIRONMENT, EALTH,
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
59 WOODFIN PLACE
ASHEVILLE, NORTH CAROLINA 28801
PHONE/704/251- 6208 FAX/704/251-6254
TO: IV\��F_ 1°�C_ � e-2
FAX # : ��Uc 156a
FROM:
DATE: \b \ 1 \a
# OF PAGES INCLUDING THIS COVER:
MESSAGE : If questions, please call 704/251-6208 .
\OD��C\Q, -vOC � f

CHAMPION EOHS 0:704-646-6892 NOV 11 '96 8:20 Na .001 P.02
Champion International
Canton, NC . _
NC/TN State Line True Color mg/1 (SLc) _
NFDES Color Model Calculation
Date SU Color Date Sl.c Color Date SLc Calor
01/01/95 21.5 02/07/95 22T . 16/95 16.5
01/02195 22.8 2/08/95 23.7 03/17/95 17.1
01/0 9S 25.4... 02/09/95 23.1 03/18/95 18.5
01/04/95 25.6 02/10/95 20.3 03/19/95 18.1
01/05/95 29.0 a2/11195 17.6 63120195 19.8
WOOS- 23.8 02/12N5' 18.1_ 03/21/95 7.7 _
01/07(95' 17.2 02/13/95 19.2 0322J95 17.9
01108T95 20.1 02114195 19.3 0323/95 17.8
Ol/09/95 22.S 02/15/95 19.8 03/24195 18.1
01/10/95 21.2 02/16/95 16.0 0325/95 fs.5
01/11/95. 20.9 02/ 77/95 "15.4 03/26/95 17.6
01/12/95 ­ 8. 02/18/95 15.6 03/27/95 ]7.4-
01/13/95 20.6 02/19/95 15.4 0398/95 16.8
01/14/95 1&1 02/20/95 14.6 03/29/95 15.2
01/15195 16.2 02/21/95 14.8 03/30/95 16.7
01/16/95 14.6 02/22/95 14.8 03/31/95 19.3
01/17/95 15.0 02/23%95 13.8 04101/95 20.3
01/18/95 15.0 02/24/95 14.3 04/02/95 20.8
01/19/95 14.8 _ 02/25/95 14.2 04/03/95 22.0
0120/95 1s.0 02/26/95 15.4 b4jUW.S 26.1
6
l/21T95 15.5 0227/95 15.9 04/05/95 26.2
0122/95 15.6 0228/95 15.2 04p16/95 23.5
0123/95 15.7 03/01/95 ]5.8 04107/95 22.0
0124/95 17.3 03/02/95 - 17.2 04/08/95 22.3
01/25/95 17.6 03/03/95 19.5 04/09/9.5 25.1
01/26/95 16.6 03104/95 17. 04/10/95 29.6
0127/95 16.0 03/05/95 16.5 04/11/95 31.7
0128195 18.3 03/06/95 17.4 04/12(95 32.1
01 J29/95 19.0 03/07/95 18.6 04/13/95 26.5
01/30/95 20.0 03J08/95 1.5.7 *04/147§5 24.9
01/31/95 _ 20.0 )3/09/95 16.0 - 04115/95 23.5
02/01/95 21.b 03/10/95 TO 04116/95 23.4
02/02/95 20.1 03/11/95 16.2 04/17195 22.3
02/03/95 24.8 03/12/95 14.7 O4/18/95 20.3
02/04/95 19.0 03/13/95 14.7 1 /95 19.6
02/05/95 17.6 0371 15.3 O4/20/95 20.6
02/0 /9 20.8 03 5 5 1 15.5 04/21/95 20.7
SKK 11/8196

CHAMPION EOHS }:704-646-6892 NOV ' "96 8:21 No .001 P .03
Champion International
- -- -- I Canton, NC I -
__ NCIITI State Line True Color ME (SLO
N1'DLS Color Model Calculation
64/22195 17.4 _ 5/31/95 26.7 07/09%95 30.5
04123/95 21.9 06/01/95 24.0 07/10/95 36.7 _
04/24/95 - 20.9 06/02/95 17.6 - 07/11/95 30.0
_ _04125/95 21.3 06/03/95 _ 17.$ •• 12I0 27.9
/95 _ 19.9 06/04/91 21.9- 07/13/95 28.8
04MI95 18.1 06/05/95 24.0 07/14/95 32.4
04/28/95 16.5 06/06/95 23.6 07/i3X5 25.8
04/29/95 21.6 06/07/95. 24.8 07/23/95 35.1
04/30/95 26.3 06/08/95 33.1 07/24/95
05/01/95 26.8 06/09/95. .. .......37. 07/25/95 36.6
05/OW95 .. ........1 .3 06/10/95 31.6 07/205 _ 35.8
05103/95 22.5 06/11/95 29.7 07/2'1195 39.8
051005 25.3 06/12/95 25.4 07/28/95 30.4
05105/95 24.4 06/13/95 26.9 07/2 5 30.1
05 5 22.3 06/14/95 25.7• 07/30/95 34.6
0 7 5 22.5 06/15/95 20.9 07/31/95 38.8
05/08J95 -- 22.1 06/16/95 19.8 08/)l/95 26.9
05/09/95 23.9 _ 06/17/95 18.7- O8%O7J95 35.0
05/10/95 ­23.1 06/18/95 21.9 OS/03/95 35.1
051II/95 21.7 0 195 25.3 08/04/95 29.5
05/12/95 21.3 06/20/95 223 08/05/95 26.7
05/13/95 27.8 _ 06/21/95 21.1 MOOS- 249.3
05/14/95 ...._.._.24.6 06122/95 18.5 _08/07/95 30.3
05/15/95 20.4 06/23/95 21.1 08/08/95
05/16N5 22.5 06/24/95 24.7 • 08/09/95 30.1
05/17/95 24.5 06/25/95 22.0 08%10%95• 31.4
05/18/95 23.8 06/26/95 19.9 08/11/9S 31.4
05/19/95 22.0 06/27/95 21.1 08/12/95 35.7
05/2.0/95 26.2 06128/995 27.$ 08/13/95 42.9-
05/21/95 29.8 06/29/95 26.6 08/14/95 59.4
05/22/95 28.9 06/30/95 zf,9 08/15/95 80.1
05/23/95 25.9 07/01/95 22,6 08/16/95_ 43.2
05/24/95 30.5 07/62/95 24.7 08/17/95 29.6
05/25/95 _ 32.1 07/03/95 28.3 8/18/95 53.0
O5/26/9$ 31 07/04/95 41.7 _ . 691ff 5 22.6
05/27/95 25.1 07/05/95 42.7 09j(15/95 23.3
05/28/95 --25.3 07/06/95 34.6 09/06/95 73.6
OS/29/95 23.3 07/07/95 28.9 09/07/95 23.4
05130/95 _... 29.2 07/08/951 28.2 09MI95 1 243
SKK 11/8/96

CHAMPION EDHS 1:704-646-6892 NOV ?1r'96 8:22 No .001 P .04
Champion International
-- I Canton,NC __
NC/IN State Line True Color mg/l (SLc
NPDES Color Model Calculation
09/09/95 26.3 - 10/17/95 26.0 li/24/95 22.3
09/10/95 30.5 / 5 24.6 11125/95 22.4
09/11/�526.5 101106 23.1 11/2619.5 25.4
69/12/95 26.7 10/20/95 23.9 11/27/95 23.5
09/13/95 27.9 10%21/95 24.7 11/28/95 23.2
09/14/95 26.2 10/2?,/95 25.0 11)29%95 24.0
09/15/95 32.4 10123/95­ 25.8 11/30/95 7.5
09/16/95 30.9 10/Z4j93 2 .3 12/01/95 26.3
0 17 5 27.6 10/25/95 26.5 1ZI02/95 31.5
09/18/95 26.9 10126/95 34.8 12103/95 25.6 _
09/19/95 27.1 10/27/95 32.8 12/04/95 25.2
09/20/95 29.8 10/28/95 29.0 12/05/95 23.1_
"& 5 40.1 10/29/95 34.6 12/06/95 25.6
09/22/95 36.7 10/30/95 36.8 12/07/95 27.0
09/23/95 28.3 10/31/95 _ 34.0 12/08/95 27.4
O§/1 95 28.6 11/01/95 - 29.3 12/09/95- 22.6
09/25/95 32.0 11/02/95 26.1 12/10/95 25.3
-09/26/95 34.7 I1/03/0 7.2 12/11/95 26.2
7 5 35.5 11/04/95 29.0 12/12/95 29.2_
09/28/95 39.2 11/05/95 30.2 12/13/95 32.8
09/29/95 40.7 11/06/95 45.0 IW14/95 23.7
09/30/95 41.5 11/07/95 27.5 12/15/95 27.2
10/01/95 44.2 '11/68/95 21.2 12/16/95 30:4
10/02/95 38.6 11/09/95 23.5 12/17/95 13.3
10/03/95 35.4 _ 11/10/95 22.8 12/18/95 24.7
LO/04/95 17.5 11/11195 18.2 12/19/95 20.1
_
I0105195 17.3 11lIZ195 17.5 12/20/95 19.5
10/0619.5 16.2 11/13/95 18.3 12121%95 24.1
10/07/95 18.1 11114/95 20.7 12/22/95 22.9
10/09/95 19.0 11/15/95 21.1 I2/23/95 23.4
10/09/95 70.1 11/16/95 21.6 12/24/95 24.0
10/10/95 20.7 11/17/95 210 12/25/95 23.4
10/11/95 20.5 11/18/95 20.4 12/26/95 24.1
IO/12/95 20.6 11/19/95 23.5 12/27/95 253
10/13/95 20.9 11/20/95 26.2 12/28/95 26.5
10/14/95 22.8 W21/95 -- 21.8 12/29/95 25.8
10/15/95 22.1 11/22/95 25.7 12J 5 24.7
10/16/95 25.9 *' '11 3/ 5 26.5 12/31195 28.1
SKK 11/8196

CHAMPION EOHS :704-646-6892 NOV 11106 8:22 Na .001 P .OS
Chain ion International
- - Canton.NC _
N4&N State line True Color mg/1(SLc)
NPDES Color Model Calculation
01/01/96 23.1 02l10/J 17.3 03%2I%96 24.3
Ol/U2/96 21.7 62/il/96 17.8 _ 03/'Z(96 21.6
01/03/96 20.1 02/17496 19.5 03/23I96 18.5
01/04/96 27.1 02/13/96 19.6 03 6 18.7
01/05/96 27. U 14/96 19.9 03/25/96 24-7
___ 27.5 02/15/96 20.7 03/26/96 22.2
61/07/96 6.3 1 02/16/96 19.6 03/27/96 19.9
_
01/08/96 32.8 _ 02/17/96 19.3 03/28/96 15.6
01/09/96 45.6 �02/18/96 26.5 03/29( 16.5
OV10196 36.0 .._.OVI-9/96 27.3 03/30/96 17.2
11 25.8 62NI96 21.9 03/31/96 20.1 _
01/12/96 33.3 02/21/96 _ 21.9 04/01/96 17.4
.01/13/96 39.0 02/22/96 _ ._20.1 04/02/96 I9.3
01/14/96 28.6 0223/96 18.6 04/03/96
01/15/96 23.6 18..5 04/04/96 -_ 19.2
Olt 6 22.3 02J25/96 23.4 04/05/96 19.6
01/17/96 19.2 02126/96 26.1 04/06/96 ---_ 17.6
01%18/96 16.3 _ 02/27/96 211*­ -04/07/96 17.3
01/19/96 17.4 0228/96 17.2 04 17.0
01/20/996 1 .1 02/29/96 19.3 04/09/96 16.7
�01121196 19.3 03/01/96 18.7 04/10/96 17._5
OM2196 19.7 03/02/96 211.5" b4%11196 17.6
01/23/96 -- 18.7 03/D3/96 20.5 04/12/96 - 22.1
01/24/96 18.2 -03/04/96 18.2 04/13/96 _..-
0 25/96 I8.4 ...11'9/I15/96 18.0 04/1*6 - 17.5
0126/96 17-5 03/06/96 15.4 04/15196 19.2
0127/96 16.6 03/07/96 16.8 04/16/96 22.1
0128/96 15.6 03/08(96 15.9 04/17/96 R-9 _
01/29/96 16.3 03/00/96 17.4 04/18/96 19.9
I 0 6 17.2 03/10/96 F _ 19.0 04/19/96 19.5
01/31/96 20.0 03/11/96 19.3 04/20/96 2{l2
02/Dl/96 17.1 03/12/96 26.4 04/21/96 18.9
- OZ(02/96 17.1 03/13/96 21,4 0422/96 21,8
02103/96 .. 1.5.8 03/14/96 20.1 00RD 5
02/04/96 15.0 (3/15/96 18.3 64)t4%96 27.5
0210S/96 15.8 03/16/96 17.5 04,25/96 2-4,0
02/06/96 27.0 D3/17/96 17.7 [M%l6%9G 17.8
02/07/96 23.6 03/18/96 21.3 04I27/96 ] .
02/08/96 20.5 17.5 04/28196 17.5
02/09/96 17.1 68 16.4 04/29/96 16.9
SKK 1118/96

CHAMPION EDHS :704-646-6892 NOV 11 '06 8:23 Na .001 P .06
4�
C11aMpinn Intemational
Canton, NC
NQ TN State Line True Color mg/1(SLc)
NPDES Color Model Calculation
04/30/96 15.8 28.9 07/17/96 30.6
05/01/96 ]7.4 06/09/96 19,2 .07/18/96 25.5.
05/02/96 17,6 66110/96 17.2 U7119/9G 25.2
05/03/96 17.9 66%11/96 18.5 28.0
6S/U4/96 18.4 06/12/96 17.6 07/21/96 32.7
05/05/96 18.6 06/13/96 - 1 .9 07MB6 32.5
05/06/96 19.1 06/14/96 17.9 07/23%96 31.7
05/07/96 21.1 06/15/96 23.8 07/24196 31.5
05/08/96 19.9 06/16/96 20.7 07/25/96
05/09/96 20.5 06/17/96 21.7 07/26/96 24.2
05/10/96 21.4 06/18/96 25.5 07/27/96 24.5
05/11/96 24.4 06/19/96 23.0 07/28/96 23.2
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05/12/96 21.0 06/20/96 23.2 07/29/96 D.8
05/13/96 25.1 b07/3
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05/15/96 22.6 06/23/96 30.3 08/01/96 18.9
05/16/96 17.9 06/24/96 31,7 08/02/96 19.4
05/17/96 25.5 06/25/96 31.1 08/03/96 24.9
05/18/96 23.8 --06126/96 26.8 O8/04/96 - 44.0
05/19/96 25.0 _ OG/27 9 30.8 08/05/96 58.2
5 0/96 25.3 06/28/96. 29.3 08/D6/96 31.G
05/21/96 23.6 0029/96 28.8 08/07/96 25.7
05%22/96 _ 18.9 06/10/96 26.1 08/08/96 277- ..._
05/23/96 13.8 07/01/96 35.2 U /0 6 25.7
05/24/96 12.4 --- 07/02/96 39.7 08/10�6 28.4
05/25/96 15.2 07/03/96 30.0 68/106' _ 27.7
05/26/96 17.9 07/04/96 38.0 08/12/96 17.1
05/27/96 19.3 07/05/96 38.1 08/0196 16.4
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05/30/96 17.9 07/08/96 40.7 08/16/96 2A.4
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06/04/96 - 23.3 07/13/96 33.8 08/21/96 _ 30.0
06/05/96 23.9 07/14/96 '35.7 08/22J96 33.7
06/D6J96 26.0 07/15/96 32,7 08/23/96 21.4
O6/07/96 23.6 -- 07/16/96 30.3 08/24J96 22.5
SKK 1118196

CHRMPION EOHS :704-646-6892 NOV 11 '96 8:23 No .001 P .07
Champion International
Canton,NC _
NC/IN State Line True Colormg/l (SLc)
NPDES Color Model Calculation
08/25/96 21.7 (T/29/96 17.1 11/04/96 30,1
08/26/96 21.5 09/30/96 20.0­ 111/05/96 25.9
08/27/96 23.8 - 10/01/96 21.4 11/06/96 22.0
08)28/96 -- 28.7 10/02/96 20.8 -
08/29/96 _ 21.9 10/03/96 19.7
08/30/96 24.9 10/04/96 23.6
08/31/96 23.5 10/05/96 24.1 _
09/01/96 24.6 10/06/96 22.9
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69/03/96 25.8 10/09/96 23.9 -
09/04/96 17.5 _ 10/09/96 24.5 _
09/05/96 17.1 10J10/96 25.8
09/06/96 21.6 10/11/96 19.8
09/07/96 304 10/12/96 21.3
09/O8/96 27.3 10/13/96 _ 47.1
09/09/96 54.8 10/14/996 80.4 -
09/10/96 51.3 10/15/96 43.3
09/11/96 35.7 10/16/96 28.0
09/12/96 _ 33.5 10/17/96 22.6
09/13/9b 31.0 10/18/96 18.0
09/14/96 40.2 W19/96 14.9
09/15/96 36.3 10/20/96 15.4
09/16/96 28.0 10/21/96 16.3
09/17/96' 18.5 10/22/96
09/18/96 24.8 10/23/96 22.2
09/19/96 28.7 10/24/96 27.4
09/20196 27.3 10/25/96 30.9 -
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09/24/96 32.7 10�29/96 32.5 -
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SKK 11/8f96

NC CEM WO ENVSCI Fax:[phone] Nov 8 'w- 14:11 P.01/03
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' State of North Carolina Y '
Department of Environment,
Health and Natural Resources �4 61
f� A Division of Water Quality _
X James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary p E H N R
A. Preston Howard, Jr., P.E., Director
November 6, 1996
Mr. John Pryately
Champion International WWTP Lab
P.O. Box C-10
Canton, NC 28716
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Mr. Pryately:
Enclosed is a report for the inspection performed on October 2, 1996 by Mr.
Gary W. Francies. Within thirty days, please supply this office with a written item for
item description of flow these deviations were corrected. A response is not required
for comments or recommendations. If the deviations cited in the enclosed report are
not corrected, enforcement actions may be recommended. For certification
maintenance, your laboratory must continue to carry out the requirements set forth
in 15A NCAC 2H .0800.
Thank you for your cooperation during the inspection. Please contact us at 919-
733-3908, extension 243, or, 704/251-6208 ,extension 285, if you have questions
or need additional information.
Sincerely, /�
"� -mgf-
James W. Meyer
Laboratory Section
Enclosure
cc: William B. Edwards, Jr.
Gary W. Francies
Asheville Regional Office
Laboratory Section,4405 Reedy Creek Road, yC FAX [phone]
Raleigh,North Carolina 27607-6445 Niq
An Equal Opportunity/Affirmative Action Employer
Voice 919-733-3908 50%recycles/10%post-consumer paper

ON- SITE INSPECTION REPORT w
LABORATORY NAME: Champion International
WWTP Lab
ADDRESS: P. O. Box C-10
Canton, NC 28716
CERTIFICATE #: 198
DATE OF INSPECTION: 10/2/96
TYPE OF INSPECTION: Maintenance
EVALUATOR(S) : Gary Francies
LOCAL PERSON(S) CONTACTED: John Pryately, Derric Brown, Mike Cody
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the
requirements of 15A NCAC 2H . 0800 for the analysis of environmental
samples .
II. GENERAL COMMENTS:
The laboratory is spacious and well equipped. All equipment is well
maintained. Since the last inspection the laboratory has obtained the
following equipment : 1) a water distillation system for the bacteriology
lab, 2) an ice machine, 3) a DR 4000 spectrometer for COD and river
Color analyses, and 4) two Accument 10 pH meters . Records are well kept
and most data appeared accurate. Excellent sops (Standard Operating
Procedures) have been developed for each parameter. Some further quality
control procedures need to be implemented.
A Fecal Coliform MPN sample was split with the following results :
Champion Laboratory State Laboratory
70/100 ml 170/100 ml
gassed 2-1-0 gassed 4-1-0
An effluent Fecal Coliform MPN sample was split with the following
results :
Champion Laboratory State Laboratory
<20/100 ml 13/100 ml

Page 2 .
Champion
General Comments continued
Effluent samples were split with the following results (all values are
mg/1) :
Champion Laboratory State Laboratory
COD 184 154
Ammonia nitrogen,
distilled, electrode Not Analyzed 4 . 9
undistilled,electrode 6 .4 4 . 6
The States central lab also analyzed the ammonia nitrogen sample by the
Automated Method and obtained a value of 5 . 0 mg/l.
TSS 13 13 .5
Total Residue 1713 1776
Hardness 210 211
BOD 6 .7 7 . 1
III. DEVIATIONS, REQUIREMENTS and COMMENTS:
Color
DEVIATION: Values less than the established minimum reporting level were
reported.
REQUIREMENT: For analytical procedures requiring analysis of a series of
standards, the concentrations of these standards must bracket the
concentration of the samples analyzed. One standard must have a
concentration equal to the laboratory' s lower reporting concentration
for the parameter involved. For example, if you choose to have a lower
reporting limit of 5 mg/l for a particular parameter, you must analyze
a 5 mg/l standard and report lower samples as <5 mg/l . If you choose
100 mg/1 for the top of your standard curve, you must analyze a 100 mg/l
standard and all samples above this limit must be diluted and reanalyzed
to fall within the curve. For colormetric analyses a curve consisting of
a blank and five standards must be analyzed. This curve must be checked
each time samples are analyzed with a blank and a medium level standard.
Instead of a standard curve, a three point (low, medium and high
standard) curve may be analyzed with each group of samples . Ref: 15A
NCAC 2H . 0805 (a) (7) (I) .
COMMENTS : This occurs at the Big Creek sampling site with the
spectrophotometric procedure. The minimum reporting level has been
established at 10 C. U.
COMMENTS : It is recommended that the absorbance reading of the lowest
standard (minimum reporting level) occasionally be documented. It should
be >. 005, preferably > . 010 absorbance units .

Page 3 .
Champion
COD
COMMENTS : It is recommended that the absorbance reading of the lowest
standard (minimum reporting level) occasionally be documented. It should
be >. 005, preferably >. 010 absorbance units.
Ammonia Nitrogen
DEVIATION: The meter being used, an Orion 940, does not calibrate a
straight line curve when a multiple point calibration is used. It makes
a point to point calibration. A mid-range calibration check standard was
not analyzed to verify both segments of the calibration.
REQUIREMENT: The calibration curve must be checked with a mid-range
standard. If a point to point curve is established, each segment must be
verified. Ref : 15A NCAC 2H . 0805 (a) (7) (I) .
COMMENTS: If each segment of the curve is not checked, a linear
regression calculation may be done to establish a straight line curve.
Other options would be to do a two-point calibration or use the
spectrophotometric procedure.
DEVIATION: The value obtained on the mid-range quality control standard
was often not acceptable.
REQUIREMENT: For analyses that require a series of standards, a mid-
range standard must be analyzed with each group of samples . When the
mid-range standard varies by more than ± 10%, or is outside the
established control limits, whichever is lower, the analysis is out of
control. The analysis must be terminated and the problem corrected. Ref:
15A NCAC 2H . 0805 (a) (7) (B) , (F) and (I) .
COMMENTS : It is recommended that the slope value be documented. The ten
fold concentration millivolt change for should be 54-60 . If the slope
value is not acceptable, the samples should be reanalyzed.
Fecal Coliform
DEVIATION: The water bath thermometer is calibrated quarterly, but it is
not documented.
REQUIREMENT: Supporting records shall be maintained as evidence that
these practices are being effectively carried out. All analytical
records must be available for a period of three years . Ref : 15A NCAC 2H
. 0805 (a) (7) and (a) (7) (G) .
DEVIATION: The calibration of the pH meter used to check the media was
not documented.
REQUIREMENT: See the requirement above.

ppppp-
Page 4 .
Champion
DEVIATION: The Town of Canton effluent sample was not dechlorinated.
REQUIREMENT: All chlorinated samples must be dechlorinated at the time
of sample collection. Ref: Standard Methods, 18th Edition - Method 9060
A.2 .
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory
bench sheets and contract lab reports to DMRs submitted to this
Division. Data were reviewed for these months : March and June 1996 . No
errors were noted. It appears the facility is doing a good job of
accurately transferring data.
V. CONCLUSION:
overall, the laboratory is doing a good job and appears to be producing
quality data. Upon correction of the above deviations, the requirements
of certification will be met. Implementing the recommendations will
further improve the quality of the data.
Report prepared by: Gary Francies Date: 10/18/96

State(pf North Carolil-ICA
Department of Environment,
Health and Natural Resources10
`� •
Division of Water Quality
James B. Hunt,Jr., Governor
Jonathan B. Howes,Secretary ID E H N R
A. Preston Howard,Jr., P.E., Director
Asheville Regional Office
WATER QUALITY SECTION
October 30, 1996
Mr. Derric Brown
Champion International Corporation
Canton Mill
Post Office Box C-10
Canton, North Carolina 28716
Subject : Performance Audit Inspection
Status : Compliant
Canton Mill WWTP
NPDES Permit No. NC0000272
Ha . ood County
Dear Mr. Brown:
The Performance Audit Inspection which Gary Francies of the
Division' s Regional =Office Laboratory and I conducted on October
2, 1996 on Champion' s Canton Mill wastewater treatment program
indicated that the self-monitoring program (flow measurement,
sample collection, and laboratory analyses) was being conducted
in accordance with terms and conditions contained in the subject
NPDES Permit.
Personnel present from the Mill during the inspection were:
Derric Brown, John Pryately, Richard Davis, and Mike Cody.
The purpose of this inspection was to determine the quality
of the self-monitoring program being conducted by the Mill and
assess the reliability of its reported data. The inspection
consisted of evaluation of the following: flow monitoring
equipment, sample collection and preservation techniques, and of
laboratory analytical techniques, record . keeping and data
reporting procedures : ,
The self-monitoring program being conducted by the Mill was
shown to be operating according to applicable standards with the
exception of some minor deviations which are outlined in the
attached Laboratory On-site Inspection Report . Flow measurement
and sampling procedures were acceptable.
Interchange Building,59 Woodfin Place - NIAXAn Equal OpportFAX 704-251-6452
Asheville,North Carolina 28801 unity/Affirmative Action Employer
Voice 704-251-6208 lll� 50%recycles/10%post-consumer paper

