NC0000752_Permit (Issuance)_20041230

NPDES DOCIMENT SCANNIN` COVER SHEET
NPDES Permit:
NC0000752
Roanoke Rapids Mill WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Permit
History
Document Date:
December 30, 2004
This document is printed on reuse paper - izore any
content on the reirerse side

A
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
December 30, 2004
Mr. Chris Puryear, Environmental Engineer
International Paper Corporation
Roanoke Rapids Mill
100 Gaston Road
Roanoke Rapids, North Carolina 27870
Subject: Issuance of NPDES Permit NC0000752
Roanoke Rapids Mill
Halifax County
Dear Mr. Puryear:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9,1994 (or as subsequently amended).
This final permit includes no major changes from the draft permit sent to you on November 10,
2004.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable
to you, you have the right to an adjudicatoryhearing upon written request within thirty (30) days following receipt
of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh,
North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements
to obtain other permits which maybe required by the Division of Water Quality or permits required by the
Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit
that may be required. If you have any questions concerning this permit, please contact Dawn Jeffries at telephone
number [phone], extension 595.
Sincerely,
ORIGINAL SIGNED BY
Tom Belnick
Alan W. Klimek, P.E.
cc: Central Files
Raleigh Regional Office/Water Quality Section
NPDES Unit
Aquatic Toxicology Unit
EPA, Region IV
Noy` Carolina
Naturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recydedll0% Post Consumer Paper

•a
Permit NC0000752
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control Act, as
amended,
International Paper Corporation
is hereby authorized to discharge wastewater from a facility located at the
International Paper Corporation WWTP
100 Gaston Road
Roanoke Rapids
Halifax County
to receiving waters designated as the Roanoke River in the Roanoke 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 February 1, 2005.
This permit and authorization to discharge shall expire at midnight on March 31, 2007.
Signed this day December 30, 2005.
ORIGINAL SIGNED BY
Tom Belnick
.Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

a- t
Permit NC0000752
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked.
As of this permit issuance, any previously issued permit bearing this number is no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises under the permit
conditions, requirements, terms, and provisions included herein.
International Paper Corporation is hereby authorized to:
1. Continue to operate an existing 28.0 MGD wastewater treatment facility (outfall
001) consisting of the following:
• Mechanical bar screen
• Primary clarifier
• Emergency holding pond
• Sludge lagoon
• Aeration basin
• Three stabilization ponds
Facility is located at the International Paper Wastewater Treatment Plant, North
Roanoke Avenue, Roanoke Rapids, Halifax County.
2. Continue to discharge non -contact cooling water from the B & C evaporator
(outfall 002) and the turpentine condensor (outfall 003), and
3. Discharge from said treatment works at the locations specified on the attached
map into the Roanoke Rover which is classified C waters in the Roanoke River
Basin.

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International Paper - NC0000752
Facility
USGS Quad Number: B28NW
Receiving Stream: Roanoke River
Lat.: 36°28'19"
Long.: 77°38'14"
Location
Stream Class: C
Subbasin: Roanoke, 03-02-08
forth
SCALE 1:24,000

3
Permit No. NC0000752
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 from outfall serial number 001 - process water and stormwater. Such discharges
shall be limited and monitored by the Permittee as specified below:
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28.0 MGD
.
Continuous
Recorder
I or E
BOD, 5 day, 20°C
6,852 Ibs/day
13,704 lbs/day
Daily*
Composite
E
Total Suspended Solids
16,055 Ibs/day
32,110 lbs/day
_
Daily'
Composite
E
Dissolved Oxygen
Daily
Grab
. E, U, D
Temperature
Daily
Grab
E, U, D
Conductivity
Daily
Grab
E, U, D
NH3 as N
Monthly
Composite_
Composite
E
E
Total Nitrogen (NO2+NO3+TKN)
Monthly
Total Phosphorus
Monthly
Composite
E
Chronic Toxicity`s
Quarterly
Composite
E
Arsenic3
Quarterly
Composite
E
Chlorides4
Quarterly
Composite
E
Coppers
Quarterly
Composite
E
pH
6.0 — 9.0 standard units
Dail?
Grab
E
Pentachlorophenol4
1.55 Ibs/day
Weekly
Grab
E
Trichlorophenol4
_
1.42 lbs/day
Weekly
Grab
E
Footnotes:
1 Sample locations: E - Effluent, I - Influent, U - Upstream at NC Highway 48 Bridge, D - Downstream at
NC Highway 158. All upstream and downstream samples shall be collected as grab samples. Stream
sampling shall be conducted 3/week during June, July, August and September and weekly during the
remainder of the year.
2 Chronic Toxicity (Ceriodaphnia) P/F at 3.7%; March, June, September and December; see A (4), Chronic
Toxicity Pass/Fail Permit Limit.
3 Monitoring for metals, chlorides, and the whole effluent toxicity test shall be conducted at the same time.
4 Monitoring for pentachlorophenols and trichlorophenols is not required based on the information
contained in the International Paper comment letter (dated December 8, 2004) to the draft permit. If
chlorophenolic-containing biocides are used at the facility, monitoring for pentachlorophenols and
trichlorophenols shall commence immediately for the duration of the use of the biocides and for a period
of not less than two months after discontinuing use of the biocides.
5 Daily shall mean everyday except Saturdays, Sundays, and legal holidays.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

}
Permit No. NC0000752
A(2). 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 from outfall(s) serial number 002 - non -contact cooling water. Such discharges
shall be limited and monitored by the Permittee as specified below:
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Footnotes:
1. The temperature of the effluent will be regulated so that the temperature of the receiving stream does
not increase more than 2.8°C above the natural water temperature and does not exceed a maximum of
29°C.
2. The pH shall not be less than 6.0 standard units nor more than 9.0 standard units. In the event that
effluent pH shall be recorded outside this range, any value that falls within the range of pH measured
at the upstream and downstream points shall be considered compliant. Effluent pH shall be sampled
on the same days that stream samples for pH are taken. See Condition A(6.), pH Re -opener.
3. Upstream at NC Highway 48 Bridge, Downstream at NC Highway 158.
There shall be no chromium, zinc or copper added to the treatment system except as pre -approved
additives to biocidal compounds. The permittee shall obtain authorization from the Division prior to
any use of biocide in the cooling water (See A(5.), Biocide Condition).
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit No. NC0000752
A(3). 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 from outfall(s) serial number 003 - non -contact cooling water. Such discharges
shall be limited and monitored by the Permittee as specified below:
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Semi-annually
Grab
Effluent, Upstream,
Downstream3
Footnotes:
1. The temperature of the effluent will be regulated so that the temperature of the receiving stream does
not increase more than 2.8°C above the natural water temperature and does not exceed a maximum of
29°C.
2. The pH shall not be less than 6.0 standard units nor more than 9.0 standard units. In the event that
effluent pH shall be recorded outside this range, any value that falls within the range of pH measured
at the upstream and downstream points shall be considered compliant. Effluent pH shall be sampled
on the same days that stream samples for pH are taken. See condition A(6.), pH Re -opener.
3. Upstream at NC Highway 48 Bridge, Downstream at NC Highway 158.
There shall be no chromium, zinc or copper added to the treatment system except as pre -approved
additives to biocidal compounds. The permittee shall obtain authorization from the Division prior to
any use of biocide in the cooling water (See A(5), Biocide Condition).
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit No. NC0000752
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 3.7%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent
versions or "North Carolina Phase 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,
and 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.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that
does have a detectable impairment of reproduction or survival. The definition of "detectable impairment,"
collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase
II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for
the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent
to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section 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
Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
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 No. NC0000752
A(5.) BIOCIDE CONDITION
The permittee shall not use any biocides except those approved in conjunction with the permit application. The
permittee shall notify the Director in writing at least ninety (90) days prior to instituting use of any additional
biocide in the treatment system, which may be toxic to aquatic life (other than biocides previously reported to
the Division). Such notification shall include completion of Biocide Worksheet Form 101 and a map indicating
the discharge point and receiving stream.
A(6.) pH REOPENER
The Division may re -open this permit to remove pH limitation footnotes at Outfalls 002 and 003, should new
information indicate water quality problems due to declining pH in this portion of the river.

INTERNATIONAL
December 8, 2004
Dawn Jeffries
NPDES Unit
NCDWQ
1617 Mail Service Center
Raleigh, N.C. 27699- 1617
Dear Ms Jeffries:
PAPER
ROANOKE RAPIDS MILL
100 GASTON ROAD
ROANOKE RAPIDS, NC 27870
PHONE: [phone]
Subject: Draft NPDES Permit
NC0000752 comments
International Paper appreciates the opportunity to comment on the draft NPDES permit
NC0000752 received from your office on November 12, 2004. There were only two
items that we felt needed to be addressed. The first item relates to the request in the
permit to monitor for ammonia nitrogen three times per week on the treatment system
effluent. Per your email to Chris Puryear dated November 16, 2004 it is our
understanding that we have agreement for the monitoring frequency for ammonia
nitrogen to be once per month in the final permit.
The other item we would like to address concerns the trichlorophenol and
pentachlorophenol notification under section A (1) footnote 4. The footnote says that
the mill sent a letter to DWQ dated December 15, 1988 stating that we do not use
biocide containing either of those compounds. Since the mill is now owned by
International paper and we would like to restate, under the International Paper banner,
that the mill still does not use biocides containing either trichlorophenol or
pentachlorophenol. Could you please change the footnote to reflect the new
notification? If you have any questions, please feel free to contact me at (252) 533-
6237.
Chris Puryear
Environmental Engineer III
xc: Mary Lee Ransmeier
Neal Davis
Matt Giffin
Dick Jackson
Anitra Collins
Glenn Rives
\]\\
DEC 1 6 2004
DE11R
P01NT SC'.!';;CE KkA ;,N

IP-Roanaoke mill
1 Subject: IP-Roanaoke mill
Date: Fri, 19 Nov 2004 10:42:47 -0500
From: [e-mail]
To: [e-mail]
CC: [e-mail]
Dawn, I have no comments on the draft permit.
Karrie-Jo Robinson -Shell, P.E.
1 of 1
11/19/2004 10:52 AM

IP draft permit
Subject: IP draft permit
Date: Thu, 18 Nov 2004 16:32:53 -0500
From: Myrl Nisely <[e-mail]>
To: Dawn Jeffries <[e-mail]>
Dawn, in light of our telephone conversation, the IP permit is OK to
issue from RRO perspective. I understand you will be dropping back to
the monthly schedule for ammonia in the final version. I agree.
Myrl
Myrl A. Nisely <• ---<
Environmental Chemist II
NC DENR - Div. Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Telephone: [phone], Extension 272
Fax: [phone]
[e-mail]
1 of 1
11/19/2004 7:06 AM

Re: NPDES Permit, Ammonia Monitoring
•
Subject: Re: NPDES Permit, Ammonia Monitoring
Date: Tue, 16 Nov 2004 07:35:34 -0500
From: Dawn Jeffries <[e-mail]>
Organization: NC DENR DWQ
To: Chris Puryear <[e-mail]>
Chris,
I'm sorry, that was my mistake. I will correct it (change it back to monthly
monitoring) when I send out the final.
Thanks,
Dawn
Chris Puryear wrote:
> Dawn,
> Got the new permit on Friday and wanted to say thanks for getting it out to
> us so quick after your visit. I have done an initial review and find that
> the ammonia monitoring requirement has increased from once per month to 3
> times per week. We submitted a request in November 1998 asking for a
> reduction in ammonia monitoring requirements (actually Myrl wrote the
> letter) and it was approved. Is there some reason for an increase in
> frequency? As you observed during your visit our effluent wastewater
> characteristics do not change very quickly due to the long (35 day)
> detention time. When we received the last permit in 1997 we were required
> to monitor for ammonia 3 days per week. We investigated several analytical
> options and decided to pursue the electrode method. We found that even
> though this was the most cost effective method we could not achieve
> repeatable results. We started sending samples to a contract lab and
> discovered that the possibility of missing a sample due to shipping errors
> sometimes occurred and the analytical cost was high. Is there anything I
> can to for you to show that the monthly analytical frequency for ammonia is
> sufficient? Please let me know if there is anything I can do to help
> facilitate the process and thanks for the helpful language on the river
> water pH issue. Take care.
>
> Chris
1 of 1 11/16/2004 7:35 AM

