NC0000272_TMDL Dioxin Load_19991001

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Total Maximum Daily Load for Dioxin to the Pigeon River and
Waterville Lake, North Carolina
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Prepared by:
NC Department of Environment and Natural Resources
Division of Water Quality
Water Quality Section
Post Office Box 29535
Raleigh, NC 27626-0535
[phone]

INDEX OF TMDL SUBMITTAL
303(d) List Information
State North Carolina
Name of 303(d) listed waterbody Pigeon River: 5-(7)a to 5-(7)f
Waterville Lake
8 Digit Cataloging Unit 06010106
Area of Impairment 38.6 river miles (including lake)
340 acres of Waterville Lake
WQS Violated Dioxin in fish tissue
Water Use Classification C
Pollutant of Concern Dioxin (2,3,7,8-TCDD)
Source of Impairment Champion International - Canton Mill
Public Notice Information
Notification: There was a public meeting on June 6, 1996 to garner public input on Champion's
NPDES permit, which contained a limit for dioxin. This meeting was noticed at least one month
prior in several newspapers in the region. DWQ will renotice this limit as,a TMDL during the
coming Basinwide planning meetings scheduled for winter 2000.
TMDL Information
Critical Conditions Daily loads discharged from Champion
Annual average flow in Pigeon River used as regulated by
Procedures for Assignment of Water Quality
Standards 15A NCAC"2B .0206
Seasonality Identical summer and winter limits
Development tools Mass balance equation
Supporting documents Files for NPDES permit NC0000272
Procedures for Assignment of Water Quality Standards
15A NCAC 2B .0200 Rules
TMDL 0.1 pg/1 (picograms per liter)
Loadings . ,0.1 pg/1 _ point source .
0:0 pg/1 nonpoint sources
Margin of Safety .013 pg/1 in waste concentration (— 11.4%)
Implementation NPDES permit limit assigned to Champion
1

Pigeon River Section on 303 ( d) List - for Dioxin
�
Watershed
VicinityMa of Pigeon River�• Waterville Lake
P 9
:::: •::. :.•:.: .:. •• ............... .....
.:; : i C:.nt(m)
Pigeon Section on 303 d List for Dioxin
N � )
Waterville Lake on 303 d List for Dioxin
`" ems'`:::.
• Champion-Canton Mill
m•. ::::::: :::::•::. ::::•. 0 Municipalities
0 9 Hydrologic•: Pigeon Watershed USDA H drolo i c Uni
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Section 303(d) Requirements
Section 303(d) of the Clean Water Act (CWA) requires states to develop a list of waters not
meeting water quality standards or which have impaired uses. Waters may be excluded from the
list if existing control strategies for point and nonpoint source pollution will achieve standards and
uses. Listed waterbodies must be prioritized, and a management strategy or total maximum daily
load (TMDL) must subsequently be developed for all listed waters.
Background and Purpose
Five freshwater segments, 5-(7)a to 5-(7)f, in the Pigeon River and Waterville Lake are listed on
the 303(d) list for fish advisories due to contamination by dioxin. On the published North Carolina
1998 303(d) list there is a caveat listed for the Pigeon segments which states the following:
"The Pigeon River remains on the list due to fish consumption advisories even though fish tissue
data indicate declining levels of dioxins in fish. Controls have been placed on point sources
upstream of the sampling locations and concentrations in fish are expected to continue to decline.
DWQ will not develop a TMDL or further management strategies, however, dioxin levels in fish
will continue to be monitored."
Contrary to this statement, the North Carolina Division of Water Quality (DWQ) has decided to
draft a TMDL in order to expedite the Pigeon River segments'and Waterville Lake's removal from
the 303(d) list. Also, part of that statement is misleading as Champion International Mill in
Canton, NC is the sole source of dioxin in the Pigeon watershed.
Numerous isomers of dioxin exist and are monitored in fish tissue and in point source effluent;
however, the isomer 2,3,7,8 TCDD (Tetrachloro-dibenzo-p-dioxin) is the one that is restricted in
the effluent and will be the standard for this TMDL. In the TMDL, "dioxin" refers to 2,3,7,8
TCDD. It is also important to note that Champion has not measured detectable concentrations
2,3,7,8 TCDD since November, 1989.
TMDL Development
To develop a TMDL,DWQ employed a mass balance equation that considers the mean annual
flow of the river, the design flow of the discharger, and the human health standard for dioxin to
determine a maximum allowable effluent concentration. North Carolina's regulation for flow
design criteria for effluent limitations, Procedures for Assignment of Water Ouality Standard 15A
NCAC 2B .0206, requires use of"the mean annual flow to protect human health from carcinogens
through the consumption of water, fish and shellfish unless site specific contamination concerns
necessitate the use of an alternative design flow."
Mass balance equation for dioxin in Pigeon River at Champion Intemational-Canton:
CuQu + CwQw =CdQd where:
Cu ='upstream concentration
Cw =waste concentration
Cd=downstream cone. (or standard in this case) .
Qu= upstream flow
Qw = waste flow (design flow)
Qd =downstream flow (equal to Qu + Qw)
2 ,

If the equation is solved for Cw it yields a concentration that would meet the human health
standard for dioxin downstream of the effluent. In other words, the TMDL should, at least, be
below this concentration.
Cw = (CdQd- CuQu)/Qw
Qw =46.3 cfs (29.9 MGD x 1.547 cfs/MGD =46.3 cfs)
Qu = 327 cfs (mean annual flow)
Qd= 373.3 (Qw + Qu),
Cu = 0 (assumed, since mill is only source in basin)
Cd=0.014 pg/I (NC standard for human health)
Cw = [0.014 pg/I (373.3 cfs) - 0 (327 cfs) ] /46.3 cfs
Cw =0.113 pg/I
So; the waste concentration must be less than 0.113 pg/I at mean annual flow for the Pigeon River
to meet the North Carolina human health standard for dioxin. -
Margin of Safety
DWQ issued Champion an NPDES permit with a reduced dioxin limit in December, 1996
(Appendix I). The limit was designed to protect the human health standard for dioxin downstream
of the discharge. The limit is 0.1 pg/l. To lend further perspective to this limit, a picogram is 10"14
gram; this is equivalent to saying that one penny (picogram) is equal to 10-14 times
1,000,000,000,000, or 1 quadrillion, dollars.
If you substitute the permitted limit for Cw and solve for Cd, the dioxin standard is not
violated:
Cd= (CuQu + CwQw)/Qd
Cd= [0 (327 cfs) +0.1 pg/I (46.3 cfs)] /373.3 cfs
Cd=0.0124 pg/I
The margin of safety may be calculated as follows (Cs =NC standard for human health, Cd from
directly above, or downstream concentration at permitted limit):
[(Cs -Cd)/Cs] * 100 =MOS
[(0.014 - 0.0124)/0.014] * 100 = 11.4%
Thus, there is an 11.4% margin of safety.
Seasonality
Seasonality is not considered to be an issue in the case of dioxin as it is aknown carcinogen. The
duration of exposure assumed for carcinogens is over a lifetime. Dioxin is highly bioavailable and
has a long half-life making it available throughout the year. While there may be more up-take of
dioxin by fish in the summer months, inputs from the winter and fall still have the potential of
impacting fish tissue concentrations throughout the year.
3

TMDL Calculation
As explained above, Champion International is the only source in the basin, so it will receive the
whole allowable TMDL load. This is manifest in its NPDES concentration limit of 0.1 pg/l.
No other sources will be permitted to discharge dioxin into the Pigeon River or any of its
tributaries.
In the late 1980's Champion made two changes that resulted in the nondetect levels of dioxin in the
facility's effluent: 1) It increased the level of chlorine dioxide substitution used for pulp
bleaching and decreased the use of elemental chlorine; and 2) Champion changed the types of
defoamers that were used in pulp bleaching. These defoamers have low levels of dioxin and furan
precursors relative to the defoamers previously used. These changes resulted in nondetect effluent
levels of 2,3,7,8 TCDD since November, 1989.
In 1993 Champion converted both of their hardwood and pine bleaching processes to OD100
which is elemental chlorine free (ECF). The OD100 process includes oxygen delignification prior
to pulp bleaching. Oxygen delignification reduces the amount of chlorine dioxide needed to
bleach pulp. The OD 100 process goes beyond the requirements of EPA's Cluster Rule for paper
and pulp-industry to minimize dioxin and other discharges.
Implementation of Dioxin TMDL
Champion International was issued an NPDES permit on December 12, 1996 that limited effluent
dioxin concentrations to 0.1 pg/l (Appendix I). The permit states that "the�sample shall be
analyzed in accordance with the appropriate method of analysis specified in Analytical Procedures
and Quality Assurance for Multimedia.Analysis of Polychlorinated Dibenzo-para-dioxins and
Plychlorinated Dibenzofurans by High Resolution Gas Chromotoeraphy/High Resolution Mass
Spectrometry, EPA, 1987 (EPA Method 8290), or another equivalent analytical protocol approved
by DWQ." Monitoring shall be performed on a quarterly basis in four areas of the facility: influent
to wastewater treatment facility, sludge, landfill leachate and effluent. A problematic situation
arises in the laboratory analysis, however, as the analytical detection limit is 10 pg/l, while the
permitted limit is 0.1 pg/l. The possibility exists that Champion could exceed the permitted limit
but escape detection. The fish tissue analysis, explained in the following paragraph, provides some
assurance that dioxin levels in the Pigeon River have, indeed, been decreasing.
The NPDES permit also requires that Champion perform fish tissue analysis in accordance with a
DWQ approved monitoring plan. Fish tissue analysis between 1990 and 1998 have shown
declining levels of dioxin (Appendix II). During 1990 and 1991, detectable levels of dioxin
occurred in nine of fifteen samples each year. Moreover, detectable levels were measured in
redbreast sunfish, largemouth bass, and bluegill, as well as bottom feeders. By 1993, four out of,
fifteen tissue samples yielded concentrations above detection. Detectable concentrations-were
observed in non-bottom feeders (largemouth bass] as late as 1995. Since 1996, the only species to
contain detectable dioxin levels have been.bottom feeders such.as common carp, channel catfish,
and flathead catfish. In 1998,_only common carp showed detectable levels in three of fifteen
samples; flathead catfish and channel catfish had nondetectable levels of dioxin.
DWQ recommends that contaminated sediments in the Pigeon River and.Waterville Lake remain
undisturbed so that they may be "capped" by sedimentation. As demonstrated, this strategy and
4

the reduced effluent concentration have proven to be successful-at reducing fish tissue
concentrations.
Public Participation
There was a public meeting on June 6, 1996 to gamer public input on Champion's NPDES permit,.
which contained a limit for dioxin. This meeting was noticed at least one month prior in several
newspapers in the region. At EPA's request, DWQ could renotice this limit as a TMDL during the
coming Basinwide planning meetings scheduled for fall 1999. .
�a
Tracking Progress
As explained in previous sections, effluent dioxin is monitored on a quarterly basis and fish tissue
analyses are conducted annually. The existing NPDES permit will expire on November 30, 2001.
The necessity for fish tissue analyses and effluent monitoring will be reevaluated in the next
NDPES permit.
1
5

Making Or mark for you.
BVZ LUE RIDGE PAPER PRODUCTS INC.
December 17, 1999
Mr.Forrest Westall
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,North Carolina 28801
Re: North Carolina NPDES Permit No.NC0000272
Blue Ridge Paper Products,Inc.-Canton Mill
1999 Waterville Reservoir Sampling Requirement Results
Dear Forrest:
On August 8, 1999,in accordance with Part III Section K of the Canton Mill's NPDES Permit,Waterville
Reservoir was sampled at three locations for temperature,dissolved oxygen,conductivity,PH,Total
Nitrogen(TN),Nitrite+Nitrate(NO2+NO3),Ammonia(NH3-N),Total Kjeldahl Nitrogen(TKN),Total
Phosphates(PO4),and Chlorophyll-a. Water samples were collected at 0.1 meters beneath the surface of
the water in the take prior to Laurel Branch,near Wilkins Creek and near the dam as stated in the permit.
Temperature,dissolved oxygen,conductivity, Secchi Depth and pH were measured in the field while the
remaining samples were collected and preserved in the field and sent off to a North Carolina certified
laboratory for analysis. Attached is a table summarizing the results of the above analyses for each
sampling site. This table will be attached to the mill's November DMR which is scheduled to be mailed by
December 21".Please see the attached letter from Pace Analytical and the original purchase order
concerning the omission of the Total Phosphorous(TP)analysis. As a result of Pace Analytical Services,
Inc.'s error,the TP analysis was not performed in conjunction with the fish tissue analysis.
If there are any questions or comments please contact me at(828)646-6749.
Sincerel 9RO/
Melanie S. Hager
Associate Environmental Engineer
SE
C
175 Main Street P.O.Box 4000 Canton, North Carolina 28716 828-646-2000

Blue Ridge Paper Products, Inc. - Canton, NC
Results of 1999 Waterville Reservoir Sampling NPDES Permit Requirement
Sample Waterville Reservoir Waterville Reservoir Waterville Reservoir
Parameter Units prior to Laurel Branch near Wilkins Creek near the dam
Temperature Celsius 26.9 26.6 26.2
Dissolved Oxygen mg/1 9.4 8.9 8.9
Conductivity umhos 442 386 443
pH 8.2 8.9 9.1
TN mryl(ppm) ND(0.20) ND(0.20) ND(0.20)
NO2 + NO3 M94(ppm) ND(0.10) ND(0.10) ND(0.10)
TKN M94(ppm) ND(0.10) ND(0.10) ND(0.10)
NH3-N mg4(ppm) ND(0.10) ND(0.10) ND(0.10)
PO4 M94(ppm) ND(0.02) ND(0.02) ND(0.02)
Chlorphyll-a ug,1(ppb) 45.657 48.861 30.705
Secchi Depth meters 1.24 1.61 1.88
Sample Notes.
Laurel Branch Site Sampled on 8/8/99 at 09:40
Wilkins Creek Site Sampled on 8/8/99 at 09:55
Dam Site Sampled on 8/8/99 at 10:15
1999 Waterville Lake.xis MSH 1277/99

d
Pace Analytical Services,Inc.
• 54 Ravenscroft Drive
Pace
Analytical Asheville,NC28801
Tel:[phone]
Fax:[phone]
12/12/99
Ms. Melanie Hager
Blue Ridge Paper Products, Inc.
175 Main Street
Canton, NC 28716
Re: Waterville Lake Discharge Testing Lab Error, project#937218
Dear Ms. Hager,
In reference to the samples received in our lab on August 9, 1999, Pace
Analytical did not test the entire test as requested on the purchase order
#C61875.
Total Phosphorus was mistakenly not checked in and was not tested.
This error was not detected until the results were sent out and samples were out
of hold time.
We apologize for this error and will review all your requested test much closer in
the future.
Sincer
Walter Miller
General Manager
Attachment:

PURCHASE ORDER
ALL PURCHASING INFORMATION SHOV
u8 LUrE Rrl D G 1i VA I'I:R P li O D L CT 5 INC. BELOW MUST APPEAR ON ALL CORI
SPONDENCE, INVOICES, PACKING SLI
;ANTON, NORTH CAROLINA 28716
ETC.,REFERRING TO THIS ORDER.
I
PAYMENT TERMS DATE NO LATER THAN PURCHASE ORDER/REL NO.
INff
0. 00 NET 30 DAYS REQUIRED TAXABLE LE HELO SHIPPING ORD R SUPPIEMEMNQ
TERM ROUTING YE5
91
AICHA UPS SHIP MATERIAL TO IEXFAAPRON
PAGE 1
PACE ANALYTICAL SERVICES INC CANTON MILL
WALIER L MILLER CANTON, NC 28716
54 RAVENSCROFT DRIVE
ASHEV I LLE NC 28801 MAIL INVOICES IN TRIPLICATE TO
P. O. BOX 4000
J CANTON, NORTH CAROLINA 28716
JITY U/M BA ITEM DESCRIPTION
SYMBOL UNIT PRICE
1 SV NPDES REQUIRED SAMPLES TO BE ANALYZED BY PACE iERVICE
603. 0001
RIT
ANDLYTICAL AMMONIA)OORTHO&OTOTAL(TOTAL PHOSPHOROUSANA , AANDNIITo
CHLOROPHYLL A. THREE SAMPLES WILL BE TAKEN TO
DELIVERY DATE: 0S/05/99
YEAR 2000 - IN THE EVENT THE GOODS CONTAIN ANY
ROGRAMS, SOFTWARE, FIRMWARE OR THE LIKE,
ELLER REPRESENTS THAT CANTON MILL OPERATIONS
SHALL NOT BE
DATES FOLLOWINGVERSELY SEPTEMBERFECTED 1, 1999Y CHANGE IN I
TOTAL COST OF THIS PURCHASE ORDER NOT TO
EXCEED $$603. 00 WITHOUT PRIOR APPROVAL,
EITHER VERBAL OR WRITTEN, FROM BLUE RIDGE
OUTER PROD.APPROVALPWILLABENNONEHILLABLEEXCESS WITH
Blue Ridge Paper Products,Inc.
ES AND GOODS SUPPLIED THE FOLLOWING:
TO THIS ORDER MUST BEAR ASTATE- IMPORTANT - MAIL ACKNOWLEDGMENT
'AIJIIALLY IDENTICAL WITH THE FOLLOWING:
CERTIFY THAT THESE GOODS WERE PRODUCED IN COMPLIANCE WITH ALL E TO SING
REQUIREMENTS OF SECTIONS e,7,AND 12 OF THE FAIR LABOR STANDARDS AND CORRESPONDENC SIGNING 1HI5 ORDER. Tav Y /"r SELL RS 82E) 646 6
•.ENDED,AND OF REGULATIONS AND ORDERS OF THE UNITED SAES DEPART- /
:BOP ISSUED 11NDER SKTION ld THEREOF.
THIS ORDER
HE PLAREOF WHICH ALS CONSTITUTE A�PA T OF TOHIS IPURRCHASE ORDER. THE BACK

�a
SEP 1 1 1997
r j Champion
N pora ton
September 8, 1997
Mr. Mike McGhee
US EPA, Region W
61 Forsyth Street
Atlanta,GA 30303
Subject: Draft Report entitled"Ecological Assessment of the Pigeon River and
Waterville Reservoir dated 7/16/97.
Dear Mike:
Thank you for the opportunity to review the subject draft report prepared by Dave
Melgaard and presented to us on July 17, at a meeting of the Technology Working Group
in Atlanta. Champion has serious concerns about not only the tone of the report, which
tends to dwell too much on the past history of the river and the mill,but also because it
conveys the idea,as if it were fact,that there are still serious problems in the receiving
stream. Every single study that has been made of the ecology of the Pigeon River since
the Canton mill modernization, whether by Tennessee, Oak Ridge National Labs,North
Carolina, Carolina Power and Light or Champion, shows significant improvement in
species diversity, abundance and fish body condition. And each following study shows
more favorable results than those done in previous years, i.e. the river continues to
improve with time
Dioxin body burdens in fish show a steady and consistent decline, and both states
have revised their fish advisories to reflect this improvement (the report only
acknowledges that North Carolina has revised its advisory). Tennessee uses a more
restrictive dioxin criteria for its stream advisory on the Pigeon than it does for other
Tennessee streams, and if this were not the case, it is doubtful that there would be any
advisory on the Pigeon river within Tennessee.
The report states "concerns have been expressed . . . about the presence of dioxin
in the sediments in Waterville Lake". As you know,this issue was addressed at great
length in the last FERC relicensing of the CP&L hydroelectric facility. Several
restrictions were placed on CP&L to ensure that sediments were not released from

Champion International Corporation
Mr. Mike McGhee
U.S. EPA, Region IV
September 8, 1997
Page 2
Waterville reservoir, and it was agreed that continued monitoring of fish flesh was the
surest means of ensuring this result, as it was expected that over time the contaminated
sediments would be covered with clean sediments. Both Tennessee and North Carolina,
as well as EPA agreed to these conditions as a part of their"sign off' of the new license.
All indications are that this control mechanism is working as evidenced by the trend
downwards in fish flesh results. To our knowledge not a single bit of scientific evidence
has been offered to support these"concerns". To the contrary, everything that has been
done to investigate the basis for concern has shown none. This includes an investigation
by the Health departments of both states concerning alleged high cancer incidents in
Hartford, TN and the area around Canton,NC that showed no statistically significant
difference in cancer mortality in either area when compared to other similar populations;
a finding by EPA of the absence of dioxin in drinking water supplies in the Hartford, TN
area; and an assessment by EPA's Agency for Toxic Substances and Disease Registry of
possible routes of human exposure to dioxin from the Pigeon River that concluded that
contact with, or consumption of water from, the river does not represent a significant
human exposure pathway. Many of these points, incidentally, were made by John
Hankinson is his Aug. 29, 1996 letter to David Jenkins (copy attached) replying on behalf
of the EPA Administrator to questions about the proposed NPDES permit..
In summary, there is no new evidence (or old evidence, for that matter), and there
are no new issues that have been presented. All the issues previously raised by the same
concerned parties have already been addressed by EPA,FERC and the two states. Why
then is there a need to initiate a new look at these same issues? It would seem that all that
needs to be done is to compile the many studies of the river that have been done, and
summarize the conclusions drawn from the studies.
If, however, EPA has already decided to initiate this new study, it is imperative
that any data or studies reviewed be carefully screened to ensure that they are
comparable. For example, different Index of Biological Indices (IBI's) are used in several
of the aquatic life studies. Secondly, any procedures used to collect new data must be
proven and certified. In this regard,the possible use of semipermeable membranes being
promoted by U.S. Fish and Wildlife as passive monitors and mentioned in the draft report
would not meet this criteria. We have researched this method and understand it has not
received an official approval as a test method. Secondly, its use is suggested as a
surrogate for actual fish flesh data, in cases where fish cannot be collected for various
reasons. Certainly,this is not the case for this river system given the tremendous amount
of actual fish data that have been collected by the various entities.

C• ampion International Corporation
Mr. Mike McGhee
U.S. EPA, Region IV
September 8, 1997
Page 3
Champion believes the scope of study envisioned in this draft report is not justified, and
we request you seriously consider our comments. If there are any questions please let me
know.
Sincerely,
hEOyC/kys
Attach.
CC: Paul Davis
Dick Diforio
Gary Guzy
John Hankinson
David McKinney
Bob Perciasepe
Linda Rimer
Forrest Westall

S � J
y UNITED STATES'ENVIRONMENTAL PROTECTION AGENCY
moopI$ REGION 4
345 COURTLAND STREET.N.E.
ATLANTA.GEORGIA 30365 ,
AUG 2 9 1996
REF: 4WM-WPEB
Mr. David Jenkins, Director
Conservation and Public Policy
American Canoe Association, Inc.
7432 Alban Station Boulevard
Suite B-226 ,
Springfield, Virginia 22150-2311
SUBJ: NPDES 'Permit for Champion International
Canton, North Carolina
Dear Mr. Jenkins:
Thank you for your July 25, 1996, letter to Administrator
Browner regarding the State of North Carolina's proposed National
Pollutant Discharge Elimination System (NPDES) permit- for the
Champion discharge to the Pigeon River. Your letter has been
referred to me for a response.
As background, please be aware that NPDES permitting authority
for this discharge now resides with the State. Also, variances for
color and temperaE'ure must first be approved by the State. I
understand that the State will make determinations on both the
permit and the variances sometime this fall. The Environmental
Protection Agency's (EPA) role is to overview the State' s draft
permit to ensure that the goals of the Clean Water Act (CWA) are
met and to separately review and approve any variance(s) . I am
enclosing for your information a copy of this office's recent•
comments on the State's draft permit.
You raised a number of different concerns that I would like to
address individually. Regarding the color variance, -you requested
that this office consider the adverse economic implications that
its continuation woa13- have on dowii`streaai'business interests and
property owners during our- review of any State-approved variance.
We do not have any current information on the number of tourists or
recreational users that visit area rivers .such as the Nantahala,
Chatooga, and/or the Ocoee or projections concerning the Pigeon
River. We also do not have any. information about the number of
dollars spent on activities related to recreational or other uses
of these, rivers. If you could provide such information, we would
be glad to consider it when we evaluate any future State-approved
variance.

z
You also requested that the color variance be denied now or
allowed only until the end of the decade, both resulting in a 50
color unit limit applied to Champion' s discharge pipe. As
background, please note that the variance must be re-approved ever}
three years . Champion requested and received a continuation of the
color variance from North Carolina based on economic costs and lack
of available technology to meet the State' s water quality criterion
between the discharge point and the Tennessee state line. Such a
variance is allowed under both North Carolina law and the Clean
Water Act and its implementing regulations . For your information,
I have enclosed sections from the EPA guidance Water Quality
Standards Handbook and from 40 Code of Federal Regulations §131 . 10
regarding variances . This office approved North Carolina' s action
in November 1994 . Please refer to pages 4 and 5 of our enclosed
comment letter to North Carolina regarding the color provisions of
the Champion draft permit .
Regarding dioxin, you expressed concern that -eater releases
from Waterville Reservoir after exposure to contaminated sediments
may impact recreational users of the river. For several reasons, I
do not believe that potential recreational exposure to dioxin in
the water column represents a threat to human health. In December
1988, at this office' s request, the Agency for Toxic Substances and
Disease Registry, a branch of the Department of Health and Human
Services, conducted an assessment of possible routes of human
exposure to dioxin from the Pigeon River. The assessment concluded
that contact with, or consumption of water from, the river does not
represent a signi6icant human exposure pathway. I am enclosing a
copy of that report for your information. Also, EPA' s draft
national assessment of dioxin does not consider dermal exposure to
be a significant human pathway. If dioxin was contained in water
releases from the reservoir, one would expect it to accumulate in
the tissue of downstream fish. However, current dioxin levels in
fish are generally lower than 5-7 years ago. Due to this
improvement in water quality, North Carolina has lifted its 1989
fish advisory for top-feeding fish and Tennessee revised its
existing fish advisory in March 1996.
You also requested that a plan be developed to deal with these
dioxin-contaminated sediments and that Champion pay for its
development. Waterville Reservoir has already been assessed by
this office as a potential Superfund site. Because of its long
distance downstream from the Champion discharge and the partial
lifting of the North Carolina fish advisory, the reservoir was not
listed as a Superfund site. It is our best judgement that the most
environmentally protective solution is to allow cleaner sediments
to continue to build up, cover, and isolate the more contaminated,
deeper lake sediments. In our view, any dredging or removal of the
deeper contaminated sediments would release dioxin back into the
lake' s water column, cause increased dioxin buildup in fish and
other aquatic life tissue, and contaminate downstream segments of
the river.

j 3
Regarding oxygen-demanding wastes, you requested that they be
treated so that the river can meet dissolved oxygen standards to
support aquatic life. Protecting aquatic life and meeting both
North Carolina' s and Tennessee' s dissolved oxygen standards is the
basis for the current permit' s 5-day biochemical oxygen demand
(HODS) limits and requirements to provide side stream oxygenation
and monitor for dissolved oxygen at three different stations on the
Pigeon River. The proposed permit' s BODS limits are even more
stringent than those of the current permit and should maintain
dissolved oxygen water quality standards in the river in both
states .
Regarding the temperature variance, please refer to pages 3
and 4 of our enclosed comment letter to North Carolina cited above .
You indicated that this office is allowing the degradation of
the Pigeon River to ccntinue to perpetuity. You also indicated
that this office has =_=ad vic_aticn of the intent of = e C%71
and has not made any' real attempt to enforce its intent with
respect to this discharge and the Pigeon River. I must strongly
disagree with these assertions . Prior to the 1989 NPDES permit
issued by this office, Champion had neither dioxin nor color
limits. Champion has been and is currently complying with both the
color and dioxin provisions of that permit. Color levels at the
North Carolina/Tennessee state line are now consistently in the 10-
30 color unit range (the standard is 50) . To express these color
levels in more common terms, the Pigeon River has improved from a
consistent coffee'color to a ginger ale color. As cited above,
both North Carolina' s and Tennessee's dioxin fish advisories have
been modified.
I believe that these all indicate a vast improvement in the
water quality of the Pigeon River and that this office had a large
part in this achievement. It is my intent that any new permit for
Champion issued by North Carolina retain and improve on the
environmental gains that we have already made. I believe that our
enclosed comments on the proposed permit are also consistent with
that goal.
Please contact me if I can be of further assistance.
Sincerely,
John H. Hankinson, Jr.
Regional Administrator
Enclosures

w i
BLUE RIDGE
PAPER PRODUCTS INC.
WATER OLP,LG,. S I
June 27, 2001
Dr. Luanne Williams
Occupational and Environmental Epidemiology Branch
Parker Lincoln Building
2728 Capital Boulevard
1912 Mail Service Center
Raleigh,NC 27699-1912
RE: Pigeon River Dioxin in Fish
Dear Dr. Williams:
Attached is the information that we discussed concerning Pigeon River dioxin in fish tissue
analysis from 1996-2000. Since 1990 annual fish tissue surveys of the Pigeon River have been
conducted in August by the Canton Mill. EA Engineering Science and Technology, Inc. has
collected all of the fish tissue samples. While the name has changed the same laboratory in
Sacramento, California (Enseco 1990-1994, Quanterra 1995-1999, Severn Trent 2000) has
conducted all of the fish tissue analysis.
The attached information includes the following:
Attachment I Location Maps
Attachment II Blue Ridge Paper Canton Mill
Fish Tissue Results Summary
1996-2000
Attachment III 1996 Summary of CDD/F Isomer Analysis
Attachment IV 1997 Summary of CDD/F Isomer Analysis
Attachment V 1998 Summary of CDD/F Isomer Analysis
Attachment VI 1999 Summary of CDD/F Isomer Analysis
Attachment VII 2000 Summary of CDD/F Isomer Analysis
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
v
Attachment II includes a summary of the fish tissue results for 1996-2000. The toxicity
equivalency factors (TEFs) are from the World Health Organization (WHO/97, van Leeuwen,
1997) and applied to all 17 CDD/F isomers. As we discussed, a value of zero was applied to the
toxicity equivalence calculation (TEQ) when the CDD/F isomer concentrations were below the
level of detection. As shown in Attachment III, all sport fish in North Carolina have been below
the level of detection for all 17 CDD/F isomers since 1996 (Station 5 is in Tennessee). The
TEQ's for all catfish are either zero or below 3ppt. The TEQ's for carp in the main stem of the
Pigeon River are also below 3ppt. However, the TEQ's for Stations 4A and 413, in Walters Lake,
remain above 3ppt.
This data, which includes the more recent TEF's and all 17 CDD/F isomers, support revision of
the fish consumption advisory for dioxin in the Pigeon River. Blue Ridge Paper Products Inc.,
recommends the consideration of a complete lifting of the advisory for catfish, and a lifting of
the advisory for carp in the main stem of the Pigeon River.
Please contact me if you have any questions regarding this information at(828) 646-2318.
Sincerely,
Derric Brown
Manager, Environmental Affairs
xc: Forrest Westall
Keith Haynes

t I .
i
Walters Dam
413 Wilkins Creek
Cataloochee Station 4B
Creek RM 39.0
Station 4A
White Oak 4A RM 41.5
Creek Walters Lake
Fires CreeK
New Hepco Bridge I
i
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ti Flow Ferguson Bridge
Jonathons
Creek Gtab eel,
G
3 Station 3
RM 52.3
Station 2 Fiberville
RM 59.0
Waynesville STP / Clyde STP
RM 57.1 Mill Outfall
RM 58.4 k RM 63.3 Canton, NC
® Station 1 O
Clyde RM 64.5
(Control)
i
I
I
Figure 2-1. Sampling station locations on the Pigeon River-North Carolina Reach.
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Figure 2-3. Sampling Station No. 2 on the Pigeon River.
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Figure 2-5. Sampling Station No. 4A on the Pigeon River.
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Figure 2-6. Sampling Station No. 4B on the Pigeon River.
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BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS, 1996-2000(a)
1996 Results`' 1997 Results"'
Number of Length Number of Length
Station Species Fish Range(mm) TEQ(c) Station Species Fish Range(min) TEQ(c)
1 Redbreast sunfish 5 154-185 0.00• I Redbreast sunfish 5 144-161 0.00
RM 64.5 Rock bass 5 160.208 0.00• RM 64.5 Rock bass 5 162494 0.00
Black redhorse 5 401-440 0.00• Black redhorse 4 291.424 0.00
2 Redbreast sunfish 5 179-187 0.00• 2 Redbreastsunfish 5 183-200 0.00
RM 59.0 Redbreast sunfish 5 183.191 0.00• RM 59.0 Redbreast sunfish 5 160-I81 0.00
Common carp 5 543-580 1.60 Common carp 5 506.615 1.46
3 Redbreast sunfish 5 184-190 0.00• 3 Redbreastsunfish 5 187-202 0.00
RM 52.3 Redbreast sunfish 5 165-185 0.00• RM 52.3 Redbreast sunfish 5 164-195 0.00
Common carp 5 516-630 1.02 Common carpi 5 450-505 0.00
4A Black crappie 5 216-233 0.00• 4A Black crapppie 5 215-231 0.00
RM 41.5 Black crappie 5 215-229 0.00• RM 41.5 Black crappie 5 220-230 0.00
Common carp 5 562-632 5.01 Common carp 5 570-655 2.94
Channel catfish 5 418.482 2.33
4B Black crappie 5 223.258 0.00 a 4B Black crappie 5 226-241 0.00
RM 39.0 Largemouth bass 5 278.310 0.00• RM 39.0 Largemouth bass 5 270-360 0.00
Common carp 5 470-623 4.51 Common carp 5 605.690 13.70
Flathead catfish 5 430-540 0.62
5 Rock bass 4 169-186 0.00' 5 Rock bass 5 143-214 0.00
RM 19.0 Smallmouth bass 5 315.454 0.00• RM 19.0 Smallmouth bass 5 278-367 0.00
Stallmouth buffalo 5 451.555 0.07 Smallmouth buffalo 5 406-525 0.00
Total Fish Filleted 89 Total Fish Filleted 99
i
i
(a) Survey conducted by EA Engineering Science,and Technology. Analyses conducted by ENSECO Laboratories 1990-1994,Quanterm Laboratories 1995-1999,Severn Treat Laboratories in 2000.
(b) Survey conducted in August.
(c) Dioxin Toxic Equivalent Concentration using methodology from(1989),Toxicity Equivalent Factors from Van Leeuwen(WHO/97).
(.) CDD/F isomer concentrations were below the level of detection,therefore a value ofzero was applied to the TEQ calculation.
NOTE:0.000 denotes values less than or equal to 0.0005.