Mr. Derric Brown
October 30, 1996
Page Three
B. LABORATORY EVALUATION
1 . FACILITIES AND EQUIPMENT: Laboratory space is adequate
for testing performed for the facility. All equipment
is well maintained. The lab routinely conducts NPDES
testing for temperature, ammonia nitrogen, pH, five-
day biochemical oxygen demand (BOD5) , dissolved oxygen,
total suspended solids, total dissolved solids, total
solids, chemical oxygen demand (COD) ,. total hardness,
color, and settleable matter. Hydrologic Inc. ,
performs testing for effluent toxicity. Dioxin
analysis is performed at Champion' s West Nyack lab.
Zinc and chloroform analyses are performed at Pace Labs
in Charlotte, NC.
2 . METHODOLOGY: All testing procedures are based upon
Standard Methods 18th edition. Any deviations are
addressed in the attached ON-SITE INSPECTION REPORT
completed by Mr. Francies as part of the Laboratory
Certification Program. A review of data revealed no
errors . The facility appears to be doing a good job of
accurately transferring data.
a. Color; Values are being reported which are less
than the established minimum reporting level.
(REGULATORY REQUIREMENT)
b. Ammonia Nitrogen; The meter being used does not
calibrate a straight line curve when a multiple
point calibration is performed. (REGULATORY
REQUIREMENT)
C . Ammonia Nitrogen; An unacceptable value was often
obtained on the mid-range quality control
standard. (REGULATORY REQUIREMENT)
3 . RECORDS KEEPING: Laboratory record keeping generally
was appropriate and consistent with good laboratory
practice .
a. Fecal Coliform; Documentation is not kept for the
quarterly calibration of the water bath
thermometer. (REGULATORY REQUIREMENT)

l i
Mr. Derric Brown
October 30, , 1996
Page Four
b. Fecal Coliform; Documentation of the calibration
of the pH meter used to check the media was
lacking. (REGULATORY REQUIREMENT)
The results of the laboratory analysis, not included in the
attached Report, for the samples collected during the inspection
will be forwarded to you upon receipt.
Should you have any questions concerning this Report, please
do not hesitate to contact me at 704-251-6208 . The assistance
provided to me by all Mill personnel involved during the
inspection was greatly appreciated.
Si erely,
D. Keith Ha es
Environmental Specialist
Attachment
xc : Roger Pfaff, EPA
Gary Francies

United Siates mmental Protection Agency Form Approved •.
W_------oton, D.C. 20460 OMB No. 2040-0003
PA NPDES Compliance Inspection Report Approval Expires 7-31-85
Section A: National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 21_.I 3 1 NC0000272 11 12 96/10/2 17 18 Iq I 19 �g � L I
201
Remarks u t_ , I` I
I I I I I I I I I I I I I I I I I I I I I I I I I I I
" Reserved Facility Evaluation Rating BI QA Reserved
67 I I I_I I69 70 14LJ I L
71 �N I 72 [N J j 73 �74 75 �ao
W Section 0:Facility Date
Name and Location of Facility Inspected Entry Time Permit Effective Date
Champion International Corp. 8:30 am
Canton Mill
Canton, Haywood County Exit rime/Date Permit Expiration Date
4:30 pm
Name(s)of On-Site Representative(s)/ritle(s) Phone No(s)
Derric Brown- Environ. Supervisor 704-646-2318
Name,Address of Responsible Official Title
Mr. Steve Hadden Vice-President/Operations Mgr.
PO Box 10-C
Canton, NC. 28716 Phone No. Contacted
No
Section C:Areas Evaluated During Inspection CODES L S-Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated/Not applicable
$ Permit $ Flow Measurement $ Pretreatment ES
Operations &Maintenance
S Records/Reports $ Laboratory N Compliance Schedules Sludge Disposal
S Facility Site Review S Effluent/Receiving Waters $ Self-Monitoring Program Other.
Section D:Summary of Findings/Comments (Attach additional sheets if necessary)
Effluent Data ARO Mill Permit Limits(Daily Avg/Mon Ave)
BODs = 7.1 mg/1 6.7 mg/1 30.0 mg/l - 45.0 mg/l
TSS = 14 mg/l 13 mg/l 30.0 mg/l - 45.0 mg/l
TR = 1776 mg/1 1713 mg/l
COD = 154 mg/1 184 mg/l
NH3 = 4.6 mg/l 6.4 mg/1
Fecal = 13/100 ml <20/100 ml
Two of the four aeration basins were in operation, with the other two in the digester mode.
One (#1) of the three primary clarifiers was down for repairs to the sweeper support shaft.
All three final clarifiers were in operation. The Parshall Flume/flow meter is calibrated
quarterly. Effluent flow at the time of the inspection was 24.7 MGD. Maintenance records are
kept by computer in the treatment maintenance shop. Effluent samples were split with the
facility. All sampler refrigeration units were operating at the proper temperature. One of
the four belt presses was in operation and one was out of service for rebuilding.
Maintenance work is still being performed on the aerator platforms.
Name(s)and Signature(s) of Inspector(s) Agency/Office/Telephone Date
D.KEITH HAYNES[
l/ DWQ/ARO 704-251-6208 ?6030
Si of Review r Agency/Office Date
DWQ/ARO 704-251-6208
Regulatory Office Use Only
Action Taken Date Compliance Status
El Noncompliance
P Compliance

1
Mr. Derric Brown
October 30, 1996
Page Two
The Performance Audit •Inspection (PAI) rating for this
facility is "B" . A PAI rating sheet is attached for your review.
FINDINGS AND RECOMMENDATIONS
Recommendations found in this section will appear as PERMIT
(REGULATORY) REQUIREMENTS to correct deviations or as SUGGESTIONS
to strengthen the self-monitoring and laboratory program.
Regulatory requirements will be referenced by the appropriate
authority.
A. FIELD EVALUATION
1. FLOW MEASUREMENT: Flow is measured prior to the 001
covered discharge structure using an eight foot free
flow Parshall flume in conjunction with a Fischer &
Porter Ultra-sonic flow meter with Foxboro recorder and
totalizer.
2 . " The effluent sampling devices for outfall 001 are three
ISCO model 3710 composite samplers. with refrigeration.
Proportional composite samples are collected for every
250, 000 gallons of effluent . One of the samplers is
used for special studies . Sampler tubing is changed on
a monthly basis .
The two influent composite samplers are both ISCO model
3170 with refrigeration. The temperature in each of
the samplers was about 3°C.
3 . RECORD MAINTENANCE: Records and data handling
procedures appear to be satisfactory and consistent
with self-monitoring requirements contained in the
NPDES Permit .
4 . PERMIT VERIFICATION: The Permit was issued by EPA and
expired on October 24, 1994 . The Permit will be
reissued by DWQ early in November to correspond with
the French Broad River Basin Plan renewal schedule.

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Page 2 .
Champion
General Comments continued
Effluent samples were split with the following results (all values are
mg/1) :
Champion Laboratory State Laboratory
COD 184 154
Ammonia nitrogen,
distilled, electrode Not Analyzed 4 . 9
undistilled, electrode 6.4 4 . 6
The States central lab also analyzed the ammonia nitrogen sample by the
Automated Method and obtained a value of 5. 0 mg/l.
TSS 13 13 . 5
Total Residue 1713 1776
Hardness 210 211
BOD 6.7 7 . 1
III. DEVIATIONS, REQUIREMENTS and COMMENTS:
Color
DEVIATION: Values less than the established minimum reporting level were
reported.
REQUIREMENT: For analytical procedures requiring analysis of a series of
standards, the concentrations of these standards must bracket the
concentration of the samples analyzed. One standard must have a
concentration equal to the laboratory' s lower reporting concentration
for the parameter involved. For example, if you choose to have a lower
reporting limit of 5 mg/l for a particular parameter, you must analyze
a 5 mg/1 standard and report lower samples as <5 mg/l . If you choose
100 mg/l for the top of your standard curve, you must analyze a 100 mg/1
standard and all samples above this limit must be diluted and reanalyzed
to fall within 'the curve. For colormetric analyses a curve consisting of
a blank and five standards must be analyzed. This curve must be checked
each time samples are analyzed with a blank and a medium level standard.
Instead of a standard curve, a three point (low, medium and high
standard) curve may be 'analyzed with each group of samples . Ref: 15A
NCAC 2H . 0805 (a) (7) (I) .
COMMENTS : This occurs at the Big Creek _ sampling site with the
spectrophotometric procedure. The minimum reporting level has been
established at 10 C. U.

Page 3.
Champion
Color continued
COMMENTS: It is recommended that the absorbance reading of the lowest
standard (minimum reporting level) occasionally be documented. It should
be >. 005, preferably >. 010 absorbance units .
COD
COMMENTS: It is recommended that the absorbance reading of the lowest
standard (minimum reporting level) occasionally be documented. It should
be >.005, preferably >. 010 absorbance units.
Ammonia nitrogen
DEVIATION: The meter being used, an Orion 940, does not calibrate a
straight line curve when a multiple point calibration is used. It makes
a point to point calibration. A mid-range calibration check standard was
not analyzed to verify both segments of the calibration.
REQUIREMENT: The calibration curve must be checked with a mid-range
standard. If a point to point curve is established, each segment must be
verified. Ref: 15A NCAC 2H .0805 (a) (7) (I) .
COMMENTS: If each segment of the curve is not checked, a linear
regression calculation may be done to establish a straight line curve.
Other options would be to do a two-point calibration or use the
spectrophotometric procedure.
DEVIATION: The value obtained on the mid-range quality control standard
was often not acceptable.
REQUIREMENT: For analyses that require a series of standards, a mid-
range standard must be analyzed with each group of samples . When the
mid-range standard varies by more than ± 10%, or is outside the
established control limits, whichever is lower, the analysis is out of
control. The analysis must be terminated and the problem corrected. Ref:
15A NCAC 2H . 0805 (a) (7) (B) , (F) and (I) .
COMMENTS: It is recommended that the slope value be documented. The ten
fold concentration millivolt change for should be 54-60 . If the slope
value is not acceptable, the samples should be reanalyzed.

l .
Page 4 .
Champion
Fecal coliform
DEVIATION: The water bath thermometer is calibrated quarterly, but is
not documented.
REQUIREMENT: Supporting records shall be maintained as evidence that
these practices are being effectively carried out. All analytical
records must be available for a period of three years . Ref: 15A NCAC 2H
. 0805 (a) (7) and (a) (7) (G) .
DEVIATION: The calibration of the pH meter used to check the media was
- .� not documented.
REQUIREMENT: See the requirement above.
DEVIATION: The Town of Canton effluent sample was not dechlorinated.
REQUIREMENT: All chlorinated samples must be dechlorinated at the time
of sample collection. Ref: Standard Methods, 18th Edition - Method 9060
A.2 .
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory
bench sheets and contract lab reports to DMRs submitted to this
Division. Data were reviewed for these months : Marchand June 1996. No
errors were noted. It appears the facility is doing a good job of
accurately transferring data.
V. CONCLUSION:
Overall, the laboratory is doing a good job and appears to be producing
quality data. Upon correction of the above deviations, the requirements
of certification will be met. Implementing the recommendations will
further improve the quality of the data.
Report prepared by: Gary Francies Date: 10/18/96

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Permit No. NC0000272
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT -�
r _ .
TO DISCHARGE WASTEWATER UNDER THE
i
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM��/
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Champion International Corporation
is hereby authorized to discharge wastewater from a facility located at
Champion Canton Mill Wastewater Treatment Plant
off Highway 215
Canton
Haywood County
to receiving waters designated as the Pigeon River in the French Broad River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III, and IV hereof.
The permit shall become effective
This permit and the authorization to discharge shall expire at midnight on November 30, 2001.
Signed this day F+N,i!-�
DpAr-
r— T
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Mangement Commission
�2nPr Rat - SuS:J'Ecr Tb 6�140J4e —Sue oN �I�,arcr v5 oPPicF2.5
Rc(oMMOA)DArnoag AND tDtAe(,roa's Ft) nW' 7tu5(aA1

Permit No. NC0000272
SUPPLEMENT TO PERMIT COVER SHEET
Champion International Corporation
Canton Mill Wastewater Treatment Plant
Y
is hereby authorized to:
1. Continue to operate an existing wastewater treatment facility for the treatment of wastewater
d paper mill, the Town of Canton's
and stormwater associated with the pulp an
chlorinated domestic wastewater, and Champion's landfill leachate consisting of a grit
chamber, bar screens, lift pumps, polymer addition, pH control (CO2 injection or H2SO4
backup), three primary clarifiers, nutrient feed, aeration basins, three secondary clarifiers,
residual belt presses, effluent flow measurement, cascade aeration (with oxygen injection),
and Canton mill gen Wast waterection facilities
Treatment Plant, off Hiecified in ghway 215, Canton,located
Hay Haywood County,Champion
.
2. Discharge from said treatment works at the location specified on the attached map into the
Pigeon River which is a Class C waters in the French Broad River Basin.

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ROAD CLASSIFICATION
SCALE 1 :24 000 ='
PRIMARY HIGHWAY UGHr•DUTY ROAD,HARD OR 0 1 MILE
HARD SURFACE IMPROVEDSURFACE e
SECONDARY HIGHWAY 0 7000FEET
HAROSURFACE C=311111111111= UNIMPROVED ROAD
-
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Lat: 35032'08" Long: 820 5042r rr =3 �=
Map # E7SE Sub-basin 04-03-05 CONTOUR INTERVAL 5 FEET - `
Stream Class C ' =s
QUAD LOCATION Champion International
Discharge Class Indust rial/ Domestic
Canton Mill WWTP
Receiving Stream Roeon Rver r NC0000272
Qw: 29.9 Permit exp. 11/30/01 Haywood County

A. (I). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0000272
During the period beginning on the effective date of the permit and lasting until expiration of the permit, the Permittee is authorized to discharge from outfall(s)
serial number 001. Such discharges shall be limited and monitored by the pennillce as specified ied below:
(Ufluent Characteristics Discharge Limitations Monitoring Requirements
Lbs Units (Specifyi Measurement Sample ISample
Mon. Avg. Daily Max. Mon. Avg, Rally Max. Frequency_ Tyne Location
I-low 29.9 MGD Continuous Recording I or E
UODs 3598.0 12458.0 Daily Composite E,I
OCO Weekly Composite E
TSS 12549.0 49560.0 Daily Composite E.1
NH3-N Daily Composite E
Fecal Coliform 200 /100 ml 400 /100 ml Weekly Grab E
Dissolved oxygen 2 Daily Grab E
Total Nitrogen (NO2 + NO3 + TKN) Monthly Composite E
'total Phosphorus Monthly Composite E
Temperature 3 Daily Grab E
Chronic Toxicity 4 Quarterly Composite E
Total Residue Daily Composite E
Total Dissolved Solids Daily Composite E
Hardness 2/Month Composite E
Mercury s .014 pg/I 2/Month Grab E
I Sample locations: E- Effluent, l - Influent. Instream sampling is specified in Part [, A (2).
2 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l. See Part f, Section A(2)and Part III,Condition 1.
3 The monthly average instream temperature measured at a point 0.4 miles downstream of the discharge location shall not exceed 32.0°C during the months of July, August,and
September and shall not exceed 29.0°C during the months of October through June. The monthly average instream temperature measured at this location shall not exceed the
monthly average instream temperature of the upstream monitoring location by more than 13.9°C. See Part 111, Condition L.
4 Chronic Toxicity Testing at 87 %; March,June,September, and December; See Part Ill,Condition G.
5 The mercury limit shall be implemented December 1, 1997 unless those conditions specified in Part III, Condition M can be met. Values
detected at less than 0.2 µg/I will be considered zero for 'purposes of compliance.
The effluent pli shall not be less than 6.0 standard units nor greater than 9.0 standard units.
'['here shall be no discharge of floating solids or visible foam in other than trace amounts.

\. (I). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL (Continued)
Permit No. NC0000272
During the period beginning on the effective date of the permit and lasting until expiration of the permit, the Permittee is authorized to discharge from outfali(s)
serial number 001. Stich discharges shall be limited and monitored by the permiuce as specified below:
Discharge Limitations Monitoring Requirements
eristics
Effluent Charact Lbs/day Units (S ep clfv) Measurement Samote 'Sampi
Mon. Avg. Daily x.Ma Mon. Avg. Daily Max. Frequency Type Location
Quarterly Composite E
Trichlorophenol Quarterly Composite E
Penlachlorophenol 2/Month Composite E
Zinc Quarterly Composite. E
Cadmium Quarterly Composite E
Selenium Quarterly Composite E
Silver Monthly Composite E
AOX 0.1 pg/l Quarterly Composite E
2,3,7,8 Tetrachloro-dibenzo-p-
dioxin (See Part III, Condition
11) Daily Composite , E,I
Color (See Part III, Condition E) Daily Grab E
Conductivity Daily Grab E
1�1

Part I DES No. NC0000272
A. (2). INSTREAM MONITORING REQUIREMENTS
Stream Mile Location Description Parameter Frequency
_Designation Marker
UP 64 5 Pigeon River upstream of the Temperature : Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the BODS I/Week
discharge) Conductivity Dail
Color * e
2/Week
Flow * Daily
Fecal coliform
DN 1 62.9 Pigeon River at Fiberville Bridge Temperature D�k
D.O. Daily
r Conductivity Daily
Fecal Coliform I/Week
DN2 Color * 2/Week
57.7 Pigeon River Above Clyde Temperature Daily
DN3 D.O. Daily
55.5 Pigeon River Below Clyde Temperature I/Week
- • D.O. I/Week
DN4 Color * 2/Week
53.5 Pigeon River at NCSR 1625 Temperature 1/Week
bridge D.O. I/Week
Color * 2/Week
DNS 42.6 Pigeon River at Hepco Temperature 1/Week
D.O. I/Week
Color * yWcek
Flow * Dail
Waterville Reservoir (See Pan III, Condition Annually
IC)
DN6 26.0 Pigeon River prior to mixing Color * 2/Week
with BigCreek
BC — 26.0 Mouth of Big Creek prior to Color * ypycek
mixing with the Pi eon River
D v? 24.7 Pigeon River at Browns Bridge Temperature I/Week
(—NC/IN State Line) D.O. ]/Week
BODS I/Week
Color * yWcek
All instream samples shall be grab samples.
*Color(Additional,See Pan III,Condition E) All instream samples collected for these streams shall be
representative of the Pigeon River and Big Creek,respectively. Both true and apparent color shall be monitored using
the methods specified in Pan III, Condition E. Samples shall be collected at stations DN6, BC,and DN7 only during
times when at least one generator at CP&L is in operation and releasing water to the Pigeon River. Flow monitoring
is necessary,as specified above,for the True Color calculation stipulated in Part III,Condition E.
Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9(DNI),57.7
(DN2), and 55.5 (DN3)shall not be less than 5.0 mg/l and the instantaneous minimum dissolved oxygen
concentration shall not be less than 4.0 mg/1 (See Part III, Condition I).

E. REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE
1) Champion shall take such action as necessary to prevent their
contribution of true color from causing true color at the North Carolina/
Tennessee state line from exceeding 50 true color units at all flows
equal to or exceeding 126 cfs.(81.4 MGD, the seven day, ten year low
flow level).
Compliance with this requirement shall be measured through a
calculation of instream true color levels at
the North Carolina/
_Tennessee stake line by the following eq
SL _ (WTP� /R 341+((HEf-WfP f x Dcl
c HE x 10 (-0.224 x LOG kru + 0.781)
f
Where: WTPc = Monthly average Waste Treatment
Plant discharge color.
Calculated as the average (pounds
of all daily loading values (p
of true color per day) for a
calendar month.
WTpf = Monthly average Waste Treatment
Plant discharge flow (mad).
I lE f = Monthly average HEPCO,North Carolina
flow (mad) - daily now values less than
81.4 mad shall be entered as 81.4 mad.
SLc = Monthly average Instream true color
at North Carolina/Tennessee border
(state line).
D = Color concentration of all dilution
c streams (13 C.U.).
The SLc shall be calculated for each calendar month. The SLc values for
each month shall not exceed 50 true color units. Any violation
t is true
color units for this average value shall be considered a violation of this
permit.
2) The average daily discharge of true color for each calendar month shall not exceed
132,341 pounds per day. The average annual effluent true color loading shallexceed 1249923 pounds per day. For the purpose of this perindonly, "pounds of
true color' is calculated by the following equation:
Effluent Flow (mad)x Effluent True Color Level
(Platinum Cobalt Units) x 8.34.

3) The method of analyses used to measure true color for this calculation shall be the
procedure referenced in FR 39 430.11(b) (May 29, 1974).
4) All samples collected for color analysis shall be measured and reported as true color
and apparent color using the procedure referenced in FR 39 430.11 (b) (May 29,
1974) -"true and apparent color.
5) Prior to the next permit renewal, the color model specified in 1)
above, shall be recalibrated using the period of record and simulations
specified in the supplement to the hearing record and in the color
variance document.
F. SCHEDULE FOR CONTINUED COLOR MINIMIZATION
Champion shall continue to study, evaluate, and pursue color removal
technologies and shall report its findings to the Division of Water Quality
in accordance with the following schedule:
Date Activitv
Continuing Commercial demonstration of bleach filtrate recycling
(BFRTM)
March 1, 1998 In conjunction with, the Triennial Review of NC Water
Quality Standards:
1) Submit a status report on the technical, economic, and
operational feasibility of BFRTM technology, including those
analyses prepared for other permitting agencies concerning
its effects on air emissions.
2) Evaluate and 'report on end-of-pipe color reduction
technologies.
3) Evaluate and report on minimization of color losses from
manufacturing processes and from raw material storage areas.
December 1, 1998 Based on the results of the demonstration project and the
conclusions of the status report, Champion will decide and
report on the decision to operate BFRTM technology as a fully
commercial process on the pine line.
December 1, 2000 Champion will evaluate color reduction strategies for further
optimization of BFRTM technology and report on the
feasibility of implementation on the hardwood line.
March 1, 2001 Champion .will evaluate and report on end-of-pipe color
reduction technologies in conjunction with the Triennial
Review of NC Water Quality Standards.
June 1, 2001 Champion will submit a report to NCDEHNR, Division of
Water Quality, on the comparative evaluation of the above
collective efforts as part of the variance review process
(Triennial Review) and the NPDES renewal process.
This NPDES permit shall be subject to reopening in order to modify the
color requirements based upon any breakthrough in color removal
technologies. Such breakthroughs shall be brought to the NPDES
Committee for consideration, by Champion, and the Division of Water
Quality, as soon as they are discovered.

G. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The permittee is required to perform the toxicity test as specified below or an equivalent
toxicity test as approved by the Division.
The effluent discharge shall at no time exhibit chronic toxicity using test procedures
outlined in the"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"
Revised November 1995, or subsequent versions.
The effluent concentration at which there may be no observable inhibition'of reproduction
or significant mortality i87% (defined as treatment two in the procedure document).The
permit holder shall perform auanerly monitoring using this procedure to establish
compliance with the permit condition.The tests will be performed during the months of
be
March June Se tember and December.Effluent sampling for this testing shall performed at the NPDES pemutted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the
rformed,
Effluent Discharge Monitoring Form(MR-1) for the month in which it was pe
: using the parameter code TGP3B. Additionally,DWQ Form AT-1 (original) is to be sent to
the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
4401 Reedy Creek Road
Raleigh,North Carolina 27607
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response
data.Total residual chlorine of the effluent toxicity sample must be measured and reported
if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity
monitoring is required,the permittee will complete the information located at the
number,
of the
aquatic toxicity (AT)test form indicating the facility name, permit number,pipe
county, and the month/year of the report with the notation of"No Flow"in the comment
area of the form.The report shall be submitted to the Environmental Sciences Branch at the
address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits,then
monthly monitoring will begin immediately until such time that a single test is passed.
Upon passing,this monthly test requirement will revert to quarterly in the months specified
above. ,
Should the permittee fail to monitor during a month in which toxicity monitoring is
required,then monthly monitoring will begin immediately until such time that a single test
is passed. Upon passing, this monthly test requirement will revert to quarterly in the
months specified above.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream,this
dified to include alternate monitoring requirements or
permit may be re opened and mo
limits.