Draft Permit Reviews (3)
Subject: Draft Permit Reviews (3)
Date: Tue, 16 Nov 2004 11:55:31 -0500
From: John Giorgino <[e-mail]>
To: Dawn Jeffries <[e-mail]>
Hi Dawn, I have reviewed the following permits:
NC Outward Bound School (NC0040754)
City of Lowell (NC0025861)
Roanoke Rapids Mill (NC0000752)
Roanoke Rapids does not contain tyhe new EPA testing language (please
see the other permits for the correct page). Also, the chr tox pages
has us listed as the Environmental Sciences "Branch". We are now a
"section". I think Kevin Bowden sent over a revised page with the
section change. Thanks for sending the drafts over.
-John
1 of 1
11/16/2004 11:59 AM

Copies of the draft
permit 4nd Other sup-
porting information on
file used to determine
conditions present in
the draft permit are
available upon re-
quest and payment of
P the costs of reproduc-
' tion. Mail comments
and/or requests for in-
formation to the NC
Division of Water
Quality at the above
a address or call Ms.
' Carolyn Bryant at
[phone], ex-
tension 520. Please
include the NPDES
permit number in any
' communication. Inter-
yJ ested persons may al-,
so visit the Division of
Water Quality at 512
L. N. Salisbury Street,
Raleigh, NC 27604-
►, 1148 between the
' hours of 8:00 a.m.
and 5:00 p.m. to re-
view information on
file.
• ! International Paper
Corporation at 100
,( Gaston Road, Roa-
noke Rapids, NC
27870 has applied for
renewal of NPDES
permit NC0000752 for
its International Paper
Corporation WWTP in
Halifax County. This
permitted facility dis-
charges treated proc-
ess wastewater
through outfali 001
and non -contact cool-
ing water through out -
falls 002 and 003 to
the Roanoke River in
the Roanoke River
Basin. Currently, BOD
is water quality limit-
ed. This discharge
may affect future allo-
cations in this portion
of the watershed.
November 14; 2004
IMy commission expires
(SEAL)
AFFIDAVIT OF PUBLICATION
ROANOKE RAPIDS
DAILY AND SUNDAY HERALD
ROANOKE RAPIDS, NC 27870
To: NCDENR/DWQ/NPDES
Attn: Carolyn Bryant
1617 Mail Service Ctr.
Raleigh, NC 27699-1617
Date Description Amount
Wastewater Permit
November 14 14 3/4" @ $9.90
$146.03
BILLS DUE AFTER FIRST INSERTION TO INSURE REQUIRED NUMBER OF PUBLICATIONS —
ATTORNEYS PLACING ADVERTISING ARE RESPONSIBLE FOR ACCOUNTS.
AFFIDAVIT OF PUBLICATION
North Carolina
Halifax County ' .L C� •
Before the undersigned, a Notary Public of said County and State, u commissioned,
qualified, and authorized by law to administer oaths, personally appeared Cathy C. Jones,
who being first duly sworn, deposes and says: that he/she is Asst. Bookkeeper.
(Owner, partner, publisher, or other officer or employee authorized to make this affidavit) of
THE ROANOKE RAPIDS HERALD engaged in the publication of a newspaper known as
DAILY AND SUNDAY HERALD, published, issued, and entered as second class mail in the
City of Roanoke Rapids in said County and State; that he/she is authorized to make this
affidavit and sworn statement; that the notice or other legal advertisement, a true copy of
which is attached hereto, was published in THE DAILY AND SUNDAY HERALD on the
following dates:
November 14, 2004
and that the said newspaper in which such notice, paper, document, or legal advertisement was
published, at the time of each and every such publication, a newspaper meeting all of the
requirements and qualifications of Section 1-597 of the General Statutes of North Carolina and
was a qualified newspaper within the meaning o lection 1-597 of the General Statutes of
North Carolina. �� , t
Signed _I:ct k_ (, -`—(i t p �J
Assistant Bookkeeper
Subscribed and swom to before me this November 19, 2004.
NOTARY PUBLIC

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0000752
Facility Information
Applicant/Facility Name:
International Paper Corporation/Roanoke Rapids Mill
Applicant Address:
North Roanoke Avenue, Roanoke Rapids, NC 27870
Facility Address:
North Roanoke Avenue, Roanoke Rapids, NC 27870
Permitted Flow
28.0 MGD
Type of Waste:
Industrial (100%)
Facility/Permit Status:
Class IV /Active; Renewal
County:
Halifax County
Miscellaneous
Receiving Stream:
Roanoke River
Regional Office:
Raleigh (RRO)
Stream Classification:
C
State Grid/USGS Quad:
B28NW/Roanoke Rapids
303(d) Listed?
Yes
Permit Writer:
Dawn Jeffries
Subbasin:
03-02-08
Date:
October 11, 2004
Drainage Area (mi2):
8,384
4.01110P
Lat. 36° 28' 19" N Long. 77° 38' 14" W
7Q10 (cfs)
1,120
30Q2 (cfs)
1,120
Average Flow (cfs):
2,400
IWC (%):
3.7%
BACKGROUND
The International Paper WWTP is permitted to discharge 28.0 MGD of process water through
Outfall 001, non -contact cooling water through Outfalls 002 and 003, and car wash rinse water
through Outfall 004. The current permit was issued August 25, 1997 and expired May 31, 2002.
The Permittee submitted its renewal application, Standard Form C, on November 28, 2001.
DWQ personnel visited the site on October 13, 2004. This visit revealed two significant changes
that should be reflected in the renewal. First, the car rinse station that historically discharged
through Outfall 004 no longer exists; and secondly, the facility no longer processes any
wastepaper as it has in the past. It is now strictly an unbleached kraft mill.
Verification of Existing Conditions and DMR Data Review
This facility discharges in subbasin 03-02-08 to the Roanoke River, which is classified C waters
at this point and is considered impaired on an evaluated basis due to a fish advisory for mercury.
Although the river is not listed as impaired for dissolved oxygen in the 2002-303(d) list, instream
oxygen levels are also sometimes problematic in this portion of the river due to flow variations
from an upstream hydroelectric dam. When less flow is released from the dam, the downstream
water level drops and surrounding swamps drain into the river too quickly, depleting oxygen.
DMR data from January 2002 through September 2004 were reviewed and are summarized in
Attachment 1. Instream data for dissolved oxygen and temperature were also reviewed and are
summarized in Attachments 2 and 3. Note that between the upstream and downstream sampling
stations, the Roanoke Rapids WWTP (8.34 MGD) also discharges treated wastewater.
Correspondence/Compliance
The Raleigh Regional Office (RRO) conducted several site visits during this permit term to
evaluate compliance. A Staff Report was also prepared in conjunction with the permit renewal.
RRO finds the facility to be in compliance with the NPDES permit and recommends renewal.
Fact Sheet
NPDES NC0000752 Renewal
Page 1

The International Paper WWTP has received one Notice of Violation (NOV) over the course of
this permit term. This violation was for pH at Outfalls 002 and 003 on May 27, 2004. Reported
values were 5.9 (at 002) and 5.4 (at 003).
The facility conducts quarterly toxicity testing and has passed every test since 2000.
PERMITTING STRATEGY
Waste Load Allocation (WLA)
The Division prepared the last WLA for the previous permit renewal in 1997. Current limits
were based on guidelines and water quality standards. The current permit includes limits for
flow, BOD5, TSS, pH, pentachlorophenol, and trichlorophenol. These limits were derived based
on 40 CFR 430.1 and 430.5 (BPT/BAT). At the time of the last renewal, increased production
indicated an increase in limits. However, limits were not increased but remained the same as in
the previous WLA (based on BPJ) because guidelines for pulp and paper mills were then under
review, there were indications of dissolved oxygen problems in the river, and the facility was
having no trouble meeting the lower limits.
Now, guidelines for this industry (430.3 BCT/BAT) are no longer under review, and production
data again indicate an increase in BOD5 limits for these parameters (see Attachment 4).
However, the facility still has no difficulty meeting the lower limits in its current permit. In
addition, instream data show that the 5.0 mg/1 dissolved oxygen standard is occasionally
approached at the downstream monitoring point in the summer months. Finally, a discussion
with Jennifer Everett from the Division's Planning Section revealed that there are still significant
concerns about DO in this portion of the Roanoke River and extensive work is being done on the
part of many organizations in an effort to prevent dissolved oxygen levels in the river from
dropping below the water quality standard. In light of this, the Division again proposes renewing
the permit with no increase in the BOD5 limits that are in the current permit and with reduced
limits for TSS, pentachlorophenol, and trichlorophenol based on production.
Based on instream data that the permit holder has submitted, which reflect naturally occurring pH
at levels occasionally below 6.0 standard units in this portion of the river, DWQ proposes to
renew this permit with a footnote to the pH limit requirements at Outfall 002 and Outfall 003.
(These outfalls discharge non -contact cooling water back into the river a short distance
downstream from where it was drawn.) The footnote states that in the event that the effluent pH
at these outfalls is outside the range of 6.0 — 9.0 standard units, any value that falls within the
range of pH measured at the downstream and upstream points will be considered compliant. It
also requires instream pH to be sampled on the same days that effluent samples are taken. Data
showing effluent and instream pH levels can be found in Attachment 5.
Reasonable Potential Analysis (RPA)
The Division conducted EPA -recommended analyses to determine the reasonable potential for
toxicants to be discharged by this facility, based on DMR data from January 2002-September
2004. Calculations included arsenic, chlorides, and copper. Although there were detections of
these parameters, results suggest no reasonable potential for the facility to discharge any of them
in amounts that would violate water quality standards. Therefore, monitoring without limits will
continue to be required.
SUMMARY OF PROPOSED CHANGES
• Decreased limits for Total Suspended Solids, Pentachlorophenol, and Trichlorophenol as
dictated by effluent guidelines using production data
Fact Sheet
NPDES N00000752 Renewal
Page 2

• Removed Outfall 004 from the permit
• Footnoted pH limits on outfalls 002 and 003 to include consideration for natural
conditions
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: November 10, 2004
Permit Scheduled to Issue: January 3, 2005
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact
Dawn Jeffries at [phone] ext. 595.
NAME: DATE:
REGIONAL OFFICE COMMENTS
-Os
"Jo/
NAME: DATE:
SUPERVISOR: DATE:
Fact Sheet
NPDES NC0000752 Renewal
Page 3