I
BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS, 1996-2000(a) (cont.)
1998 Resohst"r 1999 Resultsrot
Number of Length Number of Length
Station Species Fish Range(mm) TEQ(c) Station Species Fish Range(man) TEQ(c)
1 Redbreast surdish 5 145-176 0.00• 1 Redbreast sunfish 5 141-177 0.00
RM 64.5 Rock bass 5 158-179 0.00• RM 64.5 Rock bass 5 164-180 0.00
Black mdhorse 5 340-396 0.06 Black redhorse 5 352-427 0.00•
2 Redbreast sunfish 5 164.177 0.00• 2 Redbreast sunfish 5 167-190 0.00
RM 59.0 Redbreast sunfish 5 166-193 0.00• RM 59.0 Redbreast sunfish 5 158-178 0.00
Cannon carp 5 551-661 2.05 Common carp 5 54"15 0.20
3 Redbreast sunfish 5 168-193 0.00• 3 Redbreast sunfish 5 169-189 0.00
RM 52.3 Redbreast sunfish 5 167.200 0.00• RM 523 Redbreast sunfish 5 162.176 0.00•
Common carp 5 449.550 0.00• Common carp 5 500.591 1.10
4A Black crappie 5 220-240 0.00• 4A Black crappie 5 220-268 0.00
RM 41.5 Largemouth bass 5 227-330 0.00• RM 41.5 Black crappie 5 219.244 0.00
Common carp 5 585-621 2.32 Common carp 5 574645 0.92
Charnel catfish 5 416-458 0.00• Channel catfish 5 425-482 0.83
4B Black crappie 5 233-252 0.00• 4B Black crappie 5 233-244 0.00•
RM 39.0 largemouth bass 5 259-330 0.00• RM 39.0 Largemouth bass 5 276-305 0.00
Common carp 5 563-686 11.67 Common carp 5 62I680 5.61
Flathead catfish 5 414-523 0.00• Flathead catfish 5 372-513 0.00
5 Rock bass 4 155-I90 0.00• 5 Rock bass 5 170.203 0.00•
RM 19.0 Smallmouth bass 5 295-365 0.02 RM 19.0 Smallmouth bass 5 297-430 0.00
Smallmouth buffalo 5 464-537 0.000 1 Smallmouth buffalo 5 476-565 0.09
Total Fish Filleted 99 Total Fish Filleted 100
(a) Survey conducted by EA Engineering,Science,and Technology. Analyses conducted by ENSECO Laboratories 1990.1994,Quanterra Laboratories 1995-1999,Seven Trent Laboratories in 2000.
(b) Survey conducted in August
(a) Dioxin Toxic Equivalent Concentration using methodology from(1989),Toxicity Equivalent Factors from Van Leeuwen(W110/97}
(.) CDD/F isomer concentrations were below the level of detection,therefore a value of zero was applied to the TEQ calculation.
NOTE:0.000 denotes values less than or equal to 0.0005.

BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS, 1996-2000(a) (cont.)
2000 Resultsot
Number of Length
Station Species Fish Range(mm) TEQ(c)
1 Redbreast sunfish 5 137-148 0.00*
RM 64.5 Rock bass 5 162.186 0.00*
Black remorse 5 357-396 0.00*
2 Redbreast sunfish 5 169.176 0.00*
RM 59.0 Redbreast sunfish 5 164-181 0.00
Common carp 5 505-582 0.40
3 Redbreast sunfish 5 169.181 0.00*
RM 52.3 Redbreast sunfish 5 186-199 0.00*
Common carp 5 514-569 0.05
4A Black crappie 5 212-241 0.00
RM 41.5 Black crappie 5 220-241 0.00*
Common carp 4 559-604 2.00
Channel catfish 5 435487 0.70
4B Black crappie 5 213-231 0.00*
RM 39.0 Black crappie 5 220-230 0.00*
Common carp 4 593-712 7.43
Flathead catfish 5 407-450 0.000
5 Rock bass 5 171-198 0.00*
RM 19.0 Smallmouth bass 5 209-238 0.00*
Black remorse 5 427-476 0.12
Total Fish Filleted 98
I
(a) Survey conducted by EA Engineering,Science,and Technology. Analyses conducted by ENSECO Laboratories 1990-1994,Quamerm Laboratories 1995-1999,Severn Trent Laboratories in 2000.
(b) Survey conducted in August.
(c) Dioxin Toxic Equivalent Concentration using methodology from(1989),Toxicity Equivalent Factors from Van Leeuwen(WHO/97).
(•) CDDlF isomer concentrations were below the level of detection,therefore a value ofzem was applied to the TEQ calculation.
NOTE:0.000 denotes values less than or equal to 0.0005.

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ATTACHMENT III
Summary of CDD/F Isomer Analyses and Toxicity from the Equivalent Values
Values of Fish Tissue Composite Samples Pigeon River, August 1996.
I '
STATION 1
COMPOSITE 1RF COMP. 2RF COMP. 3RF
REDBREAST SUNFISH ROCK BASS BLACK REDHORSE
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
I
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.130 * 0.000 0.085 * 0.000 0.089 * 0.000
1,2,3,7,8-PeCDD 1.0 0.160 * 0.000 0.170 * 0.000 0.150 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.140 * 0.000 0.180 * 0.000 0.110 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.140 * 0.000 0.180 * 0.000 0.110 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.150 * 0.000 0.190 * 0.000 0.120 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.230 * 0.000 0.320 * 0.000 0.150 * 0.000
OCDD 0.0001 1.500 * 0.000 2.100 * 0.000 1.000 * 0.000
Dibenzo£uran
2,3,7,8-TCDF 0.1 0.110 * 0.000 0.140 * 0.000 0.400 * 0.000
1,2,3,7,8-PeCDF 0.05 0.130 * 0.000 0.310 * 0.000 0.170 * 0.000
2,3,4,7,8-PeCDF 0.5 0.110 * 0.000 0.260 * 0.000 0.150 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.110 * 0.000 0.061 * 0.000 0.083 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.091 * 0.000 0.051 * 0.000 0.069 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.300 * 0.000 0.260 * 0.000 0.290 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.120 * 0.000 0.068 * 0.000 0.093 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.790 * 0.000 0.067 * 0.000 0.045 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.040 * 0.000 0.097 * 0.000 0.065 * 0.000
OCDF 0.0001 0.460 * 0.000 0.220 * 0.000 0.230 * 0.000
I
Total TEQ 0.00 0.00 0.00
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENT III
Summary of CDD/F Isomer Analyses and Toxicity from the Equivalent Values
Values of Fish Tissue Composite Samples Pigeon River, August 1996. (cont.)
STATION 2
COMPOSITE 1RF COMP. 2RF COMP. 3RF
REDBREAST SUNFISH REDBREAST SUNFISH COMMON CARP
CDD/F ISOMERS TEF Results. (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3.,7,8-TCDD 1.0 0.100 * 0.000 0.120 * 0.000 1.500 1.500
1,2,3,7,8-PeCDD 1.0 0.160 * 0.000 0.180 * 0.000 0.510 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.091 * 0.000 0.110 * 0.000 0.400 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.150 * 0.000 0.140 * 0.000 1.500 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.096 * 0.000 0.120 * 0.000 0.390 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.800 * 0.000 1.100 * 0.000 3.100 0.031
OCDD 0.0001 2.300 * 0.000 3.000 * 0.000 22.000 0.002
Dibenzofuran .
2,3,7,8-TCDF 0.1 0.150 * 0.000 0.130 * 0.000 0.710 0.071
1,2,3,7,8-PeCDF 0.05 0.140 * 0.000 0.140 * 0.000 0.250 * 0.000
2,3,4,7,8-PeCDF 0.5 0.120 * 0.000 0.120 * 0.000 0.400 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.054 * 0.000 0.079 * 0.000 0.250 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.045 * 0.000 0.066 * 0.000 0.100 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.280 * 0.000 0.270 * 0.000 0.350 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.060 * 0.000 0.089 * 0.000 0.047 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.086 * 0.000 0.074 * 0.000 0.270 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.059 * 0.000 0.110 * 0.000 0.076 * 0.000
OCDF 0.0001 0.230 * 0.000 0.270 * 0.000 0.420 * 0.000
Total TEQ 0.00 0.00 1.60
I
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
I
I
I

ATTACHMENT III
Summary of CDD/F Isomer Analyses and Toxicity from the Equivalent Values
Values of Fish Tissue Composite Samples Pigeon River, August 1996. (cont.)
STATION 3
COMPOSITE 1RF COMP. 2RF COMP. 3RF
REDBREAST SUNFISH REDBREAST SUNFISH COMMON CARP
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD
1.0 0.130 * 0.000 0.130 * 0.000 0.870 0.870
1,2,3,7,8-PeCDD 1.0 0.200 * 0.000 0.190 * 0.000 0.590 * 0.000
1;2,3,4,7,8-HxCDD 0.1 0.250 * 0.000 0.160 * 0.000 0.400 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.250 * 0.000 0.170 * 0.000 1.500 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.260 * 0.000 0.170 * 0.000 0.400 * 0.000 j
1,2,3,4,6,7,8-HpCDD 0.01 0.400 * 0.000 0.420 * 0.000 3.500 0.035
OCDD 0.0001 1.300 * 0.000 1.300 * 0.000 16.000 0.002
I
Dibenzofuran j
2,3,7,8-TCDF 0.1 0.160 * 0.000 0.180 * 0.000 1.100 0.110
1,2,3,7,8-PeCDF 0.05 0.230 * 0.000 0.200 * 0.000 0.410 * 0.000
2,3,4,7,8-PeCDF 0.5 0.200 * 0.000 0.170 * 0.000 0.610 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.081 * 0.000 0.073 * 0.000 0.470 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.067 * 0.000 0.061 * 0.000 0.310 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.270 * 0.000 0.270 * 0.000 0.370 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.090 * 0.000 0.082 * 0.000 0.083 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.084 * 0.000 0.050 * 0.000 0.340 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.120 * 0.000 0.073 * 0.000 0.039 * 0.000
OCDF 0.0001 0.220 * 0.000 0.440 * 0.000 0.420 * 0.000
Total TEQ 0.00 0.00 1.02
i
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENT III
Summary of CDD/F Isomer Analyses and Toxicity from the Equivalent Values
Values of Fish Tissue Composite Samples Pigeon River, August 1996. (cont.) _
STATION 4A
COMPOSITE 1RF COMP. 2RF COMP. RF3
BLACK CRAPPIE BLACK CRAPPIE COMMON CARP
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
I
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.150 * 0.000 0.180 * 0.000 4.200 4.200
1,2,3,7,8-PeCDD 1.0 0.170 * 0.000 0.210 * 0.000 1.300 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.270 * 0.000 0.290 * 0.000 1.100 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.230 * 0.000 0.250 * 0.000 5.200 0.520
1,2,3,7,8,9-HxCDD 0.1 0.260 * 0.000 0.280 * 0.000 1.200 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.260 * 0.000 0.330 * 0.000 11.000 0.110
OCDD 0.0001 0.920 * 0.000 2.200 * 0.000 34.000 0.003
Dibenzofuran
2,3,7,8-TCDF 0.1 0.200 * 0.000 0.280 * 0.000 1.800 0.180
1,2,3,7,8-PeCDF 0.05 0.280 * 0.000 0.250 * 0.000 0.740 * 0.000
2,3,4,7,8-PeCDF 0.5 0.250 * 0.000 0.220 * 0.000 0.180 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.071 * 0.000 0.089 * 0.000 0.880 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.056 * 0.000 0.070 * 0.000 0.820 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.280 * 0.000 0.230 * 0.000 0.620 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.076 * 0.000 0.095 * 0.000 0.036 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.045 * 0.000 0.075 * 0.000 1.400 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.065 * 0.000 0.110 * 0.000 0.290 * 0.000
OCDF 0.0001 0.110 * 0.000 0.430 * 0.000 0.430 * 0.000
Total TEQ 0.00 0.00 5.01
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) . !
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
I
I

ATTACHMENT III
Summary of CDD/F Isomer Analyses and Toxicity from the Equivalent Values
Values of Fish Tissue Composite Samples Pigeon River, August 1996. (cont.)
STATION 4B
COMPOSITE 1RF COMP. 2RF COMP. 3RF
BLACK CRAPPIE LARGEMOUTH BASS COMMON CARP
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.110 * 0.000 0.130 * 0.000 4.000 4.000
1 2,3,7,8-PeCDD 1.0 0.240 * 0.000 0_230 * 0.000 0.100 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.220 * 0.000 0.200 * 0.000 0.670 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.190 * 0.000 0.170 * 0.000 2.800 0.280
1,2,3,7,8,9-HxCDD 0.1 0.210- * 0.000 0.190 * 0.000 0.650 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.380 * 0.000 0.240 * 0.000 5.900 0.059
OCDD 0.0001 1.200 * 0.000 0.960 * 0.000 17.000 0.002
i
Dibenzofuran
I
2,3,7,8-TCDF 0.1 0.270 * 0.000 0.230 * 0.000 1.700 0.170
1,2,3,7,8-PeCDF 0.05 0.320 * 0.000 0.290 * 0.000 0.560 * 0.000
2,3,4,7,8-PeCDF 0.5 0.290 * 0.000 0.260 * 0.000 1.500 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.087 * 0.000 0.095 * 0.000 0.630 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.066 * 0.000 0.075 * 0.000 0.960 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.250 * 0.000 0.270 * 0.000 0.460 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.093 * 0.000 0.100 * 0.000 0.100 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.110 * 0.000 0.051 * 0.000 0.500 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.160 * 0.000 0.073 * 0.000 0.089 * 0.000
OCDF 0.0001 0.370 * 0.000 0.150 * 0.000 0.320 * 0.000
Total TEQ 0.00 0.00 4.51
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENT III
Summary of CDD/F isomer Analyses and Toxicity from the Equivalent Values
Values of Fish Tissue Composite Samples Pigeon River, August 1996. (cont.)
i
STATION 5
COMPOSITE 1RF COMP. 2RF COMP. 3RF
ROCK BASS SMALLMOUTH BASS S.M. BUFFALO
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
i
2,3,7,8-TCDD 1.0 0.077 * 0.000 0.120 * 0.000 0.120 * 0.000
1,2,3,7,8-PeCDD 1.0 0.170 * 0.000 0.240 * 0.000 0.230 * 0.000
1,2,3,4,7,8-HXCDD 0.1 0.140 * 0.000 0.160 * 0.000 0.190 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.140 * 0.000 0.160 * 0.000 0.190 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.140 * 0.000 0.160 * 0.000 0.200 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.160 * 0.000 0.180 * 0.000 0.330 * 0.000
OCDD 0.0001 0.960 * 0.000 2.000 * 0.000 2.400 * 0.000
I
Dibenzofuran
2,3,7,8-TCDF 0.1 0.120 * 0.000 0.370 * 0.000 0.700 0.070
1,2,3,7,8-PeCDF 0.05 0.180 * 0.000 0.200 * 0.000 0.065 * 0.000
2,3,4,7,8-PeCDF 0.5 0.150 * 0.000 0.170 * 0.000 0.120 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.130 * 0.000 0.051 * 0.000 0.160 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.110 * 0.000 0.043 * 0.000 0.130 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.260 * 0.000 0.300 * 0.000 0.240 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.140 * 0.000 0.057 * 0.000 0.180 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.140 * 0.000 0.039 * 0.000 0.046 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.200 * 0.000 0.057 * 0.000 0.067 * 0.000
OCDF 0.0001 0.220 * 0.000 0.200 * 0.000 0.520 * 0.000
Total TEQ 0.00 0.00 0.07
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
I

AN f,crfiai crcl�hr:I'm e.-In f IVI
1'997
Surrilirml Jrrrrrrraeary o,(,)f.-,, r, COOD/ F Issounraerr .Arknomilly
NIMBI

ATTACHMENT IV
I
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1997 PIGEON RIVER FISH TISSUE COMPOSITES.
STATION 1
REDBREAST SUNFISH - 1RF ROCK BASS - 2RF BLACK REDHORSE - 3RF
CDD/F ISOMERS TEF Results(a) TEQ(b) Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.11 * 0.000 0.23 * 0.000 0.22 * 0.000
1,2,3,7,8-PeCDD 1.0 0.26 * 0.000 0.56 * 0.000 0.38 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.38 * 0.000 1.00 * 0.000 0.75 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.34 * 0.000 0.94 * 0.000 0.68 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.34 * 0.000 0.94 * 0.000 0.68 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.41 * 0.000 1.20 * 0.000 0.59 * 0.000
OCDD 0.0001 0.56 * 0.000 1.60 * 0.000 0.9.9 * 0.000
Dibenzo£uxan
2,3,7,8-TCDF 0.1 0.14 * 0.000 0.24 * 0.000 0.17 * 0.000
1,2,3,7,8-PeCDF 0.05 0.22 * 0.000 0.75 * 0.000 0.40 * 0.000
2,3,4,7,8-PeCDF 0.5 0.23 * 0.000 0.79 * 0.000 0.42 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.63 * 0.000 0.56 * 0.000 0.71 * 0.000 .
1,2,3,6,7,8-HxCDF 0.1 0.62 * 0.000 0.56 * 0.000 0.70 * 0.000
2,3,4,6,7,8-1ixCDF 0-.1 0.67 * 0.000 0.60 * 0.000 0.76 * 0.000
1,2,.3,7,8,9-HxCDF 0.1 0.77 * 0.000 0.70 * 0.000 0.88 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.16 * 0.000 0.42 * 0.000 0.22 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.23 * 0.000 0.59 * 0.000 0.31 * 0.000
OCDF 0.0001 0.50 * 0.000 1.50 * 0.000 1.00 * 0.000
Total TEQ 0.00 0.00 0.00
I
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) . !
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
II
i

ATTACHMENT IV
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1997 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 2
REDBREAST SUNFISH - 1RF REDBREAST SUNFISH - 2RF COMMON CARP - 3RF
CDD/F ISOMERS TEF Results (a) - TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.26 * 0.000 0.12 * 0.000 1.40 1.400
1,2,3,7,8-PeCDD 1.0 0.33 * 0.000 0.25 * 0.000 0.74 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.53 * 0.000 0.52 * 0.000 0.83 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.48 * 0.000 0.48 * 0.000 1.80 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.48 * 0.000 0.48 * 0.000 0.76 * 0.000
1,2,3,4, 6,7,8-HpCDD 0.01 0.64 * 0.000 0.60 * 0.000 5.50 0.055
OCDD 0.0001 1.20 * 0.000 0.68 * 0.000 31.00 0.003
Dibenzofuran I
2,3,7,8-TCDF 0.1 0.11 * 0.000 0.10 * 0.000 0.98 * 0.000
1,2,3,7,8-PeCDF 0.05 0.33 * 0.000 0.20 * 0.000 0.38 * 0.000
2,3,4,7,8-PeCDF 0.5 0.35 * 0.000 0.21 * 0.000 0.64 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.31 * 0.000 0.38 * 0.000 1.40 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.30 * 0.000 0.37 * 0.000 1.40 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.33 * 0.000 0.40 * 0.000 1.50 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.38 * 0.000 0.47 * 0.000 1.80 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.21 * 0.000 0.13 * 0.000 1.00 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.29 * 0.000 0.18 * 0.000 1.40 * 0.000
OCDF 0.0001 1.30 * 0.000 0.62 * 0.000 1.30 * 0.000
I
Total TEQ 0.00 0.00 1.46
I
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) . s
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
I

ATTACHMENT IV
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1997 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 3
REDBREAST SUNFISH - 1RF REDBREAST SUNFISH - 2RF COMMON CARP - 3RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.18 * 0.000 0.18. * 0.000 0.33 * 0.000
1,2,3,7,8-PeCDD 1.0 0.35 * 0.000 0.23 * 0.000 0.40 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.29 * 0.000 0.32 * 0.000 0.34 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.26 * 0.000 0.29 * 0.000 0.59 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.26 * 0.000 0.29 * 0.000 0.31 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.49 * 0.000 0.62 * 0.000 1.60 * 0.000
OCDD , 0.0001 1.40 * 0.000 1.00 * 0.000 14.00 0.001
Dibenzo£uran
2,3,7,8-TCDF 0.1 0.18 * 0.000 0.21 * 0.000 0.42 * 0.000
1,2,3,7,8-PeCDF 0.05 0.24 * 0.000 0.21 * 0.000 0.39 * 0.000 I,
2,3,4,7,8-PeCDF 0.5 0.25 * 0.000 0.22 * 0.000 0.30 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.17 * 0.000 0.31 * 0.000 0.38 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.17 * 0.000 0.31 * 0.000 0.60 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.29 * 0.000 0.33 * 0.000 0.33 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.22 * 0.000 0.39 * 0.000 0.47 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.20 * 0.000 0.17 * 0.000 0.13 * 0.000
1,2,3,4,7,6,9-HpCDF 0.01 0.29 * 0.000 0.23 * 0.000 0.13 * 0.00
OCDF 0.0001 5.50 0.001 0.43 * 0.000 0.66 * 0.000
Total TEQ 0.00 0.00 0.00
(
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) . I
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
I

ATTACHMENT IV
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1997 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 4A
I
BLACK CRAPPIE 1RF BLACK CRAPPIE 2RF COMMON CARP - 3RF CHANNEL CAT. - 5RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,E-TCDD 1.0 0.27 * 0.000 0.10 * 0.000 2.30 2.300 2.00 2.000
1,2,3,7,8-Pe CDD 1.0 0.62 * 0.000 0.33 * 0.000 1.10 * 0.000 1.20 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.37 • 0.000 0.32 * 0.000 0.73 * 0.000 0.65 • 0.000
1,2,3,6,7,8-HxCDD 0.1 0.34 * 0.000 0.29 * 0.000 3.10 0.310 2.90 0.290
1,2,3,7,8,9-HxCDD 0.1 0.34 * 0.000 0.29 * 0.000 0.48 * 0.024 0.53 * 0.000
1,2,3,4,6,7,8-HpCDO 0.01 0.32 * 0.000 0.28 * 0.000 8.80 0.088 3.80 0.038
OCDD 0.0001 0.43 • 0.000 0.80 • 0.000 32.00 0.003 13.00 0.001
Dibenzofuran
2,3,7,8-TCDF 0.1 0.27 0.000 0.19 * 0.000 2.10 0.210 0.69 * 0.000
1,2,3,7,8-PeCDF 0.05 0.25 * 0.000 0.28 * 0.000 0.82 * 0.000 0.42 " 0.000
2,3,4,7,8-PeCDF 0.5 0.26 * 0.000 0.29 * 0.000 1.50 * 0.000 1.10 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.15 * 0.000 0.12 * 0.000 0.73 * 0.000 0.50 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.15 * 0.000 0.12 * 0.000 0.70 * 0.000 0.51 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.32 * 0.000 0.26 * 0.000 0.45 * 0.000 0.54 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.18 * 0.000 0.15 * 0.000 0.11 • 0.000 0.20 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.13 * 0.000 0.11 * 0.000 1.10 ' 0.000 0.74 • 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.18 * 0.000 0.16 * 0.000 0.19 * 0.000 0.21 * 0.000
OCDF 0.0001 0.71 * 0.000 0.71 * 0.000 0.50 0.000 0.68 • 0.000
Total TEQ 0.00 0.00 2.94 2.33
I
I
(a) Units = ppt (parts per trillion) or pg/g picogram per gram).
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989).
(c) Toxicity Equivalent Factors from van Leeuwen (1997).
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
i

ATTACHMENT IV
Ir
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1997 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 4B I
BLACK CRAPPIE - 1RF LARGEMOUTH BASS 2RF COMMON CARP - 3RF FLATHEAD CAT. - 5RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.17 * 0.000 0.21 * 0.000 11.00 11.000 0.62 0.620
1,2,3,7,8-PeCDD 1.0 0.39 * 0.000 0.32 * 0.000 1.80 * 0.000 0.45 • 0.000
1,2,3,4,7,8-HxCDD 0.1 0.75 * 0.000 0.42 + 0.000 1.20 * 0.000 0.34 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.70 * 0.000 0.38 * 0.000 4.90 0.490 1.30 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.66 • 0.000 0.38 * 0.000 0.65 * 0.000 0.14 • 0.000
1,2,3,4,6,7,8-Hp CDD 0.01 0.33 * 0.000 0.36 * 0.000 11.00 0.110 1.60 ` 0.000
OCDD 0.0001 0.45 + 0.000 0.65 * 0.000 27.00 0.003 2.40 * 0.000
Dibenzofuran ,
2,3,7,8-TCDF 0.1 0.43 • 0.000 0.30 * 0.000 2.00 0.200 0.31 * 0.000
1,2,3,7,8-PeCDF 0.05 0.37 * 0.000 0.21 • 0.000 O.B3 * 0.000 0.20 * 0.000
2,3,4,7,8-PeCDF 0.5 0.38 * 0.000 0.22 * 0.000 3.80 1.900 0.37 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.29 * 0.000 0.16 * 0.000 0.82 ` 0.000 0.12 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.30 * 0.000 0.16 * 0.000 2.60 • 0.000 0.64 * 0.000 r
2,3,4,6,7,8-HxCDF 0.1 0.31 * 0.000 0.25 + 0.000 0.91 * 0.000 0.32 • 0.000
1,2,3,7,8,9-HxCDF 0.1 0.34 • 0.000 0.20 • 0.000 0.24 • 0.000 0.21 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.09 ` 0.000 0.12 • 0.000 1.20 • 0.000 0.33 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.12 * 0.000 0.16 * 0.000 0.07 • 0.000 0.10 • 0.000
OCDF 0.0001 0.36 * 0.000 0.67 * 0.000 1.30 • 0.000 0.97 * 0.000
Total TEQ 0.00 0.00 13.70 0.62
(a) Units = ppt (parts per trillion) or pg/g picogram per gram).
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989).
(c) Toxicity Equivalent Factors from van Leeuwen (1997).
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
i
i

ATTACHMENT IV
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1997 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 5
I
ROCK BASS - 1RF SMALLMOUTH BASS - 2RF SM BUFFALO - 3RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.15 * 0.000 0.27 * 0.000 0.22 * 0.000
1,2,3,7,8-PeCDD 1.0 0.31 * 0.000 0.27 * 0.000 0.37 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.30 * 0.000 0.29 * 0.000 0.25 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.27 * 0.000 0.27 * 0.000 0.22 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.27 * 0.000 0.27 * 0.000 0.22 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.15 * 0.000 0.25 * 0.000 0.38 * 0.000
OCDD 0.0001 0.48 * 0.000 1.50 * 0.000 1.30 * 0.000
Dibenzo£uran
i
2,3,7,8-TCDF 0.1 0.25 * 0.000 0.44 * 0.000 0.64 * 0.000
1,2,3,7,8-PeCDF 0.05 0.22 * 0.000 0.15 * 0.000 0.42 * 0.000
2,3,4,7,8-PeCDF 0.5 0.23 * 0.000 0.16 * 0.000 0.44 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.15 * 0.000 0.16 * 0.000 0.19 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.15 * 0.000 0.15 * 0.000 0.18 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.33 * 0.000 0.32 * 0.000 0.27 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.19 * 0.000 0.19 * 0.000 0.23 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.08 * 0.000 0.10 * 0.000 0.15 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.10 * 0.000 0.14 * 0.000 0.20 * 0.000
OCDF 0.0001 0.23 * 0.000 0.58 * 0.000 0.87 * 0.000
Total TEQ 0.00 0.00 0.00
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

mad H;Aao� w
99 99d (81
slultr1ril mrrNffAlq ,ofr CDD/ F Issomna Amiratallyssi

ATTACHMENT V
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1998 PIGEON RIVER FISH TISSUE COMPOSITES.
STATION 1
REDBREAST SUNFISH - 1RF ROCK BASS - 2RF BLACK REDHORSE - 3RF
CDD/F ISOMERS TEF Results(a) TEQ(b) Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.19 * 0.000 0.29 * 0.000 0.18 * 0.000
1,2,3,7,8-PeCDD 1.0 0.44 * 0.000 0.64 * 0.000 0.52 + 0.000
•1,2,3,4,7,8-HxCDD 0.1 0.55 * 0.000 0.67 * 0.000 0.52 + 0.000
1,2,3,6,7,8-HxCDD 0.1 0.52 * 0.000 0.63 * 0.000 0.49 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.49 * 0.000 0.59 * 0.000 0.46 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.29 * 0.000 0.35 * 0.000 0.24 * 0.000
OCDD 0.0001 0.57 * 0.000 2.30 * 0.000 0.24 * 0.000
Dibenzo£uran
i
2,3,7,8-TCDF 0.1 0.14 * 0.000 0.18 * 0.000 0.64 0.064
1,2,3,7,8-PeCDF 0.05 0.17 * 0.000 0.16 * 0.000 0.49 * 0.000
2,3,4,7,8-PeCDF 0.5 0.17 * 0.000 0.15 * 0.000 0.46 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.17 * 0.000 0.17 * 0.000 0.22 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.17 * 0.000 0.16 * 0.000 0.22 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.19 * 0.000 0.19 * 0.000 0.25 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.19 * 0.000 0.19 * 0.000 0.25 * 0.000
1,2,3,4,6,7,8-HpCDF 0.,01 0.08 * 0.000 0.08 * 0.000 0.12 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.10 * 0.000 0.10 * 0.000 0.14 * 0.000
OCDF 0.0001 0.35 * 0.000 0.93 * 0.000 0.90 * 0.000
Total TEQ 0.00 0.00 0.06
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENT V -
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1998 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 2
REDBREAST SUNFISH - IRF REDBREAST SUNFISH - 2RF COMMON CARP - 3RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.20 * 0.000 0.28 * 0.000 1.30 1.300
1,2,3,7,8-PeCDD 1.0 0.25 * 0.000 0.30 * 0.000 1.70 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.46 * 0.000 0.28 * 0.000 0.92 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.41 * 0.000 0.24 * 0.000 3.90 0.390
1,2,3,7,8,9-HxCDD 0.1 0.39 * 0.000 0.23 * 0.000 0.82 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.84 * 0.000 1.50 * 0.000 9.50 0.095
OCDD 0.0001 1.60 * 0.000 2.80 * 0.000 36.00 0.004
Dibenzofuran
I
2,3,7,8-TCDF 0.1 0.14 * 0.000 0.17 * 0.000 2.60 0.260
1,2,3,7,8-PeCDF 0.05 0.24 * 0.000 0.28 * 0.000 0.49 * 0.000
2,3,4,7,8-PeCDF 0.5 0.25 * 0.000 0.29 * 0.000 0.94 0.000
1,2,3,4,7,8-HxCDF 0.1 0.21 * 0.000 0.14 * 0.000 0.70 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.21 * 0.000 0.14 * 0.000 0.88 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.22 * 0.000 0.14 * 0.000 0.19 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.24 * 0.000 0.16 * 0.000 0.19 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.09 * 0.000 0.06 * 0.000 0.47 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.11 * 0.000 0.07 * 0.000 0.13 * 0.000
OCDF 0.0001 0.26 * 0.000 0.19 * 0.000 0.26 * 0.000
i
Total TEQ 0.00 0.00 2.05
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
I��

