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F WA?F
O�� ROG Michael F. Easley, Governor
Y William G. Ross Jr., Secretary
r North Carolina Department of Environment and Natural Resources
1
`C Alan W. Klimek, P.E. Director
Division of Water Quality
December 30, 2004 '
Mr. Chris Puryear, Environmental Engineer ('
International Paper Corporation lJ l JAN - 5
Roanoke Rapids Mill
100 Gaston Road
Roanoke Rapids, North Carolina 27870---
Subject: Issuance of NPDES Permit NC O000752
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).
2004. This final permit includes no major changes from the draft permit sent to you on November 10,
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable
to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt
of this letter. This request must be in the fort 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 may be 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 }emu 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.
ca Central Files
110cigh Regional Office/ Water Quality Section
NPDES Unit
Aquatic Toxicology Unit
EPA, Region IV
am`
rar
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet h2o.mr.state-nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

Permit NC0000752
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
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

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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POnds
66
le
%ok" AAA
Outfall 003
Outfall 001
Outfall 002
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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:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location'
Flow
Continuous
Recorder
I or E
BOD, 5 day, 20°C
06,852lbs/da
13,704 Ibs/da
Dail
Com osite
E
TotalSus ended Solids
32,110 lbs/day
Dail
Composite
E
Dissolved Oxygen
Dail
Grab
E, U, D
Temperature
Dail
Grab
E, U, D
ConductivityDail
Grab
E, U, D
NH3 as N
Monthly
Composite
E
Total Nitrogen NO2+NO3+TKN
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Chron" ic Toxici
Quarter)
Composite
E
rs Aenic
Quarterly
Composite
E
Chlorides
Quarterly
Composite
E
Copper'
Quarter)
Composite
E
H
6.0 — 9.0 standard units
Dail
Grab
E
Pentachloro henol
1.55 lbs/day
Weekly
Grab
E
Trichlorophenol
1.42lbs/day I
Weekly
Grab I
E
Footnotes:
I 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:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly
Daily
Measurement
Sample
Sample Location
Average
Maximum
Frequency
Type
Flow
Semi-annually
Estimate
Effluent
Temperature `C
Semi-annually
Grab
Effluent
pH
6.0 — 9.0 standard units
Semi-annually
Grab
Effluent, Upstream,
Downstream!
Footnotes:
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 belo%c_
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly
Daily
Measurement
Sample
Sample Location
Average
Maximum
Frequency
Type
Flow
Semi-annually
Estimate
Effluent
Temperature °C
Semi-annually
Grab
Effluent
pH
6.0 — 9.0 standard units
Semi-annually
Grab
Effluent, Upstream,
Downstream3
Footnotes:
I. 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
and 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, quarterx monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent
versions or "North Carolina Phase lI 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
Il 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 TGP313 for
the pass/fail results and TRP313 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.

/1 NPDES Permit Requirements
Page 1 of 16
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events.
3/Week
Samples are collected three times per week on three separate calendar days.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC 1251, et. seq.
Annual Averaa
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which
is not a designed or established or operating mode for the facility.
Calendar Dav
The period from midnight of one day until midnight of the next day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Quart
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 10o ml in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time
interval between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically.
Composite samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour
period of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period
with the time intervals between samples determined by a preset number of gallons passing the sampling
point. Flow measurement between sample intervals shall be determined by use of a flow recorder and
totalizer, and the preset gallon interval between sample collection fixed at no greater than 1/24 of the
expected total daily flow at the treatment system, or
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at
a constant time interval. This method may only be used in situations where effluent flow rates vary
less than 15 percent. The grab samples shall be taken at intervals of no greater than 20 minutes apart
during any 24-hour period and must be of equal size and of no less than 100 milliliters. Use of this method
requires prior approval by the Director.
� ttc