Monthly Average Data •
Month
Jan-02
Feb-02
Mar-02
Apr-02
May-02
Jun-02
Jul-02
Aug-02
Sep-02
Oct-02
Nov-02
Dec-02
Jan-03
Feb-03
Mar-03
Apr-03
May-03
Jun-03
Jul-03
Aug-03
Sep-03
Oct•03
Nov-03
Dec-03
Jan-04
Feb-04
Mar•04
Apr-04
May-04
Jun-04
Jul-04
Aug-04
Sep-04
Flow Temperature BOD TSS
(MGD) (deg C) (IbsJday) (IbsJday)
12.1 6.8 4198 5699
12.6 9.4 4537 6686
13.3 11.4 5783 3992
15.6 19.2 3604 4785
11.0 21.3 2136 3137
7.9 26.3 1868 3245
10.5 28.5 1824 3003
17.0 27.7 1635 3955
17.9 24.4 2083 3439
13.9 18.7 1782 2331
14.1 11.7 1258 1963
15.9 5.3 2286 3487
14.1 4.1 3016 2803
13.8 5.9 1670 2768
15.5 12.7 2213 2485
16.7 16.2 2633 3932
16.2 21.1 2795 4363
15.8 25.7 2762 4151
10.8 27.6 2589 3525
13.0 27.5 2903 3417
15.0 23.9 3524 5701
19.0 18.1 2513 3882
19.3 14.8 2379 3490
19.4 6.6 2558 5014
18.3 4.7 2593 3933
17.1 6.4 2582 4349
12.8 12.0 1684 2425
14.0 17.0 1257 1125
14.1 24.9 1155 1450
12.0 26.8 996 1224
10.7 29.0 1042 1331
17.2 26.6 1279 1093
17.8 24.6 1236 1465
DO
(nil)
2.6
1.8
1.1
1.3
1.4
0.4
0.9
1.7
2.2
2.6
3.5
4.7
2.6
7.2
3.7
2.7
1.6
0.6
0.9
1.1
1.7
2.1
2.3
5.1
5.7
3.6
3.3
4.0
2.7
2.8
1.5
2.2
2
TN
(IbsJdau)
9.25
9.9
8.1
7.83
7.8
9.7
7.1
4.9
5.0
5.7
4.7
5.4
6.1
6.0
6.5
7.5
12.5
8.6
9.0
5.7
9.2
6.3
6.0
6.0
1.2
5.4
6.1
6.5
5.67
5.24
5.6
3.53
2
TP
(IbsJday)
1.22
1.46
3.66
1.06
1.58
1.13
1.14
0.79
0.39
0.81
0.35
0.57
0.26
0.55
0.82
0.52
0.30
0.84
0.34
0.74
1.18
0.44
0.40
0.26
0.46
0.59
0.69
1.05
1.08
0.88
1.02
0.624
0.76
NH3-N
(IbsJday)
1.41
1.22
2.33
1.48
2.07
2.50
2.11
0.66
1.16
1.83
1.75
1.74
1.78
2.37
3.39
3.82
3.35
1.91
1.44
1.19
1.25
1.74
1.95
1.86
4.00
1.80
0.50
4.90
2.80
1.90
0.65
1.30
0.27
Conductivity Arsenic Chlorides Copper
(pmoh/cm) (mgli) (mgf) mg/I)
1727
1843
1930 0.0240 37.50 0.01500
1941
2327
2480 0.0200 39.40 0.00300
2166
1839
1655 0.0120 27.30 0.01100
1613
1537
1450 0.0150 24.80 0.00500
1586
1505
1533 0.0090 24.30 0.00700
1410
1655
1718 0.0130 22.00 0.00400
1784
1498
1605 0.0120 26.00 0.00700
1387
1467
1423 0.0170 19.70 0.01800
1531
1518
1557 0.0230 23.00 0.01000
1717
1685
1489 0.0190 48.00 0.00810
1512
1348
1307 0.023
23.00
0.01
Avg
14.7
17.8
2375
3323
2.5
6.55
0.85
1.95
1659
0.0170
28.64
0.00901
Max
19A
29.0
5783
6686
7.2
12.50
3.66
4.90
2480
0.0240
48.00
0.01800
Min
7.9
4.1
996
1093
0.4
1.23
0.26
0.27
1307
0.0090
19.70
0.00300
Atttachment 1

Dissolved Oxygen
E
as
co LTC N
To -
a 0
D CI [Si
co
T
N
T
O
T
co
co
(Ow) ue6A p panIossip
d
N
0
2
a
Attachment 2

Temperature
0
ce)
to
N
0
N
10
T
3s alnwiadwal
0
T
Co
1s0,14
40
A/,
cil
02
`'0,0,
isl
inn
sg
co
00s� G
A-L
OO'..A
iv
Attachment 3

PERMIT LIMITS FOR NC0000752 ACCORDING TO 40 CFR 430 SUBPART C.
Production:
1998 - 504,500 tons (2,764,400 lbs/day)
1999 — 521,675 tons (2,858,500 lbs/day)
2000 — 488,333 tons (2,675,800 lbs/day)
*3-year average is 2,766,200 lbs/day. All three years' average fall within 20% of this cycle
average. Most recent and conservative average (2000) chosen to determine limits.
The guidelines for this facility provide the effluent limitations for BOD5, TSS, and pH using both
BPT (40 CFR Part 430.30) and BCT (40 CFR Part 430.33). Limitations for BPT are identical to
those for BPT. Limitations for pentachlorophenol and trichlorophenol are provided using BAT
(40 CFR Part 430.34).
Parameter
Monthly Average
Daily Maximum
Source — 40 CFR
TSS
6.0 lbs/1000 lbs product
12.0 lbs/1000 lbs product
BPT/BCT; 430.30 & 430.33
BOD5
2.8 lbs/1000 lbs product
5.6 lbs/1000 lbs product
BPT/BCT; 430.30 & 430.33
pH
6.0 — 9.0
6.0 — 9.0
BPT/BCT; 430.30 & 430.33
Pentachlorophenol
-
0.000581bs/1000 lbs product
BAT; 430.34
Trichlorophenol
-
0.00053 lbs/1000 lbs product
BAT; 430.34
Monthly average
Daily Maximum
TSS = 6lbs 10001bsproduct * (2,675,8001bsproduct I day)
TSS =16,055 lbs/day (Currently permitted for 16,800 lb/day)
BOD5 —(2.811.,! 10001bsproduct * (2,675,8001bsproduct/day)
BOD5= 7,492 lbs/day (currently permitted for 6,8521b/day)
TSS - 121bs 10001bsproduct * (2,675,800lbsproduct/day)
TSS = 32,110 lbs/day (Currently permitted for 33,600 lb/day)
BOD5 = 5.61b /l000lbsproduct)* (2,675,8001bsproduct I day)
BOD5=14,984 lbs/day (Currently permitted for 13,704 lb/day)
Pentachlorophenol =(o.00058lb,tj"0�Qlb* (2,675,8001bsproduct /day)
sproduct
Pentachlorophenol = 1.55 lbs/day (Currently permitted for 1.63 lbs/day)
Trichlorophenol = 0.000581b* (2,675,800lbsproduct/day)
1000lbsproduct
Trichlorophenol = 1.42 lbs/day (Currently permitted for 1.49 lbs/day)
Attachment 4

Upstream Downstream Outfall 002 Outfall 003
Date max min max min max min max min
Jan-02 7.2 6.4 7 6.4 6.7 6.5 6.9 6.5
Feb-02 6.9 6.4 6.8 6.4 6.7 6.5 6.9 6.4
Mar-02 7.0 6.4 6.8 6.3 6.9 6.4 6.9 6.5
Apr-02 6.8 6.1 6.7 5.9 6.6 6.2 6.6 6.2
May-02 6.7 6.2 6.6 6.2 6.4 6.3 6.5 6.2
Jun-02 6.7 6.2 6.5 6.2 6.6 6.2 6.9 6.2
JuI-02 6.7 6.2 6.6 6.2 6.8 6.2 6.8 6.2
Aug-02 6.6 6.2 6.6 6.2 6.4 6.2 6.5 6.3
Sep-02 6.6 6.2 6.5 6.1 6.6 6.1 6.4 6.2
Oct-02 6.9 6.1 7.0 7.2 6.9 6.1 6.9 6.3
Nov-02 6.6 5.5 6.5 5.7 6.6 6.3 7.1 6.2
Dec-02 6.7 6.0 6.7 6.0 6.5 6.2 6.6 6.3
Jan-03 6.9 6.0 6.9 6.0 6.8 6.0 6.8 6.1
Feb-03 6.9 6.4 6.8 6.4 6.9 6.4 6.9 6.4
Mar-03 8.1 6.4 8.7 6.3 7.2 6.5 7.0 6.5
Apr-03 6.9 6.4 6.7 6.3 6.9 6.6 6.8 6.5
May-03 6.7 6.3 6.6 6.3 6.7 6.5 6.6 6.4
Jun-03 6.9 6.2 7.0 6.0 7.0 6.5 6.9 6.3
JuI-03 6.6 6.2 6.5 6.1 6.7 6.4 6.6 6.3
Aug-03 6.7 6.2 6.6 6.1 6.7 6.5 6.7 6.3
Sep-03 6.6 6.2 6.5 6.1 6.6 6.5 6.5 6.4
Oct-03 7.4 6.3 6.7 6.2 6.7 6.5 6.6 6.4
Nov-03 7.2 6.2 7.0 6.2 7.1 6.4 6.8 6.3
Dec-03 6.7 6.2 6.7 6.0 6.7 6.3 6.6 6.2
Jan-04 7.3 6.1 7.1 6.1 7.0 6.3 7.2 6.3
Feb-04 7.0 6.2 6.8 6.2 6.8 6.4 6.8 6.3
Mar-04 6.9 6.2 6.7 6.2 6.7 6.2 6.8 6.3
Apr-04 6.8 6.1 6.7 6.0 6.5 6.2 6.6 6.2
May-04 6.8 6.1 6.7 6.0 6.7 5.9 6.7 5.4
Jun-04 6.9 5.9 6.7 5.9 6.9 6.2 6.8 6.0
JuI-04 6.6 5.8 6.6 5.9 6.7 6.5 6.6 6.3
Aug-04 6.4 5.9 6.2 5.7
Sep-04 6.8 6.0 6.6 6.0
Attachment 5

DO issues in the Roanoke River
Subject: DO issues in the Roanoke River
Date: Mon, 25 Oct 2004 14:31:19 -0400
From: Jennifer Everett <[e-mail]>
To: Dawn Jeffries <[e-mail]>
CC: Darlene Kucken <[e-mail]>, Al Hodge <[e-mail]>,
Ken Schuster <[e-mail]>, Boyd Devane <[e-mail]>
Dawn,
Per our discussion regarding a permit renewal on the Roanoke River,
please find below justification to keep the facility's discharge at its
current loading. The Roanoke River downstream of the Roanoke Rapids Dam
is heavily monitored and discussed between several State and Federal
agencies. Since the major fish kill event in 1995 in the Roanoke River
due to severe low dissolved oxygen levels, the US Army Corps of
Engineers(ACE) has been coordinating with The Division of Water Quality
(RRO, WaRO and Planning), Wildlife Resources Commission and the US Fish
and Wildlife Service to prevent such events from reoccurring. This
collaboration and coordination involves weekly teleconference calls in
the summer months and bi-weekly conference calls during the rest of the
year. The main focus of these conference calls is to discuss current DO
values in the river and current and projected flow releases from J.H.
Kerr which ultimately reflects the flow regime from Roanoke Rapids Dam.
Since the Roanoke River is surrounded by adjacent swamps with naturally
occurring low DO values, the mechanism of introducing a significant
amount of these swamp waters into the river needs to be manipulated with
a 'ramping' down flow regime. Currently, there are four USGS Water
Quality gaging stations collecting DO, temp, Ph data on a real-time
basis. These stations have been strategically located at Halifax, Oak
City, Jamesville and Westover (Hwy 45).
In addition, the ACE has initiated a Section 216 Study which is also
sponsored by the States of VA and NC. The Water Quality Task Group of
this study will be producing a water quality model (hopefully, the model
has not been approved yet). This model(if approved) will be set from
the Roanoke Rapids Dam to the mouth of the Roanoke River as to assume
assimilative capacity issues. This study is to provide recommendations
for operating procedures and J.H. Kerr.
As you can see this watershed reflects current and past DO issues. Due
to this, we recommend no increase of loading to the facility's discharge.
Sincerely,
Jennifer
1 of 1 10/25/2004 2:37 PM