NOTE: Failure to achieve test conditions as specified in the cited document, such as
minimum control organism survival, minimum control organism reproduction, and
appropriate environmental controls, shall constitute an invalid test and will require
immediate follow-up testing to be completed no later than the last day of the month '
following the month of the initial monitoring.
H. DIOXIN MONITORING
For permit compliance purposes, the point of compliance shall be defined as the final
effluent before discharge. Compliance with the daily maximum permit limit shall be
demonstrated by determining the TCDD concentration at the final discharge point.
Adequate sample volume shall be collected to perform the analysis. The total sample
volume shall be collected and preserved in accordance with Part 11, Section D Monitoring
and Records. The sample shall be analyzed in accordance with the appropriate method of
analysis specified in AlalVtleal procedures and Quality Assurance for Multimedia Analysis
of Pol chlorinated Dibenzo are dioxins a )li.,chlorinated Dibenzofurans by High
Resolution Gas Chromatoora h /Hi h Resolution Mass S ectromet ,EPA, 1987 (EPA
Method 8290), or another equivalent analytical protocol approved by DWQ. A single
sample may be analyzed to determine compliance with the daily maximum effluent
limitation. Alternatively, a sample volume may be collected to enable the sample to be split
(duplicate analysis). If the analysis of either split sample is below the detection limit, the
quantity, for the purposes of compliance evaluation, is considered to be zero. If both splits
are positive, the results of the two analyses shall be averaged to determine compliance with
the daily maximum effluent limitation. If the measurement is below detection limits the
q::y.:ity for the purposes of compliance evaluation is considered to be zero. The detection
limit using these methods for the purpose of compliance evaluation is considered to be 10 picograms per liter. The dioxin isomer to be limited at the effluent by this
permit is 2,3,7,8 TCDD. The chlorodibenzo dioxins and furans to be
monitored are:
DIOXIN DIBENZOFURAN
Isomer Isomer
2,3,7,8 TCDD 2,3,7,8 TCDF
1,2,3,7,8 PeCDD 1,2,3,7,8 PeCDF
1,2,3,4,7,8 HxCDD 2,3,4,7,8 PeCDF
1,2,3,7,8,9 HxCDD 1,2,3,4,7,8 HxCDF
1,2,3,7,8,9 HxCDF
1,2,3,6,7,8 HxCDD 1,2,3,6,7,8 HxCDF
1,2,3,4,6,7,8 H CDD 2,3,4,6,7,8 HpCDF
P 1,2,3,4,6,7,8 HpCDF
1,2,3,4,7,8,9 HpCDF
Fish tissue analysis will be performed in accordance with the Division of Water Quality
approved monitoring plan, which shall be reviewed as necessary. The monitoring plan is
an enforceable part of this permit. All dioxin data collected as part of this monitoring
requirement will be reported as required in the plan, no later than 180 days after sampling.

The permittee shall perform the following analyses for the above listed
isomers:
Quarterly COMPOSITE
1. Influent to wastewater treatment facility Quarterly COMPOSITE
2. Sludge
• Quarterly COMPOSITE
3. Landfi11leachate
Quarterly COMPOSITE
4. Effluent
r ,
1. DISSOLVED OXYGEN REQUIREMENT concentration of not less
The permittee shall maintain an average daily dissolved oxygenat River Miles
than 5.0 mgl1 with a minimum instaZaneoussve value
not
te less
than
operate o�gen injection
62.9 (DNl), 57.7 (DN2), and 55S ( 9 n-dI P requirement
. These
facilities at the out structure,at 0.9 miles downstream with this
hts disegchazge, and at 2.1 miles
downstream of the discharge,as necessary,to comply
facilities shall be operated in a manner which will maintainthe water quality standard for
n use as a suplement to the
dissolved oxygen in the Pigeon River downstream of the discharge. Champion shall
report the date and duration of oxygen injectio p
monthly Discharge Monitoring Report (DMR) forms.
J. INFLOW[I.IFILTRATION AT THE TOWN OF CANTON
The permittee shall make continued efforts to promote reduction of inflow/infiltration to the
Town of Canton's wastewater collection system.
K, WATERVILLE RESERVOIR SAMPLING REQU�MENT
Sampling for Waterville Reservoir shall be conducted once annually during 1
and 2000. Sampling shall be performed during a low flow period to corresponndd with the
with
fish tissue study. Sampling parameters and stations are as follows:
Parameters*
Sampling Statr°n H, TN,
Waterville Reservoir prior to Laurel Branch PO4, TP,
Temperature, D.O., conductivity, p
NO2 + NO3, NH3-N, TKN,
Chlorophyll-a, Secchi Depth
Waterville Reservoir near Wilkins Creek Same as above
Same as above
Waterville Reservoir near the dam
All samples shall be collected at 0.1 meters beneath the surface of the water in the lake.

L. TEMPERATURE VARIANCE REVIEW
During the next permit renewal, Champion shall complete an analysis of
temperature data using the period of record and simulations specified in the
supplement to the hearing record. As part of this analysis, Champion shall
submit a complete temperature variance report documenting the need for a
continued temperature variance in accordance with 40 CFR 125, Subpart H.
The report shall be submitted with the request for permit renewal, no later
than June 1, 2001.
r
M. MERCURY MONITORING
Mercury shall be monitored twice per month at the effluent for a period of
twelve months after the effective date of the permit. Results shall be
reported using a quantitation level of 0.2 µg/l.
As indicated in Part I, A (1), a mercury limit of 0.014 µg/l shall be
implemented twelve months after the effective date unless:
1) Champion submits the appropriate minor modification fee and
requests that the Division of Water Quality review the existing effluent
data upon completion of nine months worth of sampling, and
2) All effluent mercury samples indicate values less than the
quantitation level during this nine month period.
If both conditions 1) and 2) are met, the Division will modify the permit to
eliminate the mercury limit and reduce the effluent monitoring to quarterly.
N. BALANCED AND INDIGENOUS SPECIES STUDY.
Champion shall submit a balanced and indigenous species study prior to the
next permit renewal, no later than June 1, 2001. The study shall be
performed in accordance with the Division of Water Quality approved plan.
This plan shall be submitted for approval no later than March 1, 2000. The
.balanced and indigenous study plan shall conform to the specifications
outlined in 40 CFR 125 Subpart H.

ENVIRONMENTAL MANAGEMENT COMMISSION
RECEIVED
OCT 1 .5 1996
IN THE MATTER OF REQUEST FOR ) EPnARCiiF_UT��64:1nl4Gi`^ T
VARIANCE FROM WATER QUALITY ) CC,;""^""'
STANDARD-BASED EFFLUENT ) MODIFICATION OF COLOR
LIMITATIONS BY CHAMPION ) VARIANCE GRANTED
INTERNATIONAL CORPORATION, ) ON JULY 13, 1988
CANTON,NORTH CAROLINA )
THIS MATTER came on to be heard before the NPDES (National Pollutant Discharge
Elimination System) Committee of the North Carolina Environmental Management Commission
at its scheduled meeting in New Bern, North Carolina, on October 9, 1996, pursuant to the
NPDES Committee's proposal to modify an existing color variance granted to Champion
International Corporation on July 13, 1988.
- Upon duly made motion and vote, the NPDES Committee hereby adopts the following
Findines of Fact and Conclusions of Law:
FINDINGS OF FACT
1. Pursuant to a request for variance, dated January 12, 1988, submitted by
Champion International Corporation ("Champion"), the NPDES (National Pollutant Discharge
Elimination) Committee of the North Carolina Environmental Management Commission granted
Champion a variance from the North Carolina water quality standard for color, as that standard is
interpreted by the U.S. Environmental Protection Agency. The variance was memorialized in the
NPDES Committee's Final Decision, dated July 13, 1988.
2. Pursuant to Ordering Paragraph 6 of its Final Decision, the NPDES Committee
established-a Variance Review Committee to review the Canton Mill's proposed modernization

program and to recommend any changes to the existing variance. As stated in Ordering
Paragraph 6 of its Final Decision, the NPDES Committee is charged with determining "if
changes in the variance are warranted due to the effectiveness of the treatment system or because
of advances in color reduction technologies for this type wastewater."
ee convened three times, and presented the results
J. The Variance Review Committ
ion's effluent color discharge to the NPDES Committee
of its review and consideration of Champ
at its March 13, 1996, meeting in Raleigh,North Carolina.
4. The Variance Review Committee made several recommendations to modify the
existing variance to the NPDES Committee,through a verbal presentation at the March 13, 1996,
meeting, and through memoranda dated March 7, 1996, from Greg Thorpe ("Review of Proposed
Modifications to Champion's Canton Mill Color Variance by the NPDES Committee"), and
March 6, 1996, from Dennis C. Loflin ("Consideration of Proposed Modifications to Champion
International Corporation's Color Variance for the Canton Mill NPDES Permit"), which are
incorporated herein by reference.
5. Based on a consideration of the Variance Review Committee's reports and
e NPDES Committee voted to propose modifications to the existing
recommendations, th
variance, and directed its staff to carry out the public notice, comment and hearing process
required by G.S. 143-215.3(e) and Ordering Paragraph 8 of its July 13, 1988,Final Decision.
onducted by Mr. Harlan Britt, appointed as hearing officer
6. A public hearing was c
for the NPDES Committee and for the contemporaneous NPDES permitting process, on June 6,
1996, in Haywood County,North Carolina.

" 3 l
7. The hearing officer made several recommendations to modify the existing
variance to the NPDES Committee, through a verbal presentation at the October 9, 1996,
meetine,'and through a-memorandum dated October 2, 1996, which is'incorporated herein by
reference.
8. Modificatioe of the variance as recommended by the Variance Review Committee
r=
AU not result in any discharge of waste that would endanger human health or safety. The
variance for color is to allow discharge of wastewater at levels that will prevent Champion's
contribution to the true color from causing the true color at the North Carolina/Tennessee State
line to exceed 50 true color units at all flows equal to or greater than 126 cfs at the Hepco
Gauging Station. The substance being discharged, for which the variance is sought, is not
bioaccumulative. The color does not, at the volumes and levels involved here, present a risk of
indirect or direct human impact or broad environmental damage. The waters are not water
supply. Therefore, the discharge will not endanger human health or safety.
9. Reduction of color discharge by application of best available technology is still
not economically reasonable and results in serious hardship without equal or greater benefit to
the public. A detailed and thorough study and evaluation of color removal technologies was
performed and reported in Champion's 1995 and 1996 Color Removal Teehnoiogv Reports
submitted to Division as required by the existing color variance.
10. Champion has now completed its mill modernization project which re-con gured
its facility as an oxygen delignification, 100% chlorine dioxide substitution (OD-100) bleach
mill. The project resulted in limited color reduction in its effluent discharge. The end-of-pipe
technologies considered in 1988 and updated for the 1996 review .established: a) standard

,4
waterhvastewater separation technology (lime, alum, or polymer) has not been applied in a
similar fashion,b)these technologies would result in high capital and operating costs at the mill,
c) color reduction on this type of waste, using these type technologies' has no operational
rmal paper mill production variations, and consistent
efficiency track record" (effective under no
moval), and d) the pr
ocess color removal effectiveness of OD-100 may
and reproducible color re
present other in-process reduction opportunities that have not yet been realized.
11. A schedule for continued color minimization is necessary. Members of the "
public. EPA and the State of Tennessee commented that the variance document proposed in the
public notice did not include any milestones for continued color reduction. Therefore, the
schedule contained in the Ordering Paragraph 4, infra, is established.
12. In review of the color data, including the short time since the re-configured mill
became_ fully operational, it is determined that a more restrictive limitation should apply for
color. Therefore, the more restrictive monthly and annual average color limitations contained in
the Ordering Paragraph 2, infra, are established. _
olor discharge information from the
13. Based on the continued development of c
hampion is required to statistically evaluate its monthly average color
reconfigured mill, C
discharge, its annual average color discharge, and the performance of the state line color mto be
These evaluation processes are to be ongoing and the results of the evaluations are required
reported to the Division of Water Quality prior to each water quality standards triennial review
period. The results of these evaluation processes shall be utilized by the Division and the next
variance Review Committee to make recommendations to the NPDES Committee on future

5
revisions to the variance. Champion shall follow the Color Data Variance Review Requirements
proposed by the staff and the hearing officer, in reporting these evaluations.
14. As provided in Findings of Fact#8, supra, Champion is also required to take such
actions as necessary to prevent their contribution of true color from exceeding 50 true color units
at the North Carolina/Tennessee state line at all flows equal to or greater than 126 cfs at the
r
Hepco Gauging Station. Furthermore, the method by which compliance is determined shall
continue to be the color predictive model.
CONCLUSIONS OF LAW
1. Pursuant to the Ordering Paragraph 6 of the July 18, 1988, Final Decision, the
NPDES Committee has reviewed the existing variance following the Champion Canton Mill
modernization program.
2. The previously existing variance from the North Carolina water quality standard
for color, memorialized in the NPDES Committee's Final Decision, dated July 18, 1998, remains
in effect except as specifically modified herein.
3. Based on the effectiveness of the treatment system subsequent to the Canton Mill
modernization project and due to the potential for improvements in color reductions by use of
bleach filtrate recycling (BFR"), changes to the variance are warranted.
Based on the foregoing Findings of Fact and Conclusions of Law, it is hereby ORDERED
that the previously existing variance from the North Carolina water quality standard for color as
memorialized in the July 13, 1988 Einal Decision Ordering Paragraphs, continues in effect as
hereby modified, to read as follows:'
' For ease of reference, the language of the July 13, 1988 Final Decision Ordering
Paragraphs is included verbatim, with the modifications denoted by overstriking for deletions

;6
van
is granted, pursuant to G.S. 143-214.3(e), as a
1 Champion's petition for a
variance to water quality based effluent limitations for color.
2. The Division of r
,, ,,r.,�Water Quality' shall issue NPDES
Permit No. NC0000272, for the Canton Mill,•and medif3 draft its provisions to reflect all the
this modification,
conditions of
r
including the following specific wording.
1 Champion shall take such action as necessary to prevent their
contribution of true color from causing the true color at the North
Carolina/Tennessee State line from exceeding S& 50 true color units
at
flows equal to or exceeding 126 cfs (81.4 MGD, the seven-day,
low flow level) at the Hepco Gauging Station.
on
of instream true color leveComliance with this requirement shall be measured throuh a
ls at the North Caro ina/Tennessee sta eclinelby
the following equation: \
RE4�
Sly_ (NyTP"LR 41 + ((HEt_--MaRtLDW
(-0.224 x LOG(ITO+ 0.781)
HEf x 10
Where:
tNTp�= Monthly average Waste Treatment Plant discharge color. (E-L�
age of all daily loading values (pounds of true
Calculated as the aver
color per day) for a calendar month.
Wrlpf= Monthly average Waste Treatment Plant discharge flow(mgd).
HE/ = Monthly average HEPCO, North Carolina flow (MGD). Daily
flow values less than 81.4 mgd shall be entered as 81.4 mgd.
and bolding for additions. Management has been reorganized and NPDES
2The Division of Environmental Manag
permitting is now administered by the Division of Water Quality.

7 ,
SI, = Monthly average Instream true color at North Carolina/Tennessee
border(state line).
D,= Color concentration of all dilution streams (13 C.U.).
The SL,-shall be calculated for each calendar month.
The aver-age of any'ea. 11--days) r ealeulated SL values
for each month shall not exceed SS 50 true color units. Any exceedance
Of '95 50 true color units for this average value shall be considered a
violation of this permit/variance aYePpt as Y e .:.,ea in T **,z==_ f
II. The average daily discharge of true color for each calendar month
shall not exceed258,945 132,341 pounds per day. The average annual
effluent true color loading shall not exceed 172,368 124,923 pounds per
day. •For the purpose of this permit/variance only, "pounds of true color"
is calculated by the following equation:
Effluent Flow (mgd) x Effluent True Color Level (Platinum Cobalt Units)
x 8.34.
III. Champien is nei required te edu dailya ♦1 effluent tFae 7
leading to less than 124,193 _ a per a
JL PIL. The method of analyses used to measure true color shall be
the procedure referenced in FR 39 430.11(b) (May 29, 1974).
3. The Division of Effi,irenmenW ManagefneiA Water Quality shall include review
of this variance as a specific item in its Triennial Water Quality Standards review, as required by
the federal Clean Water Act, and make appropriate recommendations to the NPDES Committee.
4. 'Champion shall continue to study, 'artd evaluate and pursue color removal
technologies and shall report its findings to the Division of Efwireflmeatal MmagemeWater
Quality im nedintel upen dissevery d afmuallyon er bee_ April
en. _f _--h ye in
accordance with the following schedule:

\ 8 ^
DATE ACTIVITY
Continuing Commercial demonstration of bleach filtrate
recycling(BFRT") _
March 1, 1998 In conjunction with the scheduled Triennial
Review of N.C.Water Quality Standards:
1, Submit a status report on the technical,
economic, and operational feasibility of
r` BFRTb1 technology, including those
analyses prepared for other permitting
agencies concerning its effects on air
emissions.
2. Evaluate and report on end-of-pipe color
reduction technologies. .
3. Evaluate and report on minimization of
color losses from manufacturing process
and from raw material storage areas.
December 1, 1998 Based on the results of the demonstration project
and the conclusion of the status report.
Champion will decide and report on the decision
to operate BFRT" technology as a fully
commercial process on the pinewood line.
December 1,2000 Champion will evaluate color reduction
strategies for further optimization of BFRT"
technology and report on the feasibility of
implementation on the hardwood line.
March 1,2001 Champion will evaluate and report on
end-of-pipe color reduction technologies in
conjunction with the Triennial Review of N.C.
Water Quality Standards.
June 1,2001 Champion will submit a report to N.C. DEHNR,
Division of Water Quality, on the comparative
evaluation of the above collective efforts as part
of the variance review process (Triennial Review
of North Carolina Water Quality Standards).

q
5. The Division will provide a status summary report on color removal at the Canton
Mill to the NPDES Committee amually, an erbefore Ame 30 of eae ""_, prior to completion
of the Triennial Water Quality Standards review.
5A. Based on the continued development of color discharge information from the
reconfigured mill, Champion will statistically evaluate its monthly average color discharge,
r
its annual average color discharge, and the performance of the state line color.model.-This
evaluation process shall be ongoing and the results of the evaluation shall be reported to
the Division prior to each triennial review period referenced in this variance. The results
of this evaluation process will be utilized by the Division and the Variance Review
Committee to make recommendations to the NPDES Committee on revisions to the
variance. Champion shall follow the Color Data Variance Review Requirements proposed
by the staff and,the hearing officer in reporting these evaluations.Fella'Ain .
,. r i and r
arA In conjunction with the firs subsequent triennial water quality standards reviews aft
r a tFieaaial , the Division will nominate a variance review
committee. The NPDES Committee will have final approval of the selection of this committee.
_A44eh will Committee membership may consist of Natural ReseuE nd-
Developinen Department Staff and at least twe individuals considered authorities on pulp and
paper technology or environmental aspects of that industry from the university or research
communities; That review committee's report and recommendation will be examined by the
NPDES Committee fora decision on the adequacy of the existing variance. The NPDES
3 The Variance Review Committee membership qualifications are changed to provide
greater flexibility in appointments.

10 ,
Committee will determine if changes-in the variance are warranted due to the effectiveness of the
treatment system or because of advances in color reduction technologies for this type wastewater.
All revisions adopted by the NPDES Committee will require the modification of the Company's
State NPDES Discharge Permit.
7: The variance proceeding, and the NPDES Permit No. NC 0000272, shall at all
times be subject to reopening .in order to modify the color requirements based upon any
breakthrough in color removal technologies.-Such breakthroughs shall be brought to the NPDES
Management
Committee for consideration, by Champion and the Division of
Water Quality, as soon as they are discovered.
g, This variance shall extend for an indefinite period of time, subject to
,, — and Any modification or
consideration of the three-year reviews ="�
termination based thereon shall be subjected to the public hearing process required by G.S.
143-21 5.3(e).
it is further ORDERED that this Modification of Color Variance shall be effective as of
-issued NPDES Permit No. NC 0000272 for the Canton Mill, and the
the effective date of the re
terms of the previously existing variance shall continue in effect until that time.

This the day of October, 1996.
Daniel V. Besse, Chairman
NPDES Committee

12
CERTIFICATE OF SERVICE
This is to certify that I have this day served a copy of the foregoing MODIFICATION OF
COLOR VARIANCE GRANTED ON JULY 13, 1988 on the parties listed below by the
methods indicated, addressed to each as follows:
U.S. MAIL
William Clarke
Roberts & Stevens
Suite 900 r
One W. Park Square
Asheville,North Carolina 28802
A. Preston Howard.Jr.,Director
HAND DELIVERY
Division of Water Quality
N.C. Department of Environment,Health
and Natural Resources
9th floor, Archdale Building
Raleigh,North Carolina 27601-7687
HAND DELIVERY
Jennie Odette, Clerk
Environmental Management Commission
N.C. Department of Environment,Health
and Natural Resources
9th floor, Archdale Building
Raleigh,North Carolina 27601-7687
U.S.MAIL
Paul Davis
Tennessee Department of Environment
& Conservation
6th floor, L & C Annex
401 Church Street
Nashville,Tennessee 37243-1534
U.S.MAIL
David McKinney
Tennessee Wildlife Resources
Ellington Agriculture Center
p. 0. Box 40747
Nashville,Tennessee 37204
U.S. MAIL
Gary Davis
Tennessee Environmental Council
1700 Hayes Street. Suite 101
Nashville.Tennessee 37203

13
Mike McGhee U.S. MAIL
Director of Water Management
100 Alabama Street, S W
Atlanta, Georgia 30303
This the 15th day of October, 1996.
MICHAEL F. EASLEY
Attorney General
/13354 //nn
Daniel C. Oakley ,
Senior Deputy Attorney General
Environmental Division
P. O. Box 629
Raleigh,North Carolina 27602-0629
919/733-5725

ENVIRONMENTAL MANAGEMENT COMMISSION
RECEIVED
OCT 1.5 1990
IN.THE MATTER OF REQUEST FOR ) " Et+�,1RCtF!c4T14 n!�G4_ r
VARIANCE FROM WATER QUALITY
STANDARD-BASED EFFLUENT ) MODIFICATION OF COLOR
LIMITATIONS BY CHAMPION ) VARIANCE GRANTED
INTERNATIONAL CORPORATION, ) ON JULY 13, 1988
CANTON,NORTH CAROLINA )
THIS MATTER came on to be heard before the NPDES (National Pollutant Discharge
Elimination System) Committee of the North Caroliria•Environmental Management Commission
at its scheduled meeting in New Bern, North Carolina, on October 9, 1996, pursuant to the
NPDES Committee's proposal to modify an existing color variance granted to Champion
International Corporation on July 13, 1988.
Upon duly made motion and vote, the NPDES Committee hereby adopts the following
Findings of Fact and Conclusions of Law:
FINDINGS OF FACT
1. Pursuant to a request for variance, dated January 12, 1988, submitted by
Champion International Corporation ("Champion"), the NPDES (National Pollutant Discharge
' Elimination) Committee of the North Carolina Environmental Management Commission granted
Champion a variance from the North Carolina water quality standard for color, as that standard is
interpreted by the U.S. Environmental Protection Agency. The variance was memorialized in the
NPDES Committee's Final Decision, dated July 13, 1988.
2. Pursuant to Ordering Paragraph 6 of its Final Decision, the NPDES Committee
established a Variance Review Committee to review the Canton Mill's proposed modernization

2
program and to recommend any changes to the existing variance. As stated in Ordering
Paragraph 6 of its Final Decision, the NPDES Committee is charged with determining "if
changes in the variance are warranted due to the effectiveness of the treatment system or because '
of advances in color reduction technologies for this type wastewater."
3. The Variance Review Committee convened three times, and presented the results
r
r
of its review and consideration of Champions effluent color discharge to the NPDES Committee
at its March 13, 1996, meeting in Raleigh,North Carolina.
4. The Variance Review Committee made several recommendations to modify the
existing variance to the NPDES Committee, through a verbal presentation at the March 13, 1996,
meeting. and through memoranda dated March 7, 1996, from Greg Thorpe ("Review of Proposed
Modifications to Champion's Canton Mill Color Variance by the NPDES Committee"), and
March 6. 1996, from Dennis C. Loflin ("Consideration of Proposed Modifications to Champion
International Corporation's Color Variance for the Canton Mill NPDES Permit"), which are .
incorporated herein by reference.
5. Based on a consideration of the Variance Review Committee's reports and
recommendations, the NPDES Committee voted to propose modifications to the existing
variance, and directed its staff to carry out the public notice, comment and hearing process
required by G.S. 143-215.3(e) and Ordering Paragraph 8 of its July 13, 1988,Final Decision.
6. A public hearing was conducted by Mr. Harlan Britt, appointed as hearing officer
for the NPDES Committce and for the contemporaneous NPDES permitting process, on June 6,
1996, in Haywood County,North Carolina.