ATTACHMENT V
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1998 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 3
REDBREAST SUNFISH - 1RF REDBREAST SUNFISH - 2RF COMMON CARP - 3RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.34 * 0.000 0.22 * 0.000 0.38 * 0.000
1,2,3,7,8-PeCDD 1.0 1.30 * 0.000 0.50 * 0.000 0.39 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.98 * 0.000 0.75 * 0.000 0.51 * 0.000
1,2,3, 6,7,8-HxCDD 0.1 0.93 * 0.000 0.70 * 0.000 0.45 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.87 * 0.000 0.66 * 0.000 0.43 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 1.20 * 0.000 0.60 * 0.000 1.40 * 0.000
OCDD 0.0001 5.10 0.001 1.20 * 0.000 9.00 0.001
Dibenzo£uran
2,3,7,8-TCDF 0.1 0.28 * 0.000 0.21 * 0.000 0.47 * 0.000
1,2,3,7,8-PeCDF 0.05 0.27 * 0.000 0.22 * 0.000 0.30 * 0.000
2,3,4,7,8-PeCDF 0.5 0.26 * 0.000 0.21 * 0.000 0.31 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.43 * 0.000 0.16 * 0.000 0.27 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.42 * 0.000 0.16 * 0.000 0.54 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.48 * 0.000 0.18 * 0.000 0.28 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.49 * 0.000 0.19 * 0.000 0.31 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.19 * 0.000 0.07 * 0.000 0.32 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.23 * 0.000 0.09 * 0.000 0.29 * 0.000
OCDF 0.0001 2.50 * 0.000 0.29 * 0.000 0.23 * 0.000
Total TEQ 0.00 0.00 0.00
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENT V "
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1998 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
i
STATION 4A
BLACK CRAPPIE 1RF LARGEMOUTH BASS - 2RF .COMMON CARP - 3RF CHANNEL CAT. - 5RF
CDD/F ISOMERS TEF Results (a) TEO Results TEQ Results TEO Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.49 • 0.000 0.15 * 0.000 1.60 1.600 0.28 * 0.000
1,2,3,7,8-PeCDD 1.0 0.47 * 0.000 0.25 * 0.000 1.30 + 0.000 0.36 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.35 * 0.000 0.19 * 0.000 0.86 • 0.000 0.49 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.59 * 0.000 0.17 * 0.000 3.90 0.390 0.43 ' 0.000
1,2,3,7,8,9-HxCDD 0.1 0.30 • 0.000 0.16 * 0.000 0.75 * 0.000 0.41 • 0.000
1,2,3,4,6,7,8-HpCDD 0.01 1.20 * 0.000 0.51 ' 0.000 14.00 0.140 0.65 * 0.000
OCDD 0.0001 1.90 * 0.000 1.30 • 0.000 63.00 0.006 0.93 * 0.000
Dibencofuran
2,3,7,8-TCDF 0.1 0.24 • 0.000 0.19 0.000 1.80 0.180 0.18 • 0.000
1,2,3,7,8-PeCDF 0.05 0.06 ' 0.000 0.08 ' 0.000 0.99 + 0.000 0.15 . 0.000
2,3,4,7,8-PeCDF 0.5 0.24 * 0.000 0.08 * 0.000 1.30 ' 0.000 0.16 0.000
1,2,3,4,7,8-HxCDF 0.1 0.37 * 0.000 0.10 * 0.000 0.68 ' 0.000 0.37 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.36 * 0.000 0.10 0.000 1.90 * 0.000 0.36 * 0.000
2,3,4,6,7,E-HxCDF 0.1 0.38 ' 0.000 0.10 ' 0.000 0.28 + 0.000 0.38 * 0.000
1,2,3;7,8,9-HxCDF 0.1 0.43 * 0.000 0.12 • 0.000 0.11 * 0.000 0.42 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.22 ' 0.000 0.06 • 0.000 1.60 • 0.000 0.13 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.10 ' 0.000 0.08 * 0.000 0.10 • 0.000 0.16 * 0.000
OCDF 0.0001 0.18 ' 0.000 0.18 * 0.000 0.26 • 0.000 0.25 • 0.000
Total TEO 0.00 0.00 2.32 0.00
(a) Units - ppt (parts per trillion) or pg/g picogram per gram).
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989).
(c) Toxicity Equivalent Factors from van Leeuwen (1997). -
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEO calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENT V
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1998 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
' STATION 9B
1
BLACK CRAPPIE - 1RF LARGEMOUTH BASS - 2RF FLATHEAD CAT. - 3RF COMMON CARP - 4RF
CDD/F ISOMERS TEF Results (a) TEO Results TEO Results TEQ Results TEO
Dibenzodioxin
f
2,3,7,8-TCDD 1.0 0.15 * 0.000 0.17 * 0.000 0.20 * 0.000 9.10 9.100
1,2,3,7,8-PeCDD 1.0 0.16 * 0.000 0.18 * 0.000 0.35 * 0.000 2.00 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.18 * 0.000 0.12 * 0.000 0.38 * 0.000 1.30 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.16 * 0.000 0.11 * 0.000 0.33 * 0.000 5.20 0.520
1,2,3,7,8,9-HxCDD 0.1 0.15 * 0.000 0.10 * 0.000 0.32 * 0.000 0.78 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 1.50 * 0.000 0.47 * 0.000 0.34 * 0.000 12.00 0.120
OCDD 0.0001 5.30 0.001 1.40 * 0.000 1.80 * 0.000 46.00 0.005
Dibenzofuran
2,3,7,8-TCDF 0.1 0.21 * 0.000 0.19 * 0.000 0.34 * 0,000 3.30 0.330
1,2,3,7,8-PeCDF 0.05 0.09 * 0.000 0.07 * 0.000 0..14 * 0.000 0.99 * 0.000
2,3,4,7,8-PeCDF 0.5 0.09 * 0.000 0.07 * 0.000 0.15 * 0.000 3.20 1.600
1,2,3,4,7,8-HxCDF 0.1 0.06 * 0.000 0.05 * 0.000 0.29 * 0.000 1.00 * 0.000 {
1,2,3,6,7,8-HxCDF 0.1 0.06 * 0.000 0.05 * 0.000 0.28 * 0.000 1.00 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.06 * 0.000 0.05 * 0.000 0.30 * 0.000 0.32 * 0.000 {
1,2,3,7,8,9-HxCDF 0.1 0.07 * 0.000 0.06 * 0.000 0.33 * 0.000 0.22 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.06 * 0.000 0.05 * 0.000 0.16 * 0.000 1.20 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.08 * 0.000 0.07 * 0.000 0.11 * 0.000 0.07 * 0.000
OCDF 0.0001 0.15 * 0.000 0.13 * 0.000 0.26 * 0.000 1.20. * 0.000
Total TEO 0.00 0.00 0.00 11.67
(a) Units = ppt (parts per trillion) or pg/g picogram per gram).
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989).
(c) Toxicity Equivalent Factors from van Leeuwen (1997).
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEO calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
I
I
I

ATTACHMENT V
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1998 PIGEON RIVER FISH TISSUE COMPOSITES. (coast.)
STATION 5 j
SMALLMOUTH BUFF. - 2RF ROCK BASS - 3RF SM. BASS - 4RF
CDD/F ISOMERS TEF Results TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.31 * 0.000 0.11 * 0.000 0.21 * 0.000
1,2,3,7,8-PeCDD 1.0 0.42 * 0.000 0.26 * 0.000 0.46 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.26 * 0.000 0.12 * 0.000 0.41 * 0.000
1,2,3, 6,7,8-HxCDD 0.1 0.91 * 0.000 0.11 * 0.000 0.36 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.24 * 0.000 0.10 * 0.000 0.34 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 1.10 * 0.000 0.14 * 0.000 0.47 * 0.000
OCDD 0.0001 3.50 * 0.000 1.30 * 0.000 2.80 * 0.000
Dibenzofuran
2,3,7,8-TCDF 0.1 0.14 * 0.000 0.13 * 0.000 0.24 0.024
1,2,3,7,8-PeCDF 0.05 0.28 * 0.000 0.19 * 0.000 0.19 * 0.000
2,3,4,7,8-PeCDF 0.5 0.29 + 0.000 0.20 + 0.000 0.20 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.51 + 0.000 0.09 * 0.000 0.19 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.50 * 0.000 0.09 * 0.000 0.19 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.52 * 0.000 0.09 * 0.000 0.20 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.59 * 0.000 0.10 * 0.000 0.22 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.17 * 0.000 0.05 * 0.000 0.12 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.16 * 0.000 0.07 * 0.000 0.15 * 0.000
OCDF 0.0001 0.20 * 0.000 0.16 * 0.000 0.34 * 0.000
Total TEQ 0.00 0.00 0.02
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

nriot
®r
of %MD/ F I ssion rr .A ra 6rsulill I 1 81
Ir
ul fn m y

ATTACHMENT VI
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1999 PIGEON RIVER FISH TISSUE COMPOSITES.
STATION 1
REDBREAST SUNFISH - 1RF ROCK BASS - 2RF BLACK REDHORSE- 3RF
CDD/F ISOMERS . TEF Results(a) TEQ(b) Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.21 * 0.000 0.37 * 0.000 0.33 * 0.000
1,2,3,7,8-PeCDD 1.0 1.50 * 0.000 0.94 * 0.000 0.54 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.36 * 0.000 0.91 * 0.000 0.48 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.42 * 0.000 1.00 * 0.000 0.48 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.37 * 0.000 1.10 * 0.000 0.51 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.60 * 0.000 L 20 * 0.000 1.40 * 0.000
OCDD 0.0001 1.10 * 0.000 7.90 0.00 6.30 0.00
Dibenzofuran
2,3,7,8-TCDF 0.1 0.17 * 0.000 0.31 * 0.000 0.30 * 0.000
1,2,3,7,8-PeCDF 0.05 0.40 * 0.000 0.74 * 0.000 0.34 * 0.000
2,3,4,7,8-PeCDF 0.5 0.37 * 0.000 0.76 * 0.000 0.38 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.27 * 0.000 1.20 * 0.000 0.53 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.26 * 0.000 0.76 * 0.000 0.55 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.28 * 0.000 0.76 * 0.000 0.50 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.31 * 0.000 0.65 * 0.000 0.68 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.32 * 0.000 1.20 * 0.000 0.56 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.33 * 0.000 0.53 * 0.000 0.28 * 0.000
OCDF 0.0001 0.55 * 0.000 3.30 * 0.000 2.00 * 0.000
Total TEQ 0.00 0.00 0.00
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENT VI
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1999 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 2
REDBREAST SUNFISH - 1RF REDBREAST SUNFISH - 2RF COMMON CARP - 3RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioain
2,3,7,E-TCDD 1.0 0.37 * 0.000 0.29 * 0.000 0.27 * 0.000
1,2,3,7,8-PeCDD 1.0 1.30 * 0.000 2.30 * 0.000 1.10 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.66 * 0.000 0.43 * 0.000 0.99 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.55 * 0.000 0.36 * 0.000 1.70 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.56 * 0.000 0.37 * 0.000 0.84 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 2.40 * 0.000 2.00 * 0.000 18.00 0.180
OCDD 0.0001 5.20 0.001 5.00 * 0.000 170.00 0.017
Dibenzofusan
2,3,7,8-TCDF 0.1 0.40 * 0.000 0.39 * 0.000 0.36 * 0.000
1,2,3,7,8-PeCDF 0.05 1.10 * 0.000 0.64 * 0.000 1.30 * 0.000
2,3,4,7,8-PeCDF 0.5 1.10 * 0.000 0.64 * 0.000 1.30 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.82 * 0.000 0.38 * 0.000 0.70 * 0.000
1,2,3, 6,7,8-HxCDF 0.1 0.61 * 0.000 0.29 * 0.000 0.52 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.75 * 0.000 0.35 * 0.000 0.64 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.88 * 0.000 0.41 * 0.000 0.75 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.19 * 0.000 0.13 * 0.000 0.34 * 0.000
1,2,3,4,7,8, 9-HpCDF 0.01 0.29 * 0.000 0.21 * 0.006 0.20 * 0.000
OCDF 0.0001 1.20 * 0.000 0.63 * 0.000 0.68 * 0.000
Total TEQ 0.00 0.00 0.20
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENT VI
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1999 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 3
REDBREAST SUNFISH - 1RF REDBREAST SUNFISH - 2RF COMMON CARP - 3RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.36 * 0.000 0.37 * 0.000 0.57 0.570
1,2,3,7,8-PeCDD 1.0 0.86 * 0.000 1.20 * 0.000 0.78 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.44 * 0.000 0.33 * 0.000 0.89 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.39 * 0.000 0.57 * 0.000 2.80 0.280
1,2,3,7,8,9-HxCDD 0.1 0.40 * 0.000 0.55 * 0.000 0.89 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 2.10 * 0.000 2.40 * 0.000 13.00 0.130
OCDD 0.0001 7.20 0.001 7.70 0.001 72.00 0.007
Dibmzo£uran
2,3,7,8-TCDF 0.1 0.32 * 0.000 0.21 * 0.000 1.10 0.110
1,2,3,7,8-PeCDF 0.05 0.32 * 0.000 0.33 * 0.000 0.61 * 0.000
2,3,4,7,8-PeCDF 0.5 0.36 * 0.000 0.37 * 0.000 0.87 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.31 * 0.000 0.46 * 0.000 0.98 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.30 * 0.000 0.52 * 0.000 1.10 * 0.000
2,3,4, 6,7,8-HxCDF 0.1 0.31 * 0.000 0.30 * 0.000 0.44 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.21 * 0.000 0.24 * 0.000 0.39 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.72 * 0.000 0.65 * 0.000 0.97 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.25 * 0.000 0.36 * 0.000 0.27 * 0.000
OCDF 0.0001 2.20 * 0.000 2.60 * 0.000 2.30 * 0.000
Total TEQ 0.00 0.00 1.10
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005. I
I

i
ATTACHMENT VI
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1999 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 4A
BLACK CRAPPIE - 1RF BLACK CRAPPIE - 2RF COMMON CARP - 3RF CHANNEL CAT.- SRF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ Results TEQ
Dibensodioxin
2,3,7,8-TCDD 1.0 0.18 * 0.000 0.08 * 0.000 0.58 0,580 0.83 0.830
1,2,3,7,8-PeCDD 1.0 0.25 * 0.000 0.48 * 0.000 0.72 * 0.000 1.10 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.21 * 0.000 0.21 * 0.000 0.55 * 0.000 0.88 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.23 * 0.000 0.24 * 0.000 2.30 * 0.000 1.40 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.19 * 0.000 0.19 * 0.000 0.47 * 0.000 0.49 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 1.20 * 0.000 0.98 * 0.000 14.00 0.140 2.40 * 0.000
OCDD 0.0001 1.10 * 0.000 1.20 * 0.000 70.00 0.007 8.20 0.001
Dibenzo£uran
2,3,7,8-TCDF 0.1 0.13 * 0.000 0.13 * 0.000 1.90 0.190 0.20 * 0.000
1,2,3,7,8-PeCDF 0.05 0.38 * 0.000 0.32 * 0.000 0.98 * 0.000 0.69 * 0.000
2,3,4,7,8-PeCDF 0.5 0.39 * 0.000 0.33 * 0.000 0.57 * 0.000 0.56 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.25 * 0.000 0.31 * 0.000 0.43 * 0.000 0.38 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.22 * 0.000 0.28 * 0.000 1.90 * 0.000 1.10 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.26 * 0.000 0.33 * 0.000 0.04 * 0.000 0.40 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.25 * 0.000 0.31 * 0.000 0.03 * 0.000 0.38 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.06 * 0.000 0.08 * 0.000 0.63 * 0.000 0.28 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.07 * 0.000 0.09 * 0.000 0.02 * 0.000 0.17 * 0.000
OCDF 0.0001 0.15 * 0.000 0.16 * 0.000 0.14 * 0.000 0.16 * 0.000
Total TEQ 0.00 0.00 0:92 0.93
(a) Units = ppt (parts per trillion) or pg/g picogram per gram).
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989).
(c) Toxicity Equivalent Factors from van Leecuwen (1997).
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENT VI
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1999 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 4B
BLACK CRAPPIE - 1RF LARGEMOUTH BASS - 2RF FLATHEAD CAT. - 3RF COMMON CARP - 4RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.27 * 0.000 0.32 * 0.000 0.46 * 0.000 4.70 4.700
1,2,3,7,8-PeCDD 1.0 1.20 * 0.000 1.20 * 0.000 1.30 * 0.000 2.10 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.59 * 0.000 0.65 * 0.000 0.59 * 0.000 0.99 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.49 * 0.000 0.54 * 0.000 0.49 * 0.000 5.20 0.520
1,2,3,7,B,9-HxCDD 0.1 0.50 * 0.000 0.55 * 0.000 0.50 * 0.000 1.20 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 1.10 * 0.000 1.30 * 0.000 0.83 * 0.000 14.00 0.140
OCDD 0.0001 1.90 * 0.000 1.40 * 0.000 1.40 * 0.000 51.00 0.005
Dibenzofuran
2,3,7,8-TCDF 0.1 0.28 * 0.000 0.31 * 0.000 0.15 * 0.000 2.40 0.240
1,2,3,7,8-PeCDF 0.05 0.39 * 0.000 1.20 * 0.000 1.30 * 0.000 1.50 * 0.000
2,3,4,7,8-PeCDF 0.5 0.39 * 0.000 1.20 * 0.000 1.30 * 0.000 1.80 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.19 * 0.000 0.41 * 0.000 0.25 * 0.000 0.67 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.14 * 0.000 0.30 * 0.000 0.18 * 0.000 0.60 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.17 * 0.000 0.37 * 0.000 0.23 * 0.000 1.20 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.20 * 0.000 _ 0.44 * 0.000 0.26 * 0.000 1.50 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.14 * 0.000 0.44 * 0.000 0.69 * 0.000 1.30 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.22 * 0.000 0.69 * 0.000 1.10 * 0.000 0.32 * 0.000
OCDF 0.0001 1.10 * 0.000 0.84 * 0.000 0.48 * 0.000 0.95 * 0.000
Total TEQ 0.00 0.00 0.00 5.61
(a) Units = ppt (parts per trillion) or pg/g picogram per gram).
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989).
(c) Toxicity Equivalent Factors from van Leeuwen (1997).
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
i
i

ATTACHMENT VI
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 1999 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 5
SMALLMOUTH BUFF. - 2RF ROCK BASS - 3RF SM. BASS - 4RF
CDD/F ISOMERS TEF Results TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.31 * 0.000 0.29 * 0.000 0.19 * 0.000
1,2,3,7,8-PeCDD 1.0 1.10 * 0.000 1.40 * 0.000 0.34 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.36 * 0.000 0.59 * 0.000 0.23 * 0.000
1,2,3, 6,7,8-HxCDD 0.1 0.32 * 0.000 0.52 * 0.000 0.19 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.32 * 0.000 0.51 * 0.000 0.26 * 0.000
1,2,3,4, 6,7,8-HpCDD 0.01 0.93 * 0.000 1.80 * 0.000 1.00 * 0.000
OCDD 0.0001 3.90 * 0.000 7.40 0.001 11.00 0.001
Dibenzofuran
2,3,7,8-TCDF 0.1 0.88 0.088 0.28 * 0.000 0.38 * 0.000
1,2,3,7,8-PeCDF 0.05 0.67 * 0.000 0.64 * 0.000 0.26 * 0.000
2,3,4,7,8-PeCDF 0.5 0.65 * 0.000 0.62 * 0.000 0.24 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.24 * 0.000 0.86 * 0.000 0.15 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.21 * 0.000 0.75 * 0.000 0.06 * 0.000
2,3,4, 6,7,8-HxCDF 0.1 0.23 * 0.000 0.85• * 0.000 0.11 * 0.000
1,2,3,7,8, 9-HxCDF 0.1 0.26 * 0.000 0.96 * 0.000 0.22 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 1.20 * 0.000 0.69 * 0.000 0.18 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 1.50 * 0.000 0.29 * 0.000 0.15 * 0.000
OCDF 0.0001 0.61 * 0.000 2.30 * 0.000 3.00 * 0.000
Total TEQ 0.09 0.00 0.00
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

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ATTACHMENT VII '
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY I
EQUIVALENT VALUES FOR THE 2000 PIGEON RIVER FISH TISSUE COMPOSITES.
STATION 1
REDBREAST SUNFISH - 1RF ROCK BASS - 2RF BLACK REDHORSE- 3RF
CDD/F ISOMERS TEF(c) Results(a) TEQ(b) Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.48 * 0.000 0.45 * 0.000 0.38 * 0.000
1,2,3,7,8-PeCDD 1.0 0.54 * 0.000 0.74 * 0.000 0.57 * 0.000
1,2,3,4,7,8-HXCDD 0.1 0.48 * 0.000 0.58 * 0.000 0.50 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.39 * 0.000 0.47 * 0.000 0.41 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.40 * 0.000 0.47 * 0.000 0.41 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.31 * 0.000 0.41 * 0.000 0.26 * 0.000
OCDD 0.0001 0.65 * 0.000 0.82 * 0.000 0.64 * 0.000
Dibenzofuran
2,3,7,8-TCDF 0.1 0.24 * 0.000 0.32 * 0.000 0.47 * 0.000
1,2,3,7,8-PeCDF 0.05 0.29 * 0.000 0.40 * 0.000 0.35 * 0.000
2,3,4,7,8-PeCDF 0.5 0.28 * 0.000 0.38 * 0.000 0.33 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.39 * 0.000 0.44 * 0.000 0.36 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.32 * 0.000 0.36 * 0.000 0.29 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.38 * 0.000 0.42 * 0.000 0.34 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.44 * 0.000 0.50 * 0.000 0.40 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.15 * 0.000 0.18 * 0.000 0.14 * 0.000
1,2.,3,4,7,8,9-HpCDF 0.01 0.20 * 0.000 0.23 * 0.000 0.18 * 0.000
OCDF 0.0001 0.59 * 0.000 0.73 * 0.000 0.57 * 0.000
Total TEQ 0.00 0.00 0.00
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

G .
ATTACHMENT VII
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 2000 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 2
REDBREAST SUNFISH - 1RF REDBREAST SUNFISH - 2RF COMMON CARP - 3RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
213,7,8-TCDD 1.0 0.31 * 0.000 0.43 * 0.000 0.42 * 0.000
1,2,3,7,8-PeCDD 1.0 0.76 * 0.000 0.66 * 0.000 0.61 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.69 * 0.000 0.49 * 0.000 0.53 * 0.000
1,2,3, 6,7,8-HxCDD 0.1 0.57 * 0.000 0.40 * 0.000 2.50 0.250
112,3,7,8,9-HxCDD 0.1 0.57 * 0.000 0.41 * 0.000 0.59 * 0.000
1,2,3,4,6,7,8-HxCDD 0.01 1.10 * 0.000 0.61 * 0.000 14.00 0.140
OCDD 0.0001 0.92 * 0.000 1.50 * 0.000 92.00 0.009
Dibenzo£uran
2,3,7,8-TCDF 0.1 0.27 * 0.000 0.27 * 0.000 0.35 * 0.000
1,2,3,7,8-PeCDF 0.05 0.47 * 0.000 0.42 * 0.000 0.46 * 0.000
2,3,4,7,8-PeCDF 0.5 0.45 * 0.000 0.40 * 0.000 0.44 * 0.000
112,3,4,7,8-HxCDF 0.1 0.61 * 0.000 0.39 * 0.000 0.57 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.49 * 0.000 0.31 * 0.000 0.46 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.59 * 0.000 0.37 * 0.000 0.55 * 0.000
112,3,7,8,9-HxCDF 0.1 0.69 * 0.000 0.44 * 0.000 0.64 * 0.000
1,2,3,4, 6,7,8-HpCDF 0.01 0.26 * 0.000 0.19 * 0.000 0.65 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.33 * 0.000 0.24 * 0.000 0.26 * 0.000
OCDF 0.0001 1.20 * 0.00 0.72 * 0.00 0.79 * 0.00
0.0001 Total TEQ 0.00 0.00 0.40
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
I

� o
ATTACHMENT VII
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 2000 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 3
REDBREAST SUNFISH - 1RF REDBREAST SUNFISH - 2RF COMMON CARP - 3RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ
Dibenzodioxin
213,7,8-TCDD 1.0 0.43 * 0.000 0.32 * 0.000 0.53 * 0.000
1,2,3,7,8-PeCDD 1.0 0.63 * 0.000 0.46 * 0.000 0.52 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.55 * 0.000 0.38 * 0.000 0.42 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.45 * 0.000 0.31 * 0.000 0.95 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.46 * 0.000 0.32 * 0.000 0.35 * 0.000
1,2,3,4, 6,7,8-HpCDD 0.01 1.60 * 0.000 0.65 * 0.000 4.40 0.044
OCDD 0.0001 7.30 0.001 1.50 * 0.000 21.00 0.002
Dibenzofuran
2,3,7,8-TCDF 0.1 0.43 * 0.000 0.39 * 0.000 0.57 * 0.000
1,2,3,7,8-PeCDF 0.05 0.31 * 0.000 0.28 * 0.000 0.32 * 0.000
2,3,4,7,8-PeCDF 0.5 0.30 * 0.000 0.27 * 0.000 0.44 * 0.000
112,3,4,7,8-HxCDF 0.1 0.43 * 0.000 0.29 * 0.000 0.31 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.35 * 0.000 0.23 * 0.000 0.25 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.41 * 0.000 0.28 * 0.000 0.29 * 0.000
112,3,7,8,9-HxCDF 0.1 0.48 * 0.000 0.32 * 0.000 0.34 * 0.000
112,3,4,6,7,8-HpCDF 0.01 0.20 * 0.000 0.16 * 0.000 0.23 * 0.000
112,3,4,7,8, 9-HpCDF 0.01 0.26 * 0.000 0.21 * 0.000 0.18 * 0.000
OCDF 0.0001 0.62 * 0.000 0.49 * 0.000 0.48 * 0.000
Total TEQ 0.00 0.00 0.05
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.
it
I

i
ATTACHMENT VII "
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 2000 PIGEON RIVER FISH TISSUE COMPOSITES. (cont.)
STATION 4A
BLACK CRAPPIE - 1RF BLACK CRAPPIE - 2RF CHANNEL CAT. - 3RF COMMON CARP - 4RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.29 * 0.000 0.24 * 0.000 0.70 0.700 1.10 1.100
1,2,3,7,8-PeCDD 1.0 0.54 * 0.000 0.45 * 0.000 0.71 * 0.000 1.70 * 0.000
1,2,3,4,7;8-HxCDD 0.1 0.52 * 0.000 0.40 * 0.000 0.43 * 0.000 1.40 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.43 * 0.000 0.33 * 0.000 1.50 * 0.000 5.70 0.570
1,2,3,7,8,9-HxCDD 0.1 0.43 * 0.000 0.33 * 0.000 0.35 * 0.000 0.97 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.36 * 0.000 0.69 * 0.000 1.80 * 0.000 19.00 0.190
OCDD 0.0001 0.93 * 0.000 1.60 * 0.000 7.00 0.001 47.00 0.005
Dibenzofuran
2,3,7,8-TCDF 0.1 0.34 * 0.000 0.32 * 0.000 0.48 * 0.000 1.40 0.140
1,2,3,7,8-PeCDF 0.05 0.34 * 0.000 0.27 * 0.000 0.29 * 0.000 1.10 * 0.000
2,3,4,7,8-PeCDF 0.5 0.33 * 0.000 0.27 * 0.000 0.37 * 0.000 1.50 * 0.000
1,2,3,4,7,E-HxCDF 0.1 0.37 * 0.000 0.27 * 0.000 0.42 * 0.000 1.10 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.30 * 0.000 0.22 * 0.000 0.34 * 0.000 1.40 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.36 * 0.000 0.26 * 0.000 0.41 * 0.000 0.55 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.42 * 0.000 0.30 * 0.000 0.47 * 0.000 0.64 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.17 * 0.000 0.13 * 0.000 0.33 * 0.000 1.70 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.21 * 0.000 0.17 * 0.000 0.06 * 0.000 0.48 * 0.000
OCDF 0.0001 0.50 * 0.000 0.49 * 0.000 0.55 * 0.000 0.68 * 0.000
Total TEQ 0.00 0.00 0.70 2.00
(a) Units - ppt (parts per trillion) or pg/g picogram per gram).
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989).
(c) Toxicity Equivalent Factors from van Leeuwen (1997) . -
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENTVII
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 2000 PIGEON RIVER FISH TISSUE COMPOSITES. (cost.)
STATION 4B
BLACK CRAPPIE - 1RF BLACK CRAPPIE. - 2RF FLATHEAD CAT. - 3RF COMMON CARP - 4RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ Results TEQ
Dibenaodioxin
2,3,7,8-TCDD 1.0 0.41 * 0.000 0.37 * 0.000 0.42 * 0.000 4.40 4.400
1,2,3,7,8-PeCDD 1.0 0.69 * 0.000 0.52 * 0.000 0.52 * 0.000 2.00 * 0.000
1,2,3,4,7,8-H..KCDD 0.1 0.55 * 0.000 0.50 * 0.000 0.44 * 0.000 2.20 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.45 * 0.000 0.41 * 0.000 0.40 * 0.000 8.80 0.880
1,2,3,7,8,9-HxCDD 0.1 0.45 * 0.000 0.41 * 0.000 0.36 * 0.000 1.20 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 1.10 * 0.000 0.94 * 0.000 0.90 * 0.000 32.00 0.320
OCDD 0.0001 1.20 * 0.000 0.64 * 0.000 2.00 * 0.000 120.00 0.012
Dibenzofuran
2,3,7,8-TCDF 0.1 0.40 * 0.000 0.48 * 0.000 0.27 * 0.000 4.20 0.420
1,2,3,7,8-PeCDF 0.05 0.38 * 0.000 0.34 * 0.000 0.32 * 0.000 1.90 * 0.000
2,3,4,7,8-PeCDF 0.5 0.37 * 0.000 0.33 * 0.000 0.31 * 0.000 2.80 1.400
1,2,3,4,7,8-HxCDF 0.1 0.44 * 0.000 0.37 * 0.000 0.33 * 0.000 1.90 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.35 * 0.000 0.30 * 0.000 0.26 * 0.000 2.70 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.42 * 0.000 0.36 * 0.000 0.31 * 0.000 0.53 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.49 * 0.000 0.42 * 0.000 0.36 * 0.000 0.59 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.18 * 0.000 0.17 * 0.000 0.19 * 0.000 2.30 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.23 * 0.000 0.22 * 0.000 0.24 * 0.000 0.76 * 0.000
OCDF 0.0001 0.67 * 0.000 0.72 * 0.000 0.59 * 0.000 0.57 * 0.000
Total TEQ 0.00 0.00 0.00 7.43
(a) Units = ppt (parts per trillion) or pg/g picogram per gram).
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989).
(c) Toxicity Equivalent Factors from van Leeuwen (1997).
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005.

ATTACHMENT VII
SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY
EQUIVALENT VALUES FOR THE 2000 PIGEON RIVER FISH TISSUE COMPOSITES. (cont. )
STATION 5
ROCK BASS - 1RF SMALLMOUTH BASS - 2RF BLACK REDHORSE- 3RF
CDD/F ISOMERS TEF Results (a) TEQ Results TEQ Results TEQ j
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.45 * 0.000 0.31 * 0.000 0.35 * 0.000
1,2,3,7,8-PeCDD 1.0 0.68 * 0.000 0.49 * 0.000 0.57 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.58 * 0.000 0.46 * 0.000 0.42 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.47 * 0.000 0.37 * 0.000 0.35 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.47 * 0.000 0.38 * 0.000 0.35 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.37 * 0.000 0.56 * 0.000 0.44 * 0.000
OCDD 0.0001 1.40 * 0.000 1.50 * 0.000 1.60 * 0.000
Dibenzofuran
2,3,7,8-TCDF 0.1 0.50 * 0.000 0.23 * 0.000 1.20 0.120
1,2,3,7,8-PeCDF 0.05 0.40 * 0.000 0.32 * 0.000 0.33 * 0.000
2,3,4,7,8-PeCDF 0.5 0.38 * 0.000 0.31 * 0.000 0.32 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.40 * 0.000 0.35 * 0.000 0.34 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.32 * 0.000 0.28 * 0.000 0.28 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.38 * 0.000 0.34 * 0.000 0.33 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.44 * 0.000 0.40 * 0.000 0.38 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.17 * 0.000 0.13 * 0.000 0.14 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.22 * 0.000 0.16 * 0.000 0.18 * 0.000
OCDF 0.0001 0.70 * 0.000 0.51 * 0.000 0.47 * 0.000
Total TEQ 0.00 0.00 0.12
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from van Leeuwen (1997) .
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.
Note: 0.000 denotes values less than or equal to 0.0005. j
i
I'

_. iwcneei� cesey
Governor
r i` t William G. Ross.Jr Secretary
7 — Department of Environment and Natural Resources
j O "" �-,,- Kerr T. Stevens
7 Division of Water Quality
MEMORANDUM i
To: Jimmie Overton
Forrest Westall J 4 20 J
ll k
Through: Trish MacPherson -
WATER QUALITY SECTION
From: Bryn H. Tracy 04Vv _ SHEVI L REGIONAL OFFICE
Subject: Comments on the NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc., Canton Mill,
Balanced and Indigenous Species Study for the Pigeon River
I have reviewed this study and my comments are provided herein:
1. This study was required by NPDES permit, but the work was not performed by a NCDWO-certified laboratory.
2. In a letter from Ms. Coleen Sullins to Mr. Robert Williams (Blue Ridge Paper Products, Inc, (BRP)), it was specifically
stated: "Task 1 --It is important to select species for modeling, which are native to the Pigeon River basin." And in an
e-mail from me to Keith Haynes (dated March 17, 2000), 1 specifically requested: "Task 1 -- Species chosen for study
should be those native species currently inhabiting the Pigeon River orspecies that were known or suspected to have
occurred in the river prior to mill operation but no longer occur in the river due to mill operation. The importance of
modeling species native to the French Broad River and Pigeon River basins can not be over emphasized." Two of
the species (common carp and redbreast sunfish) which were modeled are not native to the basin and should not
have been modeled. Other species, such as the river chub, mottled sculpin, and banded sculpin should have been.
NC DWO was not given the opportunity to comment on the species chosen for modeling.
3. In the same letter and e-mail, it was stated: "It is our findings that there are currently no nuisance species in the river.
And, . . ."to my knowledge, there are no commercially important or nuisance species in the river. Common carp
should not be modeled as a nuisance species. Consultant should define nuisance species". The consultant never
defined nuisance species prior to the study and common carp should not have been modeled as a representative
important species. My use of the word: "nuisance" was based upon their study plan,where they stated: ". . . and
one species that has the potential to become a nuisance species". My definition or understanding of "nuisance' was
different than BRP's definition.
4. In the same letter and (more emphatically) in the same e-mail it was stated: "The NCIBI should not be used as its
metrics were not calibrated nor was it correctly designed for streams the size of the Pigeon River'. Despite this, the
1995/1997 version of the Index was used. Conclusions based upon the 1995/1997 Index and its metric criteria were
not and are not currently valid.
5. Page 1-2-- "By the mid-80's the aquatic life in the river was consistent with the expectations for a Class C stream in
North Carolina (EA 1988)". This statement, which was repeated in 1990s reports,was pointed out in 1996 to BRP (at
that time Champion International Corp.) that their interpretation of the regulations was in error and this statement was
not true.
e*o
tJuDENR
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh,NC 27699-1621 [phone]
1 800 623-7748

V' 7 rvucna=i r casiey
\O� \�•QG Governor
CO ,7 William G.Ross.Jr..Secretary
--r Department of Environment and Natural Resources
YL O < Kerr T.Stevens
Division of Water Quality
6. Page 3-1 -- If recolonization sources are lacking downstream of the mill and because the darter fauna in the Pigeon
River has been severely impacted for many decades, would BRP (and other responsible entities and interested
parties) fund efforts to reintroduce species that were eradicated by the mill's effluent and prevented from
recolonization by the Walters Dam?
7. Pages 3-2 and 3-3 -- "Species richness in the most thermally affected zone (Fiberville) is comparable to upstream of
the mill and better than the NC zones further downstream" --this maybe true, but the species (and their abundances)
above and below the mill are entirely different. Later (buried in the report), Table 4-7 shows that the fauna of the most
thermally affected site is only 16% similar to that of the reference site. Equating equal species richness at the two
sites with having no thermal impact and indicative of a balanced fish community below the mill is not valid.
S. Pages 3-2 and 3-3 --common carp and redbreast sunfish are not native to the Pigeon River basin and both species
are considered tolerant. Nuisance species, as requested in an earlier correspondence, was never defined.
9. Pages 3-2, 3-3, and 3-9-- redbreast sunfish is a thermally tolerant fish whose percent abundance progressively
declines the further removed from the mill (refer to Table 4-2). Above the mill, the species constitutes only 2.5%of
the fauna, at Fiberville 64%, and at River Mile 19.3, 0%. Contrary to the report, this species clearly indicates that
nuisance species are dominant and the community, at certain sites, is dominated by thermally tolerant species.
Likewise, biomass data (page 4-15) also show the dominance of these two species in the nearfield areas (53%-68%).
10. Page 3-3 -- YOY (young-of-year) should not be collected and should not be considered when using the NC IBI (or any
other version).
11. Page 3-4 -- as earlier stated, the NC IBI should not have been used as a measure of community health or as a tool to
assess thermal impacts.
12. Page 3-4 -- if the upstream site is used as the reference site (a thermally unimpacted site), then downstream sites
clearly show spatial faunal differences that can be attributed, at least in part, to temperature differences.
13. Page 3-5--what is BRP's evidence (basis) that the river below the mill should not be cool water system, like it is
above the mill? The elimination of darters and other species was most likely due to extremely poor water quality(in
the broadest sense including chemical and thermal pollutants). The recovery below the mill in North Carolina of the
greenside darter, greenfin darter, tangerine darter, and other species will likely take a long time, if ever.
14. Page 3-9 --species richness conclusion --this is clearly a misinterpretation of the data.
16. Page 3-10 -- Competitive Advantage to Certain Species -- Redbreast sunfish seemed to dominate the communities
below the mill. Would not this species decrease and rockbass increase if the temperature below the mill was cooler?
16. Page 3-11 -- Community Dominated by Thermally Tolerant Species -- "Furthermore, most citizens and anglers
probably consider the presence of large numbers of redbreast sunfish to be a positive attribute of the fish community
rather than a negative one." This clearly is an opinion and not supported by any published facts. The redbreast
sunfish is not native to the mountain streams and is a indicator of some past alteration to the stream and community.
In eastern Tennessee, this species is implicated in out-competing and displacing the native longear sunfish (Etnier
and Starnes 1993. This presence and abundance of the redbreast sunfish in mountain waters should not be viewed
as a positive attribute.
-A
NM MR
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh,NC 27699-1621 [phone]
1 800 623-7748