Whole Effluent Toxicity Testing Self -Monitoring Summary September 15, 2004
FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
International Paper Co. -New Hanover chr lim: 23%
NC0081507/001 Begin:7/1/1996 Frequency: Q P/F + Jan Apr Jul Oct
County New Hanover Region: WIRO Subbasin: CPFI7
PF: 0.05 Special
7Q 10: 0.13 IWC(%) 37 Order:
+ NonComp:Single
2000 N - - N - - N - - N
2001 N - - N - - N - - N
2002 N - - N - - N - - N
2003 N - - N - - N - - N
2004 N - H - - H
International Paper Roanoke Rapids chr lim: 3.7%
NC0000752/001 Begin: l0/l/1997 Frequency: Q P/F + Mar Jun Sep Dec
County. Halifax Region: RRO Subbasin: ROAN
PF: 28.0 Special
7Q10: 1500 IWC(%)4.2 Order:
+ NonComp:Singlc
Y 2000 - - Pass - - Pass - - Pass - - Pass
2001 - - Pass - - Pass - -- Pass - - Pass
2002 - - Pass - - Pass - -- Pass - - Pass
2003 - - Pass - - Pass - --- Pass --- - Pass
2004 - - Pass - - Pass -
J.P. Stevens-Wagram chr lim: 9% Y 2000 - Fed Pass - Fall 25.5 25.5 Pass - Pass
NC0005762/001 Begin. l/1/2001 Frequency: Q Feb May Aug Nov + NonComp:Singlc 2001 - Pass - - Pass - - P889 - - Pass
County, Scotland Region: FRO Subbasin: LUM51 2002 - Pass - Pass - Pass Pass
PF: 7.0 Special 2003 - Pass - - Pass - - Pass - - Pass
7010: 117 IWC(%)9.0 Order 2004 - Pass - - Pass - -
Jefferson Smurfit Corp. chr lim: 11%
NC0005061/001 Begin:8/12004 Frequency: Q Jan Apr Jul Oct
County. Cleveland Region: MRO Subbasin: BRD04
PF: 0.010 Special
7Q10: 0.12 I W C(%) 11.0 Order:
+ NonComp:Singlc
2000 Pass
2001 Pass
2002 Pass
2003 pass
2004 Pass
Pass - - Pass
Pass - - Pass
Pass - - Pass -
Pass - - Fail >44
Pass - - Pass
>44
Invalid
Pass
Fad
Pass
31.1
Pass
>44
Jefferson W WTP chr lim: 14%; if pf 0.6MGD chr lim 30% Y 2000 - Pass - - Pass - - Pass - - Pass
NC0021709/001 Begin:6/12001 Frequency:0 Feb May Aug Nov + NonComp:Singlc 2001 - Lale,Pass NR - Pass - - Pass - - Pass
County. Ashc Region: WSRO Subbasin: NEW01 2002 -- Pass - - Pass - - Pass - - Pass
PF: 0.30 Special 2003 _- Pass - Pass - Pass - - NR/Pass
7010: 2.2 IWC(%) 14.0 Order: 2004 - Pass - - Pass --- Pass
Johnston Co. Regional WWTF chr lim: 4% (a) PF>4.99MGD; 6%® PF 7.0 MGD 2000 - Pass - - Fad Pass - Pass
NC0030716/001 Begin:2/12002 Frequency: Q Feb May Aug Nov + NonComp:Singlc 2001 - Pass - - Pass - Pass
County Johnston Region: RRO Subbasin: NEU02 2002 - Pass - - Pass -- --- Pass
PF: 5 Special 2003 - Pass - - Pass Pass - NR
7Q10: 184 IWC(%)3.6 Order 2004 - Pass - -- Pass -
Pass
Pass
Pass
Pass
NR
Pass
K-T Feldspar chr lim: 6.0% ;' 2000 - Pass - --- Pass - Pass - - Pass
NC0000400/001 Begin:8/I/2004 Frequency: Q Feb May Aug Nov + NonComp:Single 2001 - Pass - Pass - Pass - Pass
County. Mitchell Region: ARO Subbasin: FRB06 2002 - Pass - --- Pass - - Pass -- - Pass -
PF: 1.73 Special 2003 - Pass - Pass - Pass - - Lisle Pass
7Q10: 44,0 IWC(%) 5.73 Order 2004 - Pass - - Pass
Kenly WWTP chr lim: 22% 2000 >50 21.9 >50 - Pass - -- Pass Pass
NC0064891/001 Begin 5/1/1998 Frequency: Q P/F + Mar Jun Sep Dec + NonComp:Single 2001 -- Pass Pass - Pass - Pass Pass - - Pass
County Johnston Region: RRO Subbasin:NEU06 2002 -- - Pass - Pass - - Pass - - Pass
PF: 0.63 Special 2003 .-. Pass - Pass - Pass - Pass
7010:4.4 IWC(%)22 Order: 2004 - Pass Pass -
Kinder Morgan Southeast Terminals LLC 24hr ac moni epis flhd
NC0032875/001 Begin: 3/12004 Frcquency: 5 OWD/A
County: Johnston Region: RRO Subbasin: NEU02
PF: N/A Special
7Q10: 0.0 IWC(%) 100.0 Order.
NonComp:
2000 H 54.7 H H H H H - H H H
2001 H H H H H 97.4 H H H - H
2002 - H H H - H >100 H H H H H
2003 H -- >100 H H H H H H H H
2004 - H >100 H H H H
Kinder Morgan Southeast Terminals LLC 24HR LC50 AC MONIT EPIS FTHD
NC0032875/002 Begin:3/12004 Frequency: 5 OWD/A
County Johnston Region: RRO Subbasin: NEU02
PF: VAR Special
7Q10: 0.0 IWC(%) 90 Order:
NonComp:
2000 H H H 11 H H H - - H H
2001 H H H H H >100 H H - H
2002 - H H H --- H - - H -
2003 - - >100 -- - -- - - -
2004 - H >100
H
King's Mtn: Pllot Cr. WWTP chr lim: 33%
NC0020737/001 Begin:5/12004 Frequency. Q Jan Apr Jul Oct
County. Cleveland Region: MRO Subbasin: BRD05
PF: 6.0 Special
7Q 10: 19.0 1 W C(%) 33 ado:
NonComp:Single
2000 Fail 20.3 NR/20.3 NR/Late Fail 40.6 <6.25 B.8
2001 Pass -- -- Pass -- - Pass -
2002 Pass - Pass - - Pass
2003 pass >100 - Pass >100 - Pass
2004 Pass - -- Pass - - Invalld,Fall
8.8
Pass,Pass -
Fea 8.8 70.7
Pass - -
Pass -
Y Pre 2000 Data Available
LEGEND:
PERM - Permit Requirement LET- Administrative Letter - Target Frequency - Monitoring frequency: Q- Quarterly; M- Monthly; BM- Bimonthly; SA- Semiannually; A- Annually; OWD- Only when discharging; D- Discontinued monitoring requirement
Begin - Fitst month required 7Q10 - Receiving stream low flow criterion (efs) +- quarterly monitoring increases to monthly upon failure or NR Months that testing must occur - ex. Jan, Apr, Jul, Oct NonComp - Current Compliance Requirement
PF - Permitted flow (MGD) IWC% Instream waste concentration P/F - Pass/Fail test AC - Acute CHR - Chronic
Data Notation: f- Fathead Minnow; • - Ccriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test
Reporting Notation: - - Data not required; NR - Not reported Facility Activity Status: 1- Inactive, N - Newly Issued(To construct); H - Active but not discharging; t-Morc data available for month in question; - ORC signature needed
26

§ 430.28
§ 430.28 Best management practices
(B1VIPs).
The definitions and requirements set
forth in 40 CFR 430.03 apply to facilities
in this subpart.
Subpart C-Unbleached Kraft
Subcategory
§ 430.30 Applicability; description of
the unbleached kraft subcategory.
The provisions of this subpart are ap-
plicable to discharges resulting from:
the production Lpiii. and paper a
d kraft he pro notion of
pulp and paper at unbleached kraft-
neutral sulfite semi -chemical (cross re-
covery) mills; and the production of
pulp and paper at combined unbleached
kraft and semi -chemical mills, wherein
the spent semi -chemical cooking liquor
is burned within the unbleached kraft
chemical recovery system.
40 CFR Ch. I (7-1-03 Edition,
*430.31 Specialized definitions.
For the purpose of this subpart, tilt
general definitions, abbreviations. and
methods of analysis set forth in 40 CH
part 401 and §430.01 of this part shall
apply to this subpart.
§ 430.32 Effluent limitations rep.
resenting the degree of effluent re.
duction attainable by the applica.
tion of the best practicable contrd
technology currently available
(BPT).
Except as provided in 40 CFR 125.30
through 125.32, any existing point
source subject to this subpart must
achieve the following effluent limits.
tions representing the degree of efflu•
ent reduction attainable by the apple•
cation of the best practicable control
technology currently available (BPT):
SUBPART C
[BPT effluent limitations for unbleached krafl facilities)
1
Pollutant or pollutant property
Kg/kkg (or pounds per 1,000
Ib) of product
Maximum far
any 1 day
Average el
daily values
for 30 con-
secutive days
BOD5
TSS
pH
5.6
12.0
(')
21
6.0
fl
' Within the range of 6.0 to 9.0 at all limes.
SUBPART C
[BPT effluent limitations for unbleached kraft facilit' producing pulp and pap ag-thwuthleached kratt-neutral
mica) (cros's recovery) prose -- �--
sulfite semi.
Pollutant or pollutant property 10(Ac -
Kg/kkg (or pounds per 1,000
Ib) of product
Maximum for
any 1 day
Average d
daily values
for 30 con-
secutive days
BOD5
TSS
pH
8.0
12.5
C1
4,0
625
' Within the range of 6.0 to 9.0 at all times.
-Inn
Environmental Protection Agency
§ 430.33
SUBPART C •
(BPT effluent limitations for unbleached krafl facilities where pulp and paper are produced using a cymhined unbleached_krah
and semi -chemical process. wherein the spent semi -chemical cooking liquor is burned within the unbleached Kraft chemica! re-
covery syslertrT •
.) T `
Pollutant or pollutant property
Kglkkg (or pounds per 1,000
Ib) of product
Average of
Maximum for daily values
any 1 day for 30 con-
secutive days
BOOS
Tss
pH
(a)
("1
(°)
•(Reserved)
1430.33 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the applica-
tion of the best conventional pollut-
ant control technology (BCT).
Except as provided in 40 CFR 125.30
through 125.32, any existing point,
source subject to this subpart shall
achieve the following effluent limita-
SUBPART C
tions representing the degree of efflu-
ent reduction attainable by the appli-
cation of the best conventional pollut-
ant control technology (BCT). except
that non -continuous dischargers shall
not be subject to 1 maximum_
and average-of-30- serutiv_e-rtn,ys,
imittions. but shall be subject to an-
nua average effluenETimltatllons:
[BCT effluent limitations for unbleached kraft facilities]
Pollutant or pollutant properly
Kg/kkg (or pounds per 1,000 Ib) of
product
BOD5
Tss
pH
Continuous;
di
dis-
chargers (annual average),
Maximum
for any 1
day
l-i
2A
Average of
daily values
tor 30 non-
secuI ve
days
1.9
3.6
C1 ('1
'Within the range of 6.0 to 9.0 at all times.
PART C r °7'
Ifite' emi•chemical cross
recovery)
[BKT effluent limitations for unbleached kraN•neutra ( eery) process and/or a combined un-
bleached krafl and semi -chemical process, wherein lhe1pent semi -chemical cooking liquor is burned within the unbleached
kralt chemical recovery system]
Pollutant or pollutant property
Kg/kkg (or pounds per 1,000 Ib) of
product
Continuous dischargers Non-contin-
Maximum
for any 1
day
daily values chargers
for 30 con- (annual
average).
secutive days
Average of uous tli5•
BOOS
TSS
pH
'Within the range of 6.0 to 9.0 at all times.
120
8.0
12.5
(1)
4.0 2.9
6.25 3.57
(') j (')
.
i=7ti'�}
rife!