_.3
7• The hearing officer made several recommendations to modify the existing
variance to the NPDES Committee, through a verbal Presentation .at the October 9, 1996,
meeting, and through a memorandum dated October 2, 1996, which is incorporated herein by
reference.
8. Modification of the variance as recommended by the Variance Review Committee
Y.,
will not result in any discharge of waste that would endanger human health or safety. The
variance for color is to allow discharge of wastewater at levels that will prevent Champion's
contribution to the true color from causing the true color at the North Carolina/Tennessee State
line to exceed 50 true color units at all flows equal to or greater than 126 cfs at the Hepco
Gauging Station. The substance being discharged, for which the variance is sought, is not
bioaccumulative. The color does not, at the volumes and levels involved here, present a risk of
indirect or direct human impact or broad environmental damage. The waters are not water
supply. Therefore, the discharge will not endanger human health or safety.
9. Reduction of color discharge by application of best available technology is still
not economically reasonable and results in serious hardship without equal or greater benefit to
the public. A detailed and thorough study and evaluation of color removal technologies was
performed and reported in Champion's 1995 and 1996 Color Removal Technolo Reports
in
submitted to Division as required by the existing color variance.
10. Champion has now completed its mill modernization project which re-configured
its facility as an oxygen delignification, 100% chlorine dioxide substitution (OD-100) bleach
mill. The project resulted in limited color reduction in its effluent discharge. The end-of--pipe
technologies considered in 1988 and updated for the 1996 review established: a) standard

.4 _
water/wastewater separation technology (lime, alum, or polymer) has not been applied in a
similar fashion,b)these technologies would result in high capital and operating costs at the mill,
c) color reduction on this type of waste, using these type technologies has no operational
efficiency "track record" (effective under normal paper mill production variations, and consistent
and reproducible color removal), and d) the process color removal effectiveness of OD-100 may
present other in-process reduction opportunities that have not yet been realized.
Members of the
11. A schedule for continued color minimization is necessary.
ate of Tennessee commented that the variance document proposed in the
public. EPA and the St
public notice did not include any milestones for continued color reduction. Therefore, the
schedule contained in the Ordering Paragraph 4, infra, is established.
12. In review of the color data, including the short time since the re-configured mill
is determined that a more restrictive limitation should apply for
became fully operational, it
- ons contained in
color. Therefore, the more restrictive monthly and annual average color limitati
the Ordering Paragraph 3, infra, are established.
13. Based on the continued development of color discharge information from the
nthly average color
reconfigured mill, Champ Y
Champion is required to statistically evaluate its mo
"
discharge, its annual average color discharge, and the performance of the state line color model.
These evaluation processes are to be ongoing and the results of the evaluations are required to be
reported to the Division of Water Quality prior to each water quality standards triennial review
period. The results of these evaluation processes shall be utilized by the Division and the next
Variance Review Committee to make recommendations to the NPDES Committee on future

5
revisions to the variance. Champion shall follow the Color Data Variance Review Requirements
proposed by the staff and the hearing officer, in reporting these evaluations.
14. As provided in Findings of Fact#8,supra, Champion is also required to take such
actions as necessary to,prevent their contribution of true color from exceeding 50 true color units
at the North Carolina/Tennessee state line at all flows equal to or greater than 126 cfs at the
a
r
Hepco Gauging Station. Furthermore, the method by which compliance is determined shall
continue to be the color predictive model.
CONCLUSIONS OF LAW -
1. Pursuant to the Ordering Paragraph 6 of the July 18, 1988, Final Decision,-the
NPDES Committee has reviewed the existing variance following the Champion Canton Mill
modernization program.
2. The previously existing variance from the North Carolina water quality standard
for color, memorialized in the NPDES Committee's Final Decision, dated July 18, 1998, remains
in effect except as specifically modified herein.
3. Based on the effectiveness of the treatment system subsequent to the Canton Mill
modernization project and due to the potential for improvements in color reductions by use of
bleach filtrate recycling (BFRTm), changes to the variance are warranted.
Based on the foregoing Findings of Fact and Conclusions of Law, it is hereby ORDERED
that the previously existing variance from the North Carolina water quality standard for color as
memorialized in the July 0, 1988 Final Decision.Ordering Paragraphs, continues in effect as
hereby modified', to read its follows:[
For ease of reference, the language of the July 13, 1988 Final Decision Ordering
Paragraphs is included verbatim, with the modifications denoted by overstriking for deletions

6
1. Champion's petition for a variance is granted, pursuant to G.S. 143-214.3(e), as a
variance to water quality based effluent limitations for color.
2. The Division of
*4a ent Water Quality2
'" shall issue NPDES
Permit No. NC0000272, for the Canton Mill, and medi€y draft its provisions to reflect all the
i
ooc a a cvn *T;ppEc ^exit this modification,
conditions of
r
including the following specific wording.
1. Champion shall take such action as necessary to prevent their
contribution of true color from causing the true color at the North
Carolina/Tennessee State line from exceeding Sd 50 true color units at all
flows equal to or exceeding 126 cfs (81.4 MGD, the seven-day, ten-year
low flow level) at the Hepco Gauging Station.
Compliance with this requirement shall be measured through a calculation
of instream true color levels at the North Carolina/Tennessee state line by
the following equation:
91
1�4�18
Sl._ (WTP / 8 341 + ((Uf_—W_UOJD-J
(-0.224xLOG(HE,)+ 0.781)
HEfx 10
Where:
WTP,= Monthly average Waste Treatment Plant discharge color. (C—L�3
Calculated as the average of all daily loading values (pounds of true
color per day) for a calendar month.
WTPf= Monthly average Waste Treatment Plant discharge flow(mgd).
HEf = Monthly average HEPCO, North Carolina flow (MGD). Daily
flow values less than 81.4 mgd shall be entered as 81.4 mgd.
and bolding for additions.
'- The Division of Environmental Management has been reorganized and NPDES
permitting is now administered by the Division of Water Quality.

• ram•
7
SI, = Monthly average Instream true color at North Carolina/Tennessee
border(state line).
D,= Color concentration of all dilution streams (13 C.U.).
The SL, shall be calculated ee-a- y-?3asis for each calendar month.
The average of a�l ealead& week (seven days) ef ealeul SL, values
for each month shall not exceed 83 50 true color units. Any exceedance
of 83 50 true color units for this average value shall be considered a
violation of thus permit/variance exee r n r t • -�� cded ' * ill r L•
r
I�
II. The average daily discharge of true color for each calendar month
shall not exceed 258,945 132,341 pounds per day. The average annual
effluent true color loading shall not exceed 17'_� 124,923 pounds per
day. For the purpose of this pennit/variance only, "pounds of true color"
is calculated by the following equation:
Effluent Flow (mgd) x Effluent True Color Level (Platinum Cobalt Units)
x 8.34.
I Gha.mrinr is net required te feduee L daily ra
leading, less F ian '1'A 1 n: p a a
a •e 1 v �'p�4cJ-
l The method of analyses used to measure true color shall be
the procedure referenced in FR 39 430:11(b) (May 29, 1974).
3. The Division of>;...•:_... .. eat l ManagementWater Quality shall include review
of this variance as a specific item in its Triennial Water Quality Standards review, as required by
the federal Clean Water Act, and make appropriate recommendations to'the NPDES Committee.
4. Champion shall continue to study study, a*d evaluate' and pursue color removal
technologies.and shall report its.findings to the Division of,;nvife l *R z ea � Water
�" _
Quality d r}�-upaii-disee PN and aaii 11y en er beAre
A '1 30 C 1 yeaF in
accordance with the following schedule:

8 _
DATE ACTIVITY
Continuing Commercial demonstration of bleach filtrate
recycling 03FRTM
March 11 1998 In conjunction with the scheduled Triennial
Review of N.C.Water Quality Standards:
I. Submit a status report on the technical,
economic, and operational feasibility of
BFRT" technology, including those
analyses prepared for other permitting
agencies concerning its effects on air
emissions. „
2. Evaluate and report on end-of-pipe color
reduction technologies.
3. Evaluate and report on minimization of
color losses from manufacturing process
and from raw material storage areas.
December 1, 1998 Based on the results of the demonstration project
and the conclusion of the status report.
Champion will decide to report
ep technology on ahe decision
to operate BFRT" g
s a fully
commercial process on the pinewood line.
December 1,2000 Champion will evaluate color reduction
strategies for further optimization of BFRT"
technology and report on the feasibility of
implementation on the hardwood line.
March 1,2001 Champion will evaluate and report on
end-of-pipe color reduction technologies in
conjunction with the Triennial Review of N.C.
Water Quality Standards.
June 1,20U1 Champion will submit a report to N.C. DE11NR,
Division of Water Quality, on the comparative
evaluation of the above collective efforts as part
of the variance review process (Triennial Review
of North Carolina Water Quality Standards).

_ r _
9
5. The Division will provide a status summary report on color removal at the Canton
Mill to the NPDES Committee " '^ Af prior to completion
of the Triennial Water Quality Standards review.
5A. Based on the continued_development of color discharge information from the
reconfigured mill, Champion will statistically evaluate its monthly average color discharge,
Y
its annual average color discharge, and the performance of the state line color model. This
evaluation process shall be ongoing and the results of the evaluation shall be reported to
the Division prior to each triennial review period referenced in this variance. The results
of this evaluation process will be utilized by the Division and the Variance. Review
Committee to make recommendations to the NPDES Committee on revisions to the
variance. Champion shall follow the Color Data Variance Review Requirements proposed
by the staff and the hearing officer in reporting these evaluations.
6. Fellewing the eempl n.,...,.f the _ w 41's __i - -
a-d In conjunction Nvith theist subsequent triennial water quality standards reviews aft
st ,p ...t f _ eaeh fell, .....,a tdie • , ;qp4AAthe Division will nominate a variance review .
committee. The NPDES Committee will have final approval of the selection of this committee.
v4iieh will Committee membership. may consist of bra^ ! Rese ees. and G
�ffter
Development Department Staff and aleas4individuals considered authorities on pulp and
paper technology or environmental aspects of that industry from the university. or research
communities' That review committee's report and recommendation will be examined by the
NPDES Committee fora decision on the adequacy of the existing variance. The NPDES
The Variance Review Committee membership qualifications are changed to provide
greater flexibility in appointments.

. .10 -
variance are warranted due to the effectiveness of the
Committee will determine if changes in the
treatment system or because of advances in color reduction technologies for this type wastewater.
the modification of the Company's
All revisions adopted by the NPDES Committee will require
$rate NPDES Discharge Permit,
S Permit No. NC 0000272, shall at all
7.: The variance proceeding, and the NPDE
times be subject to reopening in order to modify the color requirements based upon any
breakthrough in color removal technologies. Such breakthroughs shall be brought to the NPDES
Committee for consideration, by Champion and the Division of n
Water Quality, as soon as they are discovered.
g. This variance shall extend for an indefinite period of time, subject to
h ��. - and Any modification or
consideration of the three-year reviews �^^�`'�
termination based thereon shall be subjected to the public hearing process required by G.S.
143-215.3(e).
It is further ORDERED that this Modification of Color Variance shall be effective as of
the re-issued NPDES Permit No.NC 0000272 for the Canton Mi1L and the
the effective date of
existing variance shall.continue in effect until that time.
terms of the previously

This the day of October, 1996.
Daniel V. Besse, Chairman
r NPDES Committee

12
CERTIFICATE OF SERVICE
This is to certify that I have this day served a copy of the foregoing MODIFICATION OF
COLOR VARIANCE GRA-NTED ON JULY 13, 1988 on the parties listed below by the
methods indicated, addressed to each as follows:
William Clarke
U.S. MAIL
Roberts & Stevens
Suite 900 e
One W. Park Square
Asheville,North Carolina 28802
A.Preston Howard. Jr.,Director
HAND DELIVERY
Division of Water Quality
N.C. Department of Environment,Health
and Natural Resources
9th floor, Archdale Building
Raleigh,North Carolina 27601-7687
Jennie Odette, Clerk HAND DELIVERY
Environmental Management Commission
N.C. Department of Environment, Health
and Natural Resources
9th floor, Archdale Building
Raleigh,North Carolina 27601-7687
U.S. MAIL
Paul Davis
Tennessee Department of Environment
& Conservation
6th floor, L & C Annex
401 Church Street
Nashville,Tennessee 37243-1534
U.S. MAIL
David McKinney
Tennessee Wildlife Resources
Ellington Agriculture Center .
P. 0. Box 40747
Nashville,Tennessee 37204
Gary Davis U.S. MAIL
Tennessee Environmental Council
1700 Hayes Street, Suite 101
Nashville,Tennessee 37203

13
Mike McGhee U.S. MAIL
Director of Water Management
100 Alabama Street, SW
Atlanta,,Georgia 30303
This the 15th day of October, 1996.
MICHAEL F. EASLEY
Attorney General
/13354
Daniel C. Oakley ,
Senior Deputy Attorney General
Environmental Division
P. 0. Box 629
Raleigh,North Carolina 27602-0629
919/733-5725

FA('l SHEET: CHAMPION - CANTON`M ii,NC0000272
REVISED
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
-. FRCT SHEET
REVISED
APPLICATION FOR
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PERMIT TO DISCHARGE TREATED WASTEWATER
x.
Application No. NC0000272 Date: 9/30/96
1. ' SYNOPSIS OF APPLICATION
Applicant's Name
Champion Intemational Corporation-Canton Mill WWTP
Applicant's Address
P. 0. Box C - 10
Canton, NC 28716
Facility Address
off Highway 215
Canton
Haywood County
T e of Operation
Integrated bleached Kraft pulp and paper manufacturing facility producing food board and
fine paper.
Design Capacity of Facility
Treatment of wastewater stormwater associated with pulp and paper mill,
chlorinated domestic wastewater from the Town of Canton, and leachate
from Champion's existing landfill. The plant will be limited at 29.9 MGD
average monthly flow.
Production Capacity of Facility
712 tons per day BCT bleached Kraft
901 tons per day fine bleached Kraft
(This is based on the NPDES permit renewal application submitted by Champion)
Applicant's Receiving Water
Receiving Stream: Pigeon River
Classification: C
Sub-Basin: 04-03-05
Page 1

FACTSHEET: CHAMPION - CANTON MILL,NC0000272
REVISED
See Attachment A for a map showing the discharge location(s).
Description of Wastewater Treatment Facilities
The wastewater treatment facility consists of a grit chamber,bar screens,lift Pumps,
polymer addition,pH control (CO2 injection or H2SO4 backu ),three Primary
nutrient feed, aeration basins,three secondary clarifiers,residual belt presses, effluent flow
measurement,cascade aeration(with oxygen injection), and oxygen injection facilities.
The treatment plant receives an average of 0.9 MGD of chlorinated
domestic (untreated).wastewater from the Town of Canton; leachate from
Champion's existing landfill (which has variable flow based on storm
incidences); stormwater; and the majority of wastewater from pulp and
paper mill production and associated process wastewater.
North Carolinas wastewater treatment plant certification guidelines rate this plant as a
Class IV facility. Unless otherwise noted,monitoring frequencies reflect a Class IV facility
as outlined in 15A NCAC 2B .0500.
Summary of Existing Wastewater Treatment Plant Operation
See Attachment B (copy of the EPA issued permit-excluding boiler plate language).
Type of Wastewater(as reported by applicant).
3 %Domestic (approximately 0.9 MGD from the Town of Canton)
97 %Industrial
2. PROPOSED EFFLUENT LIMITATIONS
Basis for Final Effluent Limits and Permit Conditions
This permit was previously issued in 1989 by EPA. From that time, Champion has
incorporated thethe oxygen delignifrcation process and elemental chlorine freewith
art of C
other internal modificatiolant as ns has significantly reduced the effluent
:MP (Canton Modernization flow(from 485 MGD to
29.9 MGD).
The production values listed in 1. above were used to calculate the federal effluent guideline
limits for Pulp,Paper, and Paperboard Point Source Category(See Attachment).
However,the Champion Mill is water quality limited for BODS,so more stringent limits
have been applied.
BODSandlnst m Dissolved Oxyeen:
An EPA-approved computer model indicated that more stringent limits than those given by
federal effluent guidelines were necessary to protect North Carolinas instream dissolved
oxygen standard of 5 mg/l for Class C waters [15A NCAC 2B .0211 (b) (3) (B)]. ol
to
the absence of an end-of-pipe technology capable of consistently treating to levels
necessary to meet the limits specified by the model,North Carolina has agreed with the
continuation of the requirement that Champion meet the instream dissolved oxygen
standard by use of sidestream oxygen injection facilities, as necessary (See Part III,
Page 2

F,4C -,�.IEET: CHAMPION - CANTON Ml- , NCoo60272
REVISED
Condition I of the draft permit). Historically, Champion has maintained oxygen injection
facilities at the effluent and at approximately 0.9, 2.1, and 3.7 miles downstream of the
discharge. Oxygen injection facilities will continue to be maintained at the
effluent, 0.9, and 2.1 miles-downstream, and used as necessary to maintain
an instream`dissolved.oxy&n' level of 5 mg/l."To ensure'compliarice with the
above requirement,the average daily instream dissolved oxygen levels at river miles 62.9,
57.7, and 55.5 shall not be less than 5 mg/1 and the minimum instantaneous instream value
shall not be less than 4 mg/l. This method is acceptable based on 40 CFR 125.3 (f).
Extensive instream monitoring is required to assess Champion's impact on the Pigeon
River and to ensure that the dissolved oxygen standard is maintained throughout the
impacted zone of the river(See Part I.A(2) of the draft permit).
No instream D.O. violations have occurred since 1990.
The draft permit BOD5 limit was established based on the demonstrated level of
performance of the existing treatment plant(a site specific Best Available Technology
requirement). The monthly average BOD5 limit (3598 lbs/day)is based on the 95th
percentile value analyzed by the Log-Pearson Skew method on data from 1/91 to 12/95.
The 1/91 to 12/95 data were used as a result of the incomplete data base of post-CMP
values at optimal production and the need to simulate the projected mill "
variability under post CMP conditions including cold mill shut downs and
start ups. The 95th percentile represents two standard deviations around the mean of
daily values. In this way, day-to-day variability is measured and used to set monthly
average limits. Although the Log Pearson III method is not typically applied
to monthly averages, in this case the 60 data values were a skewed "
distribution. Upon the next permit renewal, post-CMP data, from 8/95 to the renewal
application date will be used for the data analysis (and analyzed based on influent values
and plant removal efficiencies). Based on limited post-CMP and optimal production data,
and as a result of the fact that Champion is in the demonstration process of Bleach Filtrate
Recycle (BFR), the above procedure was used for this permit cycle.
The daily maximum value has remained the same as the previous permit(124581bs/day).
During the next permit renewal,the post-CMP monthly average:daily maximum ratio will
be compared and used to calculate a new daily maximum.
As stated previously, the Champion Canton Mill cannot comply with the
predicted BOD5 level to protect the instream dissolved oxygen water quality
limit of 5 mg/l. Therefore, the limit presented in the draft permit
represents an achievable level for the mill. Because Champion has oxygen
injection facilities in place to maintain the instream dissolved oxygen
standard should worst case conditions arise, Champion complies with the
conditions set forth by 40 CFR 125.3 (f).
Effluent Dissolved Oxygen'
Effluent dissolved oxygen is limited at no less than 6 mg/l based on the above discussion.
Daily monitoring is required based on 15A NCAC 2B .0508 (d),Paper and Allied
Products, Class IV facility.
Page 3

FACTSHEET: CHAMPION - CANTON MILL,NC0000272
Total Suspended Solids
The draft TSS limits are more stringent than the current federal effluent guidelines and are
based on the 1993 proposed guidelines for the oxygen delignification process. Champion
has accepted these proposed gudielines for TSS (monthly average) in the draft permit. The
monthly average was calculated as follows:
1613 tons/day, (total production) * 2000lbs/ton * 3.89 lbs TSS/1000 lbs product
= 12549 lbs/day
the rato of
The daily maximum was based on post-CMP operatio (8/95 to 1/96 o accounttaslight
highest daily maximum:monthly average for that time period (taking
intproduction increase). The proposed daily maximum values are also more stringent than the
current federal effluent.guidelines. The production value used was as indicated
on the permit application and is within 10% of reported production capacity
values (post-August 1995).
North Carolina does not have a numeric standard for TSS. The rules
specifically regulate floating solids, The draft pertleable mit restricts
solids.[ref. 15A NCAC 2B .0211(3)(c)].
solids. Settleable solids monitoring was removed from the permit due to
consistently low values (well below North Carolina's long term average
restriction of 5 ml/1). Additionally, the limit imposed in the permit is more
stringent than current applicable federal guidelines. Finally, both benthic
and IBI studies have indicated further improvement to the Pigeon River.
Therefore, the negotiated .limit of 12,549 lbs/dap represents a reasonable . ..
compromise for, this permit cycle.
Daily monitoring is required based on 15A NCAC 2B .0508 (d) for Paper and Allied
Products, Class IV facility.
Total Residue/Total Dissolved Solids
Monioring for these parameters is uired
assess the
plant• Daily monitoring has been required to o total
correspond ndwith the requirement for TSS.
Color
Champion has applied for a variance from the instream color narrative criteria in North
Carolina[15A NCAC 2B .0211(b)(3)(F)].
The permit and variance requires that compliance be based on 50 true color
units as calculated by the color model. The color model provides
Champion a predictive tool for color loads at the state line based on
effluent values. Application of the color model allows the Division and
Champion to assess the plant's contribution to the color levels at the state
line through effluent measurements which are not compromised by
introduction of other color sources. If the model predicts an exceedance,
Champion can take immediate steps to investigate and correct potential
problems. Thus the model allows for real time adjustments to be made in
the operation of the mill to ensure protection of the 50 CU requirement at
the state line. Recent data demonstrate that true color units at the state line
Page 4

FAC,oAEET:'CHAMPION - CANTON ML—;"NC0000272
REVISED
have been below 50 CU. Monthly average numbers are around 30 CU for
the river at the state line since the reconfigured mill came on line.
Champion will be required .to comply,with a calculated monthly average
color 'load' of^132,341:Ibs/day I'at the"effluent and an annual average 'load'
of ,124,923 lbs/day.
The permit also requires that the predictive color model be recalibrated
prior to the next permit renewal. The period of record and simulations to
be used are provided as a supplement, to the hearing record.
Instream color monitoring was recommended at the first downstream station
(DNI), below Clyde (DN3), and at NCSR 1625 (DN4),-in addition to the
existing color monitoring., -Color monitoring was included at these stations
to better describe the color impacts within North Carolina. The station
above Clyde (DN2) was not included due to its proximity to DN1 and DN3
and lack of other potential contributions (such as significant streams or
discharges) within that area. Instream true and apparent color monitoring
is -required (Part LA (2)).
A schedule for continued evaluation of color minimization has been added
to the modified variance and the revised permit (See Part III, Condition F).
Essentially, the color minimization requires: 1) continued operation and
evaluation of the BFRTM system installed at the Canton Mill to establish the
operational integrity of the system and to ultimately determine that the
system is appropriate :and• can.be counted on, 2) evaluation,of applicability
of BFRTM technology to the other bleach lines at the mill (the hardwood
line), 3) identifying and evaluating other in-process opportunities:to. _ ..
reduce color discharges to the waste treatment system and development of
an appropriate time frame to integrate the recommended changes, 4)
evaluation of raw material storage areas and the feasibility of modifying the
existing system to reduce color discharges to the WWTP, and 5) evaluate
the applicability of end-of-pipe treatment technologies to achieve
significant reductions in color discharges. -The intent of the schedule is to
ensure that Champion reviews in-process modifications prior to end-of-pipe
technologies. .
A reopener clause 'vas also added in order to modify the color requirements
based upon any breakthrough in color removal technologies.
Ammonia
Monitoring requirements are included in the permit to provide data conceming levels of
ammonia discharged to the'pigeon River(which may affect instream dissolved oxygen).
f
Page 5

FACTSHEET::CHAMPION
-CANTON MILL;NC0000272
Trichloronhenol/Pentachloronhenol
The pennittee has certified that chlorophenolic biocides are not used at the facility-
certification elitninates the requirement to'include effluent limits omonitorine two g will be
eters
based on 40 CFR 430.84 and 40 CFR 430.94. However, quarterly
required.
.Chloroform-.'-,.;
Chloroform monitoring/limit has been removed from the permit. Based on
an allowable level of.,*.8 mg/l (using the federal criteria of 470 µg/1 and
existing data indicated no reasonable potential to exceed this
average flow) _
allowable effluent level. Therefore, this parameter was dropped from the
permit. ..
Fecal— Co -
Limitations for fecal coliform are based on the contribution of domestic wastewater from
the Town of Canton and the requirements of 15A NCAC 2B .0211 (b) (3) (E)•
Limitations for pH are based on 15A NCAC 2B .0211 (b) (3) (G).
Temcerature
The temperature limit and monitoring requirement is based on a.Section 316 (a)variance.::::
determination was accepted by the NC Environmental Management
Commission October 11, 1984 and.approved by EPA August 6, 1985. Upon the
next permit renewal Champion shall submit documentation regarding the
continued need for a temperature variance along with temperature data and
simulations specified in the supplement submitted with the hearing record.
This will give Champion the opportunity to stabilize the mill (with regard
to production and BFRTM implementation) and provide an ample data base
for review. Periods of record for data review have been specified in the
supplement so that no confusion will occur with the next permit renewal
period.
In making the recommendation to retain the current 316(a) variance, staff
note that a balanced and indigenous population was determined in 1984.
The 316(a) variance for Champion was also retained during the 1992
Triennial Review. Both benthic community studies and Index of Biological
Integrity studies have shown improvement below her viewed entonxisting sincell the
post Canton Modernization Program (CMP).
Staff temperature data and although some improvement has occurred (most likely
due to overall effluent flow decrease), Champion still cannot meet the
North Carolina temperature requirement. Because the Champion plant has
on and 7Q10 have not been reached during post
limited data at full producti
CMP, the temperature variance will be reviewed more thoroughly during
the next permit renewal (See Part III, Condition L of the permit).
Page 6

FAC `srJEETC CHAMPION-CANTON MI NC0000272
.REVISED
Flow
The flow limit is based on Champion's current flow values and post-CMP production plus
0.9 MGD for the Town of Canton's'wastewater (See more specific description in
'Description of Wastewater-Treatment Facility'). Due to potential
inflow/infiltration problems with the Town of Canton,the Division granted Champion's
request for 0.9 MGD increase in flow-with the provision that Champion continue to work
with Canton to reduce 1/I problems (Part III, Special Condition J).
Effluent Toxicity ,
r
The toxicity testing requirement is placed on all major facilities and other facilities with
complex wastestreams (Departmental memo 7/22/87). The toxicity limit is based on the
instream waste concentration under 7Q10 conditions (54 cfs): For Champion,the instream
waste concentration was determined by also accounting for the out-take of surface water
from the facility (30.4 MGD, as per application). Therefore, the instream waste
concentration was determined to be 87% under 7Q 10 conditions.
Champion is required to perform the NC Whole Effluent Toxicity Test or an equivalent
method(as approved by the Division)on a quarterly basis at 87%. Any equivalent method
shall also be performed on a quarterly basis.
Mercury
Mercury was found in the Champion effluent at values above detection
levels in 3 out of 4 samples taken.. Mercury is not an expected parameter..of.. _.. :
concern in pulp and paper wastewater. Due to the potential for testing
interference and the limited data set, 'monitoring shall be conducted 2/month
on the effluent for one year. On December 1, 1997 an effluent mercury
limit of 0.014 99/1 will be implemented unless Champion can meet the
conditions specified in Part III, Special Condition M. In general, should
Champion show effluent mercury levels less than 0.2 µg/I (the quantitation
level) after nine months of sampling, the Division will eliminate the
mercury limit and reduce monitoring to quarterly.
Zinc/Hardness
Reported values for zinc have exceeded the state action level. Monitoring requirements for
zinc have been included in the draft permit(15A NCAC 2B .0211 (b) (4)). Numerical
limits for zinc are not being included in the NPDES permit since the water quality standards
do not contain a numeric criteria for zinc and the biomonitoring requirements in the NPDES
permit are adequate to control toxicity due to the presence of zinc in the facility effluent.
Zinc is a function of water hardness, so hardness monitoring is required in coordination
with zinc monitoring. The monitoring frequency for zinc (2/month)is based on the
Division's standard operating procedure for monitoring of toxicants for Class IV facilities.
Champion is rated as a Class IV facility. r
Page 7