0/rrQG v may
Governor
1 0) 1 r William G. Ross.Jr..Secretary
> f JM, Department of Environment and Natural Resources
Kerr T.Stevens
Division of Water Quality
17. Page 3-13--Common Carp -- "The state has already stated that common carp is not a nuisance species in the Pigeon
River(memo from Bryn Tracy dated 17 March 2000)." The exact wording of my memorandum was: "To my
knowledge, there are no commercially important or nuisance species in the river. Common carp should not be
modeled as a nuisance species. Consultant should define nuisance species." I believe my words were taken out of
context and meaning.
18. Page 3-15 -- Redbreast sunfish -- "Since this is a popularspecies with anglers, it is expected that most people would
view its increased abundance downstream of the mill as a positive rather than an adverse impact." Clearly, this is an
opinion and not based upon published facts.
19. Pages 3-15 and 3-16-- Darters -- The presence of one or two individuals of any species of darters (or any other
species) downstream of the mill does not equate with viable populations and with improving and tolerable conditions.
20. Appendix A, Page 1-1 -- "The North Carolina Division of Water Quality(NCDWQ) does not have an established
protocol for conducting 316(a) demonstrations (email from Mr. Bryn Tracy date 116100). Nonetheless, biological
sampling was conducted in accordance with standard NCDWQ field protocols." The precise wording of my e-mail
was: "The North Carolina Division of Water Quality does not have a formal protocol for conducting 316 (a)
demonstrations such as the one being proposed for the Pigeon River. Typically, the Division handles the study
design on an informal communicative basis. You would, however, be safe in using the federal protocol and having use
approve the study design before the actual sampling is to be conducted later this year. In terms of the benthic
invertebrate community, the thermal effluent is treated just like any other WWTP effluent and upstream-downstream
type studies are done." In a later email (dated 03/17/200) and in a letter from Ms. Sullins, BRP was instructed not use
the NCIBI in its 316 (a) demonstration.
21. Appendix A, Page 2-12-- "For this report, the Of is used only to compare the 1995 and 2000 results". This statement
is not valid. The inaccurately-derived Index is used to support BRP's position that a continuation of the variance is
warranted.
22. Appendix A, Page 4-8 -- "No single species dominate the mainstream catch." The redbreast sunfish's abundance,
below the mill in North Carolina, constituted 64% (near field) to 17% (far field) of all the fish collected. Approximately
25% of all the fish collected from the entire river were the.tolerant redbreast sunfish.
23. Appendix A, Page 4-11 -- Percent Similarity-- as mentioned earlier, the thermally affected sites below the mill were
very dissimilar to the thermally unimpacted reference site.
24. Appendix A, Page 4-26 -- Life Stage and Spawning Activity--This assessment should have been made on a site-by-
site basis, not for the entire river from River Mile 64.5 to River Mile 19.3. Young-of-year should also not be included in
the analyses.
BHT/bht
PC: Dave Goodrich
Keith Haynes
Michael Meyers
c�~,'�rW
NCDEfIR
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh,NC 27699-1621 [phone]
1 800 623-7748

� r�
R

WATER STANDARDS N.C. PAPER PLANT LIGHTENS UP .+
e5il!
: House votes
to'toughen
arsenic rules
urge
Con ressmen e EPA
g ,
to enforce Clinton policy,
i i S. H.. .i+ •
r6Buus. 'Kaela �? ;
��� , ; ,I� s3�' ugz�f r l�uil'r•'�,tr>k
m,vA t r
ACK1$ oszc;u�tl
U vl eP2�Catat�VCSyVO 218.189 II S MIIt tdliG7 L tI�+ S t 'Ia x,k�v Yf i!+ �flSt}iR ¢ ' i y
MICHAEL BEAVERS-„SPECIALTO THE.OBSERVER
u.` „thepB s;Tom Wier of WaIla4Walla,Wash,and Chris Hlpgrave of Bryson CI•ty make a practice run Thursday on
a's'delayuobto'uglier,atsenw+�OW the Pigeon River In Preparation for next SatuSday'sWildwaterNationalChamplonshipson the river.
t-ll�,ly \I ,i�tlShJndalSfOrdDOlOngVPdtCrtllC271i . r
Y �. . "y t i3 It:Q ICY y 1 11 y� G1 ti U
4: " v � E>1.t :�ttrt:� !. T ;.
+� �latest m�a�seaes of se;backs for r .+ k+ .-
,W13itelHouse envuonmentai pok R Paddlers take a;d ' t ge'of river's
. . icier 2 r%• . .:: 5 ;.
Nmeteen Re ublicans oined
198 House Democrats andone in- cleaner look mill's new direction
Emi
/l dependent in directing the - �.
romnental Protection\ Agency to go forwardwith Mile the Clinton in
L/ creasinglY resentful Tenses- thepapermillin Canton also has
/ administration proposed in Janu- see,marks a milestone in its re changed
course.
\ v ary that would slashthe allowable With water taking on roveryneatweek since 1997 the mill, once
n arsenic level in water to one fifth a lighter hue, national The Wildwater National ,owned by Champion Intema-
` '�✓1 l ;; what it is today. Championships are the fast to tional and now owned by its em-
\\` ! Congress also has balked at event comes to Pigeon be held on the Pigeon, which ployees,has cut its colored dis-
V\1 q ush's proposals to allow oil and years be- charge into the Pigeon by hal£
exploration in sensitive Paddlers avoided for
��P �. cause of the discolored water Blue Ridge Paper products, the
and many moderate Republicans BY BRUCE HENDERSON and smell.Racers in kayaks and new company,is working toward
joined Democrats in criticiang AND JACK HORAN enclosed canoes will splash further improvement with envi-
his rejection of the international Staff Writers through 5%=miles of rapids be- ronmental groups that five years
Kyoto treaty to combat global The Pigeon River, which for ginning at the N.C.-Tennessee ago were enemies•
warming. decades washed the coffee-black state line
SEE WATER I l0A Wastes of an N.C. a mill into The company promises the
paper THY-�v�IDil� upstream, SEE PIGEON 117A
COOLANDBREFIY:High:78.Low:66. Business.................10 Contact Us.......2A Entertainment..BF•';Hoi
i )� Weather Clouds and spotty rain this afternoon IRdeX Classified.............lOC Deaths..............68 Faith&Values.....D':7•Lar
yt. Oroughtonight.Full Forecast,6D Comics.............12-13F Editorial...........18A Home...........:....]E;JLoc
t 1' ,bruit:

rHE CHARLOTTE OBSERVER WORLD /FROM PAGE ONE;
Paddlers tal-e advantage ®f cleaner look
Wlldwater Whitewater stream of the mill,an area still on
Plg@OrljromlA Is
Championships TENN.section �* the state's list of impaired waters.
MILES Fish tissue samples are being ana-
The USA Canoe Kayak - �- 19 lyzed to decide whether the con-
rove's r tint will continue to i Wlldwater National `Hartford P19ean River 33 sumption advisory should be
con-
rove. How much is a questioonn Championships are expected to N.C, changed,Westallsaid.
lulled by federal and state au- draw 35 to 40 competitors Ashevillelor �■ Blue Ridge's goal for the next
d1l's d s, who will renew the next Saturday. 19 e. five years,Williams said,is to re-
They'll compete permit this year. They'll compete in two Canton Blue move an asterisk on the[hill's d s-
Paddlers,meanwhile,are[lock- 1,600-foot-long sprint races 74 Rid y
Lg to the Pigeon. Eleven out- n Pa kway 26 charge permit'The variance says
tters run rafting trips on the sec-
and a race to Hartford,Tenn. 1 RI Blue Ridge can't meet the N.C:
Fastest cumulative time standard prohibiting "objection-
on from Waterville, just inside through the Class III-IV able" color discharges but is al-
oe N.C. line, to Hartford, Tenn.; Whitewater wins,said race lowed to operate an
: ACOBMERcr-STAFF P anyway.
cording to Brad Davis, presi-
organizer Chris Hipgrave. "My goal is this:I want it just as
mt of the Pigeon River Permit- Hosting the championships is take an active role in the new per- dean coming out of that pipe as it "
.es Association. the Nantahala Racing Club, mit,a spokesman said. was going in," said Charles
Davis said 55,000 people last based at the Nantahala.River. The mill has cut its color dis- Moore, county executive in
oar rafted the section during For race details,see charges by 90 percent since the Cocke County, just across the''
nee-day-per-week water re- 'www.nrcrhinos.com. 1980s, said Forrest Westall, re- state line."I think the technology
aces from a hydro plant at Wa- gional water-quality supervisor is there.It's been 93 years, and I
Race '
for the N.C. Division of Water don't think that's too much'to
Race organizer Chris Hipgmve, Quality. Westall said he expects ask."
ho has paddled the Pigeon for 10 ity to its neighbors in both states. further reductions of about 20
!ars,said he has seen the river's.. ; Last fall the company agreed to percent from current levels. Bruce Henderson:[phone];
¢k stain lighten. an unusual request: join a coals- North Carolina still advises [e-mail].
"The whitewater is phenome- tion of 'nine environmental " consumers not to eat catfish and lack Horan:[phone],
d and it's a beautiful area,"Hip- groups in hiring a Canadian ex- carp from the Pigeon down-' [e-mail].
ave said. "The Pigeon has still pert to evaluate the mill.The con-
t that kind of coffee-ish tinge to sitltant evaluated the costs and
You definitely know it's dirty." benefits of ways to remove more i
The mill, which opened in color from the mill's discharge. ■ '
38, employs 1,100 people,mak- "You're more.likely to draw a r�s ,
milk and juice cartons and en- consensus than draw a line in the r r h" r
lopepapen sand" with collaboratio Wil �; �
t 3' .q ��'�'Tr°i ✓u
3>� 4
d F r
The dark color is produced liams said. u.yxu
L�Il wood fibers are se orate � � tM � _ 1 E -lot
p d The intent of the environmen a t i +�
:n bleached to make paper. -tal groups, said David Jenkins of r
�rth Carolina se. colored cis- the American Canoe Association, � ��� �� � � ! 'Tr
s are a subjective problem,
B� � � z
a38e J P an4 was"to make sure what we're ask- T D r
d places no hard limits on their ing the mill is not impossible." r y
ease. Environmentalists say The Canoe Association and the l •OpL
naturally dark'color disrupts Clean Water Fund of North Caro-
life i r
. oftheriver. " Rel
lina woul$like the mill to reduce '
Under terms of a hotly con- color by at least one-third from its F` ; _ � wit
ited permit settlement in 1997, current output by 2006, said
Lampion made changes that re- HoPYe Ta lor-GueFora executive a{ zg 3!` 'ti was
a..
ced the color.Improvements in director of the dean water group.
process-ycling of watei,part of The
;0 millionspenntto modernize ;will piessae for a50 p scent redu
mill overthe'past decade,re- ,tion,Seay said. . .::':<iu , :T: i
ed the amount•of:discharge "Despite-improvements •since
ithecolormit 1997i'Seay.said •the water'-hash r r
mvuonmeotalists say they ve . darkened a few tithes.When we._ '� y
n a fieiysrtorporate attitude .-ter levels are low, he'sand, a•dis- a 1 ,�4;;
be Champion sold the mill to tinctive'sulfuroussmellstillwafts aa ,. ,
mPloYe?s.hvo.Yearsago•._._. Jiom the tvater'i t7 ;'n :� °° ah s '
1 lawstuf flled by hundreds of + The coahhon also'watits color q ' fg4
messee residents over Chain-' levels to be measured closer•to Its" r'bt is .
ns discharge4Ewas:settled.in t the plant;,instead of the current
3for$6.5n iron Sfateoffrcials •location'about I5.-rihiles,;down-
the cancer-caAkin'gchemicals. :stream.�o-
he foctis:of that stilt,^dioxins, •. "Our goal is to reclaim the N.C. a -
no longer deteMa`ble31n'the portion the"ivay the,:Tennessee y p
Vs wastes becausetof pro cess side wnc Tankinc�,m "

release EnvitoninentaLsts CarioeAssociation and the
unn'turallly -dark'color disrupts Clean Water}?raid of North Caro-
the i fe of the river. ' hna would like the mUl to reduce
Under terms of a hotlycon- color b at least one-third from its 1
Y .�, a ,,>.... ; :� - �"�` 5,�>xn , % ` •E
tested permit settlement in 1997, current output by 2006, said is "' g��b� ;' R� �"Qk
Champion made changes that re- Hoe Taylor-Guevara, executive .r u #��'" �` s'"',
a
duced the color.Improvements in director of the clean water group
recycling of process water,part of The Dead Pigeon River Council , =r^` 3y$
y350 million spent to modernize ,will press for a 50 percent reduc
the mill over the past decade,re- tion,Seay said
duced the amount of discharge Despite improvements since ':-
r tk
and the color in it. 1997,''Seay said the water has
Environmentalists say they've . darkened a few times.When via
seen a new corporate attitude ter levels are low, he said, a dvs
since Champion old the mill to tinctive sulfurous smell still wafts ',W
its employees two years ago,r- from the water.r "'
A lawsuit filed by hundreds of The coalition also wants color £ a, a tt
Tennessee residents over Chain- levels to be measured closer to
pion's discharge was settled in the plant, instead of the current « {I�
L993 for$65 million.State officials location about 15 miles down-
say the cancer-causing chemicals stream
at the focus of that suit, dioxins, "Our goal is to reclaim the N.C.
are no longer'detectable in the portion the way the.Tennessee t°
mill's wastes because.of process side was,"Jenkins said..
changes. The Environmental Protection
"There's an openness and will- Agency,which intervened in 1997
(ngness to sit down with the citi-. as tension grew between the two
t ,
lens downstream;and that's not states, is reviewing what further = •��• E c� �;���`�a� .., , ��
something we've had in the past," color reductions to recommend.
said Bobby Seay, a co-founder-of N.C.regulators will issue the per a
the Dead Pigeon River Council..' mit A public hearing is likely in E h t
Bob Williams,Blue Ridge's en- -September."
vironmental affairs director, said - Tennessee's Department of En- „". ;u•-rz t Js7t '. sr#}�� ', ,
the company has a new sensitiv-, vironment and Conservation will
w
vnvw.purplepicketxom.
E t
Grand Opening of The1argest t •'. � _ 6 fT mkg� tr,
Furniture Sample Mall in the Countryt
JUST ARR.IVED1 6 NEW TRUCKLOADS! �` i
,k4s `d& '+C EyrP�ff p3PA
• �`�' T 1 �. w! teal •y-•a ,t :
9
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only l left attlST® CLOSING*
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-.State of North Carolina
Department of Environment
and Natural Resources •
Division of Water Quality �__ —_ ��
Michael F. Easley, Governor NCDENR
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Acting Director
August 3,2001 O
Mr.Robert Shanahan
Vice President-Mill Manager
Blue Ridge Paper Products
P.O. Box 4000
Canton,North Carolina 28716
Subject: NPDES Draft Permit
Permit No.NC0000272
Blue Ridge Paper Products Inc.
Haywood County
Dear Mr. Shanahan:
Blue Ridge Paper Products Inc.applied for an NPDES permit renewal on February 26,2001. The Division
of Water Quality's original schedule for conducting a public hearing prior to July 31,2001 was postponed in order
to allow the EPA Tech Team and the Technology Review Workgroup the necessary time to incorporate the findings
of a third party evaluation of the Canton Mill,sponsored by the Clean Water Fund of North Carolina,American
Canoe Association,Western North Carolina Alliance,Dead Pigeon River Council,Appalachian Voices,Tennessee
Environmental Council,Southern Appalachian Biodiversity Project,Dogwood Alliance and the National Forest
Protection Council. The EPA Tech Team has completed their report and provided the Technology Review
Workgroup with the`potential' color reductions available through the application of the identified process
improvements. Based on this report,the Technology Review Workgroup developed the 'regulatory' basis for
additional color reductions in this permit cycle. Now that the EPA Tech Team and the Technology Review
Workgroup's color recommendations are final,the Division of Water Quality has prepared this draft permit and
scheduled a public hearing for September 6,2001 (additional details below).
After issuing a"pre-draft'permit,the Division of Water Quality prepared this draft permit and is once
again soliciting comments from the Environmental Protection Agency,the State of Tennessee,the City of Newport,
Cocke County,and other concerned stakeholders. The Division reviewed and considered all comments received
during the"pre-draft"comment period and modified the"pre-draft"permit and fact sheet accordingly. The
modifications reflected in this draft permit include the following:
• The dioxin monitoring special condition has been modified. The dioxin monitoring special condition in the pre-
draft permit allowed the permittee to split samples. If the analysis of either sample was below the minimum
level,then the quality was considered zero for compliance purposes. The Division received concerns over this
allowance and has modified the condition accordingly. The decision to split samples is at the discretion of the
permittee,if samples are split,the permittee must report both values and compliance shall be judge on each
sample independently.
• Dates that have passed have been deleted from the Best Management Practices Special Condition.
• Special Condition A. (8.)Requirements for Color Analysis and Compliance have been added. Based on the
recommendations of the Technology Review Workgroup and the EPA Tech Team Report,the Division of
Water Quality has developed the recommendations for additional color removal over the term of the permit.
The color reductions contained in this condition represent a 19%to 29°/"reduction in the current permitted color
load. After Blue Ridge Paper has implemented the process improvements necessary to achieve color reductions
within the targeted range,Blue Ridge Paper will evaluate the feasibility of complying with North Carolina's
1617 MAIL SERVICE CENTER,RALOOM, NORTH CAROLINA 27699-1617-TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER-50%RECYCLED/10%POST-CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Permit Number: NC0000272
color standard. Then during permit renewal process in 2006,the Division of Water Quality and the NPDES
Committee will evaluate what additional reduction,if any,are required in order to achieve compliance with
North Carolina's color standard.
Below are the Division's responses to comments received on the pre-draft permit.
➢ There were concerns over the language in the Best Management Practices Special Condition,these include:
- Special Condition A. (6.)Section A. 1,the wording"to the maximum extent possible as determined by
the mill. The language and conditions set forth in the Best Management Practices Special Condition
were developed by the EPA as part of the new Effluent Guidelines for the Pulp and Paper Industry.
After extensive research and gathering of public comment,the EPA stipulated an industry standard for
Best Management Practices. The language contained in Special Condition A.(6.) is consistent with
the industry standard as published in the Code of Federal Regulations. Since Blue Ridge Paper meets
or exceeds the Best Management Practices standards,the Division does not feel that requiring a higher
standard is justified at this time.
- Special Condition A. (6.)Section E.3,the language"failure to take the actions required by Section E.2
as soon as practicable will be a permit violation". The comment was made that this language is
unenforceable. In addition to the comment made for Special Condition A.(6.)Section E.3,it is the
Division's understanding that the language in Section A. (6.)E.3 "failure to take the actions required
by Section E.2 as soon as practicable will be a permit violation",is a`good faith' condition and that
any gross violations of this condition are enforceable.
- Monthly reporting of'action' level exceedence was recommended. In addition,to the comment made
for Special Condition A.(6.)Section E.3,please refer to the Best Management Practices Special
Condition Paragraph E. This condition requires that Blue Ridge Paper submit an annual report to the
Division of Water Quality that summarizes Best Management Practices monitoring and action levels.
The longer time frame(annual as opposed to monthly)associated with the annual submittal required in
Special Condition A.(7.)provides the Division with a more representative analysis of operations at the
mill and is better suited for analysis and conclusions. Therefore,the Division feels that annual
reporting is appropriate.
Comments were made regarding the daily maximum BOD5 limit proposed in the pre-draft permit. The
Division's review of the instream dissolved oxygen data indicates that the limits and conditions in the permit
are protecting the dissolved oxygen standard in the River. Additionally,the Division's model predicts and
actual data supports that the lowest dissolved oxygen concentrations occur at river mile 57.7,which is above
Hepco.
The Division received comments regarding the need for nutrient limits in permits above the lake. The Division
has no evidence that nutrients are a concern in this watershed. Additionally,Blue Ridge Paper's nutrient
loading is relatively low,however,nutrient monitoring will continue as a condition for this permit in order to
assess Blue Ridge Paper's nutrient loading to the River.
The Division received comments regarding the removal of the monitoring station at river mile 53.5. Blue Ridge
Paper currently is monitoring color,temperature,and dissolved oxygen at river mile 53.5. Temperature and
dissolved oxygen monitoring at this point is required according to the NPDES permit issued to the City of
Waynesville. Since Waynesville is already required to monitor this station, it is the Division's recommendation
that additional monitoring of temperature and dissolved oxygen by Blue Ridge Paper is not appropriate.
The color monitoring at this station was originally implemented in order to assess the impacts from Clyde's,the
Waynesville and Richland Creek. With the removal of Clyde's discharge,the Division feels that the continued
monitoring of color at river mile 62.9 (Fiberville)and river mile 42.6(Hepco) is sufficient.
D The Division received a request to require dioxin isomer monitoring of the octachlorinated dioxin isomers at the
internal outfalls,sludge and landfill leachate. The Division also received opposing comments suggesting that
the dioxin and furan monitoring proposed in the pre-draft unnecessary. During the previous permit cycle,Blue
Ridge Paper was required to monitor 15 isomers of dioxin and furans. Based on a review of this data and the

Permit Number: NCOOOO272
public comments received,the Division recommends continued monitoring of 2,3,7,8,TCDD and 2,3,7,8 TCDF
on the effluent,sludge,landfill leachate,and the influent to the wastewater treatment plant.
Please review the draft permit and fact sheet carefully and submit comments to DENR-DWQ NPDES
Unit. This draft permit should not be interpreted as the Division and NPDES Committee's final decision. A 30-day
public comment period follows the release of this draft permit and will close at the discretion of the hearing officer
and will be announced at the beginning of the public hearing to be held on September 6,2001. The details on where
and when the hearing will be held is listed below:
Public Hearing on regarding the Blue Ridge Paper Products Canton Mill's NPDES discharge will be held:
September 6,2001 @ 7:00 pm
at the
Tuscola High School Auditorium
564 Tuscola School Road
Waynesville,North Carolina
Haywood County
If you have any questions concerning the draft permit for your facility,please call me at(919)733-5083,
extension 508.
Sincerely,
Michael
J.�Myers,
NPDES Unit
cc: Central Files
NPDES Files
Aquatic Toxicology Unit
Marion Deerhake-North Carolina Environmental Management Commission, NPDES Committee
Jerry Wilde - Dead Pigeon River Council
402 W. Broadway
Newport, Tennessee 37821
Forrest Westall 1 Asheville Regional Office/Water Quality Section
Dan Oakley - North Carolina Attorney General, Environmental Division
Keith Haynes -Asheville Regional Office/Water Quality Section
Rob Lang-Compliance and Enforcement Unit
Diane Reid-Classification and Standards Unit
Roosevelt Childress Jr. - Environmental Protection Agency, Region IV
Karrie-Jo Shell - Environmental Protection Agency, Region IV
Don Anderson-Environmental Protection Agency, Headquarters
Mark Perez- Environmental Protection Agency, Headquarters
Justin P. Wilson- Deputy to the Governor
Tennessee State Capital, Suite G10
Nashville, Tennessee 37243
Paul Davis -Tennessee Division of Water Pollution Control
6th Floor, L&C Annex
401 Church Street
Nashville, TN 37243-1534
Charles Lewis Moore - County Executive Cocke County
360 Main Street, East
Newport, Tennessee 37821
David Jenkins-American Canoe Association
7432 Alban Station Boulevard,Suite B-232
Springfield,Virginia22150-2311

1
Permit Number: NCOOOO272
Hope Taylor- Clean Water Fund of North Carolina
29 '/a Page Ave
Asheville, North Carolina 28801
David McKinney —Tennessee Wildlife Resources
Ellington Agricultural Center
P.O. Box 40747
Nashville, Tennessee 37204
Jonathon E. Burr—Tennessee Division of Water Pollution Control
Regional Environmental Assistance Center
2700 Middlebrook Pike, Suite 220
Knoxville, Tennessee 37921
Robert Williams—Blue Ridge Paper
175 Main Street
P.O.Box 4000
Canton,North Carolina 28716
Derric Brown—Blue Ridge Paper
175 Main Street
P.O.Box 4000
Canton,North Carolina 28716
Patsy R.Williams—Chairman Newport/Cocke County Tourism Council
360 East Main Street
Court House Annex,Suite 141
Newport,Tennessee 37821
Dianne Keys—Newport/Cock County Tourism Council
360 East Main Street
Court House Annex,Suite 141
Newport,Tennessee 37821
Timothy L.Dockery—Director
City of Newport
Parks and Recreation Department
433 Prospect Avenue
Newport,Tennessee 37821
A.Dean Williams—Coordinator
Newport/Cocke County Economic Development Commission
433 Prospect Avenue
Newport,Tennessee 37821
Ray Snader—News Director
WNPC Radio AM/FM
377 Graham Street
Newport,Tennessee 27821

Permit Number: NC0000272
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POL
LUTANT DISCHARGE ELIMINATION SYSTEM ��
In com li�he ov' ofN rth Carolina�Ge'eral Statute 43f215.1, other law�l standards and
re ulat ons promulgated an� adopted by �e North Farbl a Envir nmental Management Co mission,
and the Federal V+),a7t(o
Po In�ion-Control ct, as amended,\
LLbautho/
Pa e�\ p�ductsIncis disc c urge wastdtvafer fc�/a facility 1'caied It
LJ 71
Blue Ridge Paper Products Inc.
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.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on November 30, 2006.
Signed this day RED
__)� A _
Gregory J.Thorpe,Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Number: NC0000272
SUPPLEMENT TO PERMIT COVER SHEET
Blue Ridge Paper Products,Inc.
is hereby authorized to:
1. Continue operation of a 29.9 MGD wastewater treatment plant for the treatment of wastewater
associated with the Blue Paper Products Inc. pulp and paper mill, the Town of Canton's
chlorinated domestic wastewater and landfill leachate. The treatment system consists of the
following treatment units:
Grit Chamber
Bat^ reen
�p i Tps
• Polymer additio
• pH cont�l (� . injectio)r 2SO4 backup)
Threelpruri c art ters
• Nutrient eed
• Aeraio basins
Tine s conZ clarifiers
Residdal bel presses
ffluent flo -measurement
Cascade post aeration with oxygen injection
Instream oxygen injection facilities
The facility is located at the Blue Ridge Paper Products WWTP, off Highway 215, Canton,
Haywood County, and;
2. Discharge treated wastewater from said treatment works at the location specified on the attached
map through outfall 001 into the Pigeon River, which is classified C water, in the French Broad
River Basin.
RED

I ft-
Y w ��
e 'r�re � � •
J ,_ � O utfall 001 -
:�'� ----
!��� -"fir- - ���• __ � __ _- �- ---- _s—��- -
41
ill I I ri 1 _
Y' \
Information
• Blue Ridge Papers Oulfall Facility
French Broad Hydrography slate Grid: E 7 SEFS Blue R a Products, Inc. USGS Quad: Canton
P NC000272S i
04-03-05
FUghNaysHaywood County
C]Munidpal Boundaries
0 minty Boundary
N 0.5 0 0.5 1 Miles BLUE RIDGE PAPER PRODUCTS INC.
A

Permit Number: NCOOOO272
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,the Permittee
is authorized to discharge treated industrial, municipal,stormwater and landfill wastewater through
outfall(s) 001. Such discharges shall be limited and monitored by the Permittee as specified below:
q
EfIIuent"Clia;=acter`istics�� "" Effluent,Limlts _;�, � � �Momtorin g Re uiiemetitse
- Monthly Daily-�� Measurement Sample Type -"$ample
Average_ Maximum • , 'Frequency, Location_,+,
Flow 29.9 MGD Continuous Recording I or El
BOD,5-day,20°C 3205 lb/day 10897 lb/day Daily Composite I,El
Total Suspended Residue 12549 lb/day 49560 lb/day Daily Composite I,E,
N113-N Daily Composite El
AOX 556{9-lbLday 2822.2lb/,day� Daily Composite,
Color \ I \ / , \ Dailyl _ Qompstslte` Et I
Dissolved Oxygen . \ I \.;- / /\ Dailyl I Grab I El
Te' ptramre \ I l : / J \ \ Dailyl I Grab El
P 1 1 I J / / \ \ Dailyl L Grab I El
Colydij tuvily I I / / \ Daily Grab I El
Fe sal oliform l I I 200NOOVI 400110 \Weekl I Grab I E
CQD I / J ( \ / Weekly I Composite I El
Sil,Verl / / L- \ \ / ! \Quarterly I Composite I El
Zinc / I / i Quarterly I Composite I El
L J u u u
Total Nitrogen
(NO2-N+NO3-N+TKN) Monthly Composite El
Total Phosphorus Monthly Composite El
Chronic Toxicity Quarterly Composite E,
Cadmium Quarterly Composite El
Trichlorophenol 3.0 pg/L Quarterly Composite El
Pentachlorophenol 8.9 pg/L Quarterly Composite E,
Selenium 10.6 pg/L Quarterly Composite El
2,3,7,8 Tetrachloro-dibenzo- 0.014 pg/L Quarterly Composite I,El
p-dioxin°
Conductivity Daily Grab Pigeon River
-Flo-WTI- Daily Grab Pigeon River
Fecal Coliform Weekly Grab Pigeon River
Color I I Variable Grab Pigeon River
Temperature Variable Grab Pigeon River
Dissolved Oxygen Variable Grab Pigeon River
Footnotes:
1. Sample Location: I-Influent,E,—Effluent,Pigeon River-Instream sampling as specified in A.(5.)Instream
Monitoring Special Condition. ��
2. AOX monitoring shall be in accordance Iitamplinb P�ahn Clustr rule Parame ers da ef— arcCi 19,
2001)or subsequent modifications approve by the:Div'sion. AO70 datars�a 1 be su� fitted on aqua erly basis
along with other Effluent Guideline chemcil data; e$terito�A—(7 /Effluedtr Galdelit}e'S"am ling Pla� pecial
Condition. JJ l
3. See A.(8.) Color Analysis and Complian Sei pecial�Condrtion. / �\\
4. The daily average effluent dissolved oxyg m concentmuori shall n.t_be ess t See A. .)
Dissolved Oxygen Special Condition.
5. See A.(13.) Temperature Variance Review Special Condition.
6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0(on the standard units scale).
7. Chronic Toxicity(Ceriodaphnia)at 90%Effluent Concentration:March,June, September,December(see A.
(4.)Chronic Toxicity Permit Limit(Quarterly)).