§ 430.34
§ 430.34 Effluent limitations rep-
resenting the degree of effluent re-
duction attainable by the applica-
tion of the best available tech-
nology economically achievable
(BAT).
Except as provided in 40 CFR 125.30
through 125.32, any existing point
source subject to this subpart where
chlorophenolic-containing biocides are
used must achieve the following efflu-
ent limitations representing the degree
of effluent reduction attainable by the
40 CFR Ch. I (7-1-03 Edition
application of the best available tech-
nology economically achievable (BAT).
Non -continuous dischargers shall nor
be subject to the maximum day mass
limitations in kg/kkg (lb/1000 lb), but
shall be subject to concentration limi-
tations. Concentration limitations are
only applicable to non -continuous dis-
chargers. Permittees not using
chlorophenolic-containing biocide:
must certify to the permit -issuing au-
thority that they are not using these
biocides:
SUBPART C
(BAT effluent limitations for Jrnbleached kraft acilitles]
Pollutant or pollutant property
Max
imum for any 1 day
Kg/kkg (or
pounds per
1.000 Ib) of
product
Milligrams/liter
Pentachlorophenol
Trichlorophenol
y=wastewater discharged in kgal per ton of product.
0.00058
0.00053
(0.01 )(12.6)/y
(0. 0)(12.6)/y
SUBPART C
(BAT effluent limitations for unbleached kraft facilities where pulp and paper are produced using the unbleached kraft-neutral sJ-
fite semi -chemical (cross recovery) process and/or a combined unbleached kraft and semi -chemical process, wherein Ins
spent semi -chemical cooking liquor Is bumed within the unbleached kraft chemical recovery system)
Pollutant or pollutant property
Max
imum for any 1 day
Kg/kkg (or
pounds per
1.000 Ib) of
product
Milligrams/liter
Pentachlorophenol 0.00064 (0.011)(14.0)/y
Trichlorophenol 0.00059 (0.010)(14.0)/y
y=wastewater discharged in kgal per ton of product.
§ 430.35 New source performance
standards (NSPS).
Any new source subject to this sub-
part must achieve the following new
source performance standards (NSP
except that non -continuous dis + - gers
shall not be subject to t r _ aximum
day and average of 30 secutive days
effluent limitatio + ; or BODS and TSS,
but shall be - • +ject to annual average
effluent itations. Also, for non -con -
tin .us dischargers, concentration lim-
itations (mg/1) sbal aal- where pro-
vided. Con_cen ration limitations 1 11
only 'pl5ly to non -continuous
gers. Only facilities where
chlorophenolic-containing biocides are
used shall be subject to
Pentachlorophenol and trichlorophenol
limitations. Permittees not using
chlorophenolic-containing biocides
must certify to the permit -issuing au-
thority that they are not using these
biocides:
1 An
Environmental Protection Agency
SUBPART C
(NSPS for unbleached kraft facilities where linerboard is produced]
§ 430.35
Pollutant or pollutant property
T55
Kg/kkg (or pounds per 1,000 Ib) of
product
Continuous dischargers
Maximum
for any 1
day
3.4
5.8
(I)
Average pf
daily values
for 30 con-
secutive
days
1.8
3.0
(')
Non -contin-
uous dis-
chargers
(annual
average)
0.94
1.6
(1)
j Maximum for any 1 day
Kglkkg (or
pounds per
1.000 Ib) of
product
Milligrams/liter
Pentachlorophenol
Tr'ohlorophenol
wastewater discharged in kgal per ton at all times.
0.00058
0.00053
(0.015)(9.4)ly
(0.013)(9.4)/y
'Within the range of 5.0 to 9.0 at all times.
SUBPART,C
[NSPS for unbleached kraft facilities where bag paper and other mixed products are produced]
Pollutant or pollutant property
Kg/kkg (or pounds per 1,000 Ib) of
product
Continuous dischargers
Non-
Maximum
for any 1
day
Average of
daily values
for 30 con-
secutive
days
ntln-
uouS dis-
chargers
(annual
average)
0005
TSS
p11
5.0
9.1
(')
2.71
4.8
(')
1.4
2.5
(')
Maximum for any 1 day
Kg/kkg (or
pounds per of
product
Milligrams/liter
Pentachlorophenol
in".!crophenol
y • wastewater discharged in gal per ton at all times.
0.00058
0.00053
(0.012)(11.4)/y
(0.011)(11.4)/y
'Within the range of 5.0 t6 9.0 at all times.
SUBPART C
;NSPS for unbleached/ raft facilities where pulp and paper are produced using the unbleached kraft-neutral sulfite seml-chemical
(cross recovery) process and/or a combined unbleached kraft and semi -chemical process, wherein the spent semi -chemical
cc;king liquor is timed within the unbleached kraft chemical recovery system]
Pollutant or pollutant property
Kg/kkg (or pounds per 1,
product
00 Ib) of
Continuous dischargers
Maximum
for any 1
day
Average of
daily values
for 30 con-
secutive
days
Non -contin-
uous dis-
chargers
(annual
average)
SODS 3.9 2.1 1.1
TSS 7.3 3.8 1.9
pH (') (') (')
141

dissolved oxygen while velocity decreases so there is little reaeration). The capacity for streams
to assimilate oxygen -consuming wastes is also limited under these conditions. DWQ developed
regulations for evaluating discharges to such waters.
In 1980, a study was performed on zero flow streams (7Q10 = 0 cfs and 30Q2 = 0 cfs) to
determine the effect of wastewater discharges. The study concluded that:
• Steady-state models do not apply to zero flow streams, particularly those receiving waste
from small discharges.
• The pool/riffle configuration of these small streams results in violations of the DO standard
even when wastewater is well treated.
• Small streams receiving wastes from schools, mobile home parks, subdivisions, etc. flow
through populated areas where children have easy access to streams.
• Noxious conditions were found in the low flow streams that were part of the study.
As a result of the study, regulations [15A NCAC 2B .0206 (d)] were developed that prohibit new
or expanded discharges of oxygen -consuming wastes to zero flow streams. Existing facilities
discharging to zero flow streams were evaluated for alternatives to discharge. Many facilities
found alternatives to a surface water discharge, and some built new treatment plants to meet
advanced tertiary limits for BOD5 and NH3-N.
This policy typically covers small discharges such as schools, mobile home parks, subdivisions
and rest homes, which discharge to zero flow streams in headwater areas. Such discharges
generally do not cause significant water quality problems in the mainstem of the Roanoke River
or larger tributaries, but they can cause localized problems in the zero flow receiving streams.
The results of the 1980 study were extrapolated to facilities discharging to low flow streams
(those with a 7Q10 = 0, but with a 30Q2 > 0) since similar adverse impacts are expected in these
waters. Regulations [15A NCAC 2B .0206 (d)] were developed to set effluent limitations for
new and expanding discharges to 5 mg/1 BOD5, 2 mg/1 NH3-N and 6 mg/1 dissolved oxygen
(DO) unless it is determined that these limitations will not protect water quality standards.
it.5.2 Modeling Dissolved Oxygen in the Roanoke River
In 1995, DWQ developed a field -calibrated, steady-state model for dissolved oxygen in
approximately 74 miles of the Roanoke River, which extends from the NC 48 bridge at Roanoke
Rapids to the Wildlife Resources Commission boat ramp at Hamilton. At existing permitted
loads during low flow conditions, the predicted minimum dissolved oxygen level is
approximately 6.0 mg/1. Currently, DWQ does not have the proper modeling tool in place to
determine the potential impacts of new or expanding discharges of oxygen -consuming wastes on
the lower Roanoke River and Albemarle Sound (see Recommendations).
4.5.3 Other Dissolved Oxygen Studies
Five US Geological Survey (USGS) continuous monitoring stations measure dissolved oxygen
and temperature along the Roanoke River at 15-minute intervals. Data collection began in 1998
and continues into 2001. These stations were being funded by the US Fish and Wildlife Service;

however, Dominion is funding their operation for several months in 2001. Refer to Part 3.4 for
further information and a partial data summary.
In 1996 and 1997, personnel from the Roanoke River National Wildlife Refuge monitored the
Roanoke River and its tributaries from Indian Creek to Coniott Creek for dissolved oxygen (DO)
and pH. DO concentrations less than 2.0 mg/1 were documented in Coniott Creek from April to
November 1996. In 1997, DO concentrations of less than 2.0 mg/1 were recorded only in July.
Black Gut showed DO concentrations less than 2.0 mg/1 from August to October 1996. At other
locations there were sporadic low DO events, but none were longer than two weeks duration
(DENR-DWQ, May 2000). DWQ has no means for determining whether these particular data
represent natural conditions or impacts from man -induced changes in the watershed; and
therefore, this information is simply reported. These data were not used as a basis for use
support determinations.
Studies to determine impacts of Roanoke Rapids and Gaston Hydropower Project operations on
DO concentrations in the Roanoke River mainstem and tributaries are being conducted by
Dominion, in cooperation with DWQ and other federal and state natural resource agencies, as
part of the Federal Energy Regulatory Commission's (FERC) hydropower dam relicensing
process (refer to Part 4.6.2 below for further information). Section 401 of the federal Clean
Water Act states that no federal agency can issue any license or permit to conduct any activity
that may result in a discharge to navigable waters, unless the state in which the discharge may
occur certifies that the discharge will not result in a violation of any state water quality or related
standards. The water quality studies currently being conducted will provide DWQ with the data
needed to make this determination.
DWQ will continue to evaluate proposed discharges of oxygen -consuming wastes on a case -by -
case basis. For discharges above the WRC boat ramp at Hamilton, the model will be re-
evaluated, including the proposed discharge, to determine the impact of oxygen -consuming
waste on the Roanoke River. If a discharge is proposed below the boat ramp at Hamilton, or if
the model predicts a potential impact from a proposed discharge above the boat ramp at
Hamilton, the Division will require the applicant to meet Best Available Technology (BAT)
limits or to provide/fund a multi -dimensional estuary model.
DWQ will ensure through the 401 Water Quality Certification process that Roanoke Rapids and
Gaston Hydropower Project operations will not result in violations of water quality standards.
4.6 Major Studies Related to Water Quality
Several large studies are being conducted in the Roanoke River basin that could impact water
quality. Current work includes: EPA/Weyerhaeuser Company Dioxin Contamination Studies,
FERC Relicensing of Hydropower Projects and the US Army Corps of Engineers Section 216
study. This section discusses the nature of these studies.

('q) 77Nv
;76)141 K ) 54 33)/73
1-60
l•4/7
3o'
iss I E 4 &CA lore? hefic
Tri C,11 /or the OA
(`
(`qq) S OOq / ) OO S -3o-n
.2'355l 7) 17 U 34 , 30 Z -rss
/.5cR Trick/.
('0c)
6 7.5
r� q ( a
v5s
14 , S l aTv
3af // () 15.s

10/27/04 10:42 FAX [phone]
•
EONS
1NTERNATIoNAL
ROANOKE RAPIDS MILL
I FAX
PAPER
TO: 2m4hti :Miff�iLS
Phone
Fax Phone � / 337/et
1
CC:
REMARKS: ❑ urgent
[Date
INumber of pages to follow cover sheet 5
CM;�---
FROM: EONS Department
International Paper
100 Gaston Road
Roanoke Rapids, NC
27870
/D -27—o,1
Phone [phone]
Fax Phone [phone]
For your review ❑ Reply ASAP ❑ Please Comment
7»fit
7)Tmfl u.-e d, 9'vS5 P P.
C.
4/1.; .
Note: The material contained in this communication is intended only for the use of andthe
addressee. It may contain information that is confidential, proprietary, attorney privileged, f the
exempt from disclosure under applicable law. If the reader of this communication is n
intended recipient,you are hereby notified that any dissemination, distribution or duplication of
p lease
this communication is prohibited. If you have received this communication in error, p
notify us immediately by telephone and return, by mail, the original message to us. Thank you.