CHAMPIOONNVICA TON MILL,NC0000272
FACTSHEET:
Traces
Cadmium, selenium, and silver-have been recommended for quarterly
effluent monitoring. The limited data set indicated at least one value above
allowable levels for each parameter. . Although tra a metals
r concern and
pulp and paper.wastewater, these are not typical p
no limit is recommended at this time.
Dioxin
bee
er discharge
this
Measurable
since the levels o f dioxin
iox n a e not AP There is currently a fish detected in the tconsumption advisory
for the Pigeon River downstream of the discharge. Although the advisory was
initially .in effect for consumption of all fish species, this advisory has
due to continued
been reduced to carp and catfish species only -
improvements in the River.
influent sludge,llandfill leachaterand efflue dioxin nt (See enzofuran isomersPart III,Condition H).arterly from the
7
The effluent 2,3, ,8 TCDD limit is based on 15A NCAC 2B .0208 (a) (2) (B). The
average flow of the Pigeon River(325 cfs)was used in the calculation of the allowable
effluent limit for dioxin at the NC instream water quality standard of 0.00014 ng/l [15A
NCAC 2B .0206 (a) (3) (B)J. The limit is a daily maximum limit.
Annual fish tissue analysis shall also be performed by the facility in accordance with the
monitoring plan approved by the Division.
Total Phos horusrrotal Nitrogen
Total phosphorus and total nitrogento hoeingssess is contribution l of nutrients from Champion
(A). Monthly monitoring is required to
and the potential impact to Waterville Reservoir. Waterville Reservoir
it is io be to
monitored once annually (during oppositeY
assist in characterizing nutrient impacts to the lake.
Conductivity
Conductivity monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied
Products (Water Quality Limited Facilities),for a Class IV facility.
COD
assess the potential impact of chemical oxygen demand from
COD monitoring is required to
the Champion wastewater effluent. Neither federal guidelines nor NC water quality
standards require a limit for COD. Current draft EPA regulations and supporting
documents state that COD may be related to effluent toxicity. As the permit
contains a chronic toxicity limit and the plant has not documented any
toxicity problems, no limit for COD has been proposed.
Page 8

'FAC'.'SriEET: CHAMPION - CANTON M1L,=, 4C0000272
'REVISED
AOX
Monthly effluent monitoring for AOX has been required in the permit.. .;.;
AOX,is an-overall''test"for"adsorbable organic"halides, which include =-,,,
chlorinated"organics. Trends 'in concentration changes have been observed
between AOX and specific-pollutants (dioxins, chlorinated organics) at -
pulp and paper mills. Therefore, any decrease in AOX may also indicate a
decrease in chlorinated organics. Limits for AOX are proposed .in the draft
EPA Cl'uster'Rules. Monitoring has been added with this permit to better .
characterize the effluent.
A
y
3: _ EFFECTIVE DATE OF PROPOSED EFFLUENT LIMITS
LAND COMPLIANCE SCHEDULE IF APPLICABLE)
The limits become effective on the date of permit issuance.
4. PROPOSED SPECIAL CONDITIONS WHICH WILL HAVE A SIGNIFICANT
IMPACT ON THE DISCHARGE
Toxicity Testing Requirement
Color Monitoring Requirement
Color Minimization Schedule
Dioxin Limit and Monitoring -
Waterville Reservoir Sampling
Dissulved Oxygen Requirement
5. REQUESTED VARIANCES OR ALTERNATIVES TO REQUIRED
STANDARDS
The facility requested and received a 316 (a)variance granted by EPA 8/6/85. This
determination demonstrated that the effluent limitations relating to the thermal component of
the Champion discharge based on application of NC water quality standards were more
stringent than necessary to assure protection and propagation of a balanced indigenous
population of shellfish, fish, and wildlife in the Pigeon River. Therefore, the 316(a)
determination was approved based on protection of the appropriate use classification of the
Pigeon River. This permit continues the 316(a) variance and requires studies
to be completed prior to the next permit cycle to enable re-evaluation of the
variance.
As discussed previously, Champion has applied for a variance from the instream color
narrative criteria in North Carolina [15A NCAC 2B .0211(b)(3)(F)]. See Section 2 and
the attached variance documents.
6. DISCUSSION OF PREVIOUS NPDES PERMIT CONDITIONS
See attached EPA permit.
Page 9

FACTSHEET: CHAMPION - CANTON MILL,NC0000272
REVISED
7 THE ADMINISTRATIVE RECORD
The administrative record, including application, draft permit, fact sheet,public notice,
comments received, and additional information is available by writing the Division of
Environmental-Management,Water Quality Section, P. 0.Box 29535,Raleigh,North
Carolina 27626-0535. The above documents are available for review and copying at the
Archdale Building,9th Floor,Water Quality Section,Permits and Engineering Unit, 512
North Salisbury Street, Raleigh,North Carolina 27611 between the hours of 8:00 a.m.
and 5:00 p.m.Monday through Friday. Copies will be provided at a charge of 10 cents per
page•
r
g. STATE CONTACT
Additional information concerning the permit application may be obtained at the above
address during the hours stated in item No. 9 by contacting: Susan Wilson at(919)733-
5083, extension 555.
9, PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice- 5/6196
Public Hearing -6/6/96
Permit Scheduled to Issue- October 1996
10- PROCEDURES FOR THE FORMULATION OF FINAL DETERMINATIONS
a. Comment
The Division of Environmental Management proposes to issue an NPDES Permit to this
deterrminations ar to the e tentative andent limitations are open t acomment from the publcial conditions ic.
above. These
Interested persons are invited to submit written comments on the permit application or on
the Division of Environmental Management's proposed determinations to the following
address:
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
POST OFFICE BOX 29535
RALEIGH,NORTH CAROLINA 27626-0535
Y
All comments received within thirty
days following the date of public notice will be
considered in the formulation of final determinations with regard to this application.
b. Public Hearin
Due to the public interest in the permit and the requirement of a public hearing for variance
review, a public hearing has already been scheduled. The hearing will be held June 6,
1996.
Page 10

FACTSHEET: CHAMPION - CANTON MILL, NC0000272
REVISED
C. Appeal Hearings
An applicant whose permit is denied, or is granted subject to conditions he deems
unacceptable, shall have the right to a hearing before the Commission upon making written
demand to the-Director within 30 days following issuance or denial of the permit.
d. Issuance of the permit when no hearing is held
Not applicable.
r
a
Page 11

W
RESPONSE TO COMMENTS e
CHAMPION NC0000272
TEMPERATURE
Comment: The temperature variance should be re-evaluated.
Response: Staff has recommended that the 316(a)temperature variance granted by EPA
August 6, 1985 remain in the permit. However,-upon the next permit renewal, Champion
must submit documentation regarding the need for a temperature variance along with
temperature data and simulations specified in the supplement submitted with the attached
recommendations. This will give Champion the opportunity to stabilize the mill (with
regard to production and BFR'M implementation) and provide an ample data base for
review: Periods of record for data review have been specified in the supplement so that
no confusion will occur with the next permit renewal period. .
In making the recommendation to retain the current 316(a)variance, staff noted that a
balanced and indigenous population was determined in 1984. Since that time, both .
benthic and fish community structure studies have shown improvement below the Canton
Mill. The 316(a) variance for Champion was also retained during the 1992 Triennial
a Review and submitted to EPA. Because the Champion plant has limited data at full
production and 7Q10 conditions have not been reached since completion of the Canton
Modernization Program (CMP), the temperature variance will be reviewed more
thoroughly during the next permit renewal.
DISSOLVED OXYGEN AND BOD5
Comment: The BOD and DO provisions of the permit constitute a variance to the water
quality standards for the Pigeon River, which is not authorized under the Clean Water
Act.
Response: Champion satisfies the requirements of 40 CFR 125.3 (f), therefore, the
BOD5 and DO limits do not constitute a variance. Part (1) of 40 CFR 125.3(f) is
satisfied because technology based treatment requirements are not sufficient to achieve
the standards.. The limit for BOD5 was developed based upon a site specific evaluation
of the treatment capabilities of the existing facility. This limit is less than the existing
federal guidelines and any currently proposed modifications to the guidelines. Part (2),
Champion has waived any variance request under these CWA subparts. Part (3), 02
injection is the preferred environmental and economic method to achieve the standard at
this time. Champion has already chosen and installed OD/ECF manufacturing processes
and is in the process of pilot studies for BFR on the pine line. These technologies have
reduced the BOD5 and color load on the WWTP, thereby, resulting in improved
efficiency of treatment. This was the chosen alternative during the previous permit cycle.
Champion continues to investigate further technologies (such as BFR on the hardwood
line). Further technologies should assist Champion in meeting a more stringent BOD5
limit in the future. A compliance schedule has been implemented in the revised permit to
help promote further reductions in color to the plant (which in turn should reduce
wasteloads).
Comment: The permit limits on BOD5 discharges are inadequate to meet the water
quality standard for dissolved oxygen in the river.
Response: The Champion Canton Mill cannot comply with the predicted BOD5 level
required to protect the instream dissolved oxygen water quality limit of 5 mg/l.
Therefore, the limit presented in the draft permit represents an achievable level for the
mill. However, Champion is required to maintain the instream dissolved oxygen standard
through the use of oxygen injection stations. Because Champion has oxygen injection

RESPONSE TO COMMENTS
CHAMPION NC0000272
facilities in place to maintain the instream dissolved oxygen standard should worst case
conditions arise, Champion complies with the conditions set forth by 40 CFR 125.3 (f).
Champion has not had to use the instream oxygen injection facilities since the end of
1993. The revised permit requires that Champion record the date and duration of
instream oxygen injection,when used.
Because of the resilient nature of BOD5;BOD5 monitoring has been required at the state
line. This is in addition to the extensive DO monitoring at multiple sampling points
downstream.
Comment: Sewage discharges have not been adequately addressed in the draft permit.
Response: The contribution of domestic wastewater will be more specifically addressed
in the permit and the fact sheet. The Town of Canton chlorinates untreated domestic
wastewater prior to its combining with Champion influent. The Town does not have a
combined sewer overflow system,but has had problems with inflow and infiltration
(which has been addressed in the permit). Flows from the Town average 0.7 MGD. The
Town does not have any significant industrial users and is not required to have a
pretreatment permit.
Secondary limits are not required in the Champion permit. Secondary limits only apply
to municipal discharges. This discharge is not considered to be municipal. Even so,the
Champion permit reflects a BOD5 limit of less than 30 mg/1.
Because the pulp and paper waste stream is nitrogen deficient and NH40H is added to
ensure the biological activity of the treatment system function properly, the Division sees
no need for NH3-N limits. Champion has averaged below 1.5 mg/1 monthly average for
the past year additional nutrient seed')for anion provides
the Champion wastewater treatment facility.
SOLIDS
Comment: Suspended solids limits are inadequate to protect water quality standards.
Response: North Carolina does not have a numeric standard for TSS. The rules
specifically regulate floating solids, settleable solids, and sludge deposits [ref. 15A
NCAC 2B .0211(3)(c)). The draft permit restricts floating solids. Settleable solids
monitoring was removed from the permit due to consistently low values (well below
North Carolina's long term average restriction of 5 m]/l). Additionally, the limit imposed
in the permit is more stringent than current applicable federal guidelines. Finally,both
in the p and IBI studies have indicated further improvement to the Pigeon River.
PARAMETERS OF CONCERN
Comment: The permit should contain limits on AOX, COD, Chloroform, and other
specific pollutants as contained in the proposed cluster rule.
Response: AOX has been recommended for monthly effluent monitoring in the revised
permit. COD monitoring is contained in the permit. Chloroform monitoring/limit has
been removed from the permit. Based on an allowable level of 2.8 mg/1(using the federal
criteria of 470 µg/1 and average flow) existing data indicated no reasonable potential to
exceed this allowable effluent level. Many of the other specific pollutants listed in the
proposed 1993 Cluster Rules have been dropped from the proposed 1996 Cluster Rules.
Since
o have aa
these bsis o implement theme npermit.
not enforceable at
Champion sta and North Carolina
does n
Comment: Chlorine limits should be included.

RESPONSE TO COMMENTS
CHAMPION NC0000272
Response: Champion has not shown toxicity attributable to total residual chlorine, so no
chlorine limit is required.
Comment: Metals and other parameters should be included.
Response: Cadmium, selenium, and silver have been recommended for quarterly effluent
monitoring. The limited data set indicated at least one value above allowable levels for
each parameter. Although trace metals are possible in pulp and paper wastewater, these
are not typical parameters of concern and staff do not recommend a limit at this time.
Mercury was found in the Champion effluent at values above detection levels in 3 of 4
samples collected. One of the three samples taken was a split sample in which one value
was below detection. Mercury is not an expected parameter of concern in pulp and paper
wastewater. Due to the poiential for testing interference and*the limited data set,
monitoring shall be conducted 2/month on the effluent for one year. On December 1,
1997 an effluent mercury limit of 0.014 µg/I will be implemented unless Champion can
meet the conditions specified in the permit.
Other parameters for which North Carolina has a water quality standard were reported
below allowable levels and are not considered parameters of Eoncem.
DIOXIN
Comment: Dioxin and Furaif limits are inadequate.
Response: The effluent 2,3,7,8 TCDD limit is based on 15A NCAC 2B .0208 (a) (2) (B)
and the NC instream water quality standard of 0.00014 ng/l [15A NCAC 2B .0206 (a) (3)
(B)]. The limit is a daily maximum limit. The dioxin and dibenzofuran isomers have
been recommended for quarterly monitoring (the same parameters in the previous EPA
permit and the most toxic forms) with the revised permit. The only limited parameter
will be 2,3,7,8 tetrachloro-dibenzo-p-dioxin. This is the most toxic isomer and the
parameter for which there is a North Carolina water quality standard.
I
Comment: The dioxin quantitation limit specified in the permit is inadequate.
Response: The 10 pg/1 quantitation limit is the minimum for water samples, based on
EPA-approved method. Below this level, data accuracy and precision is compromised.
Comment: Sediment sampling should be performed in Waterville Reservoir.
Response: Studies have been performed (CP&L) which correlate reduction of dioxin in
fish tissue with reduction in sediment. Both the state of Tennessee and North Carolina
have shown reduction of dioxin in fish tissue. The permit requires annual fish tissue
analysis for dioxin. Through CP&L's FERC re-licensing process, options were studied
for removal or cover of the sediment, with the recommendation that artificial capping of
sediments be required if dioxin concentrations do no continue to decrease. Staff concurs
with this assessment, due to decreasing concentrations of dioxin in the biota and the
potential problems associated with disturbing these sediments.
MISCELLANEOUS
Comment: Landfill leachate should be addressed by the permit.
Response: Leachate is directed to the Town of Canton, which discharges to the mill.
Champion is required by the permit to monitor dioxin/furan isomers from the leachate.
Champion has begun flow monitoring of the leachate and flow has been variable
(dependent on storm incidence), with averages less than .05 MGD.
� ';

Canton Mill * 7
Box C-10
Canton,North Carolina 28716
�III o d � od �
V Champion
Champion International Corporation f1f�T I 5 P*
WATER CISALITY SE10'IN
ASHEVILL[ kr "'%NAI off
October 10, 1996
Mr. Keith Haynes
Environmental Specialist
Division of Environmental Management
Water Quality Section
59 Woodfin Place
Asheville, NC 28802
RE: Stormwater Release at Champion's Canton Mill on October 8, 1996
Dear Mr. Haynes.
Champion Intemational is providing written notice of a storrnwater release from a
Chip Blower System sump to the Pigeon River. The release on October 8 was the
result of water being lost from a hole in the discharge line. No effect to the Pigeon
River was observed.
The information concerning the release is attached.
If you have any questions, please call Noureen Shaikh at [phone] or
Jim Giauque at [phone].
Sincerely,
Noureen Shaikh Jim Giauque
Assoc. Environmental Advanced Proce s
Engineer Engineer
Attachment
file:c:lkhayns4.doc

NOTIFICATION REPORT
CHAMPION INTERNATIONAL CORPORATION
MAIN STREET
PO BOX C-10
CANTON, NC 28716
HAYWOOD COUNTY
1. Name of Material: Stormwater from Sump at Chip Unloading System
2. Caller's name and position: Jim Giauque
Advanced'Environmental Engineer
3. Media into which release occurred(air, water or land): Ground, Pigeon
River
4. Quantity released: Approximately 1,000-2,000Gallons
5. Date, start and stop of release:
Start date and time: Approximately 1:30 p.m. October 8, 1996
Stop date and time: Approximately 2:00 p.m. October 8, 1996
6. Causes and source of release: A sump pump was activated to empty
stormwater that had collected in the basement of the Lower Truck Unloading
System. Water was inadvertently discharged from a hole in the pump discharge
line onto the ground. Approximately 1,000-2,000 gallons of the water
overflowed a ditch line and escaped through a storm drain (Outfall #4) and flume
to the Pigeon River.
7. Action taken to respond to release and status of actions: The Pump was
shut off to prevent further discharge.

Notification Report for
Spill/ReleaseNent
Page 2
8. Notification made:
NCDEHNR -Asheville
Date: 10/09/96 Time: 08:50 a.m.
Contact: Keith Haynes (voice mail)
Follow-up:
NCDEHNR -Asheville
Date: 10/10/96 Time: 11:40 a.m.
Contact: Keith Haynes
9. Name and telephone number of person to contact for further information:
Jim Giauque
[phone]
10. Action taken for clean-up: Wood chips in the ditchline and a culvert have
been removed to facilitate flow of water. Sump discharge line will be properly
repaired.
file:c:Xnotify07.doc

Division of Water Quality
v Biological Assessment Group
G
October 4, 1996
MEMORANDUM
To: Ken Eagleson CS
Through: Jimmie Overton
" Trish MacPherson
From: Mark Hale
Subject Revised Study Plan for Fish Tissue Mercury Assessment- Pigeon River
Attached is a revised DWQ study plan for the investigation of mercury levels in fish from Pigeon
River rescheduled for October 7-9, 1996. I have altered some text in the background discussion
of this plan regarding results that Champion has submitted. Due to a transcription error, I stated
that Champion had collected one redbreast sample below the discharge which contained mercury
exceeding the EPA screening value. After further review of Champion's results, it is evident that
no fish samples contained mercury exceeding FDA or EPA criteria in the Champion study.
Please replace the original DWQ study plan dated September 26, 1996 with the attached
document.
cc: Dr. Luanne Williams - Envir. Epidemiology Section
Roy Davis-ARO
Bryn Tracy-ESB
Susan Wilson-NPDES Group

Revised Division of Water Quality Study Plan
Assessment of Mercury in Pigeon River Fish Tissue
October 1996
f
Background
Information compiled by the Clean Water Fund of North Carolina in July of this year from
Champion International's NPDES permit application indicated the presence of mercury in the
Canton Mill effluent. The Clean Water Fund subsequently requested that the DWQ investigate
the likelihood of mercury contamination of Pigeon River fish. The ARO responded by
examining historical sets of mercury results for Pigeon River fish provided by TVA, the
Tennessee Div. of Water Pollution Control, and North Carolina(CP&L and DWQ). The most
recent mercury data dates from 1995 and was submitted by TVA and Tennessee Div. of Water
Pollution Control. Data from North Carolina sources were older(from 1989s) and sketchy at
best. Information from North Carolina and Tennessee indicated that mercury concentrations in
fish (fillet tissue) collected from the Pigeon were comparable to "background"levels found in
fish throughout the state. Results for fillet tissue showed no total mercury concentrations above
the FDA action level of 1.0 ppm. (Although health concerns are focused on methylmercury,
results and criteria are generally expressed as total mercury. Most mercury(90-95%) in fish and
shellfish is in the form of methylmercury, but due to the high cost of the analysis the EPA
recommends that total mercury be analyzed and the conservative assumption be made that all
mercury present in fish is methylmercury.)
Further fish sampling was conducted by Champion in August 1996 at two sites near the mill e
discharge as part of their dioxin monitoring program. Mercury analyses were conducted on fish I
from two stations,NC-215 above the mill discharge, and near Clyde below the discharge. t
Mercury results above and below the Champion discharge were lower than the FDA (NC) and 1
EPA action levels of 1.0 ppm and 0.60 ppm respectively. Champion results did not suggest that
the mill discharge is a significant source of mercury pollution with respect to fish tissue in the
Pigeon River.
4
Concerns over the possibility of mercury contamination in Pigeon River fish continue to arise
from DWQ staff, State Health Department officials, and others due to the incomplete nature of
North Carolina fish tissue data and the lack of piscivorous species analyses in the recent
Champion study. Releases of mercury have also been detected in the Waynesville WWTP
effluent as recently as February 1996. The DWQ Environmental Sciences Branch proposes the
following study as a means to more closely examine mercury levels associated with fish in the
North Carolina section of the Pigeon River from the Champion Mill to the Walters Lake.
Sample Collection
Fish samples will be collected from 5 stations stretching along the mainstem Pigeon River from
just above the Champion mill discharge to the Walters Lake (see map).
1) NC-215 Bridge above the Champion discharge
2) SR 1513 above Clyde at river mile 59.0
3) Old Rt. 209 at river mile 52.3
4) SR 1364 atFerguson Bridge,river mile 48.2
5) Walters Lake

i
Page 2
Fish will be collected by DWQ staff at the above stations during October 7-9, 1996 via backpack
or boat electrofishing, depending on flow and access restrictions. Since mercury has been found
to bioaccumulate to a higher degree in piscivorous fish species, these will be targeted for
collection at all stations along the Pigeon. Piscivores most likely to be encountered include
largemouth bass, smallmouth bass, and rock bass. Additional insectivores, omnivores, and
bottom feeding species will be collected at each site whenever possible. Individuals of each
species collected at each site will number at least 4 but no more than 10 and will include various
size classes when possible. Collected fish will be sorted immediately after collection, placed by
species in plastic bags, and tagged with date, location, time, and collector information. Samples
will be placed on dry ice for transport back to the ESB laboratory in Raleigh.
I
Sample Processing and Analysis
i
All samples will be processed at the ESB laboratory. Fish will be weighed to the nearest gram
and lengthed to the nearest centimeter(total length)before processing. Analysis of mercury will
be conducted using the fillet or edible portion. All fillets except for catfish (Ictalurids) will be
processed with skin on. Processed fillets will be sent to the laboratory as individuals or may be
combined to form composite samples. Composites will contain no more than 10 fillets of the
same species and will be of similar size. Processed fish samples will be hand delivered to the
DWQ Chemistry Laboratory for mercury analysis. Results will be expressed as total mercury.
QA/QC
To assess total variability, duplicates will be prepared from at least 10% of fish samples.
Duplicates will be prepared from the same original fillet or composite homogenate. At least 10%
of fillet samples will be frozen and archived at the DWQ laboratory for a period of 6 months
after the survey.