Permit Number: NCOOOO272
8. Trichlorophenol and Pentachlorophenol limits and monitoring are provisionally waived since the facility has
certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include
chlorophenolic biocide,the Permittee shall notified the Division prior to use and the limits and monitoring
requirements shall become immediately effective.
9. If after 18 months selenium has not been detected,the facility may request that the Division review selenium
data for possible removal of the limitation.
10. See A.(9.) Dioxin Monitoring Special Condition.
11. See A.(5.) Instream Monitoring Special Condition.
See A.(6.) Best Management Practices(BMP)Special Condition.
See A.(11.) Town of Canton Inflow and Infiltration Special Condition.
Definitions:
MGD—Million gallons per day lb/day—Pounds per day
ml t t iter OD—Biochemlca xygen eman�
µ �ms per liter A X-Ad. abt�Organ-ic- lide
C D-Chemicals y eh de nalD -picog m per liter

Permit Number: NC0000272
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
outfall(s) 002 (E21),shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
_ orl _ e
=Efluent Chaaceristics- Llm ­ Moni nentsz ..
Monthly Daily, ''Measurement Sample Types Sample
Average' { FMaximuni. . �F_requency,° _ _ ' �Location' `
Flow Weekly Calculated E2
Chloroform 5.15lb/day 8.60lb/day Weekly Grab E2
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E2
p-clioxm DDh
2 7 --etrachl ro-dibenzo- 31.9p Monthly tz —E3
I F
T4chlbrosyringol ` 1 k 2.5 µW \ 4onthly I I Composite E}
3,4,5-�richlorocatechoy I Y< 5.0pw \Ni nthly o`C mpos3tip Ei
3,4,6-�richlorocateaho 1 dythly I ompost a E#
3,4,5 richloroguad'ac91 1 < Composite %
3,1,6-TrichloroguaiaFbl I \< 2i5 µg/I. Montfi(ly I Composite E{
4,1,6-Trichloropaiacol I 7.5�g/L Monthly I Composite E#
2,4,5-Trichlorophenol < 2.5 µg/L5 Monthly Composite E2
2,4,6-Trichlorophenol < 2.5 µW Monthly Composite E2
Tetrachlorocatechol < 5.0 µW Monthly Composite E2
Tetrachloroguaiacol < 5.0 µg/V Monthly Composite E2
2,3,4,6-Tetrachlorophenol < 2.5 µW Monthly Composite E2
Pentachlorophenol < 5.0 µW Monthly Composite E2
Footnotes:
1. Sample Location:E2—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100 and from tap installed on filtrate pump from C102
bleaching stage D-2)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E.). See A. (7.)Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters (Internal Outfall 002 parameters+internal Outfall 003 parameters+AOX from Outfall
001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)Effluent Guideline Sampling Plan
Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance,and report
total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab samples every 4-
hours for 24-hour period from both the ac'd-and-alkaline streams which will then be co posited-separate by
the lab,and analyzed as separate 24-hr cod it",'d and4alkal e,samples% Comp Ate-codderseparate�grab
samples every 4 hours for 24-hour period ¢m bothe c�d and�lkaline sir ams,t en prepare and alyze a
single flow-proportioned composite of theacid and alkal' o-wasees6eatr / \
4. For compliance purposes,the permittee m �t reporttll�e total chlo ofo i massloading ba' sed on addition of
separate acid and alkaline chloroform mass oadin s
5. Limits are based on Minimum Levels(MI)spectfi�d in CFR 0
Definitions:
lb/day—Pounds per day pg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NC0000272
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration, the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
outfall(s)003 (Eat), shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
'`Effliieut Charaeteristi6 "` "" ;Limitg" M6-nitoring-,Req6irements2
Monthly, DailyAveraje Measurem ent Sample,Type3 Sample
Average Frequency• Location
Flow Weekly Calculated E3
Chloroform 7.14lb/day 11.93lb/day Weekly Grab E3
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E3
p-e3oxm CDD)_, F
2, ,7 8-Tetrachl ro-dibenzo'- \ 31.9 p Monthly items —E
P an(TCDF) I, ` F
Trichlorosyringol ` 1 2.5 µgV/ I Composite Ei
3,1,5-�richlorocateehol I < 5.0 µW Monthly I o`C mposTe Ei I
3, ,6-Trichlorocatedhol' I < 5.0 jt 5 ---Monthly I ompos3 e E# I
3,4,5-Trichloroguajhcgl i \ < 2.5 µgR s onthly I I Composite E)
3,4,6-�richlorogufiiacol I �< 23 µg/L5 Monthly I I Composite Ej I
4,9,6-Trichlorogua(acol 12.5k,Lg/LS Monthly I I Composite Ej I
2,4,5-Trichlorophenol < 2.5 µW Monthly Composite E3
2,4,6-Trichlorophenol < 2.5 µg/L5 Monthly Composite E3
Tetrachlorocatechol < 5.0 µg/LS Monthly Composite E3
Tetrachloroguaiacol < 5.0 µg/L5 Monthly Composite E3
2,3,4,6-Tetrachlorophenol < 2.5 pg/L? Monthly Composite E3
Pentachlorophenol < 5.0 pg/L S Monthly Composite E3
Footnotes:
1. Sample Location:E3—Effluent is composed of Bleach Plant Effluent-acid (acid sewer collected from tap
installed on filtrate pump from CIOZ bleaching stage D-100)and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage E.). See A.(7)Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters(Internal Outfall 002 parameters+internal Outfall 003 parameters+AOX from Outfall
001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)Effluent Guideline Sampling Plan
Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance,and report
total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab samples every 4-
hours for 24-hour period from both the acid-and-Aaline streams which will-then be-composited-separatel by
the lab,and analyzed as separate 24-hr com esite c'd and alkal' e�samples;�Composito colletCt�eparate grab
samples every 4 hours for 24-hour period from both the acid andnalkaline/s�reams,t}ien prepare and p alyze a
single flow-proportioned composite of di 'avid and t ika inIe-wastesmean
4. For compliance purposes,the permittee m�st reportth�eoTclt o oform mass load' g based on addttibn of
separate acid and alkaline chloroform mass loadings..
5. Limits are based on Minimum Levels(ML s�ccified in CFR 0 OJIf. IJ
Definitions:
lb/day—Pounds per day pg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NCOOOO272
A. (4.) CHRONIC TOXICITY PERMIT LIMIT(QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, uaq rter(y monitoring using test procedures outlined in the"North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised February 1998, or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent
versions.The tests will be performed during the months of March,June, September,December.Effluent sampling
for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit,then multiple-concentration testing shall be performed at a minimum,in each of the two following months as
described in"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or
subsequent versions. ��
Th ce lumtic_yalue for multiple onc' enration tests will be dl terrri'med using a geometricme Lf tbt hi' 'ghest-1
co centration hha ' g�io detec ble impairment f reproduction or,survival and the lowest concentration that does
ha e a detectable impairment o reproduction o survival/Tl1e i definition of`ddetectable impairment,"co legion
methods,exposure rtegifnes,lan further statistical methods Pre s�ccified in �e orth Carolina Phase II Chronic
Aol�Effluent Tox ci . Test Proce ure'(�R wised-February. 999$)ar subse(uent versions.
l toxicity testing esii is r Iqu red asp oI\this pe it condom ition it be entered on the Effluent Discharge
Monitoring Form( 1)for a months in which tests})vvere performee using the parameter code TGP3B �br the
s/fai a ults-aird HPjB:foi the Chroni Value. dditionally a D o AT 3 (original)is to be sent to the
fol owing addres : � 1�
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete,accurate, include all supporting chemical/physical measurements and all
concentration/response data,and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,the
permittee will complete the information located at the top of the aquatic toxicity(AT)test form indicating the
facility name,permit number,pipe number, county,and the month/year of the report with the notation of"No Flow"
in the comment area of the form.The report shall be submitted to the Environmental Sciences Branch at the address
cited above.
Should the permittee fail to monitor during a month inwhic oxicity onito s required;-monitoring-7i}1-be
required during the following month. \l �� E
Should any test data from this monitoring requir in o{tbsts e�fo" ed by Ih North Caro ma ivisio 'f Water
P t`�� 4
Quality indicate potential impacts to the receb hr,stream,614s erit ay be re-ope ed and modified to include
alternate monitoring requirements or limits. l__n I I \� /
NOTE: Failure to achieve test conditions as specified in the cited document,such as minimum control organism
survival,minimum control organism reproduction,and appropriate environmental controls,shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Permit Number: NC0000272
A. (5.) INSTREAM MONITORING SPECIAL CONDITION
Stream Mile Location Description Parameter Frequency
Designation Marker
UP 63.8 Pigeon River upstream of the Temperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the Conductivity Daily
discharge) Color' 2/Week
FloW2 Daily
Fecal coliform Weekly
DN 1 62.9 Pigeon River at Fiberville Bridge Temperature Daily
D.O. Daily
Conductivity Daily
Color 2/Week
DN2' 57.7 _Pigeon River Above Clyde Temperature Dail
/ 1 D.O. ��� Daily
D113 ( \ 55\5 { { Pigeon RlveiyBelow Clyde'\ \ See Footnote 3 See Footnote 3
D i 4 I 3.i I ( Pigeon Mverjat NCSI2 1625\ See Fpoti ote 3 See Fo i to i to 3
f bridge
D 5 42.6 PtgWn Rt rat Hepco / \ Temperature Weekl�j
1 [ \ .O. Weekly
`CDolor Wee
)<lowZ' � 2/Daily
{ U / { { Watervitie Reservoir \ See Footnote 4 Annually {
DN�6.0 U Pigeon Ri've� r prior to mixing with�Cojorj Variable)
Big Creek
BC —26.0 Mouth of Big Creek prior to Color Variable
mixing with the Pigeon River
DN7 24.7 Pigeon River at Browns Bridge Temperature Weekly
(—NC/TN State Line) D.O. Weekly
Color Variables
All instream samples shall be grab samples.
I. Color(See A. (8.) Color Analysis and Compliance Special Condition) All instream samples collected
shall be representative of the Pigeon River and Big Creek,respectively. Both true and apparent color
shall be monitored using the methods specified in A. (8.) Color Analysis and Compliance Special
Condition. Samples shall be collected at stations DN6,BC, and DN7 only when at least one generator
at CP&L is in operation and releasing water to the Pigeon River.
2. Flow monitoring is necessary, as specified above, for the True Color calculation stipulated in A. (8.)
Color Analysis and Compliance Special Condition.
3. Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9
(DNI), 57.7(DN2), shall not be less than 5.0 mg/I and the instantaneous minimum dissolved oxygen
concentration shall not be less than 4.0 mg/l (See A. (10.) Dissolved Oxygen Special Condition). If
the dissolved oxygen drops below 5.0 g/L 3 tat* nSJ hen mom ring hall-be- equir' edatstations
55.5 (DN3)and 53.5 (DN4).
4. See A. (12.) Waterville Reservoir Sari ling S'eciAI IGondi �n. L
5. Sampling is required 2/week during tl a summer d Wn e pr wen\ t ewter. Summer isdefined as the period from April 1 th 0Lghoctobr 31,wh\le`van t r is��eu ed as Nove u er 1
through March 31. vU

Permit Number: NC000O272
A. (6.) BEST MANAGEMENT PRACTICES(BMP) SPECIAL CONDITION
The permittee must implement the BMPs specified in Section A below. The primary BMP objective is to
prevent leaks and spills of spent pulping liquors, soap, and turpentine. A secondary objective is to
contain, collect, and recover at the immediate process area, or otherwise control, those leaks, spills, and
intentional diversions of spent pulping liquor, soap, and turpentine that do occur. BMPs must be
developed according to best engineering practices and must be implemented in a manner that takes into
account the specific circumstances at the mill.
Section A. BMP Implementation Requirements
1. The permittee must return spilled or diverted spent pulping liquors, soap, and turpentine to the
process to the maximum extent practicable as determined by the mill, recover such materials outside
the process, or discharge spilled or diverted material at a rate that does not disrupt the receiving
was ewater-treatmenx sY s em.
2. The-perni tee must e tablislra-progra�to identi An repair le ing-equipment!items-This((PPr0gram
must include: (i Regular daily visu�l i1spections 0f it cess area ith equipment items inlsp�nt
pulping liquok, soap, and turpentine,se�ice; (ii)Immediate repai5 of leaking equipment item, when
p ssible. Leaking equipment-iterrrrtis that cannot be repaired during normal operations mus be
icentified,to�r}poraryimeans-form gating the leaks m6t a prodded,—and-thAeaking equipment
items repaired during the next maintenance outage; m Ide tification of conditions under wl{ich
production ill be curtailed or halted\�o repair:leaking items or to prevent pulping liquor,
s0ap,.and-tu ntine leaks and spil�s- an n!A means for,tracking repairs over time to id ntify those
equipmenti ems where pgrade or rePlac m nt may be warrante based on frequency and severity of
leaks,spills, or failures.
3. The permittee must operate continuous,automatic monitoring systems that the mill determines are
necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap,
and turpentine. These monitoring systems should be integrated with the mill process control system
and may include, e.g.,high level monitors and alarms on storage tanks; process area conductivity(or
pH) monitors and alarms; and process area sewer, process wastewater,and wastewater treatment plant
conductivity(or pH)monitors and alarms.
4. The permittee must establish a program of initial and refresher training of operators, maintenance
personnel, and other technical and supervisory personnel who have responsibility for operating,
maintaining, or supervising the operation and maintenance of equipment items in spent pulping
liquor, soap, and turpentine service.The refresher training must be conducted at least annually and
the training program must be documented.
5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor,soap, or
turpentine that is not contained at the immediate process area and any intentional diversion of spent
pulping liquor, soap, or turpentine that is not contained at the immediate process area. The report
must describe the equipment items involved,the circumstances leading to the incident,the
effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion,
and plans to develop changes to equipment and operating and maintenance practices as necessary to
prevent recurrence. Discussion of the�eportsr�ust ben'ncluded as paq of the�annuaiTefreshertr�a'ning.
6. The permittee must establish a pro gra to revs v any planned modifications o the pulpin and
chemical recovery facilities and any c struct or�a� lvities/iq'the�pilll ing a Id chemical reiE very areas
before these activities commence. Th urpos� f$uch-view is tszprov�nt leaks-and spills of spent
pulping liquor, soap, and turpentine d r ng thapjagned mq��fications and to ensure that co struction
and supervisory personnel are aware o ossrb a li 4r r dive s_ � and ot;t e requirement to revent
leaks and spills of spent pulping liquors,p andturpentine duuring construlction.
7. The permittee must install and maintain secondary containment (i.e.,containment constructed of
materials impervious to pulping liquors)for spent pulping liquor bulk storage tanks equivalent to the
volume of the largest tank plus sufficient freeboard for precipitation.An annual tank integrity testing
program, if coupled with other containment or diversion structures,may be substituted for secondary
containment for spent pulping liquor bulk storage tanks.

Permit Number: NC0000272
8. The permittee must install and maintain secondary containment for turpentine bulk storage tanks.
9. The permittee must install and maintain curbing, diking or other means of isolating soap and
turpentine processing and loading areas from the wastewater treatment facilities.
10. The permittee must conduct wastewater monitoring to detect leaks and spills, to track the
effectiveness of the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must
be performed in accordance with Section E.
Section B. BMP Plan Requirements
1. The permittee must prepare and implement a BMP Plan. The BMP Plan must be based on a detailed
engineering review as described in this section. The BMP Plan must specify the procedures and the
practices required for the mill to meet the requirements of Section A,the construction the mill
determines is necessary to meet those requirements including a schedule for such construction, and
the monitoring program Oncludin the statistically derived action levels that will be used to meet the
requirements f Section E. The BMP,Plan also in s ecify the eriod of that th`e�1
deter�mt a he�ctio lefe�ls es_tab�lished under Sect
\n�, maybe xceeded without tugger#n the
rLponses sp6ci ied n S ctio8 n E. �2. T�c permittee must conduct a detailed ngineerinb iew of the uI inp n and chemical recov ry
iii
o erations--including but not limited to process equipment, stora a tanks, pipelines and pumping
s stems, loading�andIun of adm' fac Iities, andotherappurt�nantTulping and chemical recovery
egwpment items��in spent pulpinn liquor, soap,pnd-turpentine ser�ice--for the purpose of determining
t e magnitude nd ro ting of potential leaks, spills, and i tent' nal diversions of spent pulping
li o pond turpentine during the of owing periods fa
�er�ation: (i)Process start-ups and shut
owns {ii)Maintenance; (iii)Production-grade changes;�(iv}Storm or other weather events, (v)
Power failures; and (vi)Normal operations.
3. As part of the engineering review,the permittee must determine whether existing spent pulping liquor
containment facilities are of adequate capacity for collection and storage of anticipated intentional
liquor diversions with sufficient contingency for collection and containment of spills. The engineering
review must also consider: (i)The need for continuous, automatic monitoring systems to detect and
control leaks and spills of spent pulping liquor, soap, and turpentine; (ii)The need for process
wastewater diversion facilities to protect end-of-pipe wastewater treatment facilities from adverse
effects of spills and diversions of spent pulping liquors, soap, and turpentine; (iii)The potential for
contamination of storm water from the immediate process areas; and(iv)The extent to which
segregation and/or collection and treatment of contaminated storm water from the immediate process
areas is appropriate.
4. The permittee must amend its BMP Plan whenever there is a change in mill design, construction,
operation, or maintenance that materially affects the potential for leaks or spills of spent pulping
liquor,turpentine, or soap from the immediate process areas.
5. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP
Plan is prepared and,except as provided in Section B.4., once every five years thereafter. As a result
of this review and evaluation,the permittee must amend the BMP Plan within three months of the
review if the mill determines that any new or modified management ractices and engineered controls
are necessary to reduce significantly t like ood o�spent ulpin liquor,soap,-and rptu�leaks,
spills, or intentional diversions from th immedi t pro areas me udingIa�schedule for
implementation of such practices and ontrols.l ��
6. The BMP Plan, and any amendments hereto,m st br revs wed byme's8n io ei clinical man ger at the
mill and approved and signed by the mi 1 manager.Any pe�on�signmg the 1 MP Plan or i&
amendments must certify to the Divisio iT ndec pe lty of l' 'that the B�Y}PIPlan (or its am ndments)
has been prepared in accordance with good engineering practices and in accordance with this
regulation. The permittee is not required to obtain approval from the Division of the BMP Plan or any
amendments thereto.

Permit Number: NC0000272
Section C. BMP Recordkeeping Requirements
1. The permittee must maintain on its premises a complete copy of the current BMP Plan and the
records specified in Section C.2 and must make such BMP Plan and records available to the Division
for review upon request.
2. The permittee must maintain the following records for three years from the date they are created: (i)
Records tracking the repairs performed in accordance with the repair program described in Section A;
(ii)Records of initial and refresher training conducted-in accordance with Section A; (iii)Reports
prepared in accordance with Section A; and (iv) Records of monitoring required by Sections A and E.
Section D. Establishment of Wastewater Treatment System Influent Action Levels
1. The permittee must conduct a monitoring program per Section D.2,for the purpose of defining
wastewater treatmentrsystem influent characteristics or action levels described in Section D.3 that
will tri ger e�uirements to initiate investigation Con MP effect veness and to to a corrective action.
2. r e permi ce must emp oy t, he following procedur s order to evelop the action levels re by
Section D: U // � I
Monitoring parameters.The puttee must¢olle2 \-hour composite samples and analyze the
samples f r a measurre o r. awe contenV(e.g;-C-hemiQ OxYY�gen Demand (COD)or Total
Organic argon(TO).Altematively,t�e'mill-may�us.n m8asure related to spent pulping liquor
losses ea�ured continuously\4 ve!aged over 24 hours(e. ., pecific conductivity or color).
intoning locations. The permitte must conduct mokiitorin�a the point influent enter 'the
astewater treatment system. For-the-purposes of this requirement,the permittee ma elect
alternate monitoring point(s) in order to isolate possible sources of spent pulping liquor, soap, or
turpentine from other possible sources of organic wastewaters that are tributary to the wastewater
treatment facilities (e.g.,bleach plants,paper machines and secondary fiber operations).
3. By the permit effective date,the permittee must complete an initial six-month monitoring program
using the procedures specified in Section D and must establish initial action levels based on the
results of that program.A wastewater treatment influent action level is a statistically determined
pollutant loading determined by a statistical analysis of six months of daily measurements. The action
levels must consist of a lower action level, which if exceeded will trigger the investigation
requirements described in Section E, and an upper action level,which if exceeded will trigger the
corrective action requirements described in Section E.
4. By January 15,2002,the permittee must complete a second six-month monitoring program using the
procedures specified in Section D and must establish revised action levels based on the results of that
program.The initial action levels shall remain in effect until replaced by revised action levels.
5. Action levels developed under this Section must be revised using six months of monitoring data after
any change in mill design, construction, operation, or maintenance that materially affects the potential
for leaks or spills of spent pulping liquor, soap, or turpentine from the immediate process areas.
Section E. BMP Monitoring, Corrective gtionra d R ore rtin'Re uircments
11 J ) _
1. The permittee must conduct daily moil ring of th tnfluenG o the�wa ewa entreatment system to
accordance with the procedures descn V in Seciio D-for`�the pl(r o detecting teaks and spills,
tracking the effectiveness of the BMP ,!and det cti 1 trends\tn penpt pulping iquorp losses!
2. Whenever monitoring results exceed t elowcr action levelU a eriod_ofl e s ecifie" the
BMP Plan,the permittee must conduct an investigation to determine the cause of such exceedance.
Whenever monitoring results exceed the upper action level for the period of time specified in the
BMP Plan, the permittee must complete corrective action to bring the wastewater treatment system
influent mass loading below the lower action level as soon as practicable.
3. Although exceedances of the action levels will not constitute violations of an NPDES permit, failure
to take the actions required by Section E.2 as soon as practicable will be a permit violation.

Permit Number: NC0000272
4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to
Section E.1. Such reports must include a summary of the monitoring results, the number and dates of
exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to
respond to such exceedances. Submission of such reports shall be annually, by March 31s`of the
following year.
Section F. BMP Compliance Deadlines
1. The permittee is subject to the following BMP deadlines:
• Prepare BMP Plans and certify to the Division that the BMP Plan has been prepared in
accordance with this regulation not later than the permit effective date.
• Implement all BMPs specified in Section A that do not require the construction of containment or
diversion structures or the installation of monitoring and alarm systems not later than the permit
effective date.
Establisitial action levels req 'red by Section not later han the ermit effective at�
Comm c"'''„„„„„„```"`operatio t of any new or upgraded continuous, auomatic monitoring syste s that the
mill dete Ines tb be necessa n er Section- other than ose associated with construction of
containmentlor dive Sion strue re )not later i han the perm itleffective date.
Complete�construction-and operation o an�y spentl pulping liqu,r, collectio ,
containminddiversion, ot'—fiie(facilities; including any associated continuous monitoring
systems eGessary to fully tulplbment B`IPsspecifi d t` Section A not later than the permit
effectiv Me. \\ I(
tab)s evised action levels required b�Section D as son as�ossible after fully implementing
the BIGIPs specified tin Section A, bu 6 later than January 1572002. M
Submit Annual Reports required by Section EA to the Division by March 31'of the following
year.
Section G. BMP Definitions
I. Action Level: A daily pollutant loading that when exceeded triggers investigative or corrective action.
Mills determine action levels by a statistical analysis of six months of daily measurements collected at
the mill.For example,the lower action level may be the 75th percentile of the running seven-day
averages (that value exceeded by 25 percent of the running seven-day averages)and the upper action
level may be the 90th percentile of the running seven-day averages(that value exceeded by 10
percent of the running seven-day averages).
2. Division: North Carolina DENR,Division of Water Quality, 1617 Mail Service Center,Raleigh,
North Carolina 27699-1617.
3. Equipment Items in Spent Pulping Liquor, Soap, and Turpentine Service: Any process vessel, storage
tank, pumping system, evaporator,heat exchanger, recovery furnace or boiler,pipeline,valve, fitting,
or other device that contains, processes, transports, or comes into contact with spent pulping liquor,
soap, or turpentine. Sometimes referred to as "equipment items."
4. Immediate Process Area: The location at the mill where pulping, screening,knottin pulp washing,
pulping liquor concentration, pulping igwo pr rocessi�ng,�anki chemica recove facilities--are lo�c ted,
generally the battery limits of the afore entioned l rpcessoN.)'Immediate process area" inbul des spent
pulping liquor storage and spill contr I anks locatCdtat they ill, }w ethe or�totthey are ]dcated in the
immediate process area. i 1 I
5. Intentional Diversion: The planned removal val ojspent pl ulping,lic�uor soapp`oi turpentine from
equipment items in spent pulping liqubr,_soap, or turpentines`e cc by the,mill for any puip-ose
including, but not limited to, maintenance, grade changes, or process shutdowns.
6. Mill: The owner or operator of a direct or indirect discharging pulp,paper, or paperboard
manufacturing facility subject to this section.
7. Senior Technical Manager: The person designated by the mill manager to review the BMP.Plan.The
senior technical manager shall be the chief engineer at the mill,the manager of pulping and chemical

Permit Number: NC0000272
recovery operations, or other such responsible person designated by the mill manager who has
knowledge of and responsibility for pulping and chemical recovery operations.
8. Soap: The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the
wood,which precipitate out when water is evaporated from the spent pulping liquor.
9. Spent Pulping Liquor: For kraft and soda mills "spent pulping liquor" means black liquor that is used,
generated, stored, or processed at any point in the pulping and chemical recovery processes.
10. Turpentine: A mixture of terpenes,principally pinene,obtained by the steam distillation of pine gum
recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft
pulping process. Sometimes referred to as sulfate turpentine.

Permit Number: NC0000272
A. (7.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION
The bleach plant effluent samples(Outfalls 002 and 003)shall be analyzed for 2,3,7,8-TCDD in
accordance with EPA Method 1613. A single sample, from each of the bleach plant effluents, may be
analyzed to determine compliance with the daily maximum effluent limitation.
The bleach plant effluent samples (Outfall 002 and 003)shall be analyzed for the 12 chlorinated phenolic
compounds in accordance with EPA Method 1653. A single sample, from each of the bleach plant
effluents, may be analyzed to determine compliance with the daily maximum effluent limitation. The
Minimum Levels for each of the 12 chlorinated compounds are the same as the Daily Maximum
concentrations listed on the effluent pages for the respective outfall(s).
The final wastewater treatment plant effluent sample(Outfall 001)shall be analyzed for AOX in
accordance with EPA Method 1650,or subsequent test methods approved by the Division.
Tl�e perrmttee�ta request f�tmr�tng modifi ation to the Ef�luenYG deU requirement ,
in luding 1) use\of CF cei-fication in�ieu of moni�orrng fpr chloro orm in the bleach plant effl ents
(Outfall(s) 002 and 003) I h8n this rule is promulgated b EPA 2)demcnstrating compliance Ius Y g
I 1 i i r y, A; i I
saTples collected lesls frequently thaw'9ry four Etours; 3)Nus�g auto ated compo�ite volatile samplers
foy chloroform sa ling; an 4)-uging�a'atomated,'co osite sampler! foir-ehlorophenolic,2,3, ,8 TCDD
anf123,7,8 TCD sa piing. Such u u \requests;will be evaluated i alcordance with 15A2H.0 t14.
The flow calcpla ions for in emal Outfall(s) 002 d 0�\be subject to accuracy requirements
specified under Part II, Section D.3. This exclusion is similar to that provided for pump log flow
calculations.
Chemical data for Effluent Guideline parameters (Outfall(s) 002 and 003 parameters+AOX from Outfall
001) shall be submitted to the Division on a quarterly basis or more frequently(January-March, April-
June,July- September, October-December). Quarterly submissions shall be due 60 days following the
last day of each quarter(Due dates=May 31, August 31,November 30, and February 28). Chemical data
shall be submitted on Division-approved DMR forms,with a separate form provided for each month.

Permit Number: NC0000272
A. (8.) REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE SPECIAL CONDITION
1. The average daily discharge of true color for each calendar month shall not exceed 55,000 pounds per
day. The annual average effluent true color loading shall not exceed 48,000 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.
2. All samples collected for color analysis and for use in the above calculation 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 or as amended by the EPA.
3, ul a Ridge-Paper has a rea Tay process o i ntifying an tmpplemenfmg p I ossible process
optiltrizati n�tt�easures, Inch can�be taken to fu hdr r duce colordischarges'from�the-nfr 1. hum
permittee is trected}o ontinue ev\aluatmg mill�opeiatr ns with helgoal of fully identify, g
o)portunities onprevening and coy trolling measnra le lack liq in� leaks and spills (Bes
Management Practtces—LLLLLLBMPs� Such B U s�includee bm are no limited-t
> Continuous ifnprovement f crating practices so more leak and-spills-are recoverec her than
discharg td tp sev erj \\
Improvement in pre aration r planna outages a miz I ca ture of tank clean-out waste and
uting to ecove�y, /
Redlinti 6n of cle . ater that cont ously runs into sew-ers t revent dilution of sm Illet spills
and facilitate recovery of highly colored wastewaters; and
> Improvement in the equipment used for handling of knot rejects to prevent black liquor leaks into
the recovery sumps.
4. By October 1, 2003, Blue Ridge Paper shall submit to the North Carolina Division of Water Quality a
report including a statistical analysis of the Blue Ridge Paper's monthly average color discharge, mill
performance as related to color, all available data necessary to derive the lowest achievable monthly
average color loading limits. By November 1,2003,the Division of Water Quality(in consultation
with the Technology Review Workgroup)shall recommend, considering the statistical analysis report
submitted by the permittee and the demonstrated performance of the mill, the lowest achievable
monthly average color loading effluent limitations. The monthly average effluent limit and the flow
criteria used for instream color determined to be achievable shall become effective on December 1,
2003,by written notification from the Director.
5. Beginning December 1,2003,the annual average discharge of true color shall not exceed 42,000
pounds per day and the monthly average color shall not exceed the limit established according to
Special Condition A.(8.)Paragraph 4.
However, if by October 1,2003,the ivtsia f Water-Quality(DWQ), in consultationwith-the]
Technology Review Committees, and e NPhS 4mmitt el agree`[ at the are overwhel tng
technical, economic, or operational b ers to the ermsttee' abi i o��attainWie_a�jove-sta ed color
loading limits,DWQ shall recommen o the l4pb 8 mrmtVlalterrri to interim-limits tc become
effective December 1, 2003. At that ti e, DWQJsh l recomknend-a-rtewVfective date for a�hieving
an annual average color loading limit i 42 "po tends per\laayAhcse recom!rnendations L1 all be
based on what DWQ concludes Blue Ridge Paper can reasonably achieve, consideration to the
actual demonstrated color levels discharged and process optimizations implemented pursuant to
The Technology Review Workgroup shall act in an advisory role to the Noq.Carolina Division of Water Quality,
and NC DWQ shall consult with Technology Review Workgroup prior to mak7ng any decisions regarding color
reduction activities at the Canton Mill.

Permit Number: NC0000272
Special Condition A. (8.)Paragraph 3. Based on DWQ's recommendations,the NPDES Committee
will determine the alternate interim limits to become effective on December 1,2003, and the new
effective date for achieving an annual average color loading limit of 42,000 pounds per day. After the
NPDES Committee's final decision,the NPDES Permit will be modified in accordance with North
Carolina' permitting process.
6. The pe`rmittee shall submit to the Division of Water Quality, the Technology Review Workgroup and
the NPDES Committee by December 1,2003, a report on the feasibility of achieving a target annual
average color loading within the range of 34,000 pounds per day and 39,000 pounds per day. This
n report shall include identified process improvements and any other actions that would result in
i� additional color reductions, actions taken by the permittee to reduce color loading(since permit
!/`F issuance), and the technical, economic, and operational feasibility of implementing the identified
eue', improvements on a continuous or intermittent basis, in order to achieve a target annual
avera-e within the range of 34 000 pounds per day and 39,000 pounds�er dam The report shall
1 r identi spe x is economic and imple entation issues ssociated ithw thr a impro einents. The
s all also ojt expect d a ditional color reductiqq fr each technology evaluated and maximum
T color reducti.n possible using the identified technologies. The re oft shall also include a proposed
s hedule for implementation of pr9Eessi improvements.required to achieve an effluent color lading
ithin the targeted range. The peralit{ee shall;provideis! evaluation/report,together with and updated
report on the riesults of o�ngomg�anel�additional planned col r redt{ction activities,to the Division of
Water Quali the Tech piology eview Wo group and- e DES'Committee.By Februua��77j 1,2004,
IWQ(in cottation mJith the Tehrit2log}1Review Worgroup) hall approve or modifyIde Ridge
P r reco endeduan for achiayin\Q\ U 4,000—39,b0, O�pouu per day target annua arerage.
If the limits determined to be achievable,pursuant to Special Condition A.(8.)Paragraph 7, by the
eT Division of Water Quality(in consultation with the Technology Review Workgroup)are not within
the target range,the Permit shall be modified in accordance with North Carolina's permitting process
to reflect those limits.
7. By December 1,2005,Blue Ridge Paper shall submit as related to the implementation of the process
improvements evaluated according to Special Condition A. (8.)Paragraph 6, a statistical analysis of
Blue Ridge Paper's effluent and a feasibility report on color reduction technologies associated with
the Chloride Removal Process. This report shall include a statistical analysis of the Blue Ridge
Paper's monthly average and annual average color discharge, mill performance as related to color, all
available data necessary to derive the lowest achievable annual average and monthly average color
loading limits.By January 1, 2006,the Division of Water Quality(in consultation with the
Technology Review Workgroup)shall recommend, considering the statistical analysis report
submitted by the permittee and the demonstrated performance of the mill, the lowest achievable
annual average and monthly average color loading effluent.limitations. If the limits determined to be
achievable are within the target range established pursuant to Special Condition A.(8.) Paragraph 6,
the limits shall become effective on March 1,2006, by written notification from the Director. If the
limits determined to be achievable by the Division of Water Quality in consultation with the
Technology Review Workgroup)are ifot hi th target rya ge,th ermit `shall-be- odic fie--in1
accordance with North Carolina's permitting p�ce�s�to o reflect t oss�e i its.
This report also shall evaluate and reportt on c 19r reductio1gqt;echndlo as oc' 'ated with the Chloride
Removal Process(CRP)wastestream. he C . an�aiysis�S�i�ll opcentrate a the techmcas,`
economic, and operational feasibility fimplementing the identified tec6Wogies.The report shall
identify specific economic and implementation issues associated with the improvements. The report
shall also project expected additional color reduction for each technology evaluated and maximum
color reduction possible using the identified technologies. The Division of Water Quality(in
consultation with the Technology Review Workgroup)shall evaluate the feasibility of implementing
identified technologies for further color reduction and shall submit to the NPDES Committee by

• Permit Number: NC0000272
December 1,2005,DWQ's recommendations regarding color reductions associated with the
treatment of the CRP wastestream.
8. By March 1, 2006,the permittee shall submit a report to Division of Water Quality,the Technology
Review Workgroup and the NPDES Committee on the comparative evaluation of the color reduction
efforts as part of the Variance review process(Triennial Review of North Carolina's Water Quality
Standards). This report shall also include an evaluation of color in the Pigeon River at the Fiberville
Bridge, and an evaluation on the feasibility of complying with North Carolina's Color Standard.
9. The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco
USGS gauge station. The new effluent limits in this permit are more stringent than the provisions in
the 1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is
possible to calculate the monthly flow at the Canton gage station above which instream color at the
Fiberville Bridge will of exceed 50 true color units. Using the 55 0� 00 wounds per day mon I
avers a true olor to rich
mpl mented on the affective date of the permirJ the flow at the
Canton Ga a tion,wgve for color Tess(han 50 true color units at the F ervib it a Bridge
i� 171.8 MGb. emfothlylaverage colon m.the Pigeon River at the Fibervillef Br*i{dge will
be less than 5q a colnever the monthly v rage fl w(at the Canton gage station) is
greater than 1 1. MGD.
10 The govemi. flow Crit rion forcolor at Canton-is& MG ( OQ2 stream flow). The flow
established pursuant'to §pecial Condition A. (8.)Paragra�h�, is eater than this 30Q2 stre flow,
theret6Pe,Zr flows less than the I A.8 MdD at the Canton Gage tation but greater than 1!93 3 MGD
OQ t the Hepco gage station;-the monthly average-w1ortn the Pigeon River at Aepco will
be less than 50 true color units.
11. Beginning December 1, 2003,the monthly average color in the Pigeon River at the Fiberville Bridge
will be less than 50 true color units whenever the flow at Canton is greater than the flow established
using the following equation and based on the monthly average effluent limit established per Special
Condition A.(8.)Paragraph 4:
(Monthly_Aerage_Effhent_Color Limitlb/day-12468.3)
Flow_at_Carton_USGSQv1GD)= — +31.6+2.4
308.58
For flows at the Canton Gage station less than the flow established here but greater than 193.3 MGD
at the Hepco gage station,the monthly average color in the Pigeon River at Hepco will be less than 50
true color units.
12. The potential exist that there could still be periods of time corresponding to periods of lower flow in
the river, when color at Fiberville might exceed 50 true color units. Therefore,the permittee shall
continue to implement the approved Low Flow Contingency Plan for mitigating the occurrence and
degree of these potential exceedences. �l
r - nn
13. The permittee shall not increase the '1 's pulp product�pacity'du mg a term of this ermrt
unless the permittee can demonstrate��tthe increasezt oduction�arl achieved hile educin
color loading. In addition, increasing the mills pu p p tiio /c�pac ty,ma . require pert it revision
in accordance with North Carolina's 14DES Permitting rules. / / �. 1 I I I
II \7 t_ L
14. The NPDES Permit shall be subject to reopening in order to modify the color requirements based
upon the following and in association with the required triennial reviews:
> Any breakthrough in color removal technologies. Such breakthroughs shall be brought to the
NPDES Committee for consideration,by Blue Ridge Paper and the Division of Water Quality, as
soon as they are discovered.