10427/04 10:42 FAX [phone]
EOHS
0 002
9/1 733- opq
NPOES No.: NC 0000752
Facility Name: International Paper
Stream: Roanoke River
Location: Hwy 48 Bridge
Upstream
Receiving Stream Month: A
0
10
0
-
0
IN
00010 00400 00310 00300 00095
c
0
HRS
0637-: ' :
2 0632
4
0
0
st;
0
•C • Units mg/L
12.1 6.2 <2 11.0 110
. • •„... "„
c
0
0
m9/L µmho/cm
0631
6 0634
8 ,0628
g.
•
10
10.9 6.6 <2 11.1, 110
12.9 6.6 <2 11.0 110
• . • ••• ..• • • • • . • •
11 •
12 ,0626
0639
14 0626
, : ....•
13.3. 6.6 <2 10.7
:14.3 "•:'• 64. ..'''. ''.:42......;•'• '::•••:•11:0 '•'X'''
13.4 6.2 <2 10.7
' • • -•
110
100
106
t0629 •*"••••••••• •
16 ,0736
18'
,O634
20 0634
22 ,0634
23 '0633 • '
12.8 6.1 <2 10.6
".: • •
....••••
100,
• • •,
16.0 6.5 <2 10.4'
17.1 6.6 <2 10.1
:17:1, :'• -<"2
•;1.'•
Year.
2004
Coun : Halifax
Stream: Roanoke River
Location: NC Hi • hwa 158 Brid • e
100
tio
105
4 I TO,
0
0
0
•.r
1.
00010
4)
0.
Downstream
00400 00310
0
0
0,1
m
00300
c
4)
0
0
HRS•mg/L
126 ••
0610 12.0 6.1 <2
. •.•:. 4
• ?: • • ` •
Units mg/L
10.4
•••••.•
00095
• `"
u
•0
pmho/cm
• •
110
•
0612 10.5
056'gN.10
,0607 13.2
•
6.4, <2
24
.
26
0. 635
-
18.0
6.1
<2
9.8
110
27
0528
47/.9
• .:••••6,4.
..
<2 -
•
a
', ' ;110
28
0631
17.1
6.2
<2
9.7
110
29
0629
17.2
6.3
•
<2
9,6
, 105:
30
0627
18.2
6.1
<2
9.6
110
31
,
.
Average
14.6111111,
<2
10.4
107
Monthly Max.
18.216.8
<2
11.2
110
,Monthly Min.
,.
10.8 6.1
<2
9.6
100
1
,0604 13.21; 6.5 <2
00:
0604 13.4, 6.2. <2
0
10.4
110
••••(..-•••':1'05'
10.21 110
•
•
. • _
10.0 110
10.0 100
' .410.2 • :, -100
9.7 100
0612:•••••;415:6,,.if„',•63:••• ••.:••••;,•949
0611 16.3 6.3 <2
0666J',;(•,10.$••5:••••.•§17•••
0613 17.4 6.6 <2
5161;E17,47'. -611.<2
•;;;-:".•.;
0613 18.2 <2
<217
0608 t 17.5 6.2 <2
0607: i 7:4) <2
0606
• .
5;;•?•
_ 10.0 100
18.3
14.7
18.3
9.8 100
'• 110 • • .•
9.3 110
' • 9:$
9.2 105
9.1 • 105
9.1 110
9.8 106
• .•
6.0 <2
1111.
6.7 <2 1 10.4
9.1: 100
10.5
<2
110

10/27/04 10:42 FAX [phone] EOHS
1 003
NPDES No: NC 0000752
Facility Name: International Paper
Stream: Roanoke River
Receiving Stream !Month: May Year: 2004
]County: Halifax
Location: Hwy 48 Bridge
Upstream
00010
00400 00310
00300
00095
0
U
w
E
7
d)
Q1
a
E
v
s
0.
BOD5. 20-C
K
0
0
'00
0
0
0
HRS
°C
Units mg/L
mg/L
pmho/cm
1
2
3
4
0626
0629
19:7
18.1
6,1 <2
6.4 <2
0.4
9.4
110
110
5
6
06,30
0636
17.8
18.5
61.. <2
6.6 <2
9:8
9.5
145
110
7
0626
18_5
6,2 <2
9.4
115
8
9
10
0629
20.8
6.2 <2
9.1
120
11
.0630
20.7
6.6 <2
9.1
110
12
0626
21.0
6.2 <2
9.1
115
'13
14
0626
0633
•21,4
21.7
.68 <2.
6.2 <2
�.1
8.9
. '120
115
15
16
•17
18
0623
0627
22.3
22.0
6.1 <2.
6.7 <2
8.5
8.4
120
115
19
20
0623
0634
23.0
22.9
6:2 <2
6.6 <2
8.4
8.2
115
120
21.
22
025
22:4
6,2 <2
8:2
120
23
24
0647
25.1
6.2 <2
8.0
120
25
26
0628
0745
25,0
25.5
6.7 <2
6.3 <2
8.7
7.6
115
120
27
28
0754
0748
25.2
25.5
6.5 <2
6.5 <2
7.8
7.3
120
120
29
30
31
Average
Monthly Max.
Monthly Min.
21.9
25.5
17.8
IMf <2
6.8 <2
6.1 <2
8.7
9.5
7.3
116
120
105
Stream: Roanoke River
Location: NC Highway 158 Bridge
Downstream
00010
00400
00310
00300
00095
Time 2400 Clack
Temperature
a
0
N
0
0
CO
a�
0
b
0
O
t
c
0
0
HRS °C
Units
mg/L
m9/L
pmho/cm
0504 19.7
0607 18.3
0609' ' 17.8
0613 18.5
e.5o)
<2,
<2
<2
8.9
8.9
8.9.
9.0
_1.15
105
.105
110
06.08 • 18.4
. 6.1
115
0606 20.7
6.1
<2
8.7
120
;0609 20.8
6.5
<2.
8.6
110
0604 21.3
6.1
<2
8.7
115
0606. ' '21.8
6.7
8.6
115
0612 22.2
6.1
<2
8.3
115
0602 22.5
6.1
<2
7.8
120
0604 21.9
0601 ' 23.3
6.5
<2
K2
7.5
7.5
110
115
0611 23.4
6.4
<2
7.3
115
0604 ' ' 22.5
6.2
2„
7.2
120
0625 25.2
6.1
<2
7.2
120
0607.. 25,1
6.5
<2
7.8
110
0722 25.3
0730 26.1
6.1
6.7
<2
<2
6.9
7.0
120
140
0728 25.4
6.7
<2
6.9
140
22.0
<2
8.0
117
26.1
6.7
<2
9.0
140
17.8
60
<2
6.9
105

10427/04 10:42 FAX [phone]
EOHS
Q1004
NPDES No.: NC 0000752
Facility Name: International Paper
Stream: Roanoke River
Location: Hwy 48 Bridge
Upstream
U
0
0
ai a)
r
HRS
1.' 0632
Average
Monthly Max.
Monthly Min.
Receiving Stream
00010 00400 00310 00300 00095
°C Units mg/L
24.0 .6.9
.. '<2. '
23.6 6.2, <2 8.0 120
24.6 6.4
Month: Jun
IYear 2004
]County: Halifax
Stream: Roanoke River
Location: NC Highway 158 Bridge
Downstream
8.0 110
8.3 110
7.4 110
7.7 120
7.8 ..120
HRS
0609'
0600
0559:
0605
0602;
0605
0601•
0556
0600.
0559
'C Units
6.7
24.1 6.1
05633:: •24.0
0558 24.5
0$56 :'25.$
0553 24.5
0560. ,.252
7.9 115 0552
7.4 120 0559
6.7 1100 0812
23.8 <2 7.8 115
22.1
5.9 <2
8.3 120
6.7 1
24.6
24.6
24.3
24.0
25.8
22.0
mg/L
<2
<2
<2
o. 2 '.
<2
6.7 <2
5.9 <2
6.5
6.5
6.9
114
7.5 130
6.4 105

10/27/04 10:43 FAX [phone] EOHS
Zoos
NPDES No.: NC 0000752
Facility Name: International Paper
Stream: Roanoke River
Location: Hwy 48 Bridge
Upstream
Receiving Stream
0
.1
2
0
C)
O
0
N
00010 00400
TO
4,
n
HRS i �C
'629 • • 1' 24.5
0626 I 24.2
•
0.
Units
00310 00300 00095
0
N
�(1
0
0
m
6)
0�
O
0
4
G
O
0
mg/L mg/L i jmho/cm
l...?.6 •.:1'10
7.4 120
<2
4
a
6
8
•9
10
1'1
12
14
0820 j 25.0
0$35 7 :
0850 26.6
'. ... ;•
6.5 <2 5.9 130
105
6.3 <2
t •
' 0631+ 1 26.7
0620
15 .
16 *0622
17
18�
19 0625
20
'2 0628
22
27.3
28.3
6.6 110
6.1 <2 7.4 120
6.1 <2 •3120
6.2 <2 7.4 115
27.6
' 1• •'28.1
23 0621
24
I 28.4
[Month: Jul
Year. 2004
ICountj: Halifax
Stream: Roanoke River
Location: NC Highway 158 Bridge
Downstream
:3' • 120
62 ' •<2 ' 7.4
26
26 0620
27 .
28 0621
29
300622
31
Average
Monthly Max.
Monthly Min.
27.4
6.0
27.7 6.1
27.3
26.8
28.4
24.2
6.6
5.8
<2
00010
00400 00310
00300 00095
120
7.3 120
*- •• •
<2 7.3 120
HRS
6)
a.
d
0
0
N
'f1
a
O
O
-45
N
QC
V
'C
0600'. ' 24:2
0604 24.3
Units mg/L
K2;
<2
pmholcm
6.2 110 •
6.4 125
<2 7.3 110
0850 25.5
26:3
0905 26.6
<2
<2 -
<2
7.1
7.6
5.9
116
130
105
6.5
6: :
6.5
<2
6.5
6.8
130
115
0608 26.2 (6.0) <2
6.4 120
0559 28.5
6.3 125
0600 28.1 6.1
6.4 120
06o.1,T• :21. : f6.
. • 6;3" 125
14
*A6
0600-
:.; 27:9, .: 6:0' •'2
6:2 .125
0559
0559
0600
27.1-
27.1
26.9
6.1 130
6.0
6.7
125
115
26.7
<2
6.3
121
28.5
6.6 <2
6.8
130
24.2
5.9, <2 , 5.8
105