Fish Tissue Sampling Stations for Pigeon River Mercury Assessment
NCDWQ October 1996
waxem Dam
♦� Walters Lake
fatalmd�ee
Oak
( �1 Gad
(42-)
Her Hepco Bridge
Ferguson Bridge (48.2)
FLOW
yay Old Rt. 209 (52.3)
C ee
Above Clyde (59.0)
IBM DL*f cwdvn HC
(�I
waymmk R-djnd Cy®'NC
lN�1 1 Hwy. 215 Bridge

-State of North Cart a
- Department of Environment,
Health and Natural Resources
Division of Water Quality ,
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary E) G
A. Preston Howard, Jr., P.E., Director C
•October 1, 1996
Ms. Beverly H. Banister, Acting Chief
Water Permits and Enforcement Branch,Water Management Division �,
EPA Region IV 4 as 0 gib, O
100 Alabama Street, S.W.
Atlanta, Georgia 30303 CFO/OryysFOr
A(O,rFJN
Subject: NPDES Permit
Champion International Corporation
Canton Mill WWTP
NPDES Permit No. NC0000272
Haywood County
Dear Ms. Banister:
Staff of the North Carolina Water Quality Section met with EPA Region IV staff on August 28,
1996 regarding the Champion International Corporation draft permit and color variance. This letter, along
with the permit, fact sh-zet, and modified variance document, is offered in response to your comments
submitted July 3, 1996.
The following summarizes the Division's response to EPA Region IV's comments:
• BOD5. The Champion Canton Mill cannot comply with the predicted BODS level necessary to protect
the instream dissolved oxygen water quality limit of 5 mg/1, without instream treatment under low-flow
conditions. Therefore, the limit presented in the draft permit represents a site specific BAT for the
mill. The monthly average BOD5 limit (35981bs/day) is based on the 95th percentile value analyzed
by the Log-Pearson Skew method on data from 1/91 to 12/95. The 1/91 to 12/95 data were-used as a
result of the incomplete data base of post-Canton Modernization Program (CMP) values at optimal
production available and the need to simulate the projected mill variability under post-CMP conditions
including cold mill shut downs and start ups. The 95th percentile represents two standard deviations
around the mean of daily values. In this way, day-to-day variability is measured and used to set
monthly average limits. Although the Log Pearson III method is not typically applied to monthly
averages, in this case the 60 data values were a skewed distribution. The daily maximum value has
remained the same as the previous permit (12458 lbs/day).
EPA stated in their letter that the proposed BOD5 limit does not reflect actual conditions at the mill.
The values listed in their letter were taken from the permit application, which was submitted in March
1994. Current data, which was used for the draft permit (up to December 1995) indicates that the
values listed in EPA's letter are beyond BAT at this facility. Additionally, the data EPA presented does
not include any post-CMP data or data at predicted optimal production levels.
P.O. Box 29535, Raleigh, North Carolina 27626.0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10%post-consumer paper

EPA Region IN, Response
Champion-Canton Mill WWTP
NPDES No. NC0000272
Pase 2
Upon the next permit renewal,post-CMP dataed , from 8/95 to the renewal application date will be used
for the data analysis (and anal the postSCMP monthly average dailinfluent values and ylmaximum ratio ant removal will be co parted
during the next permmt renewal,
and used to calculate a new daily maximum. Based on limited post-CMP and optimal production data,
aesult of the fact that Chmion is in nd as a)r the above procedure was used for this a demonstration process of Bleach Filtrate Recycle
(
2ermit cycle.
Several protect themodeling
dissolved oxyses were gen standard uerformed to ndertct the allowable 7Q10 conditions wiitthDouallocation
ithe use of supplemental
proteP
ct injection. The allowable allocation under this scenario was less than 12001bs/day. Therefore,
en injection facilities in
in order to ensure continued protection of the dissolved oxygen standard under low flows,Champion
must continue to use the oxygen injection system. Because Champion has oxygen j
instream dissolved oxygen standard should worst case
pl conditions arise, the
ace to maintain the
applicability of 40 CFR 125.3 (f) continues.
No change is proposed for the BODE limit.
• TSS. As stated in the Fact Sheet submitted to EPA,North Carolina does not have a numeric standard
settfor TSS. The rules specifically
draft permit trestric sng floating solids. Settleable le solids, and solidsemon o[ring
15A NCAC 2B .0211(3)(c)];
na term
a er removed a a restriction n the
permit due to
the limit low imposed(well
inthe permit isCarolina's
m oei str nge t than
structure studies have
current applicable federal guidelines.the Pigeon Rrverb Thhrefore, the negotiated trait of 12,549 Ibs/day
in.iicatz., furthcr imp Riv cycle.
represents a reasonable compromise for this permit
industry. The daily maximum value
Champion agreed to accept the 1993 proposed Cluster Rules for the monthly average value, which is
more stringent than the current regulations for the pulp and paper average values. The production
was based on the maximum ratio of daily maximum values to monthly a
value optimal's within
ntapproximately
pn roxim teAgain%the va of lues s EortedPA used tfor con o ptarison purposes were taken
4 application and do not reflect current data that was used to derive the TSS limit.
from the March 199
No change is proposed for the TSS limit.
-s from the a were above
• Mercury. North Carolina agrees that the reported value
effluent at values aboted vte d tect on levels n 3 of
allowable levels. Mercury was found in the Champ
4 samples collected. Mercury is not an expected parameter of concern in pulp and paper wastewater.
Due to the potential for testing interference and the limited data set, monitoring shall be conducted
2/month on the effluent for one year. On December 1, 1997 an effluent mercury limit of 0.014 µg/1
the uantitation
will be implemented unless Champion can meet the conditions specified in Part III, Special Condition
M. In general, should Champion show effluent mercury levels less than the elirrmercury
µ� ( 9
level)
vmonitoringafter
t i e months
of s�Champion has alsDotperformedvision la fish t slinasue study formlercury to further
characterize mercury impacts. Preliminary results from the fish tissue analysis show levels similar to
fish tissue analyses from other water bodies in North Carolina.

EPA Region IV Respc- --
Champion-Canton NEI_ WTP _
NPDES No. NC0000272
Page 3
• Temperature. Champion has requested continuance of the current 316(a) variance granted by EPA
August 1985. Again, the data reviewed by EPA included only those values from 1990 to 1994. Post-
CMP and optimal production have only been reached after April 1994 (with optimal production
reached in August 1995).
A balanced and indigenous population was documented in 1984. The 316(a) variance for Champion
was also retained during the 1992 Triennial Review and submitted to EPA. Both benthic community
studies and fishery studies have shown improvement below the Canton Mill since the post-CMP.
Staff reviewed existing temperature data and, although some improvement has occurred (most likely
due to overall effluent flow decrease), Champion still cannot meet the North Carolina temperature
requirement. Because the Champion plant has limited data at full production and 7Q10 conditions
have not been reached during post-CMP, the temperature variance will be reviewed more thoroughly
during the next permit renewal with pre-established periods of record and simulations. This condition
has been specified more fully in the permit (see Part III, Condition L) and supplement to the hearing
record. S
• Instream Monitoring. North Carolina agrees with EPA in the addition of color monitoring within
North Carolina. Instream color monitoring shall be conducted 2/week at downstream locations DNI,
DN3, and DN4. Color monitoring was included at these stations to better indicate color impacts within
North Carolina. The station above Clyde (DN2) was not included due to its proximity to DNI and
DN3 and lack of other contributions (such as significant streams or discharges) within that area.
Instream true and apparent color monitoring is required (Part I.A (2)).
• Color. The color equation has been corrected as noted. The variance will be reviewed by the NPDES
Committee in October prior to issuance of the permit. If the variance is approved by the committee,the
Division will proceed to issue the permit after approval from the Director. The permit will not become
effective until at least 30 days after issuance. Due to the complexities of the permit, the Division does
not believe that separation of the permit and the color variance is beneficial.
Champion is required to comply with a calculated monthly average color'load' of 132,341 lbs/day at
the effluent [decreased from 198,813 lbs/day] and an annual average 'load' of 124,923 Ibs/day
[decreased from 132,341 lbs/day] with the modified variance.
• Implementation of a Schedule for Continued Color Improvements. Staff have worked
with Champion to establish a timeline for continued evaluation of color reduction at the mill. This is
outlined in Part III, Special Condition F of the permit.
The color variance is presented in more detail in the attached memo from Forrest Westall.
• Statistics and Periods of Record. The staff stands behind use of the Log Pearson data analysis.
The data are not normally distributed, therefore, this statistical analysis is appropriate. Due to the
limited data base for post-CMP and optimal production values, the period of record used for analysis
of color, BODS, and TSS is appropriate. During the next permit renewal, a more consistent period of
record can be established for estimations of achievable limits.
r

EPA Reg*ion 1V Response
Champion-Canton Mill W`YTP
NPDES No. NC0000272
Page 4
sfies EPA's concerns
ardin�g the
The WatLrieQuality ion NPDES permit and acolots letter r variance.ttWe look forward to ourgresponse to
development of pion
e contact David Goodrich,
these comments.
f have
htionsoncernthi3etenion 517
Supervisor, Group, telephone 73 s
Sincerely, /f
v,Steve W.Tedder, Chief
Water Quality Section
cc: Central Files
Mike McGhee,EPA Region IV
WestallwAshevill2,&O°na Office
Greg Thorpe,Planntn ranch,Water Quality Section
g
Permits and Engineering Unit

Permit No. NC0000272
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION.OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Champion International Corporation
is hereby authorized to discharge wastewater from a facility located at
Champion Canton Mill Wastewater Treatment Plant
off Highway 215
Canton
Haywood County
to receiving waters designated as the Pigeon River in the French Broad River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III, and IV hereof.
The permit shall become effective
This permit and the authorization to discharge shall expire at midnight on November 30, 2001.
Signed this day
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Mangement Commission
nzx-, Air e 1Jc my ir! >;e t_D.
rb-5cl Bclt Et�PiArC ��t,r ,I.'wt�oer.

Permit No. NC0000272
SUPPLEMENT TO PERMIT COVER SHEET
Champion International Corporation
Canton Mill Wastewater Treatment Plant
is hereby authorized to:
wastewa
i. Continue to operate an existing wastewater treatment facility for the
Le tment Town Canton's
and stormwater associated with the pulp and pap
er mill;chlorinated domestic wastewater, and Champion's landfill rol (CO2 injection or H2S leachate consisting of aO4 T
chamber, bar screens, lift pumps, polymer addition, p
backup)
belt presses, eeffllanfiflonutrient
measurement, cascade aeration tion basins, h(with oxygen injection),
III ed in Part Condition located the
Champion
oxygenand 1 1 ay 215Canton,HaywoodCounty d
Cantnill WastewaterTreatm Treatment Plant, of Hihw
2. Discharge from said treatment works at the location specified on the attached map into the
Pigeon River which is a Class C waters in the French Broad River Basin.

/jam\��-CO. l���l P t (iI �/ �• u/ `/� �r � �- ' '��
\X\ .,�1, % ; / �'. ... �• i. il, Lr•,, � � °,�� — �� •=ram J
-A.
/ .. �• jY 1 rfN°• anton\Chi•
—G L�.ee. • U �./'•%i--,ram � ��e\ rt n �'C IA L�.', O. ',j'5
tlk
"�� / / .�_-�ii/ `� �•����, � L �/� 'R�h ,._•,fay �/�\ I` � /� b /"'i O� Jv
_ '_:f �Caa;n,�. ��.r fY l ,jl,:�J` - �fl`. "\v �- .,r •��
'e w
Ischarge Po.
int
Tf
\I _ '�� Fc...,._ •C•\' -%\ 4!`f•.] /�. .:•Y /. TBM_5 38 •� ✓^�.
ROAD CLASSIFICATION
PRIMARYHIGHWAY WGHT-DUTY ROAD,HMO OR . SCALE 1 :24000
HARD SURFACE IMPROVED SURFACE 0 MALE + ;
SECONDARY HIGHWAY
XMDSURFACE � UNIMPROVED ROAD = 0 7000 FEET
m� .
Let: 35° " Long: 82°50'42" ° KtIOMFTER
32'08
411
Map # E7SE Sub-basin 04-03-05 CONTOUR INTERVAL 5 FEET
Stream Class C
Discharge Class Indust rial/ Domestic QUAD LOCATION Champion International
Receiving Stream Pigeon Rver Canton Mill WWTP
Ow: 29.9 Permit exp. 11/30/01 NC0000272
Haywood County

A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Pertnit No. NC0000272
During the period beginning
01,the
be If effective
e and monitored by the per lasting igee ntil expiration of
fret bclowlhe permit, the Pennittee is authorized to discharge from outfnll(s)
serial number 001. Such discharges Monitoring Requirements
DI s Q InK99 Ll11ft1111-M. MS2kVicement Sample .t ample
Etlluent Characteristics noire (5pecifyl Location
Lb Daily Max. Frequency T—Xfe
Mon Avg. Daily Max. Mon• Avg. Continuous Recording I or E
29.9 MGD Daily Composite E,1
Flow 3598.0 12458.0 Weekly Composite E
60D5 Daily Composite E,l
CCD 12549.0 49660.0 Daily Composite E
TSS W E
400 /100 ml Weekly Grab
NH3-N 200 /100 ml Daily Grab E
Fecal Coli(orm Monthly Composite E
Dissolved oxygen 2 Monthly Composite E
Total Nitrogen (NO2 + NO3 +TKN) Daily Grab E
Total Phosphorus Quarterly Composite E
Temperature 3 Daily Composite E
Chronic Toxicity Daily^ Composite E
Total Residue 2/Month Composite E
Total Dissolved Solids 2/Month Grab E
Hardness 01 4 µ g/
Mercury s
I S:mtple locations: C-Effluent, 1 - Influent. Instream sampling is specified in Part 1, A (2).
2 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l. See Part I,Section A(2)and Part III,Condition 1.
-1 The monthly average insiream temperature measured at a point 0.4 miles downstream of the discharge location shall not exceed 3 measu.00Cred
during the months of July,August,and
mperature
September and se 111 not exceed
temperature grin ethe monthsmof October through June oniito ng location by more than I13.9 C. Sely averagee Part III,nstrearn Condition L asured at this location shall not exceed the
uwnthly average
'I Chronic Toxicity Testing at 87 %; March,June,September, and December; See Part III,Condition G.
The mercury limit shall he implemented December 1,, 1997 unless those conditions specified in Part
Ills Condition M can be met. Values
detected at less than 0.2 99/1 will be considered zero for purposes of compliance.
The effluent pF1 shall not be less than 6.0 standard units nor greater than 9.0 standard units.
ting solids or visible foam in other than trace amounts.
There shall be no discharge of floa

r
A. (I). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL (Continued)
Permit No. NC0000272
During the Period beginning on the effective date of the permit and lasting until expiration of the permit, the Permittee is authorized to discharge from outfall(s)
serial number 001. Such discharges shall be limited and monitored by the pemii(tee as specified below:
Eftlu�er t -Characteristics
Discharge Limitations Monitoring —Requirement
Mon. Av�o. Deily Max. Mon. Units �S Da—fly Measurement Sa—m� tSam—I9
Pentao lorophe —�& Daily Max. Frequency
Pentachlorophenol Ing— Location
'Line Quarterly Composite E
rlrly
Cadmium Quarte Composite E
Selenium Composite E
Silver Quarterly Composite E
AOX Quarterly Composite E
Quarterly Composite E
2,3,7,8 Tetrachloro-dibenzo-p- Monthly Composite E
H)dioxin (See Part III, Condition 0.1 P9/1 Quarterly Composite E
Color (See Part III, Condition E)
Conductivity Daily Composite E.1
Ikl Daily Grab E
Daily Grab E

NF_ > No. NC0000272
Part I
A.(2). INSTREAM NIONITORING REQUIREMENTS Frequency
Stream Mile Location Description
Parameter
Designation Marker DIY
Pigeon River upstream
UP — 64.5 of the D.O.
TDepernture Daily
waste treatment plant outfall BOOS 1/Week
(prior to mixing with the Conductivity Daily
discharge) Color* 21Week
Flow * Daily
Fecal coliform 1/Week
Daily
DN 1 62.9 Pigeon River at Fiberville Bridge TDemOperature Daily
Conductivity Daily
Fecal Coliforrn 1/Week
Color * 2/Week
Dail
DN2 57.7, Pigeon River Above Clyde TemperatureD. Daily
55.5 Pigeon River Below Clyde Tempeature 1/Week
DN3 D.O. 1/Week
Color * 2/Week
Temperature 1/Week
DN4 53.5 Pigeon River at NCSR 1625 D O I/Week
bridge Color * 2/Week
Tempeature 1/Week
DN5 42.6 Pigeon River at Hepco D.O.
O I/Week
Color* 2iWeek
Flow * Dail
Waterville Reservoir (See Part III,Condition Annually
IQ
26.0 Pigeon River prior to mixing Color
DN6 with Big Creek
_ �6•0 Mouth of Big Creek prior to Color* 2/Week
mixing with the Pigeon River l/Week
DN7 24.7 Pigeon River at Browns Bridge TDemOpeature I/Week
(—NC/IN State Line) BOOS I/Week
Color * 21Week
All instream samples shall be grab samples.
respectively. Both true and apparent color shall be monitored using
* m samples collected for these streams shall e
Color(Additional,See Part III,Condition E) All instrea
representative of the Pigeon River and Big Creek,Samples
Y•
the
methods h specified
one generator o Condition
sin operation anld releasing wate be collected at r to the Pigeon River.. Flow onlyd DN7 during
is necessary, as specified above,for the True Color calculation stipulated in Part III,Condition E.
Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9 (DN1),57.7
(DN2),and 55.5 (DN3) shall not be less than S.0 Part and the instantaneous
nstan I)eous minimum dissolved oxygen
concentration shall not be less than 4.0 mg/I

E. REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE
1) Compliance shall be based on 50 true-color units at the I-40 bridge
(DN7) as a monthly average [measured by the method specified below].
Should the instream 50 true color units (monthly average) be exceeded
at DN7, Champion shall provide the Division of Water Quality a
summary of the monthly calculated true color units, based on the
model, as well as a summary of the measured instream values specified .
in Part I. A.(2). If Champion can demonstrate to the satisfaction of the
Director that the exceedance was not caused-by the Champion
discharge, but a result of other contributions, the' exceedance will not
be considered a permit violation. If no demonstration can be made to
the satisfaction of the Director, then the exceedance shall be considered
a permit violation.
2) Color shall be predicted through a calculation 'of3instream true color
s levels at the North Carolina/Tennessee state line by the following
equation:
SLc = TP /8.34) + ((HEf_ WTPf x D
HEfx 10 (-0.224 x LOG (HEf) +0.781)
Where: WTPc = Monthly average Waste Treatment
Plant discharge color.
Calculated as the average
of all daily loading values (pounds
of true color per day) for a
calendar month.
WTPf = Monthly average Waste Treatment
Plant discharge flow (mgd).
HEf = Monthly average HEPCO, North Carolina
flow (mgd) - daily flow values less than
81.4 mgd shall be entered as 81.4 mgd. -
SLc = Monthly average Instream true color
at North Carolina/Tennessee border
(state line).
Dc = Color concentration of all dilution
streams (13 C.U.).
The SLc shall be calculated for each calendar month. S f
runits
of thi
eaeh month shall
pemak-.
3) The average daily discharge of true color for each calendar month shall not exceed
132,341 pounds per day. The average annual effluent true color loading shall not

exceed 124,923 pounds per day. For the purpose of this permit only, "pounds of
true color' is calculated by the following equation:
Effluent Flow (mgd) x Effluent True Color Level
(Platinum Cobalt Units) x 8.34.
4) The method of analyses used to measure true color
for this calculation shall be the
procedure referenced in FR 39 430.11(b) (May 29,
5) All samples collected for color analysis shall be measured and reported as true color
and apparent color using the colo procedure referenced in FR 39 430.11 (b) (May 29,
1974) -true and apparentr.
6) Prior to the next permit renewal, the color model specified u 1)
above, shall be recal ment using
sthe the hearing andd ofdin theandscolorations
specified in the supple
variance document.
F. SCHEDULE FOR CONTINUED COLOR MINIMIZATION
Champion shall continue to study, evaluate, and pursue color removal
to accordance end shall following findings
schedulto the Division of Water Quality
Date Activitv
Continuing Commercial demonstration of bleach filtrate recycling
(BFRTM)
March 1, 1998 In conjunction with the Triennial Review of NC Water
Quality Standards:
1) Submit a status report on the technical, economic, and
operational feasibility of BFRTM technology.
e color reduction
2) Evaluate and report on end-of-pip
technologies. on minimization of
3) Evaluate and
e report
; and from raw material rstorage areas.
manufacturing procss
December 1, 1998 Based on results of one usionsh of the stat shreport, Champion e demonstration will decide and
report on the decision to operate
BFRTM technology as a fully
commercial process on the p'
December 1, 2000 Champion will evaluate color reduction strategies for further
optimization of BFRT`t technology and report on the
feasibility of implementation on the hardwood line.
March 1, 2001 Champion will evaluate and report on end-the T
reduction technologies in conjunction with the Triennial
Review of NC Water Quality Standards.
June 1, 2001 Champion will onbthe comparative evaDluation ofthetabove
Water Quality,
collective efforts as part of the variance review process
(Triennial Review) and the NPDES renewal process-
G. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)

The permittee is required to perform the toxicity test as specified below or an equivalent
toxicity test as approved by the Division.
The effluent discharge shall at no time exhibit chronic toxicity using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"
Revised November 1995, or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction
or significant mortality is 87% (defined as treatment two in the procedure document). The
permit holder shall perform uarterly monitoring using this procedure to establish
compliance with the permit condition. The tests will be performed during the months of
March. June.September, and December. Effluent sampling for this testing shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed,
using the parameter code TGP3B. Additionally, DWQ Form AT-1 (original) is to be sent to
the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
4401 Reedy Creek Road
Raleigh, North Carolina 27607
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response
data. Total residual chlorine of the effluent toxicity sample must be measured and reported
if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity
monitoring is required, the permittee will complete the information located at the top of the
aquatic toxicity(AT) test form indicating the facility name,permit number, pipe number,
county, and the month/year of the report with the notation of"No Flow"in the comment
area of the form. The report shall be submitted to the Environmental Sciences Branch at the
address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then
monthly monitoring will begin immediately until such time that a single test is passed.
Upon passing,this monthly test requirement will revert to quarterly in the months specified
above.
Should the permittee fail to monitor during a month in which toxicity monitoring is
required, then monthly monitoring will begin immediately until such time that a single test
is passed. Upon passing, this monthly test requirement will revert to quarterly in the
months specified above.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream,this
permit may be re-opened and modified to include alternate monitoring requirements or
limits.

[Is as
ed in the cited document, such as
lure to
ve test
minimum mum ciontrol organism e survivalltiminimumc nit of organism eprodu tion, and
appropriate environmental controls, shall constitute an invalid test and will require
leted no later than the last day of the month
immediate follow-up testing to be comp
following the month of the initial monitoring.
H. DIOXIN MONITORING
nal
For permit compliance purposes,the point of compliance shall be demist limit shall ned as the be
effluent before discharge. Compliance with the daily maximum pe
demonstrated by determining the TCDD concentration at the final discharge point.
olume shall be collected to perform the analysis. The Lora sample
Adequate sample v
ed in accordance with Part II, Sectiopn D Monitoring
volume shall be collected and presery
and Records. The sample shall be analyzed in accordance with the a ro riate method s
of Pol analysis chlorinated Dibenzo c araal tdio z ns and Pol chlorinLi
ated Dibenzofur, Assurance for la s b 1 HA h vsis
Resolution Gas Chromato�ra h [Hi gh Resolution Mass PP ctromey EPA,A1 single
997 (EPA
Method 8290), or another equivalent analytical protocol approved b DWQ•
sample may be analyzed to determine compliance with the daily maximum effluent
(dtuplicate anaysiatiVIl the anal psis of either piay t collected below to the detectiole the n limit,theist
quantity,for the purposes of compliance evaluation, is considered to be zero. If both splits
are he positive,
its
limitation.ylf the measurement averagedses shall be beto low detection etermine compliance
the with
quantity for the purposes of compliance evaluation is considered to be zero. The detection
considered
aluation is
pic alit using tper 1 err The d oxin isomer to b
otms
e limited at the effluentby th se 10
permit is 2,3,7,8 TCDD. The chlorodibenzo dioxins and furans to be
monitored are:
DIOXIN DIBENZOFURAN
Isomer
Isomer 2,3,7,8 TCDF
2,3,7,8 TCDD 1,2,3,7,8 PeCDF
1,293,7,8 PeCDD 2,3,4,7,8 PeCDF
1,2,3,4,7,8 HxCDD 1,2,3,4,7,8 HxCDF
1,2,3,7,8,9 HxCDD 1,2,3,7,8,9 HxCDF
1,2,3,6,7,8 HxCDF
1,2,3,6,7,8 HxCDD 2,3,4,6,7,8 HxCDF
1,2,3,4,6,7,8 HpCDD 1,2,3,4,6,7,8 HpCDF
1,2,3,4,7,8,9 HPCDF
Fish tissue analysis will be performed in accordance with the Division f Water
a ering plan is
approved monitoring plan, which shall be reviewed al necessary.
an enforceable part of this permit. All dioxin data collected as pals of this monitoring
requirement will be reported as required in the plan,no later than 180 days after sampling.
The permittee shall perform the following analyses for the above listed
isomers:
1. ent facility Quarterly COMPOSITE
Influent to wastewater treatm

2. Sludge Quarterly COMPOSITE
3. Landfill leachate Quarterly COMPOSITE
4. Effluent Quarterly COMPOSITE
I. DISSOLVED OXYGEN REQUIREMENT
The permittee shall maintain an average daily dissolved oxygen concentration of not less
than 5.0 mg/I with a minimum instantaneous value of not less than 4.0 mg/l at River Miles
62.9 (DNI), 57.7 (DN2), and 55.5 (DN3). The permittee shall operate oxygen injection
facilities at the outfall structure, at 0.9 miles downstream of the discharge, and at 2.1 miles
downstream of the discharge, as necessary, to comply with this requirement. These
facilities shall be operated in a manner which will maintain the water quality standard for
dissolved oxygen in the Pigeon River downstream of the discharge. Champion shall
report the date and duration of oxygen injection use as a supplement to the
monthly Discharge Monitoring Report (DMR) forms.
J. INFLOW/INFILTRATION AT THE TOWN OF CANTON
The permittee shall make continued efforts to promote reduction of inflow/infiltration to the
Town of Canton's wastewater collection system.
K. WATERVILLE RESERVOIR SAMPLING REQUIREMENT
Sampling for Waterville Reservoir shall be conducted once annually during 1997, 1999,,
and 2000. Sampling shall be performed during a low flow period to correspond with the
fish tissue study. Sampling parameters and stations are as follows:
Sampling Station Parameters *
Waterville Reservoir prior to Laurel Branch Temperature, D.O., conductivity, pH, TN,
NO2 + NO3, NH3-N, TKN, PO4, TP,
Chlorophyll-a, Secchi Depth
Waterville Reservoir near Wilkins Creek Same as above y
Waterville Reservoir near the dam Same as above
All samples shall be collected at 0.1 meters beneath the surface of the water in the lake.
L. TEMPERATURE VARIANCE REVIEW
During the next permit renewal, Champion shall complete an analysis of
temperature data using the period of record and simulations specified in the
supplement to the hearing record. As part of this analysis, Champion shall
submit a complete temperature variance report documenting the need for a
continued temperature variance in accordance with 40 CFR.1259 Subpart H.
The report shall be submitted with the request for permit renewal, no later
than June 1, 2001.