Permit Number: NC0000272
> An acceptable statistical analysis of effluent color discharge data demonstrating significantly
better color removal performance than that currently prescribed in the variance and permit.
> 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.
15. The transfer of this NPDES permit will not proceed until any successor—in—interest to the current
owner has agreed to accept the provisions of this permit and request and received from the NPDES
Committee a transfer of 2001 Revised Color Variance.
D l
liA _F
R
��

Permit Number: NCO0OO272
PA. (9.) DIOXIN MONITORING SPECIAL CONDITION
The permittee shall perform the analyses for 2,3,7,8 TCDD and 2,3,7,8 TCDF as outlined below:
Sampling"Point Monitoring.
--- Requirements ,
Measurement Sample Type
Frequency
Influent to Wastewater Quarterly Composite
Treatment Plant
Effluent Quarterly Composite
Sludge Annual Composite
Landfill Leachate Annual Composite
--------------------
T lsamp�l h(1 be analyzed fo CDD an�i 2,3z7,8 TCDF i��th'
EPA Met od
16 3.I A single s ple maya analyzed. Iternatively,t{�e sample vohdmes may be collected)to tenable
thesample to be split(du litte_analysis).ge Minir um Le el in the effluent for-2,3,7,8-TCDD and
2, ,7,I8 TCDF by�Pk M t(� 13 i�Pg/1• / (u\
If ,3,7,8 TCD or 2,3j7, i TCDF �e e tecX n e ue t above the quantitation le el the
permttte�tiate i�e frequen mo ng of sludge�d fill leachate.
Lj Li
Additional Requirements
Fish tissue analysis shall be performed in accordance with the Division of Water Quality approved
monitoring plan,which will 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.
DD P

Permit Number: NC0000272
A. (10.) DISSOLVED OXYGEN SPECIAL CONDITION
The permittee shall maintain an average daily dissolved oxygen concentration of not less than 5.0 mg/I
with a minimum instantaneous value of not less than 4.0 mg/1 at River Miles 62.9 (DN 1) and 57.7(DN2).
The permittee shall operate oxygen injection facilities at the outfall structure, at 0.9 miles downstream of
the discharge, and at 2.1 miles downstream of the discharge,as necessary, to comply with this
requirement. These facilities shall be operated in a manner which will maintain the water quality standard
for dissolved oxygen in the Pigeon River downstream of the discharge. Blue Ridge Paper shall report the
date and duration of oxygen injection use as a supplement to the monthly Discharge Monitoring Report
(DMR) forms. If the dissolved oxygen drops below 5.0 mg/L at station DN2 then monitoring shall be
required at stations DN3 and DN4.
A. (11.) TOWN OF CANTON INFLOW AND INFILTRATION SPECIAL CONDITION
TEie petmittee shall make continue orts to promote-re action of' flawlinfiltration taYhesov¢t�
Canton's wastewater coll ct'on� /J/�\
A. (1 .) 7ERVI LE RES O R SAMPLING S ECIAL CO DITION
If 1 � / l
Sam 1m for Wat rvtlle Reservoirsha I a condo to J
p g i � c d onc�a nually unrrg-2002-attd 2004. Sam ling
shall{ie performe�during a ow4l periods to corre�ond�with the fish-tissue-study(see A. (9.) toxin
Monitoring Special Conditi(n). \\ / \
Sa nplin�b4 p�rforml c at WatervillelRe ter it prior to atirel ranch, Waterville Reservoir near
Wllktns Fee ayd Watetvil e Reservottt te.dam. Each loc� shall be sampled for theuIlowing
parameters: L!
' -PARAMETERS,;,
Temperature
Dissolved Oxygen
Conductivity
pH
Total Nitrogen
Nitrite+Nitrate
Ammonia
TKN
PO4
Total Phosphorus
Chlorophyll-a
Secchi Depth
All samples shall be collected at 0.1 meters beneath the surface of the water in the lake.
A. (13.) TEMPERATURE VARI ERE IE� SPECI CONS ION
s 1s� iPr�
During the next permit renewal,Blue Rid Paper dial complete an analysis oftem erature an shall
submit a balanced and indigenous species Y�udy, no later than;May 1(20Q 5 �As part o this anal sis, Blue
Ridge Paper shall submit a complete tempe ature�aiiance repot docu n ing the need for a continued
temperature variance. L L1 Ll
The study shall be performed in accordance with the Division of Water Quality approved plan. Request
for revisions to this plan shall be submitted for approval no later than March 1,2005. The temperature
analysis and the balanced and indigenous study plan shall conform to the specifications outlined in 40
CFR 125 Subpart H and the EPA's Draft 316a Guidance Manual, dated 1977.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON,D.C.20460
XMEMORANDUM
DATE: July 25, 2001
SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue
Ridge Paper Products, Canton,NC
FROM: EPA Tech Team'
TO: Technology Review Workgroup
Purpose of this Analysis
As required by the 1997 Settlement Agreement,this memorandum presents a summary of an
analysis of available technologies that may be employed to further reduce color discharges from
the Blue Ridge Paper Products, Inc. (Blue Ridge)mill in Canton,NC. The analysis also includes
a summary of the economic impact("gross margin test") of the cost of implementing identified
color reduction technologies.
Members of the Tech Team visited the Canton mill on March 14, 2001 to observe and gather
information and data on the status of technologies implemented and color discharges at the mill
since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered
from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical
and financial data. This final memorandum is based on the May 4, 2001 preliminary draft
memorandum, and revisions to the July 10, 2001 draft final memorandum, based on a review of
Blue Ridge's comments,the June 8, 2001 Bleach Environmental Process Evaluation and Report
(BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group, Inc,
and additional comments from the Clean Water Fund of North Carolina, and the States of
EPA Tech Team is comprised of--Mark Perez,EPA/EAD;Karrie-Jo Shell,EPA Region 4;Don Anderson,
EPA/EAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,subcontractor to
ERG.

Tennessee and North Carolina. This memorandum presents to the Technology Review
Workgroup (TRW)process improvements evaluated by the Tech Team and considered to be
available technologies and briefly addresses relevant technologies evaluated in the BEPER.
Background and History
Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton,NC, which it
purchased from Champion International Corporation in May 1999. Operations at the mill began
in 1908, but the mill has been extensively modernized, most recently in 1993. The mill currently
operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking,
pulp from each line is further delignified in single-stage oxygen delignification systems installed
in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence pine pulp is bleached
with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery
(BFRTM)process, developed by Champion. A portion of the hardwood line bleach plant Eo-
stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated
paper including offset, tablet and envelope grades. The mill also produces 281,000 tons per year
of bleached paperboard used for liquid packaging and paper cups, including FDA approved
grades for milk and juice cartons. Since November 2000,pulp production has been reduced by
approximately 30 percent as the result of a major project to upgrade the No. 19 bleached
paperboard machine.
Continued Color Reduction Opportunities Since the 1997 NPDES Permit
The Canton Mill's 1997 NPDES permit included a schedule requiring continued study,
evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge
submitted a series of reports to the NC Department of Environment and Natural Resources,
Division of Water Quality, evaluating the performance of the BFRTM process, end-of-pipe color
reduction technologies, and practices for minimizing color losses from manufacturing processes.
Since 1997 Blue Ridge has:
• continued full-scale operation of BFR for the pine line;
• concluded that full-scale BFR is not feasible for the hardwood line,but
implemented partial reuse of a portion of the Eo-stage filtrate as an effective
color-reduction approach;
• identified and implemented several practices for reducing losses of highly-colored
black liquor from manufacturing processes; and

Page 3
• evaluated 16 end-of-pipe color removal technologies and detennined that they
were presently economically and/or technically infeasible for the Canton mill.
Process Improvements Analyzed by the Tech Team
The Tech Team identified five mill improvements capable of further reducing the discharge of
Lug 1r color in the mill effluent. For each of these improvements,technical feasibility, capital and
operating costs, and potential color reduction were reviewed. Each improvement can be
implemented independently of the others or in any combination. The costs incurred to
' implement the improvements are additive, however separate evaluations are necessary to
accurately estimate the associated color reduction achieved by implementing any combination of
improvements. End-of-pipe color treatment technologies (e.g., chemically assisted clarification
with sludge dewatering and disposal) typically require initial capital investment and ongoing
operating expenses, not savings, and are likely to incur non-water quality environmental impacts.
For this reason, the Tech Team focused on pollution prevention approaches that offer the
potential to be more cost-effective: color reduction in low flow, highly color-concentrated
wastestreams,through manufacturing process changes or in-process treatment.
The first two process improvements, discussed below (improvements in BFR reliability and leak
and spill prevention and control - Best Management Practices (BMPs)), are improvements which
the Tech Team concludes offer the highest certainty for technical feasibility and color reduction.
Blue Ridge also identified these technologies as feasible color reduction opportunities that will
be implemented, but differed from the color reduction estimates included in this memorandum.
The next two process improvements (ozone addition to an existing chlorine dioxide bleaching
stage on the hardwood fiber line; adding a second stage to the current oxygen delignification
system on the softwood fiber line) also were evaluated by Liebergott, et. al., as feasible color
reduction opportunities. Additional technical evaluation and/or laboratory testing would be
appropriate to reliably determine the technical details of how to incorporate these processes into
the existing fiber lines and to more accurately predict their achievable color reduction, and the
relationship of these technologies to BFR. Additional analyses would be appropriate to
determine the most cost-effective design and the most economically feasible schedule for
implementing one or both of these improvements.
The fifth process improvement, color treatment for the chloride removal process (CRP) purge
stream (one of the two key components of the BFR process), has the potential for additional

Page 4
color reduction. However, based upon initial bench-scale treatability studies by Blue Ridge,
further study of additional color treatment technologies is necessary. Process optimization on
both the hardwood and softwood fiber lines, as recommended in the BEPER, is anticipated to
provide additional color reduction and is identified as the sixth process improvement. It was
concluded that the process optimization option was among those with the highest certainty for
technical feasibility and color reduction.
All color reductions resulting from the mill improvements are estimates based solely on available
data and information. While the Tech Team has concluded that these technologies would reduce
the color discharge from the Canton mill, there is a lack of directly comparable operating
�� experience with these technologies in other bleached a er rade kraft mills that can be used to
RZy P g� P P g
develop precise predictions of the extent of the color reduction benefits.
The BEPER evaluated additional in-process technology options for color discharge reduction
potential, including the implementation of a hot pressurized peroxide-enhanced extraction stage
in both fiber line bleach plants. At this time, the Tech Team does not have sufficient information
to confirm the applicability of this technology at the Canton mill nor relevant data to predict its
potential color discharge reduction capabilities. Therefore, while this memorandum does not
address this technology option, it may be feasible for implementation by Blue Ridge and
contribute to reducing color. In addition,the Tech Team did not analyze nor did the BEPER
recommend a Totally Chlorine-Free (TCF) bleaching option because of the high cost of this
technology and the lack of experience in producing and successfully marketing products made
by Blue Ridge at the Canton mill.
1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal
Process(MRP). Blue Ridge has found that this process element has been more challenging and
expensive to maintain than originally planned. The target BFR recycle rate (percent closure) for
the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and
metallurgy problems(e.g., erosion of multi-media filtration tank lining) in the MRP, however,
the pine line closure has averaged only 74 percent from October 1998 to the present. Blue Ridge
has undertaken improvements to the MRP system in order to maintain the process closure rate
and increase operating time. Improvements include rebuilding piping and valves, and changing
construction materials and metallurgy to better withstand the chemical and physical stress
experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80
percent, annual average final effluent color discharge will be reduced by 1,000 to 1,2001bs/

Page 5
At this time,the Tech Team has no means of making an alternative quantitative prediction of
final effluent color reduction to compare to the Blue Ridge estimate.
2. Improved black liquor leak& spill collection and control (BMPs). The Canton mill has an
extensive spill recovery system. Sumps in this system, including one sump added in the court
yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped
with pumps that are activated automatically when sensors detect wastewaters with high
conductivity and color. High conductivity material is routed to the recovery system. Further
improvements to the black liquor collection system include:
• continuous improvement of operating practices so more leaks and spills are
recovered rather than discharged to sewer;
• further improvement in preparation for planned outages to maximize capture of
tank clean-out waste and routing to recovery;
• further reducing clean water that continuously runs into sewers to prevent dilution
of smaller spills and facilitate recovery of highly colored wastewaters; and
• further improvement in the equipment used for handling of knots rejects to
prevent black liquor leaks into the recovery sumps.
The plot below shows the color of wastewater treatment influent at the Canton mill. The
variability of influent color discharge to wastewater treatment is attributed to color discharge
peaks that represent, in part,unplanned spills or leaks discharged to sewers or intentional
diversions of highly-colored black liquor or other color sources routed to sewers during mill
equipment shutdowns.
kg/t
Figure 1
75 Daily color at influent to W W TP for Canton
so
25
L0 30 60 90 120 150 180

Page 6
Due to the nature of the manufacturing processes and practical equipment operation and
reliability, all spills and color losses to sewers cannot be fully anticipated, predicted, and
completely contained. However, a comparison of the variability of the Canton mill influent color
data to available primary influent color data at another bleached papergrade kraft mill indicate
that a detailed review of the spill prevention and recovery system at the Canton mill (by mill
staff or external consultants), including involvement by the mill operators, can further uncover
the causes of and better quantify black liquor losses and other color sources that can be avoided
or recovered. This will result in an overall reduction in color discharge, both in long-term
average and variability. Through improved planning of mill equipment shutdowns;continuing
�p aj efforts to minimize process operation variability, and increased recovery of highly-colored leaks
and spills, discharges of highly colored material to the wastewater treatment system can be '
reduced more consistently below existing levels.
Further reducing peaks in color discharges within the mill and preventing highly colored flows
from reaching the wastewater treatment system will further reduce the variability of color
discharges from the wastewater treatment system to the Pigeon River. For example, limiting the
color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to
improve the mill's 8MP system and process operations would reduce the color loadings from
mill processes to the end-of-pipe wastewater treatment system by more than P,000 IbIdayl The
Canton mill operated under this primary clarifier influent color threshold approximately 74
percent of 2000, excluding November through December 2000. This time period Enconsidered
not to be representative of steady-state operations because of the reduced pulp production
resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average
reduction of 45 percent across this"wastewater treatment system for"brown" color derived from
black liquor, this would result in a minimum decrease o ,4001b/da in the average final
effluent color load. AO-J ) � __�41 �`�� 0/�' \
Clean water, such as packing gland water, presently flows in several sewers with recovery
sumps. These colorless streams dilute other colored wastestreams, such as small black liquor
leaks and spills, to the point where the in-stream conductivity is too low to trigger recovery. By
eliminating clean water streams or diverting them away from sewers that collect black liquor
leaks and spills, wastewater streams with elevated color can be recovered more readily,resulting
in a reduction in color discharge to the end-of-pipe wastewater treatment system. Also, the
unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can
be recovered.

Page 7
At this time, the Tech Team has no basis for determining an accurate correlation between
unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill
Environmental Performance Update presented by Blue Ridge during the March 14,2001 Tech
Team Canton mill visit. During the March 14 visit, Blue Ridge staff indicated that results of
studies of sewer generated color showed a relationship between bleach plant filtrate pH and
temperature and unaccounted color generated in mill sewers. By operating within the range of
pH and temperatures identified during the studies the Canton mill has had some success in
controlling this source of unaccounted color. Based on this information, the Tech Team
concludes that by further reducing process operation variability, including operating within the,
pH and temperature range identified during the studies,the mill can continue to also minimize ,
sewer generated color,thereby reducing one source of unaccounted color. Reducing overall
color discharges through BMPs and other management practices will likely further reduce
remaining unaccounted color. However, additional studies are necessary to further develop any
relationship between accounted and unaccounted color sources. —
As noted above, analysis of primary clarifier influent color loading data demonstrates that color
loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during
steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and
intentional discharges of colored streams and continuing efforts to minimize process operation
variability,the Canton mill can achieve fiirther reduced primary clarifier influent color loads and
subsequent final effluent color discharge within this range on a more consistent basis than
demonstrated in 2000 (i.e., more than 74 percent of the time). On this basis,the Tech Team
concluded it is feasible to reduce final effluent color by more than 5,000 lbs/ ay through
improved black liquor leak and spill collection and control.
3. Ozone/Chlorine dioxide stage for hardwood bleach line. Ozone is used in more than ten kraft
mills around the world to bleach pulp, including two in the US and one in Canada. There are
several process configurations, but the most common is to operate an ozone (Z)mixer and
reactor immediately upstream of a chlorine dioxide reactor, without any washing between the
application of the two chemicals. This is known as a"ZD" stage. A system of this type was
retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999? Bleachin with ne on
the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 7 percent r duction in f�°�',�;"/�
the discharge of color in the combined mill treated effluent.' The conversion to a ZD stage
2 Munro,Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching Sequence,Tappi,2000. �w
3 Ibid.

Page 8
would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for
ozone. The energy requirements for ozone production would be offset by the energy savings
from less chlorine dioxide and caustic production,resulting in a net reduction in energy
consumption with the ZD stage.
As of September 2000, the long-term average color discharge from Canton's hardwood bleach
line was 12,800 pounds/day'. The Espanola experience suggests that implementation of a ZD
stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by
3,000 to 6,400 lbs/day. Based on comments received, the Tech Team acknowledges that
operating parameters, such as wood species processed and technology supplier performance
guarantees, may influence the practical color reduction achievable through implementation of a
ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are
based solely on the demonstrated performance and the Tech Team's assumption of color sources
at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada
(PAPTAC)meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible
communication between Blue Ridge and Domtar staff would be necessary to reliably predict the
achievable color reduction possible with this option for the Canton mill.
�FR r The technical evaluation of this process improvement included in the BEPER yielded a
hardwood filtrate color discharge reduction within the range of Tech Team estimates.
4. 2"d stage OD for pine line. Oxygen delignification(OD) on the Canton Mill pine line is a
single stage system installed in 1993. It has been concluded that retrofitting a second OD stage
for the pine line could contribute to reduced color discharges in two ways. The first would be a
reduction in color for those filtrates presently not captured and reused in the BFR process. The
second would be a color reduction in the Chloride Removal Process (CRP)purge stream as a
result of less chloride from chlorine dioxide used for bleaching.
Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed
upstream of the existing reactor. Previously,the Tech Team anticipated increasing the kappa
number(lignin content) of the cooked pulp from 24 to 32 and utilizing a two-stage OD system to
reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two-
stage system. Based upon comments from BRP and further technical analysis, and review of the
BEPER, it was concluded that it is technically feasible for a two-stage OD system at the Canton
4 Jacobs Engineering Group,2001 Color Removal Technology Assessment,February 2001.

Page 9
mill to achieve an overall reduction of 50 percent in kappa number, rather than 65 percent as
previously anticipated. Therefore, with the Canton mill continuing to pulp to a kappa number of
24,the new two-stage OD system would reduce pulp kappa number into the bleach plant from
the current output of 16 to about 12, corresponding to a 50 percent kappa number reduction from
the current digester output of 24. The quantity of color released from the bleach plant will be
reduced in proportion to the reduction of the input kappa number.
By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a
two-stage OD system, the quantity of chemicals required in the first two stages of the bleach
plant can be reduced, because there is less lignin present in the incoming pulp to remove by
bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional
reduction in chloride load to the CRP and reduce color discharged from the purge stream in
proportion to the reduction in chloride being treated.
In response to comments received, it has been concluded that implementing a two-stage OD
system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve
a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving
greater delignification with the proposed two-stage OD system. However, operating a two-stage
OD system with a higher than 50 percent delignification rate and a digester kappa number higher
than currently employed at the Canton mill is commonly seen at comparable bleached
papergrade kraft mills. Therefore,the Tech Team anticipates that additional process engineering
will maximize the benefits of a two-stage OD system at the Canton mill and enable the mill to
capture the increased delignifcation and yield gain potential of this technology and achieve
annual wood cost savings of up to approximate $950,000 from up to a 1.5 percent yield increase
across the proposed two-stage OD system.
Based on additional information supplied by Blue Ridge regarding operational limitations of the
BFR system, the Tech Team concludes that a two-stage OD system would not have a significant
impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on
a day-to-day basis.
For this analysis, it was estimated preliminarily that a second OD stage could reduce total
influent color discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from
reductions in pine line bleach plant filtrate color and CRP purge stream color.

Page 10
The technical evaluation of two-stage OD included in the BEPER yielded reduction in color
discharge influent to the wastewater treatment system within the range of the Tech Team
estimates.
5. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP) purge is a low
flow, highly concentrated waste stream. Color is typically 50,000 pen, in a 10 gpm(0.01 MGD)
flow. The CRP purge contributes up to approximately 5,000 lbs/day (13 percent) to the total mill
loading to the wastewater treatment system influent, but only 0.06 percent of the discharge flow.
It was originally speculated that it may be feasible to reduce the color in this stream by
precipitating the colored organic material with lime at a dosage of 20 g/L5, and burning the
resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials
would be necessary to test the feasibility of color removal from the CRP purge stream by lime
treatment.
Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium
compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The
preliminary results of these trials show that at a dosage of 20 g/L, none of the compounds tested
reduced color in the CRP purge stream. Although color removal was demonstrated at higher
dosage rates, increased chemical usage would result in substantially higher operating costs,
require larger sized equipment at higher capital cost, and also result in a higher production rate of
sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not
burned must be landfrlled at additional cost.
Based on preliminary laboratory trials,Blue Ridge concluded that lime treatment of the CRP
purge is not a feasible color reduction option for the Canton mill. However, the Tech Team
recommends additional review of other innovative technologies for treatment of color in the CRP
purge stream, such as the application of the X-Filter process recently implemented at a totally
chlorine free(TCF) mi116. By minimizing color contributions from this stream, the potential
exists to achieve a significant reduction in primary influent color discharge of up to 5,000
lbs/day.
5 NCASI Technical Bulleting No.239,The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching
Effluents with Lime.I. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970. '
6 Comments on the Draft Report on Additional Color Removal.Technologies and Economic Impacts for BRPP,Hope
Taylor,Clean Water Fund of North Carolina,July 18,2001

Page 11
6. Process Optimization. The BEPER identified sixteen recommendations for optimizing the
hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching
operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the
first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood
line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction
of up to 700 lbs/day from the hardwood line and up to 400 lbs/day from the softwood line. The
Tech Team estimated an additional color reduction from the CRP purge stream of 6001bs/day
resulting from the decreased chlorine dioxide usage. At this time,the Tech Team has no means
of making an alternative quantitative prediction of bleach filtrate color reduction to compare to
estimates presented in the BEPER. Therefore, it is estimated that through efforts by mill staff to
maximize the color reduction benefits from the process optimization opportunities identified by
Liebergott, et, al., the Canton mill would achieve a total color reduction of 1,7001bs/day in
wastewater treatment system influent.
Color Reduction Summary
The Tech Team estimates that by improving BFR reliability and black liquor leak and spill
collection and control, the Canton mill final effluent will be reduced by more than 5,000 lbs/day.
Process optimization, as outlined in the BEPER, would result in a further final effluent color
reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45
percent across the existing wastewater treatment for the CRP purge stream and other"brown"
color sources derived from black liquor and no reduction in color from bleach plant filtrates.
Table 1 presents asummary of the estimated reductions in final effluent color attainable with the
highest certainty by implementing improved BFR reliability, improved BMPs, and process
optimization.

Page 12
Table 1: Summary of Process Improvements and Associated Color Reductions
(Highest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) Qbs/day)
1 BFR reliability improvement --- 1,000-1,200
2 Improved black liquor leak& spill collection and --- > 5,000
control
6 Process Optimization 1,700 1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION >7,400
Additional potential mill improvements to reduce color discharge at the Canton mill were also
identified. These process improvements require further study to more accurately determine
achievable color reduction and thus are not recommended at this time for immediate
implementation. These improvements include a ZD stage in the hardwood bleach plant, with a
preliminary estimate of a 3,000 to 6,400 lbs/day color load reduction in influent to the
wastewater treatment system, and a second OD stage for the pine line, with a preliminary
estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment
system. Table 2 presents a summary of preliminary estimates of color reductions for these two
additional process improvements that need further study. Reductions presented in Table 2 are
preliminary estimates with reduced certainty compared to those presented in Table 1, but are
based upon identified technology options available for the Canton mill.

Page 13
Table 2: Summary of Process Improvements and Associated Additional Color Reductions
Needing Further Study (Reasonable Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400
line
4 2"d stage OD for pine line 1,500-2,000 1,100-1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 - 7,800
Table 3 presents a preliminary estimate of color reduction potential for the removal of color from
the CRP purge stream. The Tech Team recommends this stream for additional review of
potential color reduction technologies but cannot identify a particular technology option at this
time. Potential for additional color load reduction up to 2,750 lbs/day in final effluent to the
Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty.
Table 3: Summary of Additional Potential Color Reductions Needing Further Study
(Lowest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (Ibs/day)
5 1 Color Treatment of CRP Purge Stream #5,000 #2,750
TOTAL ADDITIONAL POTENTIAL FINAL EFFLUENT COLOR #2,750
REDUCTION
�i ran s ay7v
_ ``

Page 14
Economic Analysis
The estimated capital and operating costs for the process improvements one through four were
estimated and are summarized below. Costs could not be developed at this time for process
optimization or CRP treatment and thus are not presented. However, costs for these
improvements should be modest.
Table 3: Estimated Costs
Process Improvement Capital Cost Annual O&M
($) ($/year)
1 BFR reliability improvement $1,300,000 $85,000'
2 Improved black liquor leak& spill collection and $100,000 $50,000
control
3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000)
line savings
4 2"d stage OD for pine line $2,000,000 ($2,100,000)
savings
Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven
plants (including the Canton Mill) from Champion International Corporation. Blue Ridge Paper
Products is owned 55 percent by KPS Special Situations Fund,L.P. and 45 percent by the
employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the
1997 report EPA documented substantial losses over five years for the Canton Mill and
Champion had just announced its intention to sell or close the mill. However,because of the sale
of the mill to the Blue Ridge, the previous data are not comparable to the more recent data.
Further,the data submitted by Blue Ridge is still confidential, so this report cannot present as
much detail as the 1997 report.
The current analysis is based on information submitted by Blue Ridge covering part of
1999 (May-December) and all of 2000 (all of the existing financial data for the company). The
results may be relatively uncertain because of the lack of data and the company may be too
young for the current data to reflect its ultimate financial health. EPA used three measures of
financial health (gross profit test, discounted cash flow, and Altman's Z)7 to assess the impact of
7 See Interim Economic Guidance for Water Quality Standards: Workbook,EPA 823-B-95-002,March 1995,and
Economic Analysis for the National Emission Standards for Hazardous Air Pollutants for Source Category: Pulp and
Paper Production; Effluent Limitations Guidelines,Pretrpatment Standards,and New Source Performance
Standards:Pulp,Paper, and Paperboard Category—Phase 1.

Page 15
air emissions control technologies and devices (not addressed in this memorandum, such as
MACT II and regional NOX control) and wastewater compliance costs (separate and combined)
on the mill and company. The costs for the wastewater control options presented in Table 3 do
not change the financial status of the mill or company. However,the costs for some of the air
emissions control options do impact the health of one or both entities. When the wastewater
costs are added to costs for air emissions control, the impacts of the water costs do not change
the financial status of either the mill or company when compared to the impact of the air costs
alone.
References
Blue Ridge Paper Products,Inc. Canton Mill Canton Mill Environmental Performance Update,
Prepared for U.S. EPA Technology Review Workgroup.March 14, 2001.
Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic
Analysis of Blue Ridge Paper Products, from Bob Williams,May 18, 2001 (CBITS 00003911-
01)
Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown, Blue Ridge,
to Don Anderson, EPA, May 18, 2001
Comment Clarification of May 18, 2001 Blue Ridge Responses to EPA Questions, from Derric
Brown,Blue Ridge,June 4, 2001
Comments on Draft Final Tech Team Report, from Bob Williams, Blue Ridge,to Don Anderson,
EPA, July 13, 2001
Comments on Draft Final Tech Team Report, from Derric Brown, Blue Ridge, to Don Anderson,
EPA, July 17, 2001
Comments on Draft Final Report, email from Forrest Westall,North Carolina DENR, to Don
Anderson,EPA, July 17, 2001
Comments on Draft Final Report on Additional Color Removal Technologies and Economic
Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina,July 18, 2001

Comment on Draft Final Tech Team Report, email from Paul Davis, State of Tennessee, to Don
Anderson, July18, 2001
Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott,to
Don Anderson, EPA, July 19,2001
Jacobs Engineering Group, 2001 Color Removal Technology Assessment,Blue Ridge Paper
Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001.
Liebergott,Norm, and Lew Shackford, Bleach Environmental Process Evaluation and Report,
June 8, 2001
McCord, Aimee,A Laboratory Analysis of Color removal Across a Pulp and Paper Mill
Wastewater Treatment Facility, Canton, North Carolina, Duke University, School of the
Environment, 1995
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.
NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of
Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching
Effluent. July, 1970.
Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater
Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina, Duke University, School
of the Environment, 1996
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry. Page 182
Wiley Interscience, 1986.
Springer,Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry, 3rd edition.
Page 286. TAPPI Press, 2000.

Appendix 1: Color Balance (9/l/00 to 12/31/00)
Figure 2.6,Presented by Blue Ridge on March 14,2001
Sewer Description Color Load
ID (Ibs/day)
2B Digester area sewer: Digesters,HW 4,323
line, knot rejects
3A Alkaline sewer: Pine and HW Eo, 12,954
Pine line BSW, 02 Delig
1 PMsl1 & 12, HW weak liquor tank 1,991
5B Recovery,BLOx, CRP* 7,852
6A Acid sewer: Pine and HW Dl 17,345
filtrate+Pine D2 filtrate
Contaminated Condensate 1,591
Combined Condensate 260
Total 46,316
Primary Influent(PI) 49,284**
Unaccounted Color 2,968
(PI minus Total)
Secondary Effluent 37,696
Percent Removal in Treatment 23
* CRP contributes 5,000 to 6,000 lbs/day to 5B sewer
** Measured using test method in NCASI Tech. Bull. 803, An Update of Procedures for the
Measurement of Color in Pulp Mill Wastewaters, May 2000.

Appendix 2: Table of Effluent Color Limits, 1997 to Present
Color Limit True Color(Ibs/day)
Monthly Average Annual (Long-term)
Average
1997 Permit 125,434 98,168
Settlement Agreement, February 1998 69,000 60,000
(starting December 1, 1998)
Settlement Agreement, February 1998 --- 48,000 to 52,000
(Ultimate Target)
Interim Limits, May 2001* 55,000 48,000**.
* As recommended by Technology Review Workgroup (TRW) and incorporated by NC in
BRP's NPDES permit.
** Reduced end-of-pipe color discharges since November 2000 reflect; in part, reduced pulp
production (approximately 30 percent) during this period because of the ongoing project to
upgrade the No. 19 paper machine used to produce bleached paperboard.