10/,27/04 10:43 FAX [phone]
EOHS
Z 006
NPDES No.: NC 0000752
Facility Name: International Pa•er
Stream: Roanoke River
Location: Hwy 48 Bridge
Upstream
Receiving Stream
Time 2400 Clock
HRS
1
00010
CI
a`►
E
CI
°C
00400 00310 00300
c
cn
U x
b 0
5
= 0 in
0. c0 N_
ES
Units mg/L mg/L
2
3
4
5
6
0730
0624
27.7,
27.7
0626' [ 27.8
5,91 <2 6.9
6.0
00095
u
0
U
,mho/cm
<2 7.7
6.3 <2 7.7
110
120
110
7'
8
9
10
11
12
13
14
15
16
17
18
19
0635 26.6
0626 26.5
062.9 1 26.3
0625 1 24.5
0621 1 25.1
6.1, <2 7.9
6.4 <2
<2
<2
5.9 . <2
7.9
7.7
8.1
20
21
0623 , 25.4
6.3
<2
120
110,
120
lMonth: Auk 1Year: 2004
Coun : Halifax
Stream: Roanoke River
Location: NC Hi . hwa 158 Brid ' e
Downstream
110
8.0 110
7.9 110
00010 00400 00310
x
u 0 U
U 3 N
O
v 'n
N1 0. 0
E 0
a m
H 1
HRS °C Units mg/L
00300 00095
mglL pmho/cm
22
23
24
25
26
27
0740 26.4,
28^
29
30
0622 r 26.2
0627 26.4
0625 1 26.5
6.2
6.0
6.4
6.4
1
Average 26.411.1
6.4
31
Monthly Max 27.8
Monthly Min. 1 24.5_
5.9
<2 7.6
<2 7.6
<2 7.5
<2 - 7.5
<2 7.7
140
<2 I 8.1
<2 6.9_
120
125
0710 27.3 5.9 <2
120
117
0602 26.9
140
<2
0603 26.9, 6.1+ <2
0612 25.9
'0604 25.9
0608 25.6
110_
0604 23.5
0600 24.6
0602 25.5
0720 25.3
0600 25.6
0604 25.7
0603' 25.8
<2
6.2 <2
5.6 <2
<2
6.1 <2
6.1 <2
5.8 <2
6.2 <2
6.2,- <2
25.71111 <2
27.3 6.2 <2
23 5_ 5.7, <2
5.9 120'
6.3 110
6.7 120
6.5 120
6.3 115
6,2 130
7.4 100
6.7 110
6.2 120--
5.6 120
6.2 125
6.4 130
6.51 125'
6.4
74
5.6
119
130
100

[Fwd: IP Roanoke Rapids]
Subject: [Fwd: IP Roanoke Rapids]
From: Myrl Nisely <[e-mail]>
Date: Thu, 08 Jul 2004 15:42:56 -0400
To: Tom Belnick <[e-mail]>
CC: Ken Schuster <[e-mail]>
Fill: Ale c0 7sti
Tom, here are recent developments on the pH excursion experienced by IP in Roanoke Rapids.
It appears they are interested in pursuing a permit modification. Please advise next step.
Myrl
(ear � -17/9�°i
Original Message
Subject:IP Roanoke Rapids
Date:TJiu. Ju12004 14:37:05 -0400
From:Mary Lee Ransmeier <[e-mail]>
To:[e-mail]
CC:Chris Puryear <[e-mail]>, Jim Cooper <[e-mail]>
1 i'Vei uitta fleet( h iffatiiso(e s-,4,1)449
. �1 #o e&eri L it rat
Thank you for talking with me yesterday regarding the NPDES notice of
violation in reference to low pH reading on our non -contact cooling water
Adischarge s 002 and 003 on May 27, 2003. As we discussed, I am faxing you
some monitoring data from the river upstream and downstream. These are
grab samples. You will note that the river has been as low as 5.9 and is
frequently 6.0 both upstream and downstream. Our total mill treated
discharge with a pH of close to 7 does not seem to have any effect on the
total volume of the river either.
You mentioned our petitioning the Division to amend the permit to
more closely reflect the actual conditions of the river water and the
variation inherent in sampling and testing. While we do not have recorded
data, we know that the pH of rainwater ranges from 4.5-7 when we have
checked. Our field analyst recorded rain here on May 27, 2004. Following
3 an extensive review of our records, rain is the only cause we can possibly
o,attribute to the low pH in our non -contact cooling water on May 27, 2004.
1 -� I would also note that we have gone above the letter of the permit in
.sam ling frequency and have never had this kind of issue before.
114.
We would like to request a permit . ation and would like to
discuss what range of pH wou e considered. Also, we are in the process
4of
closing the mill car wash, discharge 004, and could remove it from our
permit at the same modification. If we close the car wash immediately,
.:� would we be required to conduct sampling and analysis for the third
' quarter? It is important for me to know this as soon as possible since we
would like to remove the structure.
1S
1 of 2
7/8/2004 5:31 PM

[Fwd: IP Roanoke Rapids]
Because of this additional information, I respectfully request that
the State reconsider the NOV letter on this noncompliance event. It would
seem reasonable to invalidate the questionable data as an anomaly, and
beyond the control of the permitee, or send a letter of non-compliance
instead. Thank you for your consideration.
Sincerely,
Mary Lee
Mary Lee Ransmeier
Manager, Environmental Performance/Safety
252-533-6255 office
252-308-3404 cell
Myrl A. Nisely < - ----<
Environmental Chemist II
NC DENR - Div. Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Telephone: [phone], Extension 272
Fax: [phone]
[e-mail]
2of2
7/8/2004 5:31 PM

Roanoke Rapids
Wastewater Treatment Plant
October 2004
Stabilization Sun f2
(190 Ate)
Cella
Pulp Mitt
Paper Milt
0041
Car Wash
1 MGD
3095 MG
16 Daya Retention
Roanoke River
O02
Non -Contact DischanCc
fAID
stA
Aerators:
31 aerators
7 Aire-02
24 spash aerators
2035 hp total
Woodyard
Stormwater
Pond
Swrmwatcr Ditch
Site Plan - Roanoke Rapids
u
001
Nam,
COrgict
irge
Oo2,

Re: ATC•Document for the International Paper mill in Roanoke Rapids, NC
Subject: Re: ATC Document for the International Paper mill in Roanoke Rapids, NC
Date: Fri, 20 Sep 2002 13:32:54 -0400
From: Natalie Sierra <[e-mail]>
Organization: NC DENR DWQ
To: Chris Puryear <[e-mail]>
Mr. Puryear,
Don't worry about another submittal. Consider this e-mail an authorization to
have the spare aerator on site. The Division encourages reliability at WWTPs,
so having the aerator on site can only help. I will put a copy of this e-mail
in the permit file; be sure to list all of the treatment components when you
next renew the NPDES permit.
Feel free to call me if you have any additional questions.
-Natalie
Chris Puryear wrote:
> Ms. Sierra,
> Thanks for your help with the ATC document for our WWTP modifications. I
> am not sure if this is required but we do have an installed spare aerator
> in the aeration pond. This extra aerator was not required by the MACT
> compliance study but is more for the convenience of our maintenance
> department. If an aerator fails for maintenance reasons then we will have
> a spare ready to go if needed. The spare aerator was not included in the
> ATC document that I sent your office. Should I redo the document and
> submit it again? I am sorry for the confusion. Thanks again for your
> help.
> Chris Puryear
Natalie.Sierra.vcf
Name: Natalie.Sierra.vcf
Type: VCard (text/x-vcard)
Encoding: 7bit
Description: Card for Natalie Sierra
1 of 1
9/20/02 1:33 PM

SOC PRIORITY PROJECT: Yes: fflffifflffl No:X
If Yes, SOC No.: fflfflfflffl
NPDES STAFF REPORT AND RECOMMENDATIONS
FOR International Paper
Date: June 28, 2002
To: NPDES Permitting Unit
Water Quality Section
Attention: Tom Belnick
—County: Halifax
_)Permit No. NC0000752
PART I - GENERAL INFORMATION
1. Facility and Address: fernational Paper
P.P.O. Box 580 /
Roanoke Rapids NC 27870
5�I,y
2. Date of Site Visit: March 11, 2002
3. Report Prepared by: Myrl Nisely
4. Persons Contacted and Telephone Number: Chris Puryear, 252-533-6237
5. Directions to Site: Rt. 48 to North edge of Roanoke Rapids
6. Discharge Point(s), List for all discharge points:
Pipe 001 Primary Outfall
Latitude: 36 ° 28' 17" Longitude: 77° 38' 12"
Pipe 002 B&C Cooling
Latitude: 36° 28' 21"
Pipe 003 Turpentine
Latitude: 36° 28' 37"
Pipe 004 Carwash
Latitude: 36° 28' 59"
Longitude: 77° 38' 21"
Longitude: 77° 38' 29"
Longitude: 77" 38' 13"
NPDES Staff Report
Page 1

SOC PRIORITY PROJECT: Yes: fflfflfflffl No:X
If Yes, SOC No.: fflfflfflffl
Attach a USGS map extract and indicate treatment facility site and discharge point
on map. Map attached
U.S.G.S. Quad No.: B28NW U.S.G.S. Quad Name: Roanoke Rapids, NC
7. Site size and expansion area consistent with application? Yes: as described
No: If No, explain:
8. Topography (relationship to flood plain included): The papermill is on the bank of
the river, in the flood plain. However, flood control via the three upstream
dams has proven effective, most recently in Hurricane Floyd when a little over
15" of rain fell in Roanoke Rapids. The site is flat. Clarifier, Emergency Pond
and sludge dewatering are on the papermill side of the Roanoke River, while the
Aeration and Stabilization basins, Discharge structure and Sludge Pond are on
the other. Gravity flow is used from the Clarifier to Aeration.
9. Location of nearest dwelling: Greater than 200' from South fence line
10. Receiving stream or affected surface waters: Roanoke River
a. Classification: C
b. River Basin and Subbasin No.: Roanoke River, 03-02-08
c. Describe receiving stream features and pertinent
downstream uses: Flow regulated by dam system, used for fishing
and secondary recreation, drinking water supply WS-IV
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted: 28 MGD
b. What is the current permitted capacity of the Waste Water Treatment facility?
28 MGD
c. Actual treatment capacity of the current facility (current design capacity)?
28 MGD
d. Date(s) and construction activities allowed by previous Authorization to
Construct issued in the previous two years: none
e. Please provide a description of existing or substantially constructed wastewater
NPDES Staff Report
Page 2

treatment facilities: Open concrete collection ditch with baffle that receives
discharges from numerous in -mill pipes, a separate pipe carrying
condensate to the aeration basin, refrigerated influent sampler, Parshall
flow meter, bar screen, influent pump station, clarifier, nutrient addition
to the clarifier effluent, piping across the Roanoke River by gravity to
aerated lagoon, cascade overflow to four stabilization ponds with
approximately 30 days retention, final bar screen, refrigerated effluent
sampler, flow meter, defoamer addition to the discharge, an emergency
pond with return pump used to contain spills and assist during plant
upsets, two rotary screen sludge thickeners, screwpress dewatering facilities
with pH and polymer addition points, and a sludge pond now used to
receive spoils from pond dredging. Overflow from the sludge pond and
leachate from the non -discharge landfill (Permit No. WQ0000436) both
enter the aeration basin by gravity
f. Please provide a description of proposed wastewater treatment facilities: During
last permit cycle hardpiping of condensates was added, with more aerators
in the lagoon.
g•
Possible toxic impacts to surface waters: none
h. Pretreatment Program (POTWs only):
in development: approved:
should be required: not needed:
2. Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied, please specify DEM permit no.: WQ0013516
Residual Contractor: Branch Residuals and Soils, LLC.
2007 Yanceyville St. Box 45, Greensboro, NC.
336-510-0340 (Consulting)
Price Construction (Spreading) 252-537-0244
Telephone No.: above
b. Residuals stabilization: PSRP:
PFRP: Other: N/A Industrial Category
c. Landfill: Non -discharge on -site, WQ0000436
d. Other disposal/utilization scheme (Specify):
NPDES Staff Report
Page 3