NJ. MERCURY MONITORING periodr a of
Mercury shall be monitored twice per month aermit the ef Resultsfluent oshall be
twelve months after the effective date of the p
reported using a quantitation level of 0.2 µg/l.
As indicated in Part 1, A (1), a mercury limit of 0.014 µg/1 shall be
implemented twelve months after the effective date unless:
1) Champion submits the appropriate minor modification fee aneffluent
requests that the Division of Water Quality review the existing
data upon completion of nine months worth of sampling, and
2) All effluent mercury samples indicate values less than the
quantitation level during this nine month period.
If both conditions 1) and 2) are met, the Division will modify the permit to
eliminate the mercury limit and reduce the effluent monitoring to quarterl y•
N. BALANCED AND INDIGENOUS SPECIES STUDY. riot to the
Champion shall submit a balanced and indigenous species study p
next permit renewal, no later than June 1, 2001. The study shall be
performed in accordance with the Division
no laterof t thaer n Marchality e, 2000.proved pThe
This plan shall be submitted for approval
outlined is 40 CFR aenous
Subparstan udy
shall conform to the specifications

FE SHEET: CHAMPION - CANTON Is _ NC0000272
REVISED
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
FRCT SHEET
REVISED
APPLICATION FOR
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PERMIT TO DISCHARGE TREATED WASTEWATER
Application No. NC0000272 Date: 9/30/96
7. SYNOPSIS OF APPLICATION
Applicant's Name
Champion International Corporation -Canton Mill WWTP
Applicant's Address
P. 0. Box C - 10
Canton, NC 28716
Facilitv Address
off Highwal, 2l i
Canton
Haywood County
Typeof Operation
Integrated bleached Kraft pulp and paper manufacturing facility producing food board and
fine paper.
Design Capacity of Facile
Treatment of wastewater stormwater associated with pulp and paper mill, _
chlorinated domestic wastewater from the Town of Canton, and leachate
from Champion's existing landfill. The plant will be limited at 29.9 MGD
average monthly flow.
Production Ca acit of Facilitv
712 tons per day BCT bleached Kraft
901 tons per day fine bleached Kraft
(This is based on the NPDES permit renewal application submitted by Champion)
Applicant's Receiving Water
Receivins Stream: Pigeon River
Classification: C
Sub-Basin: 04-03-05
Page I

FACTSHE T: CHAMPION`-??1SEDTON MILL. '0000272
See Attachment A for a map showing the discharge location(s).
Descri tion of Wastewater Treatment Facilities
The wastewater treatment facility consists of a grit chamber up screens,lift primary clPumarifiers,
polymer addition, pH control (CO2 injection or H2SO4 backu ),three rimary
nutrient feed, aeration basins, three secondary clarifiers,residual belt presses, effluent flow
xygen injection), and oxygen infection facilities.
measurement, cascade aeration (with o
The treatment plant receives an average of 0.9 MGD of chlorinated
domestic (untreated) wastewater from the Town of Canton; leachate from
Champion's existing landfill (which has variable flow based on storm
incidences); stormwater; and the majority of wastewater from pulp and
paper mill production and associated process wastewater.
i. Carolina s wastewater treatment plant certification guidelines rate this plant as a
North ted,monitoring frequencies reflect a Class IV facility
Class IV facility. Unless otherwise no
as outlined in 15A NCAC 2B .0500.
Summary of Existing Wastewater Treatment Plant O eration
ssued permit-excluding boiler plate language).
See Attachment B (copy of the EPA i
TVDe of Wastewater (as reported by applicant).
3 % Domestic (approximately 0.9 MGD from the Town of Canton)
2. PROPOSED EFFLUENT LIMITATIONS
Basis for Final Effluent Limits and Permit Conditions
This permit was previously issued in 1989 by EPA. From that time, Champion has
incorporated the oxygen delignification process and elemental chlorine free
other bleachin
he gt as
has significantly art of CTIAP reduton cde
ed the mizefflu efion fluent o (from 48.5 MGD to
29.9 MGD).
The production values listed in 1. above were used to calculate the federal effluent guideline
limits for Pulp, Paper, and Paperboard Point Source Category (See Attachment).
However,the Champion Mill is water quality limited for BOD5, so more stringent limits
have been applied.
BOD5 and Instream Dissolved Oxvoen:
An re stringent
ts than
se
iven
federal effluent guidelines were necesuter model sary to proteccated that t North Carolinas instreamodissolvedy
ass C waters [15A NCAC 2B .0211 (b) (3) (B)]. Due to
oxygen standard of 5 mg/l for Cl
the absence of an end-of-pipe technology capable of consistently treating to levels
necessary to meet the limits specified by the model,North Carolina has agreed with the
continuation of the requirement th io
vecha injection fac'litn meet hesl as necessary trearndissolved
(See Part III,
standard by use of sidestream ox�= j
Paee 2

F. ` 'SHEET: CHAMPION - CANTON i ,_L, NC0000272
• REVISED
Condition I of the draft permit). Historically, Champion has maintained oxygen injection
facilities at the effluent and at approximately 0.9, 2.1, and 3.7 miles downstream of the
discharge. Oxygen injection facilities will continue to be maintained at the
effluent, 0.9, and' 2.1 miles downstream, and used as necessary to maintain
an instream dissolved oxygen level of 5 mg/l. To ensure compliance with the
above requirement, the average daily instream dissolved oxygen levels at river miles 62.9,
57.7, and 55.5 shall not be less than 5 mg/1 and the minimum instantaneous instream value
shall not be less than 4 mg/I. This method is acceptable based on 40 CFR 125.3 (f).
Extensive instream monitoring is required to assess Champion's imp throughout the
act on the Pigeon
River and to ensure that the dissolved oxygen standard is maintained
impacted zone of the river(See Part LA (2) of the draft pe i t).
No instream D.O. violations have occurred since 1990.
The draft permit BODS limit was established based on the demonstrated level of
Performance of the existing treatment plant(a site specific Best Available Technology
requirement). The monthly average BODS limit (J598 Ibs/day)is based on the 95th
percentile value analyzed by the Log-Pearson Skew method on data from 1/91 to 12/95.
The I/91 to 12/95 data were used as a result of the incomplete data base of post-CMP
values at optimal production and the need to simulate the projected mill
variability under post CMP conditions including cold mill shut downs and
start ups. The 95th percentile represents two standard deviations around the mean of
daily values. In this way, day-to-day variability is measured and used to set monthly
average limits. Although.the Log Pearson III method is not typically applied
to monthly averages, in this case the 60 data values were a skewed
distribution. Upon the next permit renewal, post-CMP data, from 8/95 to the renewal
apPlica,ion date will be used for the data araly;;;s (ant ana:)•zed based on influent values
and plant removal efficiencies). Based on limited post-CMP and optimal production data,
and as a result of the fact that Champion is in the demonstration process of Bleach Filtrate
Recycle (BFR), the above procedure was used for this permit cycle.
The daily maximum value has remained the same as the previous permit(12.458 lbs/day).
During the next permit renewal, the post-CMP monthly average:dady maximum ratio will
be compared and used to calculate a new daily maximum.
As stated previously, the Champion Canton Mill cannot comply with the
Predicted BODE level to protect the instream dissolved oxygen water quality
limit of 5 mg/l. Therefore, the limit presented in the draft permit
represents an achievable level for the mill. Because Champion has oxygen
injection.facilities in place to maintain the instream dissolved oxygen
standard should worst case conditions arise, Champion complies with the
conditions set forth by 40 CFR 125.3 (f),
Effluent Dissolve
Effluent dissolved oxygen is limited at no less than 6 me based on the above discussion.
Daily monitoring.is required based on 15A NCAC 2B .0508 (d), Paper and Allied
Products, Class IV facility. ..
Page 3

FACTSH�tr: CHA�dPlON - CANTON N�11LL.', i000272
RED
Total SuS lids
than the current federal effluent guidelines an
uidngnent es for the oxygen delignification process. Champion
I are more string are
The draft TSS
based on the 1993 proposed g
eli
has accepted these proposed guidelines for TSS (monthly average) in the draft permit.
monthly average was calculated as follows:
1613 tons/day (total production) * 2000 lbs/ton * 3.891bs TSS/10001bs product
12549 lbs/day
The daily maximum was based on post-CMP operation (8/95 to 1/96in nd the o accountto Of
aslight
maximum values are also more stringent than the
highest daily maximum:monthly average for that time period (taking
production increase). The proposed daily production value used was as indicatadit
current federal effluent guidelines. The production capacity
on the permit application and is within l0�l0 of reported
values (post-August 1995).
numeric standard for TSS. The rules
solids, settleable solids, and sludge deposits
North Carolina does not have a
specifically regulate floating The draft permit restricts
floating
due to
[ref. 15A NCAC 2B .0211(3)(c)]. was removed from the term average
solids. Settleable solids monitoring longpermit is more
consistently low values Addition ally, hwell below e limit o imposed in he both t is me
restriction of 5 ml/1). Addition
federal guidelines. Finally,
stringent than current applicable rovement to the Pigeon River.
and IBI studies have indicated further imp resents a reasonable
Thcrcfore, the negotiated limit of12,5'1. bs/day rep
compromise for this permit cycle.
Daily monitoring is required based on 15A NCAC 2B .0508 (d)for Paper and Allied
Products, Class IV facility.
Total Res!duefIlotal Dissolved Solids
t. Dail monitoring has been required to correspond with the requirement for TSS.
ribution from e
Monitoring for these parameters is required to assess the total solids cont
plan Y
Color ce from
Champion
has NCAC 2B A2 applied for a 11(b)(3)(F)]the instream color narrative criteria in Notch
Carolina lmance be based on 50 true color
The permit and variance
requires
model that
color model provides
units as calculated by
Champion Th
a predApplication for
of thecolor
colorsmodel the
allows line
the Division and
effluent values. Application
contribution to the color levels at compromised by a state
Champion to assess the ppredicts an exceedance,
line through effluent measurements which are not
introduction of other color sources. If the model p
Champion can take immediate steps to inveime adjustments to be made in
stigate and correct potential
I
problems. Thus the model allows for real al t in of the 50 CU requirement at
the operation of the mill to ensure prote
the state line. Recent data demonstrate that true color units at the state line
Page 4

F/: SHEET: CHAn4P1ON - CANTON A ,, NC0000272
REVISED
have been below 50 CU. Monthly average numbers are around 30 CU for
the river at the state line since the reconfigured mill came on line.
Champion will be required to comply with a calculated monthly average
color 'load' of 132,341 lbs/day at the effluent and an annual average 'load'
of 124,923 lbs/day.
The permit also requires that the predictive color model be recalibrated
prior to the next permit renewal. The period of record and simulations to
be used are provided as a supplement to the hearing record.
Instream color monitoring was recommended at the first downstream station
(DNI), below Clyde (DN3), and at NCSR 1625 (DN4), in addition to the
existing color monitoring. Color monitoring was included at these stations
to better describe the color impacts within North Carolina. The station
above Clyde (DN2) was not included due to its proximity to DNI and DN3
and lack of other potential contributions (such as significant streams or
discharges) within that area. Instream true and apparent. color monitoring
is required (Part I.A
A schedule for continued evaluation of color minimization has been ,added
to the modified variance and the revised permit (See Part I11, Condition F).
Essentially, the color minimization requires: 1) continued operation and
evaluation of the BFRTM system installed at the Canton Mill to establish the
operational integrity of the system and to ultimately determine that the
system is appropriate and can be counted on, 2) evaluation of applicability
of BFRTM technology to the other bleach lines at the mill (the hardwood
Iine), 3) identifying and evaluating other in-process opportunities to -
reduce color discharges to the waste treatment system and development of
an appropriate time frame"to integrate the recommended changes, 4)
evaluation of raw material storage areas and the feasibility of modifying the
existing system to reduce color discharges to the WWTP, and 5) evaluate
the applicability of end-of-pipe treatment technologies to achieve
significant reductions in color discharges. The intent of the schedule is to
ensure that Champion reviews in-process modifications prior to end-of-pipe
technologies.
A reopener clause was also added in order to modify the color requirements
based upon any breakthrough in color removal technologies.
Ammonia
Monitoring requirements are included in the permit to provide data concerning levels of
ammonia discharged to the Pigeon River(which may affect instream dissolved oxygen).
Page 5

FACTSHEET: CHAMPION -
C D TON MILL. 0000272
R.E
Trichloroahenol/Pentachloronhenol
The permittee has certified that chlorophenolic biocides are not.used at the facility. This
certification eliminates the requirement to
ts for
two
ram
hese
ters
based on 40 CFR 430.84 and include
40 CFR 430 94. However, quarterlytmoni orin w llebe
required.
Chloroform
Chloroform monitoring/limit has been removed from the permit. Based on
an allowable level of 2.8 mg/1 (using the federal criteria of 470 µg/I and
average flow) existin allowable effluent level. Therefore, this parameter indicated no reasonable potential
dropped from the
permit. '
Fecal._ Cow cal
estic
tLimitations for fe he Town of Canton and thcolioe requements of 15A NCAC 2Bare based on the contribution of 02111 (b) (3) (E),wastewater from
Limitations for pH are based on 15A NCAC 213 .0211 (b) (3) (G).
Temoerature
aturnture limit and monitoring rcquirement is based on a Section 316 (a)variance
The r --
determination was accepted by the NC Environmental Management
Commission October 11, 1984 and approved by EPA August 6, 1985. Upon the
next permit renewal Champion shall submit documentation regarding the
ture variance along with temperature data and
continued need for a tempera
This lwill give Champion the opportunity ont rstablizetthe the
(with regard
to production and BFRTM implementation) and provide an ample data base
for review. Periods of record for data review have been specified in the
supplement so that no confusion will occur with the next permit renewal _
period.
316(aIn making the recommendation to retain the current deter variance, staff
mined in note th6taa baa=variance for Champ on was alsotreta ned dur ng the 1992 84
The 31 ( )
Triennial Review. Both benthic community studies and Index of Biologic,
Integrity studies have shown improvement below therCantoniewed existsince the
Staffpost Canton Modernization Program (CMP).
temperature data and although some i Cham ontst it cannot meehas occurred t thelikely
due to overall effluent flow decrease), P
North Carolina temperature requirement. Because the Champion h
t been reached during post
limited data at full production and 7Q10 have nouil t
reviewed more. thrn
the nextt permitterenewal (See nPartce t11I,ll eCondition L of theopermit). during
Pa.-e 6

• R — 'SHEET: CHAMPION - CANTON I:._ L, NC0000272
REVISED
Flow
The flow limit is based on Champion's current flow values and post-CMP production plus
0.9 MGD for the Town of Canton's wastewater (See more specific description in
'Description of Wastewater Treatment Facility'). Due to potential
inflow/infiltration problems with the Town of Canton, the Division granted Champion's
request for 0.9 MGD increase in flow-with the provision that Champion continue to work
with Canton to reduce I/I problems (Part III, Special Condition J).
Effluence
The toxicity testing requirement is placed on all major facilities and other facilities with
complex wastestreams (Departmental memo 7/22/87). The toxicity limit is based on the
instream waste concentration under 7Q10 conditions (54 cfs). For Champion, the instream
waste concentration was determined by also accounting for the out-take of surface water
from the facility (30.4 MGD, as per application). Therefore, the instream waste
concentration was determined to be 87% under 7Q10 conditions.
Champion is required to perform the NC Whole Effluent Toxicity Test or an equivalent
method (as approved by the Division) on a quarterly basis at 87%. Any equivalent method
shall also be performed on a quarterly basis.
Mercury
Mercury was found in the Champion effluent at values above detection
levels in 3 out of 4 samples taker.. Mercury is not an expected parameter.of ..
concern in pulp and paper wastewater. Due to the potential for testing
interference and the limited data set, monitoring shall be conducted 2/month
on the effluent for one year. On December 1, 1997 an effluent mercury
limit of 0.014 99/1 will be implemented unless Champion can meet the
conditions specified in Part III, Special Condition M. In general, should
Champion show effluent mercury levels less than 0.2 µg/I (the quantitation
level) after nine months of sampling, the Division will eliminate the
mercury limit and reduce monitoring to quarterly.
Zinc/Hardness
Reported values for zinc have exceeded the state action level. Monitoring requirements for
zinc have been included in the draft permit (15A NCAC 2B .0211 (b) (4)). Numerical
limits for zinc are not being included in the NPDES permit since the water quality standards
do not contain a numeric criteria for zinc and the biomonitoring requirements in the NPDES
permit are adequate to control toxicity due to the presence of zinc in the facility effluent.
Zinc is a function of water hardness,so hardness monitoring is required in coordination
with zinc monitoring. -The monitoring frequency for zinc (2/month)is based on the
Division's standard operating procedure for monitoring of toxicants for Class IV facilities.
Champion is rated as a Class IV facility.
Page 7

FACTSHEET: CHAMPION - C D TON MILL. 1,4 0000272
REV
Trac Metals
Cadmium, selenium, and silver have been recommended for quarterly
effluent monitoring. The limited data set indicated at least one value a one
allowable levels for each parameter. Although
tra a of Concern. and
pulp and paper wastewater, these are not typicalparameters
no limit is recommended at this time.
Dioxin
Measurale levels of dioxin have t been
dischar
this
facility since the completion of theo detected
There is wastewater
currently a fish hconsumption advisory
for the Pigeon River downstream of the discharge. Although the advisory was
initially in effect for consumption of all fish species, this advisory has
been reduced to carp and catfish species only due tb continued
improvements in the River.
influent, is required to sludge, landfill leachaterand efflue dioxin nt (See enzofuran Part I1I, Condiitions ),quarterly from the
The effluent 2,3,7,8 TCDD limit is based on 15A NCAC 2B .0208 (a) (2) (B). The
average flow of the Pigeon River(325 cfs)was used in the calculation of the allowable
effluent limit for dioxin at the NC
inst to as dailywater maximum lstandard of 0.00014 n A [15A
NCAC 2B .0206 (a) (3) (B)J.
Annual fish tissue analysis shall also be performed by the facility in accordance with the
monitoring pluu approved by the Division.
Total Phosl2horusfTotal Nitrogen
monitoring is required by 15A NCAC 2b .0508 (d) (2)
Total phosphorus and total nitrogen-d to assess the ntribution of
and the Monthly potential is reuire Waterville Reservoir.co Waterville Reservoir isto be
�pion
monitored once annually (during opposite years of CP&L's montioring) to
assist in characterizing nutrient impacts to the lake. _
Condom
Conductivity monitoring is required based on 15A NCAC 2B .0508 (d),Paper and Allied
Products (Water Quality Limited Facilities), for a Class IV facility.
COD
COD monitoring is required to as,
the potential impact of chemical oxygen demand from
the Champion wastewater effluent. Neither federal guidelines nor NC water quality
. Current draft EPA regulations and supporting
standards require a limit for COD
documents state that COD may be related to effluent toxicity. As the permit
contains a chronic toxicity limit and the plant has not documented any
toxicity problems, no limit for COD has been proposed.
Paee 8

FA _ iHEET: CHAMPION - CANTON Dyii , NC0000272
REVISED
AOX
Monthly effluent monitoring for AOX has been required in the permit.
AOX is an overall test for adsorbable organic halides, which include
chlorinated organics. Trends in concentration changes have been observed
between AOX and specific pollutants (dioxins, chlorinated organics) at
pulp and paper mills. Therefore, any decrease in AOX may also indicate a
decrease in chlorinated` organics: Limits for AOX are proposed in the draft
EPA Cluster Rules. Monitoring has been added with this permit to better
characterize the effluent.
3. EFFECTIVE DATE OF PROPOSED EFFLUENT LIMITS
(AND COMPLIANCE SCHEDULE IF APPLICABLE) '
The limits became effective on the date of permit issuance.
4. PROPOSED SPECIAL CONDITIONS WHICH WILL HAVE A SIGNIFICANT
IMPACT ON THE DISCHARGE
Toxicity Testing Requirement
Color Monitoring Requirement
Color Minimization Schedule
Dioxin Lunit and Monitoring
Waterville Reservoir Sampling
Dissolved Oxygen Requirement
5• XUESTED VARIANCES OR ALTERNATIVES TO REQUIRED
STANDARDS The facility requested and received a 316 (a)variance granted by EPA 8/6/85. This
determination demonstrated that the effluent limitations relating to the thermal component of
the Champion discharge based on application of NC water quality standards were more
stringent than necessary to assure protection and propagation of a balanced indigenous V population of shellfish, fish, and wildlife in the Pigeon River. Therefore, the 316(a)
determination was approved based on protection of the appropriate use classification of the
Pigeon River. This permit continues the 316(a) variance and requires studies
to be completed prior to the next permit cycle to enable re-evaluation of the
variance.
As discussed previously, Champion has applied for a variance from the instream color
narrative criteria in North Carolina [15A NCAC 2B .0211(b)(3)(F)]. See Section 2 and
the attached variance documents.
6. DISCUSSION OF PREVIOUS NPDES PERMIT CONDITIONS
See attached EPA permit
Page 9

1
I-ACTS14EET: C14AMPION - CANTON
A d ON MILL.NC0000272
EV_
7. THE ADMINISTRATIVE RECORD
The administrative record, including application, draft permit, fact sheet, public notice,
comments received, and additional information is available by writing the Division of
Environmental Management,Water Quality Section, P. O.Box 29535, Raleigh,North
Carolina 27626-0535. The above documents are available for review and copying at the
Archdale Building, 9th Floor,Water Quality Section,Permits and Engineering Unit, 512
North Salisbury Street,Raleigh,North Carolina 27611 between the hours of 9:00 a.m.
and 5:00 p.m. Monday through Friday. Copies will be provided at a charge of 10 cents per
page.
8. STATECONTACT
be
the above
ained
aAdditional information ddress during he hours ostated in item No. 9 by contacting:ncerning the permit application S santWil ontat (9 9) 733-
5083, extension 555.
9, PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice - 5/6/96
Public Hearing- 6/6/96
Permit Scheduled to Issue - October 1996
10. PROCEDURES FOR THE FORMULATION OF FINAL DETERMINATIONS
1. Comme�nod
oses to issue
NPDES
aThe pplicntssubject ttovironmental the effluent limitations ns anement d special conditions outlined above. to this
These
PP n to comment from the public.
determinations are tentative and are open
interested
io oeatitP ication or n
the Division of Env onmental Management's prop determinations t he following
address:
DIVISION OF ENVIRONMENTAL MANAGEMENT
POSTRUALITY SECTION
OFFICE BOX 29535
RALEIGH,NORTH CAROLINA 27626-0535
All comments received within thirty days following the date of public notice will be
considered in the formulation of final determinations with regard to this application.
b. Public Q
Due to
public hearingt in the has already sche the duled.ed. The heariuirement of a public
g will b he d June for ance
1996.
Page 10

FACTSHEET: CHAMPION - CANTON MILL. NC0000272
REVISED
C. Appeal Hearings
An applicant whose permit is denied, or is granted subject to conditions he deems
unacceptable, shall have the right to a hearing before the Commission upon making written
demand to the Director within 30 days following issuance or denial of the permit.
d. Issuance of the permit when no hearing is held
Not applicable.
Page l 1