/
Appendix 3: Ozone Bleaching
Munro,Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.

r
Appendix 4: Two-Stage Oxygen Delignification
Comparison of one- and two-stage oxygen delignification systems
Item Current Single-Stage System Proposed Two-Stage System
Oxygen Reactors One two
Input Kappa Number 24 24
Output Kappa Number 16 12
Total C102 Used 28 kg/ton* 22 kg/ton*
Oxygen Used 23.4 kg/ton* 28.3 kg/ton*
Total NaOH Used 45 kg/ton* 37 kg/ton*
* air-dried metric ton of bleached pulp

Q M
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4
Department of Environment and Natural Resources
Division of Water Quality
Fact Sheet For NPDES Permit NC0000272 1
o
A921W
Facility Information
Applicant/Facility Name': Blue Ridge Paper Products Inc.
Applicant Address': P.O. Box 4000
Facility Address": 175 Main Street
Permitted Flow2.4,1: 29.9 MGD
Type of Waste','.7: Industrial, domestic, stormwater, and landfill leachate
Facility/Permit Status°: Renewal
CountyZ•4,7:. Haywood
Miscellaneous
Receiving Stream24: Pigeon River
Stream Classification'•Z: C
303(d) Listed?': Yes - Fish Advisory, Dioxins
SubbasinZ: 04-03-05
Drainage Area (mq2 : [calculated] 130 mf
Summer 7Q10 (cfs 52 cfs at Canton and 120 cfs at Hepco
Winter 7Q10 (cfs) . 63 cfs at Canton and 183 cfs at Hepco
Average Flow (cfs)': 325 cfs at Canton and 677 cfs at Hepco
IWC (%): 100% (See Text Below)
Primary SIC Code: 2621
Regional Office: Asheville
USGS Topo Quad: Canton (E 7 SE - State Grid)
Permit Writer: Michael Myers
Date: July 24, 2001
SUMMARY
Blue Ridge Paper Products Inc. has requested renewal of their National Pollutant Discharge Elimination
System (NPDES) discharge permit NC0000272 allowing discharge of industrial, stormwater, municipal
and landfill leachate wastewaters to waters of the state. The NPDES permit will expire on November
30, 2001 and the application for renewal was received on February 23, 2001. This fact sheet
summarizes the rationale used to develop the North Carolina Division of Water Quality's
recommendations for the draft permit.
BACKGROUND
Blue Ridge Paper is an employee-owned and operated integrated, elemental chlorine free (ECF)
bleached kraft pulp with oxygen deligninifcation and bleach filtrate recycle, and paper mill in Canton,
North Carolina. Processes at the mill include a pine bleach line; hardwood-bleach line, paperboard and
fine paper production lines. Pine and hardwood chips are transported to the site via rail or truck and
subsequently processed into pulp for paper or paperboard production.
In or around 1990, Champion International Corporation (Champion Paper- now Blue Ridge Paper)
initiated a $300 million dollar modernization project termed the Canton Modernization Project. This
project eliminated the use of elemental chlorine and implemented significant changes to-both the pine
and hardwood bleaching lines.
The mill upgrade included two changes that dramatically improved the mill's environmental impact.
The first major change was the use of oxygen delignifrcation. This process is used to separate the
lignin from the fiber. This resulted in significant improvement in the mills environmental performance.
The second major change was the implementation of full-scale bleach filtrate recycle (BFR) on the pine
bleach line and caustic extration stage (E.) filtrate recycle (-20%) on the hardwood bleach line. For a
Fact Sheet
NPDES Renewal
Page 1

more detailed description of the mill improvements, refer to the Canton Modernization Project Section
below.
The Canton Modernization Project greatly reduced the wastewater generated and eventually discharged
to the Pigeon River. Even with these improvements, significant quantities of wastewater are generated
in the production of pulp and paper and proper treatment prior to discharge is required.
Wastewater generated by the Canton Mill, along with the Town of Canton's domestic wastewater, is
treated at Blue Ridge Paper's Wastewater Treatment Plant. The treatment plant is a 29.9 MGD
wastewater treatment system consisting of the following unit processes:
• Grit Chamber
• Bar screens
• Lift pumps
• Polymer addition
pH control (CO2 injection or H2SO4 backup)
• Three primary clarifiers (one normally off-line)
• Nutrient feed
• Aeration basins
• Three secondary clarifiers
• Residual belt presses
• Effluent flow measurement
• Cascade aeration (with oxygen injection)
• Oxygen injection facilities
Solids at this facility are deposited into a dedicated landfill.
The history of this mill, under the ownership of Champion Paper and now Blue Ridge Paper, has been
controversial. Under Champion Paper, the environmental impacts of the Canton Mill were noted by
concerned citizens, environmental groups, the State of Tennessee, State of North Carolina, and the
United States Environmental Protection Agency (EPA). The issues raised by these individuals and
groups contributed to the Canton Mill's improved environmental performance and resulted in a
settlement agreement issued January 8, 1998. Today the relationship among the various stakeholders
has evolved to one of cooperation. The Division commends all the groups for their willingness to work
together to improve water quality. This permit has centered around four main issues emanating from
the mill's discharge: color, temperature, oxygen consuming waste and dioxin, and a.brief synopsis
follows.
Color
On July 13, 1988, Champion Paper was granted a variance from North Carolina's narrative water
quality standard for color, which the EPA interpreted to be 50 color units. The EPA subsequently
issued a NPDES permit to Champion Paper facility in Canton, North Carolina.
In 1994, the EPA returned NPDES permitting authority for the Canton Mill back to North Carolina's
Division of Water Quality. During the permit renewal the original color variance was modified and
both were issued around December 11-12, 1996. As outlined above, over the course of this variance
the mill has initiated significant improvements, which have dramatically reduced the color loading and
other effluent characteristics.
Though the mill has made tremendous strides, color continues to be the focal point surrounding this
permit. The EPA chaired Technology Review Workgroup have recommended additional color
reduction for the up coming permit cycle. The recommendations issued by the Technology Review
Workgroup included the findings of a third party evaluation of Blue Ridge Paper's Canton mill and the.
"report issued by the EPA Tech Team . The evaluation conducted by Dr. Norm Liebergott was co-
sponsored by Blue Ridge Paper and several environmental groups and provided valuable information
for the TRW'. In addition, to identifying areas for improvement and available technologies, Dr.
Liebergott compared the Canton mill to similar mills around the world. Dr. Liebergott concluded that
the Canton mill's environmental performance is among the best in the world.
Though incredible work has been done, there continues to be a need to reduce color further. Blue
Ridge Paper's openness and willingness to work towards continued improvements has resulted in an
atmosphere of trust and cooperation among all the interested parties. This cooperation has been
extremely valuable and will continue to be critical as the additional color reductions recommended by
the Technology Review Workgroup are implemented (see attached July 24, 2001„memo from the EPA
Tech Team to the Technology Review Workgroup).
Fact Sheet
NPDES Renewal
Page 2

The Technology Review Workgroup report identifies process improvements that will result in permitted
color reductions of 6,000 pounds per day. In addition, the report identifies process improvements that
will require further study but are likely to result in total color reductions in the range of 9,000 - 14,000
pounds per day. The mill will also evaluate the feasibility of treating the highly colored low flow
wastestream from the chloride removal process (CRP). The feasibility of additional color reductions
associated with the treatment of the CRP wastestream is highly uncertain and no color reductions have
been established for this permit cycle. The result of a feasibility study on the Chloride Removal
Process wastestream will be evaluated for possible additional color reductions for the next permit cycle.
As shown in Table 1, the 6,000 pound per day annual average color reduction will become effective on
December 1, 2003. Additionally, the mill will evaluate additional process improvements in order to
achieve an annual average effluent color loading of 34,000 - 39,000 pounds per day. If the limits
determined to be achievable are within the target range,the limits shall become effective on December 1,
2005, by written notification from the Director. In the event that the achievable limits are outside of this
range then the NPDES will be reopened. At that time, public comments will be gathered and the permit
may be modified.
Table 1. Major Dates for Compliance/Reports.
Submittal/Compliance ate Requirement
2002 is issue toy Report
October tatisttca eva uatton of performance for determination of the monthly
average effluent color limit
December 1,2003 First reduction in ettluent color limit
December 1, 2003 Feasibility report on additional process improvements for further color
reductions
2004 Fish issue Study Report
December 1, 2005 Statisticalanalysis and feasibility report on treatment of URP
wastestream
March Second reduction in effluent color limit
----Marc Comparative Evaluation Report
may Balanced and Indige-n-o-u-s-S'pecies study Report
Temperature
The facility first requested and received a 316 (a) variance (approved by EPA) for temperature on
August 6, 1985. This determination demonstrated that the effluent limitations relating to the thermal
component of the Champion discharge were more stringent than necessary to assure protection and
propagation of a balanced indigenous population of shellfish, fish, and wildlife in the Pigeon River.
Therefore, the 316(a) determination was approved based on protection of the appropriate use
classification of the Pigeon River. The temperature variance was reviewed and renewed as part of the
Triennial Review in 1997.
Blue Ridge Paper submitted a Balance and Indigenous Species Study on the Pigeon River on June 1,
2001. DWQ scientist have reviewed the report and concluded that continuance of the temperature
variance is appropriate. Therefore, the Division of Water Quality is recommending continuation of the
temperature variance with reporting requirements consistent with the previous permits (see Table 1).
Oxygen Consuming Waste
An EPA approved model predicted that even with a BOD5' loading of 1209 lb/day (5.0 mg/L at 29
MGD) that the dissolved oxygen in the Pigeon River would not be protected. Since Blue Ridge Paper
cannot comply with such stringent limitations, an instream method was implemented to protect the
dissolved oxygen in the receiving stream. For further discussion on this subject refer to the
conventional pollutant section below.
Dioxins
Elevated levels of dioxins were found in fish tissue in the Pigeon River (around the late 1980s).
Subsequently, a fish consumption advisory was issued for sport fish, catfish and carp. The Canton Mill
has not discharged any detectable levels of 2,3,7,8 TCDD to the Pigeon River (since 1989) and dioxin
in fish tissue continue to decline. Currently, a fish consumption advisory continues for carp and
catfish. North Carolina has lifted the advisory on sport fish. However, the State of Tennessee
continues to post a precautionary fish consumption advisory for carp, catfish and red breasted sunfish.
BOD5 is an analytical method used to estimate the biochemical oxygen demand.
Fact Sheet
NPDES Renewal
Page 3

The fish consumption advisories in North Carolina and Tennessee are currently under review for
possible modification of the advisories. The North Carolina Division of Environmental Health (DEH)
has initiated a review of the fish consumption advisory on Pigeon River and Waterville Lake. DEH is
evaluating dropping the advisory on catfish in the North Carolina portion of the Pigeon River and
limiting the advisory on Carp to Waterville Lake. A final determination may not be finalized prior to
permit renewal, therefore, recommendations presented in this permit do not reflect this evaluation.
STREAM CONDITIONS
The facility discharges to the Pigeon River near Canton, North Carolina. The Pigeon River from
Canton to Hurricane Creek is listed as an impaired water, according to North Carolina's 2000 Draft
303(d) List, due to a fish consumption advisory for dioxins. Recent data indicate that the dioxin levels
in fish tissue continue to decline. There has been no detection of 2,3,7,8 TCDD in sport fish since
1995 and below North Carolina's fish consumption advisory level for 2,3,7,8 TCDD in catfish since
1997, based on Blue Ridge Paper's data. 2,3,7,8 TCDD continues to be detected in carp, though levels
continue to decline and are below North Carolina's advisory level.
The Pigeon River has been experiencing extremely low flows; due to extended drought conditions in
the western part of the state, with flows often less than the 7Q1O flows of 52 cfs (near Canton). Curtis
Weaver, with the USGS, provided the updated low flow statistics noted above using data from 1933
through 1999. The low flow statistics at Canton include the influence of Lake Logan, which was
constructed in 1932 and the influence of both Lake Logan and Lake Junaluska (constructed in 1913).
This reflects the current hydrography within the watershed and does not reflect conditions prior to
construction of the lakes.
The impact of this reevaluation of the low flow statistics is that the lowest seven day average flow
expected once in ten years (7Q10) has been reduced from 54 cfs to 52 cfs. This affects the instream
waste concentration which is used to determine the limits for the toxicity testing (discussed later).
INSTREAM MONITORING
The current permit requires Blue Ridge Paper to conduct an extensive instream monitoring program
consisting of 12 monitoring sites (1-upstream of mill in Pigeon River, 3-Waterville Reservoir, and 7-
downstream of mill in Pigeon River and 1-Big Creek; See Figure 1 and Table 2).
Instream Monitoring by Parameter
Blue Ridge Paper is required to monitor fecal coliform upstream (at station UP) and downstream of the
discharge (at station DNI). Analysis indicates no discernable difference between the upstream and
downstream fecal coliform levels. Upstream fecal coliform is generally in the range of 100 to 200
/100m1. The same trend is evident at the downstream sampling point. These data suggest that Blue
Ridge Paper does not contribute significant levels of fecal coliform. Monitoring of the effluent is
sufficient to monitor the mill's impact on the river. Blue Ridge Paper has volunteered to conduct
upstream sampling and this requirement will remain as a condition in the permit. Thus, the Division's
recommendation is the elimination of the downstream fecal monitoring and once per week fecal
monitoring upstream.
Blue Ridge Paper is required to monitor conductivity upstream (at station UP) and downstream (at
station DN1). There is a significant increase in conductivity between the upstream and downstream
monitoring sites. Conductivity measurements are less than 50 umhos/cmZ at the upstream monitoring
station and generally greater than 250 umhos/cm2 at the Fiberville Bridge. This increase in
conductivity is expected since conductivity is a measure of inorganic material. Thus, the Division's
recommends that conductivity monitoring continue as required by 15A NCAC 2B .0508(d).
Fact Sheet
NPDES Renewal
Page 4

Figure 1. Instream Monitoring Stations for Blue Ridge Paper Products - Canton Mill.
¢ubon 9¢.o-Abe..gip cr•••
an I
cupn epee-n.pae
station s1A-Above CIO,
Io,�/({ t WRic LedJL ek
\Station 02.9-Man Bridge
f.
bNon Ba.S-Uprn.m of BWe flidp•paper
J
USGS Sites
Primary Highways
Pigeon River Hydrography
NPDES Discharger
Municipal boundaries
The facility is required to monitor 5-day Biochemical Oxygen Demand (SODS) upstream at station UP
and downstream of the discharge at the station DN7. Levels of BOD5 have been less than 2.0 mg/L.
Based on this information and the Division's lack of need for the data, it is recommended that instream
BOD5 monitoring be eliminated from the permit.
Fact Sheet
NPDES Renewal
Page 5

Table 2. Instream Monitoring Requirements According to the 1997 NPDES Permit and Color
Variance.
Cream Mile Location Description Parameter Frequency
Designation Marker
UP 63.8 Pigeon River upstream of the I emperamre Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the BODS I/Week
discharge) Conductivity Daily
Color 2/Week
Flow Daily
Fecal coliform ][Week
Pigeon Rivir at Fiberville Bridge Temperature Daily
D.O. Daily
Conductivity Daily
Fecal Coliform I/Week
Color 2/Week
Pigeon River Above Clyde Temperature Daily
D.O. Daily
D. Pigeon River Below Clyde TemperatureI/Week
D.O. I/Week
Color 2/Week
Pigeon River at NCSR 1625 1 1 emperamreI/Week
bridge D.O. I/Week
Color 2/Week
Pigeon River at kiepco TemperatureI/Week
D.O. ][Week
Color 2/Week
Flow Daily
Waterville Reservoir Annually
DN6 26.0 Pigeon River prior to mixing Color2/Week
with Big Creek
Mouth of Big Creek prior to Color2/Week
mixing with the Pigeon River
Pigeon River at Browns Bridge TemperatureI/Week
(—NC/IN State Line) D.O. I/Week
BOD5 ][Week
Color 2/Week
Blue Ridge Paper monitors temperature upstream at station UP and downstream at all monitoring
stations except station DN6 and station BC. Comparing upstream to downstream, see Figure 2, the
temperature difference ranged from between 1.78 °C and 11.65 °C. At no time did the monthly
average temperature of the Pigeon River exceed the permitted limits of 32 °C (summer) or 29 °C
(winter).
Blue Ridge Paper monitors dissolved oxygen (DO) at all the instream stations except station DN6 and
station BC. Over the period of review (1998 —2000), dissolved oxygen did not drop below the North
Carolina's standard of 5.0 mg/L for Class C streams at any of the instream monitoring locations.
Figure 3 summarizes the results of this analysis.
During the previous permit cycle, an EPA-approved computer model indicated that BOD5 limits were
required to protect North Carolina's instream dissolved oxygen standard of 5 mg/L for Class C waters.
An economically feasible end-of-pipe technology capable of consistently treating to levels necessary to
meet the limits specified by the model did not exist. North Carolina agreed with the continuation of the
requirement that Blue Ridge Paper meet the instream dissolved oxygen standard by use of sidestream
oxygen injection facilities. Blue Ridge Paper maintained these oxygen injection facilities at the effluent
and at approximately 0.9, 2.1, and 3.7 miles downstream of the discharge. The previous NPDES
permit required Blue Ridge Paper to maintain the oxygen injection facilities located 0.9 and 2.1 miles
downstream.
To ensure compliance with the above requirement, the average daily instream dissolved oxygen levels
at stations DNl, DN2 and DN3 were required to equal or exceed 5.0 mg/L and the minimum
instantaneous instream values were required to be greater than or equal to 4.0 mg/l. If dissolved
oxygen drops below the prescribed values Blue Ridge Paper shall utilize the instream dissolved oxygen
injection stations to increase the dissolved oxygen in the river.
Fact Sheet
NPDES Renewal
Page 6

This method fulfilled the requirements of 40 CFR 125.3 (f).
Blue Ridge Paper has compiled an extensive database on instream dissolved oxygen concentrations and
stream flow. These data suggest that the dissolved oxygen sag occurs at station DN2.
Figure 2. Temperature in the Pigeon River Upstream and Downstream of Blue Ridge Paper's NPDES
Discharge.
35
Permitted Limits
30 SummerUng=3YC 1"VA C
WmfvUd=29°C dr<2XC
25
ems^ 20
@ �Siafion UP
�Statlon DN7
n -i—Delta T
o t5
PemU ' =13.9T
10
5
0
Nav-98 Fet-99 May-99 Aug-99 Dec-99 Mar-00 Jun-00 Oct-00 Jan-01 Apr-01
Time
Figure 3. Average and Minimum Dissolved Oxygen in the Pigeon River from River Mile 63.5 to the
NC/TN State Line. (Average DO* = In(DO))
12.00
10.00
8.007
rn
E
+Average DO
O1 —1F-Minimum
6.000 y_Q@ndard
9
—Average DO*
0
N
N
4.00 0
BRP discharge N(7fFNNSIdeLire
2.00
0.00
70.00 Moo 50.00 40.00 30.00 20.00 10.00 0.00
River Mile
Fact Sheet
NPDES Renewal
Page 7

Stations DN2 and DN3 were included because the dissolved oxygen model predicted that the DO sag
occurred in this area and because they represented monitoring locations upstream and downstream of
Clyde's discharge. The Town of Clyde has recently removed their discharge and the Division has
received a letter from the Town requesting rescission of the permit. Based on a review of the instream
data and the removal of Clyde's discharge, it is recommended that the dissolved oxygen compliance
point at station DN3 be eliminated.
The Division reviewed the 1998 through 2000 instream dissolved oxygen data. Over this time period,
Canton, North Carolina has experienced extreme drought conditions and flow in the Pigeon River has
often dropped below the updated 7Q10 stream flow. Under these conditions, the lowest dissolved
oxygen level observed in the North Carolina portion of the Pigeon River was 5.0 mg/L and occurred at
river mile 57.7. Additionally, a review of the average daily instream dissolved oxygen data and the
average over this time period indicates that the dissolved oxygen sag occurs at river mile 57.7. Based
on this analysis, the compliance point and monitoring requirement at river mile 55.5 have been
dropped. The oxygen injection facilities will continue to be maintained at the effluent, 0.9, and 2.1
miles downstream, and used as necessary to maintain an instream dissolved oxygen level of 5 mg/l.
The condition to maintain the instream dissolved oxygen stations shall remain a condition of the permit
until such time that the permitted loading of oxygen consuming waste to the Pigeon River is less than or
equal to that proposed by an appropriate water quality model.
If dissolved oxygen at station 57.7 drops below 5.0 mg/L, the facility is required to monitor dissolved
oxygen at river mile 55.5 and 53.5.
Instream monitoring continues to be required in order to assess Blue Ridge Paper 's impact on the
Pigeon River and to ensure that the dissolved oxygen standard is maintained within the river.
COLOR
The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco
USGS gauge station. The new effluent limits in this permit are more stringent than the provisions in the
1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is possible
to calculate the monthly flow at the Canton gage station above which instream color at the Fiberville
Bridge will not exceed 50 true color units. Using the 55,000 pounds per day monthly average true color
loading limit(implemented on the effective date of the permit)the flow at the Canton Gage station,which
will provide for color less than 50 true color units at the Fiberville Bridge is 171.8 MGD. Therefore,the
monthly average color in the Pigeon River at the Fiberville Bridge will be less than 50 true color units
whenever the monthly average flow(at the Canton gage station) is greater than 171.8 MGD. North
Carolina is recommending that the Fiberville bridge be the basis for the color variance.
The governing flow criterion for true color at Canton is 58.1 MGD (30Q2 stream flow). The flow
established is greater than this 30Q2 stream flow,therefore,for flows less than the 171.8 MGD at the
Canton Gage station but greater than 193.3 MGD at the Hepco gage station,the monthly average color in
the Pigeon River at Hepco will be less than 50 true color units.
Currently, the basis for the color variance is the Hepco station (DN5) within North Carolina, therefore
with the moving of the station from Hepco to Fiberville, DWQ recommends that the mill monitor the
Hepco station 2/week during the summer and once per week during the winter.
During the permit cycle,the effluent color limit will be reduced,therefore,the instream color criteria will
be adjusted accordingly. The monthly average color in the Pigeon River at the Fiberville Bridge will be
less than 50 true color units whenever the flow at Canton is greater than the flow established using the
following equation and based on the monthly average effluent limit established per Special Condition
A.(8:)Paragraph 4:
FlowatCanbnUSGS(MGD)_ (MonthlyAvarageEfflueztColorLiidt,W day—12468.3)+31.6+2.4
308.58
For flows at the Canton Gage station less than the flow established here but greater than 193.3 MGD at
the Hepco gage station, the monthly average color in the Pigeon River at Hepco will be less than 50 true
color units.
Compliance Summary
The facility has been in compliance with permit conditions during this cycle.
Fact Sheet
NPDES Renewal
Page 8

Toxicity Testing
Current Requirement: Chronic toxicity limit monitored quarterly @ 87%
In December 1999 the facility reported a chronic level of 81% (with a state split sample greater than
87%), with the following two months greater than 100. All other toxicity tests over the past four years
were greater than the stipulated 87%.
The toxicity testing requirement is placed on all major facilities and other facilities with complex
wastestreams. The toxicity limit is based on the instream waste concentration under 7Q10 conditions
(52 cfs updated April 2001). For Blue Ridge Paper, the instream waste concentration was determined
by also accounting for the out-take of surface water from the facility (31.6 MGD, as per application)
and water withdrawal by the Town of Canton (allocated 6.8 MGD). Therefore, the instream waste
concentration was determined to be 100% under 7Q10 conditions. The Division has set a ceiling on
the toxicity test of 90%. This was done because of difficulties associated with averaging toxicity test
with limits of 100%. The Division feels that 90% is sufficiently stringent to assess the chronic toxicity
of an effluent, while allowing for the averaging of multiple tests.
Recommended Requirement: Quarterly Chronic Toxicity @ 90% Mar, Jun, Sep, Dec
Blue Ridge Paper is required to perform the NC Whole Effluent Toxicity Test or an equivalent method
(as approved by the Division) on a quarterly basis at 90%. Any equivalent method shall also be
performed on a quarterly basis.
Toxicant Analysis
Using the self-monitoring data required per the NPDES permit, reasonable potential analyses were
conducted on the following toxicants: mercury, zinc, cadmium, selenium and silver. The standards
used for the analyses are consistent with North Carolina standards for a class C waterbody.
Cadmium—Based on the Division's analysis of self-monitoring data, this discharge does not pose a
reasonable potential to cause a violation of the North Carolina stream standard for cadmium. Effluent
monitoring of cadmium shall continue since cadmium continues to be detected in the effluent.
Mercury — Based on the Division's analysis of self-monitoring data, this discharge does not pose a
reasonable potential to cause a violation of the North Carolina stream standard for mercury.
Additionally, all mercury samples analyzed since January 1999 have been below North Carolina's
accepted detection level of 0.2 µg/L. Results from the Division's 1996 Fish Tissue Mercury
Assessment on the Pigeon River indicate, "total mercury results were comparable to `background'
levels expected for fish across North Carolina." Based on the findings in this report and the
`Reasonable Potential' Analysis, it is recommended that mercury monitoring and limitation be removed
from the permit.
Silver -Based on the Division's analysis of self-monitoring data, this discharge does pose a reasonable
potential to cause an exceedence of the North Carolina's Action Level Standard for silver. Numerical
limits for silver are not being included since silver is an action level water quality standard and the
biomonitoring requirements are adequate to control toxicity due to the presence of silver. Though no
limit is proposed, if the facility experiences chronic toxicity violations, the discharge will be re-
evaluated and a silver limit may be implemented according to the Division's Action Level Policy.
Selenium—The Division's analysis indicates that the maximum predicted concentration for selenium is
greater than the allowable concentration. This analysis included only seven data points, with six data
points below the quantitation level. One sample indicated the presence of selenium, however the
concentration reported was at the quantitation level for the method. Additionally, the QA/QC data
questions the validity of this data point. However, the Division has limited Blue Ridge Paper for
Selenium. After collecting for one and half years (six data points) of data, the facility can request that
the Division review the Selenium data for possible elimination of the limit.
Zinc- Based on the Division's analysis of self-monitoring data, this discharge does pose a reasonable
potential to cause an exceedence of the North Carolina's Action Level Standard for zinc. Numerical
limits for zinc are not being included since zinc is an action level water quality standard and the
biomonitoring requirements are adequate to control toxicity due to the presence of zinc in the facility
effluent. Though no limit is proposed, if the facility experiences chronic toxicity violations the
discharge will be re-evaluated and a zinc limit may be implemented according to the Division's Action
Level Policy. Monitoring requirements for zinc are consistent with 15A NCAC 2H .0508 (d).
Fact Sheet
NPDES Renewal
Page 9

OXYGEN CONSUMING WASTE POLLUTANTS
A site-specific Best Available Technology (BAT) based limit was calculated to determine the monthly
average 5 - day biochemical oxygen demand (BODS) limit. A site-specific BAT approach was used
because North Carolina's Division of Water Quality continues to agree that an economically feasible
end-of-pipe technology capable of reliably meeting the water quality limit specified by the existing
model does not exist at this time and no violations of the dissolved oxygen standard in the river have
been observed in recent years.
The North Carolina Division of Water Quality's recommendation for the draft permit BODS limit is
established based on the demonstrated level of performance for the existing treatment plant. Data on
treatment plant performance and influent loading from the Canton Mill (1998 through 2000) was
evaluated and examined for outliers. As indicated in the "Bleach Environmental Process Evaluation
and Report", the performance of this mill is among the best in the world. The maximum influent
loading and lowest treatment plant performance were used to develop the monthly average BOD5 limit.
The data set was sufficient to account for the day to day variability of the treatment system.
Over the time period evaluated, the treatment plant has performed extremely well. The lowest percent
removal was 96.9% and the highest influent loading was 414.9 mg/L. Based on this analysis, North
Carolina's Division of Water Quality recommends a monthly average BOD5 loading of 3205.0 lbs/day.
The limit presented in the draft permit represents and a 71-ton per year reduction in BOD5 loading to
the Pigeon River. Because Blue Ridge Paper has oxygen injection facilities in place to maintain the
instream dissolved oxygen standard should instream dissolved oxygen dictate a need, Blue Ridge Paper
complies with the conditions set forth by 40 CFR 125.3 (f).
The methodology used for the daily maximum 5 - day biochemical oxygen demand (SODS) limit was
recommended during the previous permit cycle. A site-specific daily maximum to monthly average
multiplier was used for determination of the recommended daily maximum limit. Using this
methodology and reviewing data since the Canton Modernization Project (1998 —2/2001) the
recommended daily maximum limit based on a multiplier of 3.4 (daily maximum/monthly average) is
10897 lb/day. The limit proposed represents an achievable level and approximately a 12.5% reduction
in the daily maximum BOD5 limit.
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).
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.
NUTRIENT POLLUTANT ANALYSIS
Total phosphorus and total nitrogen monitoring is required by 15A NCAC 2b .0508 (d) (2) (A).
Monthly monitoring is required to assess the contribution of nutrients from Blue Ridge Paper and the
potential impact to Waterville Reservoir. Waterville Reservoir is to be monitored once annually
(during opposite years of CP&L's montioring) to assist in the continued characterization of nutrient
impacts to the lake.
TOXICANTS
There is currently a fish consumption advisory due to dioxin 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, reflecting continued improvements in the
river.
Currently, Blue Ridge Paper is required to monitor dioxin and dibenzofuran isomers quarterly from the
influent, sludge, landfill leachate, and effluent. Based on an evaluation of the data, the Division is
recommending a revision to the special condition requiring dioxin and dibenzofuran isomers
monitoring. An improved knowledge of the dioxin and dibenzofuran isomers indicates that only 2,3,7,8
TCDD and 2,3,7,8 TCDF are pollutants of concern. Therefore, it is recommended that the dioxin
isomer special condition be modified to require monitoring only for 2,3,7,8 TCDD and 2,3,7,8 TCDF.
Fact Sheet
NPDES Renewal
Page 10

It is further recommended that the monitoring frequencies be modified based on the fact that
measurable quantities of dioxins and dioxin isomers have not been detected in the influent (since 1997),
the effluent (since 1996), sludge (since 1996) and the landfill leachate (since 1996).
The effluent limit for 2,3,7,8 TCDD has been reduced. During North Carolina's development of the
Total Maximum Daily Load for Dioxins on the Pigeon River, the EPA commented that the chronic
standard adopted by North Carolina should be applied as an effluent limit at the end of pipe. North
Carolina did not agree with this methodology, since it is inconsistent with the standard and North
Carolina rules. In addition, the management strategy implemented by North Carolina to address
dioxins in the Pigeon River for several years and the data show that this management strategy is
resulting in declining dioxin levels in the Pigeon River. The EPA, NC DWQ and Blue Ridge Paper
agreed that the TMDL requirement could be waived as long as Blue Ridge Paper's effluent was limited
at 0.014 pg/L. Therefore, the dioxin limit has been reduced to 0.014 pg/L and no TMDL will be
developed.
Annual fish tissue analysis shall continue to be performed by the facility in accordance with the
monitoring plan approved by the Division until such time that the fish advisory is lifted in both
Tennessee and North Carolina, according to North Carolina's delisting procedures.
Trichlorophenol/Pentachlorophenoi limits and monitoring are not required. The permittee has
certified that chlorophenolic biocides are not used at the facility. This certification eliminates the
requirement to include effluent limits for these two parameters based on 40 CFR 430. However, if the
facility changes future operations to include chlorophenolic biocides, limits and monitoring will be
required.
OTHER POLLUTANTS OF CONCERN
The total suspended solids (TSS) limits were calculated using the EPA promulgated Effluent
Guidelines for the Pulp, Paper, and Paperboard Point Source Category and compared to existing limits.
The TSS limits contained in the current NPDES permit are more stringent than the calculated federal
effluent guidelines since the current limits are based on the 1993 proposed guidelines for the oxygen
deligni£ication process. The Division recommends that the existing TSS limits remain unchanged for
this permit cycle.
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. Both benthic and IBI studies have indicated further improvement to the Pigeon
River. Therefore, a monthly average TSS limit of 12,549 lbs/day is recommended and a daily
maximum TSS limit of 495601bs/day is recommended.
Daily monitoring is required based on 15A NCAC 2B .0508 (d), Class IV facility.
The temperature requirement is based on a Section 316 (a) variance determination issued by the NC
Environmental Management Commission October 11, 1984 and approved by EPA August 6, 1985.
In making the recommendation to retain the current 316(a) variance, DWQ scientist evaluated Blue
Ridge Paper's Balanced and Indigenous Species Report and concluded that temperature could not be
identified as prohibiting a Balanced and Indigenous population. In addition, DWQ staff reviewed
existing temperature data and although some improvement in the instream temperature has occurred
(most likely due to overall effluent flow decrease, associated with process improvements reducing
temperature impacts), Blue Ridge Paper still cannot meet the North Carolina temperature requirement
as indicated in Figure 2 above. Therefore, DWQ is recommending that the 316(a) variance continue,
with Blue Ridge Paper conducting a Balanced and Indigenous Species Study prior to the next permit
renewal.
The flow limit is based on Blue Ridge Paper's current flow values and post-CMP production plus 0.9
MGD for the Town of Canton's wastewater. Future plant improvements may reduce the contribution
of the mill's wastewater, however the Town of Canton is proposing to increase their contribution to the
treatment plant as they expand Canton's municipal boundary.
Since flows are currently approximately 80% of the permitted capacity, the Division recommends that
the flow limit remain unchanged. During the next permit cycle the flow limit should be re-evaluated
Fact Sheet
NPDFS Renewal
Page 11

and if appropriate adjusted. Due to potential inflow/infiltratiori from the Town of Canton, the Division
continues the provision that requires Blue Ridge Paper to work with Canton to reduce I/I problems.
Chemical Oxygen Demand (COD) monitoring is required to assess the potential impact of chemical
oxygen demand from the Blue Ridge Paper wastewater effluent. Neither federal guidelines nor NC
water quality standards require a limit for COD. Though no limit is proposed, the EPA has reserved
COD for potential future limits. Therefore, COD monitoring will be continued.
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).
Metals toxicity is a function of water hardness, since Blue Ridge Paper has demonstrated reliable
compliance with toxicity, the Division recommends the elimination of hardness monitoring.
Conductivity monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products
(Water Quality Limited Facilities), for a Class IV facility.
Monitoring for total residue/total dissolved solids is required according to the existing NPDES
permit. The required conductivity monitoring is sufficient to assess Blue Ridge Paper's inorganic
loading to the Pigeon River. Therefore, the Division recommends removal of total residue and total
dissolved solids monitoring from the permit.
Limitations for pH 6.0 -9.0 are based on 15A NCAC 2B .0211 (b) (3) (G).
ISSUES ASSOCIATED wrrH EFFLUENT GUIDELINE IMPLEMENTATION
Relevant Background Information
Over the past five-year permitting cycle, the maximum 12-month production occurred from May 1999
through April 2000. Table 3 outlines the total production of various products generated at the Canton
Mill over this time period.
Pulp produced at the Canton Mill is supplemented with pine and hardwood pulp purchased from off-site
and pulp produced from trim or broke paper off the paper machines. The pulp is then used in
paperboard and fine paper production using one of the four paper machines on-site.
Table 3. Itemized Production Figures for the Maximum 12 Month Average Production Period.
Product Total for 12 Month Period Units
Pine Pulp 217,634.48 Air Dried Tons
Hardwood Pulp 298,833.91 Air Dried Tons
Purchased Pine Pulp 24,306.87 Air Dried Tons
Purchased Hardwood Pulp 22,252.21 Air Dried Tons
Broke Paper or Trim Pulp 46,559.08 Air Dried Tons
Paperboard Production 313,625.90 Off Machine Tons
Fine Paper Production 321,264.00 Off machine Tons
Blue Ridge Paper has not joined the Voluntary Advanced Technology Incentives Program (VATIP) for
existing direct or new direct dischargers as outlined in 40 CFR 430 Subpart B. The VATI Program
was set up for new or existing direct dischargers whereby mills agree to accept enforceable effluent
limitations and conditions in their NPDES permits that are more stringent than the BAT limitations, in
exchange for regulatory and enforcement related rewards and incentives.
Blue Ridge Paper will use steam stripping to treat process condensates, rather than hardpiping to the
WWTP; thus interface with the Division of Air Quality is not necessary.
Relevant Issues
Daily effluent monitoring for Adsorable Organic Halides (AOX) is required. AOX is an overall test
for adsorbable organic halides, which includes chlorinated organics. Trends in concentration changes
have been observed between AOX and specific pollutants (dioxins, chlorinated organics) at pulp and
Fact Sheet
NPDES Renewal
Page 12

paper mills. Therefore, any decrease in AOX may also indicate a decrease in chlorinated organics.
Limits and daily monitoring for AOX are required in the EPA Cluster Rules. The cluster rules are the
combined air and water rules issued by the EPA for the pulp and paper industry. The
compliance/monitoring point for the AOX limits shall be as defined in the sampling plan.
During the next permit cycle, the Division will review the AOX data for possible reduction in
monitoring frequencies.
Chloroform monitoring/limits have been added to the permit. During the previous permitting cycle, it
was determined that the discharge from Blue Ridge Paper did not have a reasonable potential to exceed
the allowable level. Therefore, no effluent limit is proposed. Limits contained in the NPDES permit
on the bleach plant effluent are based on the EPA promulgated Effluent Guidelines for the Pulp, Paper,
and Paperboard Point Source Category. Since Blue Ridge Paper operates two separate fiber lines,
there shall be two compliance points for chloroform as stipulated in the sampling plan.
In addition to the dioxin limits and conditions stated, above dioxins shall be limited and monitored on
the effluent from the each bleach plant. 2,3,7,8 TCDD and 2,3,7,8 TCDF limits are based on the EPA
promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category. The
compliance/monitoring points for each bleach plant is required as stipulated in the sampling plan.
Best Management Practices (BMPs) have been added for spent pulping liquors, turpentine, and soap.
At this time, Blue Ridge Paper is in compliance with the best management practices stipulated in the
EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category with
one remaining issue.
The remaining issue deals with the BMP Plan. As part of the EPA promulgated effluent guidelines,
facilities, which fall under subpart B, must develop a BMP Plan. This plan does not require the
approval of any regulatory authority, but must be certified by the mill manager. Currently, the BMP
Plan is in the development process and it is anticipated that this requirement will be completed prior to
issuance of this NPDES permit.
Per 40 CFR 430.24, the daily maximum limits for 12 chlorinated phenolics are "less than Minimum
Level" (<ML) as specified in 40 CFR 430.01. The compliance/monitoring point shall be set at the
effluent from the bleach plants as outlined in the sampling plan.
PROPOSED CHANGES FROM THE CURRENT NPDES PERMIT
• Monthly average BODS limit reduced 71 tons per year to 3205 lb/day.
• Daily maximum BOD5 limit reduced 12.5% to 10897 lb/day.
• Toxicity testing concentration increased to 90%.
• Removal of downstream fecal coliforrn monitoring with once per week upstream fecal monitoring.
• Removal of instream BOD5 monitoring.
• Removal of instream monitoring station 55.5.
• Removal of instream monitoring station 53.5.
• Reduce monitoring frequency at NC/TN monitoring station.
• Eliminate mercury monitoring and limitation.
• Add selenium limit.
• Trichlorophenol/pentachlorophenol monitoring has been removed.
• The upstream river mile marker now indicates that the upstream monitoring location is located at
river mile 63.8.
• The dioxin special condition has been modified to require 2,3,7,8 TCDD and 2,3,7,8 TCDF
individual isomer monitoring and to reduce the monitoring frequency of the sludge and landfill
leachate.
Fact Sheet
NPDES Renewal
Page 13