' 3. Treatment plant classification (attach completed rating sheet): Grade IV aerated lagoon;
Ratings Sheet Attached
4. SIC Code(s): 2631
Wastewater Code(s) of actual wastewater, not particular facilities i.e.., non -contact
cooling water discharge from a metal plating company would be 14, not 56.
Primary: 18
Main Treatment Unit Code: 31
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any
public monies involved. (municipals only)? N/A
2. Special monitoring or limitations (including toxicity) requests: NC Mini Chronic test
with ceriodaphnia
3. Important SOC, JOC or Compliance Schedule dates: (Please indicate)
None
Submission of Plans and Specifications
Begin Construction
Complete Construction
Date
4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge
options available? Please provide regional perspective for each option evaluated.
Flow is too large for alternatives to be practical.
Spray Irrigation:
Connection to Regional Sewer System:
Subsurface:
Other disposal options:
5. Other Special Items: Condensates that were formerly sent to the sewer are now
collected and hardpiped to aeration. There is no net change in the BOD load being
treated, however.
PART IV - EVALUATION AND RECOMMENDATIONS
The WQ RRO has performed a site visit and observed several improvements related to
hardpiping of condensates to the aeration basin for MACT Clean Air compliance.
Specifically, 7 — 75 HP aerators have been added to the pond, weekly instead of monthly
monitoring of nutrients in the aeration basin is being done, nutrient samples are taken as
composites instead of grabs, and composite samplers used for process monitoring now have
NPDES Staff Report
Page 4

refrigerators.
Water reduction projects during this permit cycle, along with production cutbacks to about
85% of capacity, have reduced the wastewater flow to historic lows of 12 to 13 MGD.
The State approved an in-house training program for the WWTP operators, and an 8 hour
refresher is given each year.
I recommend that the permit be reissued with a comment acknowledging the extra TOC
sampling of the aeration basin required by the Air Quality permit. Daily (M-F) TOC to
aerator HP is calculated, to be <= 21.5. If the ratio goes above 21.5, more aerators are turned
on.
Signs of report prep
Water
6/8102_
Date
Supervisor Da
NPDES Staff Report
Page 5

INTERNATIONAL
November 28, 2001
Mrs. Valery Stephens
Point Source Branch
Division of Water Quality
NC DENR
1617 Mail Service Center
Raleigh, N.C. 27699- 1617
PAPER
ROANOKE RAPIDS MILL
P.O. BOX 580
ROANOKE RAPIDS, NC 27870
PHONE [phone]
ECEIVE
DEC -42001
DENR WATER (DUALITY
POINT SOURCE BRANCH
Dear Mrs. Stephens:
The purpose of this correspondence is to request the renewal of NPDES permit No.
NC0000752 for the International Paper Company mill located in Roanoke Rapids, North
Carolina. Enclosed you will find a completed NPDES Application Form — Standard
Form C, Major Manufacturing or Commercial Facilities and all requested supplemental
documentation.
There have been no major modification to the wastewater treatment system since the last
permit renewal. In January 2002 modifications will be made to the wastewater
treatment system to comply with the National Emissions Standard for Hazardous Air
Pollutants (NESHAP) for the Pulp and Paper Industry condensate treatment
requirements. An explanation of the treatment system modification is included in the
supplemental documentation. If you have any questions please feel free to contact me at
252-533-6295 or Chris Puryear at 252-533-6237.
Sincerely,
Azle-
N al R. Davis
S . Environmental Engineer
xc: Paul Kinnin
Chris Puryear
Mary Lee Ransmeier
Jim Cooper
Steve Farmer
Matt Giffin - Memphis
Judy Garrett - DE+NR

INTERNATIONAL PAPER
ROANOKE RAPIDS MILL
Sludge Management Plan -
The solids that settle to the bottom of the Primary Clarifier are pumped from the center of
the clarifier to a blend tank where sulfuric acid is added to lower the pH which aids in the
flocculation process. The sludge is then pumped from the blend tank to one of two Rotary
Screen Thickeners (RST). While in route to the RST polymer is added to floc the sludge.
Solids from the RST's are sent to one of two thirty eight (38) foot Dupps Andritz screw
presses where the solids content is increased to approximately 40%. The solids are then
discharged into a screw conveyor and transferred into one of four sealed sludge -hauling
trailers. The sludge solids are taken to the mill's on site permitted landfill (permit No.
WQ0000436) for disposal. The mill also has a permit (No. WQ0013516) to land apply
sludge.
Periodically the surge basin and the stabilization ponds have to be dredged to remove
accumulated solids. This sludge is pumped to an existing sludge pond where the solids
decant and the filtrate returns to the aeration pond for treatment.
Attachment 1

INTERNATIONAL
ROANOKE RAPIDS MILL
PAPER
Wastewater Treatment System Description -
The main sewer that brings the wastewater into the facility is a concrete lined open
channel. Along the channel is the main sewer sampler, pH and conductivity probes, and
a flow meter. The instrumentation has direct readouts at the main sewer and in the
operators control room at the sludge press. The press operator monitors the operation of
the sludge press and the wastewater facility from the control room
The flow goes through a mechanical bar screen then into a wet well with three lift pumps
each with a capacity of pumping 10 million gallons a day. The wastewater is pumped to
a 200-foot diameter Primary Clarifier with a capacity of 3.8 million gallons. Flow can be
diverted directly to a surge pond that can hold approximately two days of mill effluent.
The pond is 20.4 acres and holds 28 million gallons of wastewater. The water from the
surge pond can be pumped back to the head of the wastewater plant at a rate of about 2
million gallons per day.
The flow from the Primary Clarifier is then gravity feed to the aeration pond. The
aeration pond covers 21.5 acres and has a retention time of approximately four days.
There are 24 aerators with a total of 1450 horsepower. The water then cascades down
into the first of four stabilization ponds. There are 370 acres of stabilization ponds with a
retention time of 30 — 35 days.
The final stabilization pond discharge has a bar screen with a discharge sampler. A
butterfly valve at the discharge to the river allows us to control the amount of discharge
flow. Before the butterfly valve is a Marsh McBimey velocity probe type meter where
final effluent flow is measured. We have the capability of adding defoamer after the flow
meter if there is a need to reduce residual foam at the discharge.
Sludge from the primary clarifier is pumped to a blend tank where sulfuric acid is added
for pH control and then pumped to one of two rotary screen thickeners and gravity feed to
one of two Dupps Andritz screw presses. The presses are 38 feet long and produce a
sludge cake of 40 % solids. These solids are deposited in one of four 28-foot dump
trailers and hauled to the landfill.
Dredging from the stabilization or surge ponds are pumped to the existing sludge pond.
The sludge pond is a 27.3-acre in area. Leachate from the sludge pond and landfill flow
into the aeration pond and are treated with the influent to the system.
Attachment 2

INTERNATIONAL (/la) PAPER
ROANOKE RAPIDS MILL
Facility Upgrade —
The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Pulp
and Paper Industry stipulated that unbleached Kraft paper manufacturing facilities collect
and treat foul condensates. It should be noted that this facility is not generating
additional pollutants but simply collecting specific condensates and sending them directly
to the wastewater treatment process. The overall load to the wastewater treatment will
not increase.
International Paper has chosen the "Hard Pipe" alternative for condensate collection and
treatment at the Roanoke Rapids mill. The system is composed of a collection tank for
the condensate, a "hard pipe" to the treatment system, additional aeration capacity and a
nutrient addition system.
The mill will be required to collect enough condensate, on a daily basis, to contain at
least 7.2 pounds of methanol per ton of pulp produced. The condensate will be sent
directly to the aeration pond for biological treatment. To help accomplish the reduction
in methanol
pond. The six (6) additional 75 hp aerators will be used to assure that even under a high
load condition that the methanol will be consumed in the aeration pond process. The
additional aerators will also be available for use whenever it is necessary to provide
added treatment capacity.
an additional 450 hp of aeration capacity will be installed in the aeration
Modeling of the aeration pond process indicated that the treatment system may need
nutrient addition, periodically, to assure optimum conditions for biological treatment of
the condensates. A 7500-gallon nutrient feed tank will be installed adjacent to the
existing primary clarifier. The tank will contain a, non -hazardous, mix of nitrogen and
phosphorus compounds that can be fed at the primary clarifier effluent prior to going to
the aeration pond.
The deadline for Cluster Rule compliance is April 15, 2002. The mill plans to have the
system installed and running by mid -January 2002 so that compliance can be assured
before the April deadline.
Attachment 3

�'Roanokee River
3(s) V 23 .4 1KD (w )
Canal Pump
Bu i I d i ng #27070
Sewer Ditch
Irove Iing
Screen
78056
78057
a, 7 jb58
1057
0 .01 t4C0
InternationaI Paper
Roanoke Rapids Mil I
Water System
A
Car
R inse
2 .01460
Key:
Clean/Non-Contact Water
Contact Water
Roanoke
,1.R fiver„
Clarifier 0
.58 YCD
Aerotion/
Settling
Ponds
Landf i l l
A
Effluent
7 10727107 7107 7107e
2 .81 YC0
7.27YCaIB-MiIICold
(Mao)
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Water Tank
Water Tonk
'j4HD'
(Storage
\Tank /
Stec
05 ri0
2 .26 YCD
0.26 YCD
V
Primary
Turp
Condenser
Secondary
Turp
Condenser
Recaust Hat
Digesters Waler lank
Stearn
..
0.2 a
0.82 YCD
Of
Pulp
Washers
Cloudy NW
1.2 MCU
Eva oration Po er 10 WW1
0.33 YCD 0 .03 YCU
-MII
Paper Machines
7 .5
Y
Pulp
Hot Process
Took
(Hot Water)
Ewer
Water
lank
j1,12 13
/6,6%7
Boilers.
Boiler
F eed Water
Treatment Power Boiler
Scrubber/Ash
Tanks �
310 Steam toP .72 geese -
Stem' 060
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0.05Y
Blow
Down
Tanks
002
77 10 TPPDD
Waste
Water
Treatment
0 .65 Mao
Evaps
1Tnit LigtT
F r on 4tecaus t
System
0 43 MSD
3.6 kM0 (w )
5.8 YC0 (s)
V au
B-Evaps
Surface
ondense
Sur face Condenser Sur face C000rnner
Collect ion Tank Collection Toni
.
(Pulptlill) (Utilities)
YCD (s):4 .6 YCD (w)
(1Ref
Condenser
12 Ref
Condenser
C-Evaps
Surface
ondense
Sewer Ditch
L .true Kil
Scrubber
C Steam
Evaps 0 .4 YCU
wit
White Liqua
To Digesters
A,I
V000r
1.2YCD
Stem
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E
o
0
Y
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Stocks
ewer Ditch
Revised
8 . Pate - 11/01
ar
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v,
Attachment 4

I NTERNATIONAL(/i) PAPER
ROANOKE RAPIDS MILL
Roanoke Rapids
Wastewater Treatment Plant
Stabilization Bum 12
(190 Acres)
C.
3095 MG
16 Days Rescntion
Roanoke River—....,aus.
iiTurpentine
Non -Contact Discharge
Utili
Pulp Mill
Papa Mill
Woodyard
Swcmwatrr
Pond
Aerators:
15 'Splashes' @ 60 hp high sped surface
5 Aire 02 @ 50 hp
4 Aire 02 @ 75 hp
Total hp = 1450
kl
Stormwater Ditch
Site Plan - Roanoke Rapids
Landfill Leachate
(26 Acres)
c
bizcZntict
irge
Attachment 5

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c'

INTERNATIONAL
ROANOKE RAPIDS MILL
Gr/0./1 .4t1) S
PAPER
International Paper Corporation
Roanoke Rapids Mill
Annual Production Tons
1998 504,500 tons
1999 521,675 tons
2000 488,333 tons
6t 116 ac
S Pac.J'- yr- 1-34 Z. b
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Attachment 7