,� - „.. ... the Holiday Inn
v - n Cost is$20.So
JIM BURGIPUCIn EN-TIMES for the North G
area.
TRANSYLVANIA CRoSSNORE—A tractor-trailer carrying garbage from a landfill ran of Highway 19 r Thursday in Avery Make re K GARi
Land to be marketed #tear indnstey County, Bill a vacant house and overturning where the highway intersects with Prison Camp Road. monthly meettir
The driver was not injured in the accident. Chapter of the
BREVARD—Facing a March 26 expiration of a will be held at
purchase option with Mars Hill College,Transylva- Mr.and Mrs.E
nia County is moving ahead with plans to market the �� sandwich and
remaining two parcels in its developing Brevard � ��ee �� ���� cO 884-5479.
Commerce Center.
Commissioners gave their approval Monday for C L A S S i
planning and economic development director Mark ® ��
Burrows to seek tenants to bring t new jobs to the AM full: �r� pig�� ke NANDMAO
Railroad Avenue property,where there is roam onwanis i!�/_ha toI� n 1�1��1 Arboretum wil
the 11-acre site for four small industries. - make garland
The other two of four lots have been claimed,as tervene in a dispute between North
The cost for n
pater and sewer lines and a road into the property AP AND STAFF REPORTS Earl Bee Tennessee Wildlife Re- Carolina and Tennessee over Chain 5 The Arbor
are ready. Stillwater Products moved from Califor- KNO�LLE, Tenn. — The Road)in Ash
nick and began producing its copper window roofs in Tennessee Wildlife Resources Cook- sources Commission voted unani- pion s wastewater discharges in the SOUTHER
Ash
the park in early October on the back lot next o . mission wants the state attorney mousy Wednesday o send y Gen-reso- late 1A9s8 a result, Champion invested Museum pre
Tinsley Road. A small-business incubator funded general to object o Champion In- lution to Tennessee Attorney Gen- 30 million in the early 1990E to Circuit films c
from county and grant monies is planned for the ternational citing another o erat sstate'sharles waters egon rotected that the make the plant cleaner after the
middle of the three other lots. ing permit. p p downtown
p.m.Frig
Burrows said Thursday he and County Making- The company's Canton plant is Champion spokesman n Joyce EPA imposed stricter wastewater downtown A:
shortly seeking a wastewater discharge said he'd heard about Tennessee's regulations on the paper maker. Madonna am
er Artie Wilson will meetemployers
to decide how o The state of North Carolina Admission is
get word out to prospective employers that the land permit to continue operating far abjection o the variance but was „
is available. That meeting had not been scheduled five years. Tennesseans have long not sure what effect it might have tries o say the color of the river is others.
3 complained of Champion's pollution on Champion's permit application. natural and comes from trees,"said WRITING
Thursday afternoon, count- clerk Sandra Jameson Nelson Ross of the Izaak Walton working on tl
said of the paper-making
River.The Champion Noon a variance allowing it to League. creating sale
The county's posture in attracting new jobs is paper-making plant is about ee Champ'
improving. A Superior Court judge in July dis- miles upriver from the Tennessee continue discharges at present Protection
missed the last fragment of a lawsuit that was block- border. Agency
The Environmental Protection "Anybody who knows anything finding an at
"How do they get away with Agency will not intervene unless about this part of the country 1moc+2.; Saturdayfnaii
ing progress on the incubator. I Betiding,20
The county is also working with Cashiers build- this?" said Wildlife Commissioner Tennessee objects.The EPA did in- that's not true:'
ing supply store owner Richard .Jennings —who is RIVER P
1,building another store r Pisgah Forest just north of �q ty ® s+ the National
Brewazd — to certify his private development of an Forsyth ����"Je 0����'�`� �`�������� ������� �� � � the Lifebloc
industrial park with the sate and regional market- y p a Lash's release also was the at the Botar
ing agency AdvantageWest,Burrows said. THE ASSOCIATED PRESS day after a paperwork itix-u�al fourth time in 18 months that jailers
WINSTON-SALEM — An in- jailer said. Lash was awaiting fij i
Brevard banker Perry Hendr x chairman of the Lt. Col. Michael Schweitzer,
non-profit Transylvania Partnership that is building was released mistakenly from the and possessing stolen goods.
have released di inmate by mistake.
1IPfON
the incubator, said the 20,000 square-foot shell of a Forsyth County Jail, the second on Sept. 10, jailers released the county s director of detention reunion is p
building is on hold while the private group seeks an time in two months that jailers have Jermaine Wright who was charged services, said it appears that some Tipton High
re lax in
other grant from the Farmer's Home Administra- cafeteria.B
lion o lessen what will need to be borrowed. Hen- released an innate by mistake. gi girlfriend.tin In restiga Investigators found procedures- jaila thates ew would havefoll 688-3952.
Reginald Jerome Lash, 42, gir Lash behind bars.
drix said he hopes to have an answer on that loan by walked out of jail about 8 p.m.Tues- Wright within five hours.
the end of the year.
rCa�►7�lE�E ��9A�KEGffiNCYIM Uft PLEASE CLIP AND MAIL wint YOUR eDINNER--$1.5i I
1 nITILPleasehsprovidetraditionalhome-rookedr `.,v - 6Jls t Thin strips of beet chmeals with all the trimmings for the hungry ,`�.5`, b SPECIA�, {�E 9 r `ts 5es r7 5�, eta ® unu TMRLt THURS. FSpeppers a duoons. Ser.6nUer far the homeless durin this �'� '� "^A , ' '� _.1 Pile C

u
419/23/1996 15;02 7842525452 PAGE 02
•rota igbacM,firaad:ltb atWiltaY `� '1�,7111 ASSOCIATED PRICS $Iona
maoltadala8 puhUc anowapapar�'hr1 ^ ' ' Darr11 I gervi
Icmlvlai 9lrieIN 'it'.,;,Greap■itlsd%]A1thithaim&r hl locco riods haw Floridaitan1l. Ccta
don •,:. , c-wt' ". 1datA<aetq'7g42 tharghhs'j i yeas gboat
faeTSaadeyvTsin ha' d with to ova : C ' lots two estaana ahts tkkd*,Too*
{[imlaBmlEh Wld'11 e'!: i 5�r orth
:�CuoYrikVlt'aoPl sholdn'R onalrawlY 1 InmPr
�4f NaWldl,H{m''' (,`'i l �tl0 til a ono market to the South- 01 d!
y',bpdrAWT „l
6ualtat Thar.tappea adds';" 7 anuy
Eft Yearn. aaddhe
�ota.entea•
it i10e.t{f.�a t'aaud sad t*7gkad mch
254-
t'• 't TM primm amve,l after Hurrl-
.. 'x. ,+a• rM7Yhrawwalhat �aa an lbe nmAaaocwlrJ.traess . coon Ran and RUVIR sluDlraad
et but tasesyean &nIM Saki: , Fehwrar U.Cw.lMnny!irNa to
h"the same strnluh of the Nuhth
ar AR&Mfft -012 plea It port of tfia 1v¢orCwollna aahwt within
pap off N.C107 a mveottlI�paiidan butAfropployaancladoa aiW14bpleadgiftt►tea Car icon thin
h4 allardlag to the Cur elta U In that tOvaltlgSum," sdea blot a tadard Baw l SO month, Ths huh$• Aaer
Smith told tha newepmppeerr Our Wgrlakl{SM klerMw Y an alfat to oana.vvhkh lilt July Ater
ambonkn a it,wren hope is that when A1r, Green An, Sad ku fdk h a blood
fro Ura patrol.The Ishoa this plus and UNM hh re- IAypdption fob toliam hood. IJ and Elept.hear o tore purr
L,about nine colas apvnemWty,he will lure couclsdcd Into the Vast!of the
bl. association with the Inveetyn• Creep,76,feu geutan.nE low atata'o tobacco Dla); . met
Ban=Urel ;' ernarlleml0RtolBWdel*Gov. uprooting planta and ahredding Can
_ Calls to BMWs hdmp and haw Jim Hunt'a tTrattwa tome.He tidn leaves on thA stalks. Swi
office went unaswered Sunday. worked for Oor dim h WIA a its- 'One rraon s fortune Is anoth- Yell
lg111111111tien (iron Arta the U.S.Attarrrye Cf- publtelm. er Pomona mlerortDneo Oaorgis
gra 4041pod tWnment to the haws• No ran for governor In IOW, Agriculture 0onmiAsloner 7bmmy at E
to trikkal eoraAom but btu candid n'W hempeeed by Irvin laid. ,rho misfortune or our Tun
Idlhd anAahornto p r
The fodmol govorrimemm to trp a 19m Charge or aces ng a 42A00 Carolina fanners has earned the an
Ing to determine who le rnpmulbla btll» horn So FSt undercover supply to tglitwt■t�and bw klokeJ prsl
u In CHtkd Solidi• rot v4111ng milikete of hale rat to agsnA Ha refbaad to plea bargain In up the price aevera rants o pound."
HdMiWonHwpl. I=01aeandwn Idttod, NorWCaroltnaYwoonarcwan-
bxea illegally het meghhg the ac') Pa
7aISSIngerinalm The flarcoly aoiweNatYa and d6rM Ravi fgr2,1001kar6iatubao- min
Interstate,40 out araPt decal Ppaf't rO' uncompromising Dumami n-ed bid cc farmers aM snothers001n F1orl-
Fep pro 211y a hove been tan a ng. lid,
adn9.according b imeatptLrg vh4odly every tole in ofnhm sa a power center. Crean CIA. eni
Uhl Chain or tobacco calm, from ablamp laved business aml hhdumuy. The mpsre Idasgo manna an ax• Hal
17-mr,91ADavkl d errviranmentallate slid Be Ara IBBOIkO in ¢roes mauul wdae
r wreak.on driver ferrraan to tmeharthheman ca tobeo- , and adroeaWd fiscal Inv Roger r/avle,a FIoHc4 W17acco
<o "ere, Severaf people have t>�gnm AIR
ad 11),
also of
bem co wletad. and eodal conamvaFl»r. with 40 Der o of tabacca, itt midr
C_.-T hAmfate In an extra 41%(M.
N no
o guarantee fieom N.C. Tall even
prices wore the and
at cedgr m await even !afore Berths andIto
Fran belted the c arvIlm couWue wig
doaaffon boa b0a9t, ■ Lac■tae of Idglt worldwide dItmand
n 4s Mild Ifs new on Champion pollution amdtghp tobacco stocks thMugheut yr
the Honuraait.Irvin Sold.
and aonsteaeton of out the kosvy rsitrm, floodhig NA
ea 220•seat dSi,vll nwAselwuvaD¢Sass mot it in move in the direction of a and power ouugas caused en eetf-
forthe edlagsL ill• NASHVILLE, Tone. — North no-avniwlons mill," peal Nvle, all• mated i331 mWldn lops to caliper,
Catalina elflalalm are making no ncior of Tannaeeao's water pcild. trope In North Carolina,making It R
be used to expand comlaas aboutreafdng Champlon lion control division,said the ststS'o wafet'"or agricultural
on��, ed eye,' nfan+dlathal Corp.y.to ken polko- 'That Justwam'tln na ruvutar. alatallelan Crag Hayes
We sAm"buflding. don Into the f9goon Rlvar rf partor Baia,
krge4Watory,eame a pendingfvaycarparmlh to dompsny 'ba< invested Mara than half the ataida 11
laaterymhg. Champlan4la .tv"In Cue- mor0 thAa>jROOnllllan fn poluton 2M.g00 acres devokd to F,LAooa of
tea bin bum dun Ailywaste In the arntfoL In reaerd yore Ibht hot was damaged,said Hayes,awlatant Co
river that flews Into Timmopose for brain foam from the m111 dlll or- diNctm•Of flop North t:aro0nt De. 911
more than be years It Is weking a Taste Ash and given off an odor In parbnent of Agriculture's AVOW, pk
spoofed In new permit and virisnutoomtron• turalstathticsdivttforl,
mental team. ay Camillus atll- "1'd rather it be you thou mq:' Th
*08pp ai In Am It atenda,the omit w1U Inv chh)Bald We IMW you oral we've gold Davis,who gismo e0 Scree of, be
Itp�2, strict mampian to And ways to ro• got aurae(date and pull See them Wwav qn Alacbu� Elm "Nohady aeI
dwe pvllatahr.but recqulre nothing. later.' wSnht eavbgdy to IQee At all.but V , Inn
"We,wattled W Me aaoetbing OIL moats sans for an anawSr," it's lotto boeamahody,putnutme; "ball
MyaEimgisapeectlm. In the permit with a fen MO..hIt- TIP,$sad, ATgh,aybuLMe." r:411
am.-teaches teen-aged girls the importance4 of ;gib
out with to Heel Friand girt bacalaa Members of the newly formed "You can trod hays Moro than to follow the rules.Some
du- they cant bave leg,"said Devin Sto- I0g Hlull Women of Grcater Char girls btallia tf you fella boy oome- hear ablatt the rulei aml
bar- va,ill,who attenaY Ramon7auddla lolls will be mantars U the pautr, • thl�,thadrg n9t¢olpg to run tuwk bom atrango logos,
Ito IldwvL"Bat the nkssjng the wad The girls u_M tliq 11 ri a lot Ilan i to al) their Mende and may. 'Ray, • "1 w.. satklmg W s
.. ..� + ..ter.. .LLL -...�,.�..aJ �......L.a...�J... J,J •'re, —J— . .rY
£ 'd 15:60 9661.10-81 nl •3l1In05nn siioisIn Ia a31nn 03a1 unmd

rrraN3rr•
q/zz/fib
lr•. Y 15 '�'
, ; ,.
°for. cleaxier`raver
' ''; '�t�'�NrrE vair�•:'�ciM1�ss¢or: .':��h:� �
' North Carolina d:dak say no butt[didn't SOY
1' :yes elmer.M a re9upt from Tetlita�ee to
tlwtial to Au"I
re4ulre'Cbamplon Iateraa Care •frt->. .
ther cleat up the Coltee-Colored wagewate[ It r; ', kis;•;::.:..,,
•,S'•' • uumOstu the. Riven
'u The'eelghboring'state.1a Poised to lssue'a •'
rtew five year peredt and verlaaee to eIMMA-
i rnea(al"laws to'the champion Paper mnl In
Canton"'N,C.,'ghlch Is 87 mnes UPTi of
<k!�'BeeetZ8e.:8, 3ai:t s•icCoikL.®ro.pr WermaTYist"„Mes p po�:n:u:l�get.:ft tw champion to
I.. without including!'We wasted to;see,aaeieWhtg In ILO perml ..
a r4at armmlmteat to mavw to tLa sires.:
tToo':gt a noer athAs:rglL�n.pA 1)avla.'dtrea
;or 1lnndsese:rf etef Wh eontrel
yefdn,:Ce7A'y',este'dpy a•>,� /W���µ�w t.•.
Orlwln.`./,�<"�.�/Nlfi-'_•',Y^yn•Y<j'FNI�i IA' •h'I
j `\Sn I:VYp(H wlwse V r YYG�d,en the
OU got a'tetpanse from North .ratt on 2¢ae,8,.
�'•`,lt,droftne eavlroameatet wtl:Ctels to a•rneethi8
Fjiday,iq Knoxville.He =a interviewed Yes•
rat me Tenneteea Eevt-
t6rdaY earl�Itft n1a1 C VI I . .
rebrRental Counet's INN Fltvlrunr[Ie ) con.:1
g Wt Uld bt the,$eCond Pfesliyteill+n.
Q[�13w moat Boulevard..'::!J,•.• t° , . .
;,;G�"'"Ihe DeCmlts�are;w8ttea.for.tivaYean,.; •
kira-We wdnt to see Sve years of
_' i •...:.� ..�•i.;. ... . .','.... g11i1E14~ ��.IY.C;i�ii✓f 9&ii:-..•,. 5+r'�1. +; ,
yy ewa year You an weYe
some.ldees end yofi I!?see them later"ft tseab -
:'no''for en'enewmt,i: ,As
ton-has.dumPe Waglewateta laM the
plgton lUvertior,-more than 80 years,foaling:. ,•;
the shum.lmat enteis.Tenmseee with brown
and.emgmlet�la:STh®•state vpen!M'eourt8
I f the inasto Mop North L'arb7loa from'allow is
�(tg the pollution and won 1m0;i ewe butally eveltha
Grokin MCTO so
ahpioo laa� cqu�Yserr's Our tree i'
$300 million to ponution,'Cunhomi The rlvdr b •.
cleaner as a rcsmn,and'It;Oa=omlal mmm
•ChMed up mtor0 Iluui;40,000 trips last.yeer<;.
But all ls'actlwell
:The'mm slut Buts abut dart'weetewater�that�'�
' a bI mole thad'W'dogrees holterAhanbe t
natural river watel8, '';
:The color wad the smell es;Wdi"ss the etteek
Twn to 1",tGB 211,LWOW 6
b -d L5:60 9fi6r•I0'0r Nl •3-I'Irrmstm smo IsinIO N31ea 3301 Ilued

FAX
FAX COVER SHEET
ENVIRONMENTAL, OCCUPATIONAL,
HEALTH AND SAFETY.
CHAMPION INTERNATIONAL CORP.
CANTON MILL
TO: er �oys
FROM:
DATE:
NUMBER OF PAGES: O
(INCLUDING COVER) Q
NOTE:
SF.OjPENOE
p2 pP1P�0
PN�E�ER
SENDERS PHONE NUMBER: (704) 646-67OO
FAX NUMBER.-[phone]
FAX PROBLEMS: (704) 04"700
TO' d 800' ON 90:O1 96.£0 00 Z689-9b9-voZ:OI SH03 NOIdWHHJ

::snton Mnl
Canton.NWh Qwoima 7.871 n
c Champion
.-amnion lnlern,V.ona1 Corwranon
September 24, 1996
Mr.Roy Davis
NCDEHNR
59 Woodfin Place
Asheville,NC 28801
Dear Mr.Davis,
Champion has received the final results of analyses for total mercury on fish tissue samples
collected during August 1996. These analyses were performed by Quantertll
Environmental Services using Method SW 7471-M. All samples analyzed were
composites of the right fillets of five fish.
All samples collected upstream of the mill in Canton at Pigeon River mile 04.5 are
identified as CHI-I.These samples were collected on August 14, 1996. The dam which
exists in the Pigeon River just below Champion's intake prevents the migration of fish
from downstream of Champion's discharge to the upstream sampling point.
Samples from downstream of the nrill were collected in Clyde at Pigeon river mile 59.0
and are identified as CHI-2. These fish were collected on August 13th. The species
collected at both sites are representative of populations that have been collected Annually for
the previous five years
The results for both locations are summarized as follows:
Pigaen River Mile 64.5 Canton Upstream TQtal Mercury Insft
CEH-I-IRF-Redbreast SF 0.13
CHI-I-2RF-Rock Bass 0.51
CHI-1-3RE-Bik Redhorse 0.38
Nircon River Mile 59.0 Clyde Total memilly Tylgft
CHI-2-IRF-Redbreast SF 0.048
CHI-2-2RF-Redbreast SF 0.068
CHI-2-3RF-Carp 0.041
ZO' d 800' 4N 90:OT 96.20 100 Z689-9b9—t•0L:OI SH03 N0I8WUHD

CHAMPION EOHS ID:704-646-6892 OCT 03'96 10:07 No .008 P .03
mp/SIs
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gaslao51 auuasns
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•palueimmun sT 22augoslp
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uo paseg 'lip aql anogn poloalloa sald=s al paansumu osogl uegl=I Spuea9ludrs
aas a2ngos)p [lltu mil molo9 sordTurs oql ul suog=uaauoa agl legl Rupou guom sr II
•pouodaa 2ulaq
dpue.una slanal dauaraur lelnl aql 3o uollomj u Sluu aq of pmoadxa aq pinom sasdleue
Ajnm=Id1lai4l 'wdd [ ;o gsll ul lomol dmaaaw ldgTmv r.sl galgm qs9 aoI daosrnpu
uLIIloju311110 l aql pue uonmislulurpV srLTQ pue pool•S-fl mp moNq )lam oslr.aaa. XQq L
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CHAMPION EOHS ID:704-646-6892 OCT 03'96 10:07 No .008 P .04
waay iluuad SaQdN
oaunuwoa 5uuaa78 SH(r im :aaq

DES PERMIT RENEWAL NPOES STEERING
TEAM COMMITTEE
Ben Bilus (Stamford) Ben Bilus (Stamford)
Dardc Brown Dick Diforio (Stamford)
Ed Clem (Stamford) Gerard Closset(West Nyack)
Mike Cody AI Joyce (Canton)
Al Joyce(Canton) Steve Hadden (Canton)
Susanne Koeisch Dave Hearne (Stamford)
Tom Siegrist(Stamford)
Billy Clarke (Roberts &Stevens)
Jeff MoNealey (Porter, Wright, Morris&Arthur)
SO' d 800' cN LOOT 96,£0 130 Z689-9b9-VOZ:GI SH03 NOIJWHHJ

CHAMPION EOHS ID:704-646-6892 OCT 03'96 10:08 No .008 P .06
aodea s ISOM Aaa
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SEP 19 '96 14:29 FR Q ANTERnA TO i704646GB92 P.0Sr11
. Enr4o�m�1
Total Metals
(Tissue)
Client Name: Champion International - NC
Client IO: CHI-2-2RF-Redbroact SF
Lab ID: 08912I-0019-SA
Matrix; TISSUE SamplaA: 13 AUG 96 Received: 20 AUG 96
Authorized: 20 AUG 96 Prepared: See Below Analyzed: See Below
Wet wt. Repporting Analytical Prepared Analyzed
Parameter Result Units Limft Method Date 04.0
Mercury 0.068 mg/kq 0.040 SW 7411-M 28 AUG 96 28 AUG 96
NO Not detected
NA - Not applicablc
Reported By: Marilyn Toomey Approved By: Barry votaw
The cover letter is annein2egraal part of this report.
30
LO' d 800' oN 80:OT 96,20 100 Z:689-9b9-rOL:OI SH03 N0IdHbH3

r
SEP 19 '96 14:31 FR QUANTERRR To 14TJ4S466892 P.04/it
Total Metals +
(Tissue)
Client Name: Chaammppion International - NC
Client ID: CHI 2-3RF-Caro
Lab III: 089121-0020-SA
Matrix: TISSUE Sampled: 13 AUG 96 Received: 20 AUG 96
Authorized: 20 AUU 96 Prepared: See Below Analyzed: See Below
Wei, wt. Repporting Analytical Prepared Analyzed
Parameter Result Units Limtt Method bate Date
Mercury 0.041 mg/kg 0.040 SW 7471-H 28 AUG 96 28 AUG 96
90 = Net detected
HA = Not applicable
Reported By: Marilyn Toomey Approved BY: Barry Votaw
The cover letter is an integgral part of this report.
Rev 130787
80'd 800' eN 80:OT 96.20 1D0 T689-9t+9-bOL:OI SH03 NOIdWUH3

5EP 11 196 142-32 FR GUWFEPM m 17046466692 P.05r11
Total Metals swim
(Tissue)
Client Name: Champion International - NC
L
Cent ID: CHI-I-IRF-Redbreast SF
10: 06912i-0021-31k
Matrix: TISSUE Sampled: 14 AUG 96 Received: 20 AUG 96
Authorized: 20 AUG 96 Prepared: See Below Analyzed: See Below
Net wt. Reporting Analytical Prepared Analyzed
Parameter Result Units Limit Method Date Date
Mercury 0.13 mg/kg 0.040 SW 7471-M 28 AUG 95 28 AUG 96
NO = Not detected
NA = Not applicable
Reported By: Marilyn Toomey Approved By: Barry Votaw
The cover letter is an integral part of this report.
Rev E80707
60'd 800' oN 60:01 96.20 130 Z689-9b9-b0A:0I SH03 NDIdHUH0

SEP 19 1% 14,34 FR UjA nTERRA Tn i7U6466692 P.05i11
rAtall 011
Total Metals �*
(Tissue)
Client Name: Cbamppion International - NC
Client ID: CIiI-1.1RF-Redbreast SF
Lab 10, OH9121-0021-SA
Matrix: TISSUE Sampled: 14 AUG 96 deceived: 20 AUG 96
Authorized: 20 AUG 96 Prepared: See Below Analyzed: See below
Wet tit, Reporting AnalyLlcal Prepared Analyzed
Parameter Result Units Limit Method Date Date
Mercury 0.13 mg/kg 0,040 SW 7471-M 28 AUG 96 28 AUG 96
NO - Not detected
NA = Not applicable
Reported By: Marilyn Toomey Approved By: Barry Votaw
The cover letter is an integral part of this report.
Rey 230707
OT' d 800' ON 60:O1 96,20 L00 Z689-9#9-roL:OI SH03 NOIdWUH3

r�
SEP L9 '96 14.34 FR GU*rERRA To 1?246466892 P.06i11
Total Metals
(Tissue)
Client NZMQ: ChAMVpon International - NC
Client ID: CHI-I-2RF-Rock Bass
Lab ID: 099121-0022-SA
Matrix• JFSUE Sampled: T4 AUf A6 Reeoived: 20 AUG 96
Author;zed: Eu AUG 96 prepared: See Below Analyzed: See Below
Net wt. Reporting Analytical Prepared Analyzed
Parameter Result Units Limit Method Date _ Date
Mercury 0.51 mykg 0.040 SW 7471-M 28 AUG 96 28 AUG 96
NO - Not detected
RA - Not applicabla
Reported By: Marilyn Tnomay Approved By: Barry Votaw
The cover letter is aneinto ral part of this report.
TT' d 800' oN 60:OT 96.£0 130 Z689-9#9-b0L:OI SH03 NOIdWUH3

S'FP 19 '96 14:34 FR QURNTSM M 17046466892 P.07/11
aatita�
Total Metals �^
(Tissue)
Client Name: Champion International - NC
Client 10: CHI-1-3RF-Rlk Redhorse
Lab I0: 089121-0023-SA
Hatrix: TISSUE Sampled: 14 AUG 96 Received: 20 AUG 96
Autburized: 20 AUG 96 Prepared: See Below Analyzed: Sea Below
Wet wt. Reporting Analytical Prepared Analyzed
Parameter Result Units Limit Method Date Date
Mercury 0.38 mg/kg 0.040 SW 7471-M 29 AUG 96 30 AUG 96
HO n Not detected
HA - Not applicable
Reported By: Marilyn Toomey Approved By: Barry V4t4W
The cover letter is an Interal part of this report.
Rev 1SB187
ZT' d 800' oN OT:OT 96.50 100 Z689-9b9—bOL=OI SH03 NOIdWUHO

CHAMPION EOHS ID:704-646-6892 OCT 03'96 10:10 Na .008 P .13
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SW 19 496 14:35 FR QUANTERRA TO 144746466592 p.e9i11
Sod=
MFTHnn BLANK REPORT
Metals Analysis and Preparation
project: 089121
Test: HG-CYAA-TISSUE Mercury, Cold Vapor AA
Method: SW 7471-M
McLrix: TISSUE
QC Lot: 28 AUG SO-GX QC Run: 28 AUG 96-G
Reporting
Analyto Result Unite Limit
Mercury No mg/kg 0,040
Test: MG-CVAA-TISSUE Mercury, Cold Vapor AA
Method: SW 7471-M
Matrix: IISSUt
QC Lot: 29 AUG 96-JX QG Run: 29 AUG 96-J gg
Anelyte Result UIIILS ReLimitn9
Moreury NB mg/kg 0.040
No - Not petected
VT'd 800' oN 01:OT 96.20 130 Z689-9b9-b0L:GI SH03 NOIdWHHO

CHAMPION EDHS ID:704-646-6892 OCT 03'96 10:11 No .008 P .15
v
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SEP 19 196 14136 FR MJRiTERRR TO 17046466992 P.11/ii
• r�&nemmmml
SWAM
MetalsAAnagyaisOand Preparation
Project: 089121
Category: HA-TISSU Mercury by CVAA for Tissue
Testcode: HG-CVAA-TISSUE Method: 30 747I-M
Matrixz TISSUE Concentration Units: mg/kg
QC Lot: 28 AUG 96-GX Analyzed Date: 28 AUG 96 Time: 17. 3
---Concentration------- Accuracy Precision
Analyte Spiked -----Mpasurad----• Avara?@J%) (RFD)
DCSI DCS2 AVG DCS Lmitts D Limit
Mercury 15.0 13.4 13.4 13.4 89 63-150 0.0 28
Category: HO-TISSU Mercury by CVAA fur T]saum
Testcode: HG-CVAA-TISSUE Method: SW 7471-M
Matrix: TISSUE Concentration Units: mg/kg
QC Lot: 29 AUG 96-OX Analyzed Date: Time:
----Concentrauan------- Accuracy Precision
Analyte Spiked -----ft&3urnd----- Avaraga(q� (tRPO
p DCS1 DCS2 AVG OCS Limits DC S Limit
This is a Lot Identifier. An LCS was performed instead of a OCS.
Calculations are performed before rounding to avoid round-off errors to calculated results.
9T' d 800' oN TT:OT 96.£0 130 Z689-9V9-b0L:0I 87Hd3 NE-idWdHb