• The 2,3,7,8 TCDD effluent limit has been modified to 0.014 pg/L.
• Two internal outfalls (002 and 003) have been added.
• Removal of hardness monitoring.
• Removal of total dissolved solids monitoring.
• Removal of total residue monitoring.
• An AOX limit and daily monitoring has been added to the permit per EPA Cluster Rules.
• Dioxin, chlorophenolics and chloroform limits/monitoring have been added for the effluent from
the pine and hardwood line bleach plants per EPA cluster rule.
• The BMP special condition has been updated according to the requirements of the EPA Cluster
Rule.
• For color recommendations refer to the July 24, 2001, memo from the EPA Tech Team to the
Technology Review Workgroup.
This fact sheet represents North Carolina's recommendations. The Division will review all pertinent
comments received during the public comment period and the September 6, 2001 public hearing. After
reviewing all public comments, the Director of the Division of Water Quality and the NPDES
Committee of the Environmental Management Commission will make their recommendations.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Public Notice Draft Permit, temperature variance, color variance and Public August 3, 2001
Hearing
Public Hearing September 6, 2001
ADDITIONAL INFORMATION
CANTON MODERNIZATION PROJECT
Prior to 1993, knotting hardwood brownstock was washed through one of two brownstock washer
lines. After washing brownstock was screened using a two-stage fine screening process and bleached
in one of the two bleaching lines. The two bleaching lines were operated independently for 'low'
brightness and 'high' brightness.
Since 1993, the hardwood fiberline has incorporated numerous modifications designed to increase mill
performance from both an environmental and product quality standpoint. Currently, the hardwood
fiberline consist of two stage knotting followed by pre-oxygen delignification washers. After pulp is
processed through the oxygen delignification unit, it is washed again prior to the four stage pressurized
fine screening. After screening, the pulp is bleached through one medium consistency bleach line.
Prior to 1992, pine (softwood) pulp was processed through one brownstock washing line prior to the
two stage screening process. After screening, pulp was processed through one of the two bleaching
lines. Similar to the hardwood fiberline, the softwood fiberline bleaching was operated independently
for 'low' brightness and 'high' brightness.
Like the hardwood fiberline, the softwood fiberline has incorporated numerous modifications in order
to enhance product quality and environmental performance. Currently, the softwood fiberline process
consist of two stage knotting followed by a brownstock pre-oxygen delignification line. After the initial
washing the pulp is processed through the oxygen delignification unit followed by another washing.
After the second washing pulp is screened using four stage pressurized fine screen before entering a
medium consistency bleach line.
In addition to the improvements noted, the facility has implemented full scale bleach filtrate
recycle of the pine bleach line and caustic extraction stage (Eo) recycle on the hardwood bleach
line.
Fact Sheet
NPDFS Renewal
Page 14

References
1. Division of Water Quality's Basinwide Information Management System, April 20, 2001,
http:/fh2o.enr.state.nc.ustbims/reports/basinsandwaterbodies/alpha/Ncuse.pdf
2. 1995. NPDES Regional Staff Report for NPDES Permit NC0000272, January 18, 1995,
Asheville Regional Office.
3. 2000. French Broad River Basinwide Water Quality Plan. North Carolina Division of Water
Quality, Water Quality Section.
4. 2001. NPDES Permit Application EPA Forms 1 and 2C, Blue Ridge Paper Products Inc.
5. 2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of
Water Quality, Water Quality Section. Copies obtained through Planning Branch, Archdale
Building, 512 N. Salisbury St., Raleigh, North Carolina.
6. 1993. Low Flow Characteristics of Streams in North Carolina, United States Geological
Survey Water-Supply Paper 2403. Copies obtained at U.S. Geological Survey, Map
Distribution, Box 25286, MS306, Federal Center, Denver, CO 80225.
7. 1997. NC0000272 NPDES Permit. Issued to Champion Paper, expiration November 30,
2001. Copies obtained through The Division of Water Quality, Central Files, Archdale
Building, 512 N. Salisbury St., Raleigh, North Carolina.
8. 2001. Bleach Environmental Process Evaluation and Report. Dr. Norman Liebergott, PhD,
Liebergott and Associates Consulting, Inc. and Lew Shackford, June 8, 2001.
9. 2001. Additional Color Removal Technologies and Their Economic impacts on Blue Ridge
Paper Products, Canton, NC. July 25, 2001 Memorandum from EPA Tech Team to
Technology Review Workgroup.
State Contact
If you have any questions on any of the above information or on the attached permit, please contact
Michael Myers at [phone] ext. 508.
NAME:-2 �� � DATE:
NPDES SUPERVISOR/
NAME: y— DATE: `S Z-Oo7
Fact Sheet
NPDES Renewal
Page 15

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON,D.C.20460
J*RED srgTp
A
MEMORANDUM
DATE: July 25, 2001
SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue
Ridge Paper Products, Canton,NC
FROM: EPA Tech Team'
TO: Technology Review Workgroup
Purpose of this Analysis
As required by the 1997 Settlement Agreement,this memorandum presents a summary of an
analysis of available technologies that may be employed to further reduce color discharges from
the Blue Ridge Paper Products, Inc. (Blue Ridge) mill in Canton,NC. The analysis also includes
a summary of the economic impact("gross margin test") of the cost of implementing identified
color reduction technologies.
Members of the Tech Team visited the Canton mill on March 14, 2001 to observe and gather
information and data on the status of technologies implemented and color discharges at the mill
since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered
from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical
and financial data. This final memorandum is based on the May 4, 2001 preliminary draft
memorandum, and revisions to the July 10,2001 draft final memorandum, based on a review of
Blue Ridge's comments,the June 8, 2001 Bleach Environmental Process Evaluation and Report
(BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group, Inc,
and additional comments from the Clean Water Fund of North Carolina, and the States of
Tennessee and North Carolina. This memorandum presents to the Technology Review
EPA Tech Team is comprised of--Mark Perez,EPA/EAD;Karrie-Jo Shell,EPA Region 4;Don Anderson,
EPA/EAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,subcontractor to
ERG.

Workgroup (TRW) process improvements evaluated by the Tech Team and considered to be
available technologies and briefly addresses relevant technologies evaluated in the BEPER.
Background and History
Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton,NC, which it
purchased from Champion International Corporation in May 1999. Operations at the mill began
in 1908, but the mill has been extensively modernized, most recently in 1993. The mill currently
operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking,
pulp from each line is further delignified in single-stage oxygen delignification systems installed
in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence; pine pulp is bleached
with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery
(BFRTm)process, developed by Champion. A portion of the hardwood line bleach plant Eo-
stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated
paper including offset,tablet and envelope grades. The mill also produces 281,000 tons per year
of bleached paperboard used for liquid packaging and paper cups, including FDA approved
grades for milk and juice cartons. Since November 2000,pulp production has been reduced by
approximately 30 percent as the result of a major project to upgrade the No. 19 bleached
paperboard machine.
Continued Color Reduction Opportunities Since the 1997 NPDES Permit
The Canton Mill's 1997 NPDES permit included a schedule requiring continued study,
evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge
submitted a series of reports to the NC Department of Environment and Natural Resources,
Division of Water Quality, evaluating the performance of the BFR process, end-of-pipe color
reduction technologies, and practices for minimizing color losses from manufacturing processes.
Since 1997 Blue Ridge has:
• continued full-scale operation of BFR for the pine line;
• concluded that full-scale BFR is not feasible for the hardwood line, but
implemented partial reuse of a portion of the Eo-stage filtrate as an effective
color-reduction approach;
• identified and implemented several practices for reducing losses of highly-colored
black liquor from manufacturing processes; and
• evaluated 16 end-of-pipe color removal technologies and determined that they
were presently economically and/or technically infeasible for the Canton mill.

Page 3
Process Improvements Analyzed by the Tech Team
The Tech Team identified five mill improvements capable of further reducing the discharge of
color in the mill effluent. For each of these improvements, technical feasibility, capital and
operating costs, and potential color reduction were reviewed. Each improvement can be
implemented independently of the others or in any combination. The costs incurred to
implement the improvements are additive, however separate evaluations are necessary to
accurately estimate the associated color reduction achieved by implementing any combination of
improvements. End-of-pipe color treatment technologies (e.g., chemically assisted clarification
with sludge dewatering and disposal)typically require initial capital investment and ongoing
operating expenses, not savings, and are likely to incur non-water quality environmental impacts.
For this reason,the Tech Team focused on pollution prevention approaches that offer the
potential to be more cost-effective: color reduction in low flow, highly color-concentrated
wastestreams, through manufacturing process changes or in-process treatment.
The first two process improvements, discussed below (improvements in BFR reliability and leak
and spill prevention and control -Best Management Practices (BMPs)), are improvements which
the Tech Team concludes offer the highest certainty for technical feasibility and color reduction.
Blue Ridge also identified these technologies as feasible color reduction opportunities that will
be implemented, but differed from the color reduction estimates included in this memorandum.
The next two process improvements (ozone addition to an existing chlorine dioxide bleaching
stage on the hardwood fiber line; adding a second stage to the current oxygen delignification
system on the softwood fiber line) also were evaluated by Liebergott, et. al., as feasible color
reduction opportunities. Additional technical evaluation and/or laboratory testing would be
appropriate to reliably determine the technical details of how to incorporate these processes into
the existing fiber lines and to more accurately predict their achievable color reduction, and the
relationship of these technologies to BFR. Additional analyses would be appropriate to
determine the most cost-effective design and the most economically feasible schedule for
implementing one or both of these improvements.
The fifth process improvement, color treatment for the chloride removal process (CRP)purge
stream (one of the two key components of the BFR process), has the potential for additional
color reduction. However, based upon initial bench-scale treatability studies by Blue Ridge,
further study of additional color treatment technologies is necessary. Process optimization on
both the hardwood and softwood fiber lines; as recommended in the BEPER, is anticipated to

Page 4
provide additional color reduction and is identified as the sixth process improvement. It was
concluded that the process optimization option was among those with the highest certainty for
technical feasibility and color reduction.
All color reductions resulting from the mill improvements are estimates based solely on available
data and information. While the Tech Team has concluded that these technologies would reduce
the color discharge from the Canton mill, there is a lack of directly comparable operating
experience with these technologies in other bleached papergrade kraft mills that can be used to
develop precise predictions of the extent of the color reduction benefits.
The BEPER evaluated additional in-process technology options for color discharge reduction
potential, including the implementation of a hot pressurized peroxide-enhanced extraction stage
in both fiber line bleach plants. At this time, the Tech Team does not have sufficient information
to confirm the applicability of this technology at the Canton mill nor relevant data to predict its
potential color discharge reduction capabilities. Therefore, while this memorandum does not
address this technology option, it may be feasible for implementation by Blue Ridge and
contribute to reducing color. In addition,the Tech Team did not analyze nor did the BEPER
recommend a Totally Chlorine-Free (TCF) bleaching option because of the high cost of this
technology and the lack of experience in producing and successfully marketing products made
by Blue Ridge at the Canton mill.
1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal
Process (MRP). Blue Ridge has found that this process element has been more challenging and
expensive to maintain than originally planned. The target BFR recycle rate (percent closure) for
the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and
metallurgy problems (e.g., erosion of multi-media filtration tank lining) in the MRP,however,
the pine line closure has averaged only 74 percent from October 1998 to the present. Blue Ridge
has undertaken improvements to the MRP system in order to maintain the process closure rate
and increase operating time. Improvements include rebuilding piping and valves, and changing
construction materials and metallurgy to better withstand the chemical and physical stress
experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80
percent, annual average final effluent color discharge will be reduced by 1,000 to 1,200 lbs/day.
At this time, the Tech Team has no means of making an alternative quantitative prediction of
final effluent color reduction to compare to the Blue Ridge estimate.

Page 5
2. Improved black liquor leak& spill collection and control(BMPs). The Canton mill has an
extensive spill recovery system. Sumps in this system, including one sump added in the court
yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped
with pumps that are activated automatically when sensors detect wastewaters with high
conductivity and color. High conductivity material is routed to the recovery system. Further
improvements to the black liquor collection system include:
• continuous improvement of operating practices so more leaks and spills are
recovered rather than discharged to sewer;
• further improvement in preparation for planned outages to maximize capture of
tank clean-out waste and routing to recovery;
• further reducing clean water that continuously runs into sewers to prevent dilution
of smaller spills and facilitate recovery of highly colored wastewaters; and
• further improvement in the equipment used for handling of knots rejects to
prevent black liquor leaks into the recovery sumps.
The plot below shows the color of wastewater treatment influent at the Canton mill. The
variability of influent color discharge to wastewater treatment is attributed to color discharge
peaks that represent, in part, unplanned spills or leaks discharged to sewers or intentional
diversions of highly-colored black liquor or other color sources routed to sewers during mill
equipment shutdowns.
100
kg/t
Figure 1
75 Daily color at influent to W WTP for Canton
50
25
0 30 50 90 120 150 180

Page 6
Due to the nature of the manufacturing processes and'practical equipment operation and
reliability, all spills and color losses to sewers cannot be fully anticipated,predicted, and
completely contained. However, a comparison of the variability of the Canton mill influent color
data to available primary influent color data at another bleached papergrade kraft mill indicate
that a detailed review of the spill prevention and recovery system at the Canton mill (by mill
staff or external consultants), including involvement by the mill operators, can further uncover
the causes of and better quantify black liquor losses and other color sources that can be avoided
or recovered. This will result in an overall reduction in color discharge, both in long-term
average and variability. Through improved planning of mill equipment shutdowns, continuing
efforts to minimize process operation variability, and increased recovery of highly-colored leaks
and spills, discharges of highly colored material to the wastewater treatment system can be
reduced more consistently below existing levels.
Further reducing peaks in color discharges within the mill and preventing highly colored flows
from reaching the wastewater treatment system will further reduce the variability of color
discharges from the wastewater treatment system to the Pigeon River. For example, limiting the
color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to
improve the mill's BMP system and process operations would reduce the color loadings from
mill processes to the end-of-pipe wastewater treatment system by more than 8,000 lb/day. The
Canton mill operated under this primary clarifier influent color threshold approximately 74
percent of 2000, excluding November through December 2000. This time period was considered
not to be representative of steady-state operations because of the reduced pulp production
resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average
reduction of 45 percent across this wastewater treatment system for"brown" color derived from
black liquor, this would result in a minimum decrease of 4,400 lb/day in the average final
effluent color load.
Clean water, such as packing gland water,presently flows in several sewers with recovery
sumps. These colorless streams dilute other colored wastestreams, such as small black liquor
leaks and spills,to the point where the in-stream conductivity is too low to trigger recovery. By
eliminating clean water streams or diverting them away from sewers that collect black liquor
leaks and spills, wastewater streams with elevated color can be recovered more readily, resulting
in a reduction in color discharge to the end-of-pipe wastewater treatment system. Also, the
unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can
be recovered.

Page 7
At this time, the Tech Team has no basis for determining an accurate correlation between
unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill
Environmental Performance Update presented by Blue Ridge during the March 14, 2001 Tech
Team Canton mill visit. During the March 14 visit, Blue Ridge staff indicated that results of
studies of sewer generated color showed axelationship between bleach plant filtrate pH and
temperature and unaccounted color generated in mill sewers. By operating within the range of
pH and temperatures identified during the studies the Canton mill has had some success in
controlling this source of unaccounted color. Based on this information,the Tech Team
concludes that by further reducing process operation variability, including operating within the
pH and temperature range identified during the studies,the mill can continue to also minimize
sewer generated color, thereby reducing one source of unaccounted color. Reducing overall
color discharges through BMPs and other management practices will likely further reduce
remaining unaccounted color. However, additional studies are necessary to further develop any
relationship between accounted and unaccounted color sources.
As noted above, analysis of primary clarifier influent color loading data demonstrates that color
loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during
steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and
intentional discharges of colored streams and continuing efforts to minimize process operation
variability,the Canton mill can achieve further reduced primary clarifier influent color loads and
subsequent final effluent color discharge within this range on a more consistent basis than
demonstrated in 2000 (i.e., more than 74 percent of the time). On this basis,the Tech Team
concluded it is feasible to reduce final effluent color by more than 5,000 lbs/day through
improved black liquor leak and spill collection and control.
3. Ozone/Chlorine dioxide stage for hardwood bleach line. Ozone is used in more than ten kra8
mills around the world to bleach pulp, including two in the US and one in Canada. There are
several process configurations, but the most common is to operate an ozone (Z)mixer and
reactor immediately upstream of a chlorine dioxide reactor, without any washing between the
application of the two chemicals. This is known as a"ZD" stage. A system of this type was
retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999. Bleaching with ozone on
the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 27 percent reduction in
the discharge of color in the combined mill treated effluent' The conversion to a ZD stage
z Munro,Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching Sequence,Tappi,1000.
3 Aid.

Page 8
would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for
ozone. The energy requirements for ozone production would be offset by the energy savings
from less chlorine dioxide and caustic production, resulting in a net reduction in energy
consumption with the ZD stage.
As of September 2000, the long-term average color discharge from Canton's hardwood bleach
line was 12,800 pounds/day 4. The Espanola experience suggests that implementation of a ZD
stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by
3,000 to 6,4001bs/day. Based on comments received,the Tech Team acknowledges that
operating parameters, such as wood species processed and technology supplier performance
guarantees,may influence the practical color reduction achievable through implementation of a
ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are
based solely on the demonstrated performance and the Tech Team's assumption of color sources
at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada
(PAPTAC) meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible
communication between Blue Ridge and Domtar staff would be necessary to reliably predict the
achievable color reduction possible with this option for the Canton mill.
The technical evaluation of this process improvement included in the BEPER yielded a
hardwood filtrate color discharge reduction within the range of Tech Team estimates.
4 2mi stage OD for pine line. Oxygen delignification(OD) on the Canton Mill pine line is a
single stage system installed in 1993. It has been concluded that retrofitting a second OD stage
for the pine line could contribute to reduced color discharges in two ways. The first would be a
reduction in color for those filtrates presently not captured and reused in the BFR process. The
second would be a color reduction in the Chloride Removal Process (CRP) purge stream as a
result of less chloride from chlorine dioxide used for bleaching.
Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed
upstream of the existing reactor. Previously,the Tech Team anticipated increasing the kappa
number(lignin content) of the cooked pulp from 24 to 32 and utilizing a two-stage OD system to
reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two-
stage system. Based upon comments from BRP and further technical analysis, and review of the
BEPER, it was concluded that it is technically feasible for a two-stage OD system at the Canton
Jacobs Engineering Group,2001 Color Removal Technology Assessment,February 2001.

Page 9
mill to achieve an overall reduction of 50 percent in kappa number,rather than 65 percent as
previously anticipated. Therefore, with the Canton mill continuing to pulp to a kappa number of
24, the new two-stage OD system would reduce pulp kappa number into the bleach plant from
the current output of 16 to about 12, corresponding to a 50 percent kappa number reduction from
the current digester output of 24. The quantity of color released from the bleach plant will be
reduced in proportion to the reduction of the input kappa number.
By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a
two-stage OD system, the quantity of chemicals required in the first two stages of the bleach
plant can be reduced,because there is less lignin present in the incoming pulp to remove by
bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional
reduction in chloride load to the CRP and reduce color discharged from the purge stream in
proportion to the reduction in chloride being treated.
In response to comments received, it has been concluded that implementing a two-stage OD
system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve
a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving
greater delignification with the proposed two-stage OD system. However, operating a two-stage
OD system with.a higher than 50 percent delignification rate and a digester kappa number higher
than currently employed at the Canton mill is commonly seen at comparable bleached
papergrade kraft mills. Therefore,the Tech Team anticipates that additional process engineering
will maximize the benefits of a two-stage OD system at the Canton mill and enable the mill to
capture the increased delignifcation and yield gain potential of this technology and achieve
annual wood cost savings of up to approximate$950,000 from up to a 1.5 percent yield increase
across the proposed two-stage OD system.
Based on additional information supplied by Blue Ridge regarding operational limitations of the
BFR system, the Tech Team concludes that a two-stage OD system would not have a significant
impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on
a day-to-day basis.
For this analysis, it was estimated preliminarily that a second OD stage could reduce total
influent color discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from
reductions in pine line bleach plant filtrate color and CRP purge stream color.

Page 10
The technical evaluation of two-stage OD included in the BEPER yielded reduction in color
discharge influent to the wastewater treatment system within the range of the Tech Team
estimates.
S. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP)purge is a low
flow,highly concentrated waste stream. Color is typically 50,000 pcu, in a 10 gpm (0.01 MGD)
flow. The CRP purge contributes up to approximately 5,000 lbs/day (13 percent)to the total mill
loading to the wastewater treatment system influent, but only 0.06 percent of the discharge flow.
It was originally speculated that it may be feasible to reduce the color in this stream by
precipitating the colored organic material with lime at a dosage of 20 g/L5, and burning the
resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials
would be necessary to test the feasibility of color removal from the CRP purge stream by lime
treatment.
Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium
compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The
preliminary results of these trials show that at a dosage of 20 g/L, none of the compounds tested
reduced color in the CRP purge stream. Although color removal was demonstrated at higher
dosage rates, increased chemical usage would result in substantially higher operating costs,
require larger sized equipment at higher capital cost, and also result in a higher production rate of
sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not
burned must be landfilled at additional cost.
Based on preliminary laboratory trials,Blue Ridge concluded that lime treatment of the CRP
purge is not a feasible color reduction option for the Canton mill. However, the Tech Team
recommends additional review of other innovative technologies for treatment of color in the CRP
purge stream, such as the application of the X-Filter process recently implemented at a totally
chlorine free (TCF)mi116. By minimizing color contributions from this stream,the potential
exists to achieve a significant reduction in primary influent color discharge of up to 5,000
lbs/day.
5 NCASI Technical Bulleting No.239,The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching
Effluents with Lime.1. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970.
6 Comments on the Draft Report on Additional Color Removal Technologies and Economic Impacts for BRPP,Hope
Taylor,Clean Water Fund of North Carolina,July 18,2001

Page 11
6. Process Optimization. The BEPER identified sixteen recommendations for optimizing the
hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching
operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the
first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood
line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction
of up to 700 lbs/day from the hardwood line and up to 400 lbs/day from the softwood line. The
Tech Team estimated an additional color reduction from the CRP purge stream of 600 lbs/day
resulting from the decreased chlorine dioxide usage. At this time, the Tech Team has no means
of making an alternative quantitative prediction of bleach filtrate color reduction to compare to
estimates presented in the BEPER. Therefore, it is estimated that through efforts by mill staff to
maximize the color reduction benefits from the process optimization opportunities identified by
Liebergott, et, al., the Canton mill would achieve a total color reduction of 1,700 lbs/day in
wastewater treatment system influent.
Color Reduction Summary
The Tech Team estimates that by improving BFR reliability and black liquor leak and spill
collection and control, the Canton mill final effluent will be reduced by more than 5,000 lbs/day.
Process optimization, as outlined in the BEPER, would result in a further final effluent color
reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45
percent across the existing wastewater treatment for the CRP purge stream and other"brown"
color sources derived from black liquor and no reduction in color from bleach plant filtrates.
Table 1 presents a summary of the estimated reductions in final effluent color attainable with the
highest certainty by implementing improved BFR reliability, improved BMPs, and process
optimization.

Page 12
Table 1: Summary of Process Improvements and Associated Color Reductions
(Highest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
1 BFR reliability improvement --- 1,000-1,200
2 Improved black liquor leak& spill collection and --- >5,000
control
6 Process Optimization 1,700 1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION >7,400
Additional potential mill improvements to reduce color discharge at the Canton mill were also
identified. These process improvements require further study to more accurately determine
achievable color reduction and thus are not recommended at this time for immediate
implementation. These improvements include a ZD stage in the hardwood bleach plant, with a
preliminary estimate of a 3,000 to 6,400 lbs/day color load reduction in influent to the
wastewater treatment system, and a second OD stage for the pine line, with a preliminary
estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment
system. Table 2 presents a summary of preliminary estimates of color reductions for these two
additional process improvements that need further study. Reductions presented in Table 2 are
preliminary estimates with reduced certainty compared to those presented in Table 1, but are
based upon identified technology options available for the Canton mill.

t
Page 13
Table 2: Summary of Process Improvements and Associated Additional Color Reductions
Needing Further Study (Reasonable Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400
line
4 2"d stage OD for pine line 1,500-2,000 1,100-1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 -7,800
Table 3 presents a preliminary estimate of color reduction potential for the removal of color from
the CRP purge stream. The Tech Team recommends this stream for additional review of
potential color reduction technologies but cannot identify a particular technology option at this
time. Potential for additional color load reduction up to 2,750 lbs/day in final effluent to the
Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty.
Table 3: Summary of Additional Potential Color Reductions Needing Further Study
(Lowest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (Ibs/day)
5 1 Color Treatment of CRP Purge Stream #5,000 #2,750
TOTAL ADDITIONAL POTENTIAL FINAL EFFLUENT COLOR #2,750
REDUCTION

Page 14
Economic Analysis
The estimated capital and operating costs for the process improvements one through four were
estimated and are summarized below. Costs could not be developed at this time for process
optimization or CRP treatment and thus are not presented. However, costs for these
improvements should be modest.
Table 3: Estimated Costs
Process Improvement Capital Cost Annual O&M
($) ($/year)
1 BFR reliability improvement $1,300,000 $85,0006
2 Improved black liquor leak& spill collection and $100,000 $50,000
control
3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000)
line savings
4 2nd stage OD for pine line $2,000,000 ($2,100,000)
savings
Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven
plants (including the Canton Mill) from Champion International Corporation. Blue Ridge Paper
Products is owned 55 percent by KPS Special Situations Fund, L.P. and 45 percent by the
employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the
1997 report EPA documented substantial losses over five years for the Canton Mill and
Champion had just announced its intention to sell or close the mill. However, because of the sale
of the mill to the Blue Ridge, the previous data are not comparable to the more recent data.
Further,the data submitted by Blue Ridge is still confidential, so this report cannot present as
much detail as the 1997 report.
The current analysis is based on information submitted by Blue Ridge covering part of
1999 (May-December) and all of 2000 (all of the existing financial data for the company). The
results may be relatively uncertain because of the lack of data and the company may be too
young for the current data to reflect its ultimate financial health. EPA used three measures of
financial health(gross profit test, discounted cash flow, and Altman's Z)7 to assess the impact of
'See Interim Economic Guidance for Water Quality Standards:Workbook,EPA 823-B-95-002,March 1995,and
Economic Analysis for the National Emission Standards for Hazardous Air Pollutants for Source Category:Pulp and
Paper Production;Effluent Limitations Guidelines,Pretreatment Standards,and New Source Performance
Standards: Pulp,Paper,and Paperboard Category—Phase 1.

Page 15
air emissions control technologies and devices (not addressed in this memorandum, such as
MACT II and regional NOX control) and wastewater compliance costs (separate and combined)
on the mill and company. The costs for the wastewater control options presented in Table 3 do
not change the financial status of the mill or company. However, the costs for some of the air
emissions control options do impact the health of one or both entities. When the wastewater
costs are added to costs for air emissions control, the impacts of the water costs do not change
the financial status of either the mill or company when compared to the impact of the air costs
alone.
References
Blue Ridge Paper Products, Inc. Canton Mill Canton Mill Environmental Performance Update,
Prepared for U.S. EPA Technology Review Workgroup. March 14, 2001.
Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic
Analysis of Blue Ridge Paper Products, from Bob Williams, May 18,2001 (CBITS 00003911-
O1)
.Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown, Blue Ridge,
to Don Anderson, EPA, May 18, 2001
Comment Clarification of May 18,2001 Blue Ridge Responses to EPA Questions, from Derric
Brown, Blue Ridge, June 4, 2001
Comments on Draft Final Tech Team Report, from Bob Williams,Blue Ridge,to Don Anderson,
EPA, July 13, 2001
Comments on Draft Final Tech Team Report, from Derric'Brown, Blue Ridge, to Don Anderson,
EPA, July 17, 2001
Comments on Draft Final Report, email from Forrest Westall,North Carolina DENR,to Don
Anderson, EPA, July 17, 2001
Comments on Draft Final Report on Additional Color Removal Technologies and Economic
Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001

Comment on Draft Final Tech Team Report, email from Paul Davis, State of Tennessee,to Don
Anderson, July18, 2001
Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott, to
Don Anderson,EPA, July 19, 2001
Jacobs Engineering Group, 2001 Color Removal Technology Assessment,Blue Ridge Paper
Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001.
Liebergott,Norm, and Lew Shackford, Bleach Environmental Process Evaluation and Report,
June 8, 2001
McCord,Aimee,A Laboratory Analysis of Color removal Across a Pulp and Paper Mill
Wastewater Treatment Facility, Canton, North Carolina, Duke University, School of the
Environment, 1995
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.
NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of
Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching
Effluent. July, 1970.
Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater
Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina, Duke University, School
of the Environment, 1996
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry. Page 182
Wiley Interscience, 1986.
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry, 3rd edition.
Page 286. TAPPI Press, 2000.

Appendix 1: Color Balance (9/1/00 to 12/31/00)
Figure 2.6,Presented by Blue Ridge on March 14, 2001
Sewer Description Color Load
ID (lhs/day)
2B Digester area sewer: Digesters, HW 4,323
line,knot rejects
3A Alkaline sewer: Pine and HW Eo, 12,954
Pine line BSW, 02 Delig
1 PMs11 & 12, HW weak liquor tank 1,991
5B Recovery, BLOx, CRP* 7,852
6A Acid sewer: Pine and HW D1 17,345
filtrate+Pine D2 filtrate
Contaminated Condensate 1,591
Combined Condensate 260
Total 46,316
Primary Influent(PI) 49,284**
Unaccounted Color 2,968
(PI minus Total)
Secondary Effluent 37,696
Percent Removal in Treatment 23 %
* CRP contributes 5,000 to 6,000 lbs/day to 5B sewer
** Measured using test method in NC.4SI Tech. Bull. 803, An Update of Procedures for the
Measurement of Color in Pulp Mill Wastewaters, May 2000.

Appendix 2: Table of Effluent Color Limits, 1997 to Present
Color Limit True Color (Ihs/day)
Monthly Average Annual (Long-term)
Average
1997 Permit 125,434 98,168
Settlement Agreement, February 1998 69,000 60,000
(starting December 1, 1998)
Settlement Agreement, February 1998 --- 48,000 to 52,000
(Ultimate Target)
Interim Limits, May 2001* 55,000 48,000**
* As recommended by Technology Review Workgroup (TRW) and incorporated by NC in
BRP's NPDES permit.
** Reduced end-of-pipe color discharges since November 2000 reflect, in part, reduced pulp
production (approximately 30 percent) during this period because of the ongoing project to
upgrade the No. 19 paper machine used to produce bleached paperboard.

Appendix 3: Ozone Bleaching
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.

Appendix 4: Two-Stage Oxygen Delignification
Comparison of one- and two-stage oxygen delignification systems
Item Current Single-Stage System Proposed Two-Stage System
Oxygen Reactors One two
Input Kappa Number 24 24
Output Kappa Number 16 12
Total C102 Used 28 kg/ton* 22 kg/ton*
Oxygen Used 23.4 kg/ton* 28.3 kg/ton*
Total NaOH Used 45 kg/ton* 37 kg/ton*
* air-dried metric ton of bleached pulp