NPDES Permit Requirements
Page 2 of 16
In accordance with (4) above, influent grab samples shall not be collected more than once per hour.
Effluent grab samples shall not be collected more than once per hour except at wastewater treatment systems
having a detention time of greater than 24 hours. In such cases, effluent grab samples may be collected at
intervals evenly spaced over the 24-hour period that are equal in number of hours to the detention time of the
system in number of days. However, the interval between effluent grab samples may not exceed six hours nor
the number of samples less than four during a 24-hour sampling period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. The "daily discharge" concentration comprises the mean
concentration for a 24-hour sampling period as either a composite sample concentration or the arithmetic mean of all
grab samples collected during that period. (40 CFR 122.3)
Daily Maximum
The highest "daily discharge" during the calendar month.
Samplin
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. The Division expects that sampling shall be conducted on weekdays except where holidays or other
disruptions of normal operations prevent weekday sampling. If sampling is required for all seven days of the week
for any permit parameter(s), that requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWO or "the Divisio"
The Division of Water Quality, Department of Environment and Natural Resources.
EMC
The North Carolina Environmental Management Commission.
Facility Closure
The cessation of wastewater treatment at a permitted facility, or the cessation of all activities that require coverage
under the NPDES. Completion of facility closure will allow this permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection Ieveq'� shall be considered = 1.
Grab Sample
Individual samples of at least 100 ml collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
Instantaneous flow measurement
A measure of flow taken at the time of sampling, when both the sample and flow will be representative of the total
discharge.
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NPDFS Permit Requirements
Page 3 of 16
Monthly Averagg (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Quarterly Av a (concentration limit)limit)
The average of all samples taken over a calendar quarter.
Severe prop= damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable,
or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
Upset
An incident beyond the reasonable control of the Pemrittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
WeeklyAverage (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform, the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comlly
The Penmittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation
of the Clean Water Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification; or denial of a permit renewal application [40 CFR 122.411.
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under
section 405(d) of the Clean Water Act within the time provided in the regulations that establish these
standards or prohibitions or standards for sewage sludge use or disposal, even if the permit has not yet been
modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates section 301, 302, 306, 307, 308, 318 or 405 of the
Act, or any permit condition or limitation implementing any such sections in a permit issued under section
402, or any requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8)
of the Act, is subject to a civil penalty not to exceed $25,000 per day for each violation. [40 CFR 122.41 (a)
(2)]
c. The Clean Water Act provides that any person who negkgentfy violates sections 301, 302, 306, 307, 308, 318, or
405 of the Act, or any condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, or any requirement imposed in a pretreatment program approved under section
402(a)(3) or 402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a
negligent violation, a person shall be subject to criminal penalties of not more than $50,000 per day of
violation, or by imprisonment of not more than 2 years, or both. [40 CFR 122.41 (a) (2)]

NPDES Permit Requirements
Page 4 of 16
d. Any person who knoaangly violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In
the case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[40 CFR 122.41 (a) (2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act,
and who knows at that time that he thereby places another person in imminent danger of death or serious
bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not
more than 15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment
violation, a person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than
30 years, or both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction
of violating the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined
up to $2,000,000 for second or subsequent convictions. (40 CFR 122.41 (a) (2)]
F. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such
sections in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are
not to exceed $10,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$25,000. Penalties for Class II violations are not to exceed $10,000 per day for each day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $125,000. [40 CFR
122.41 (a) (3)]
2. Duly to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment
[40 CFR 122.41 (d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Pon II. C. 4), "Upsets" (Part II. C. 5) and "Power
Failures" (Part II. C. 7), nothing in this permit shall be construed to relieve the Permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309
of the Federal Act, 33 USC 1319. Furthermore, the Permittee is responsible for consequential damages, such as
fish kills, even though the responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor
any infringement of Federal, State or local laws or regulations [40 CFR 122 41 (g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
Version 612012003

NPDES Permit Requirements
Page 5 of 16
7. Severabili
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of this
permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the remainder
of this permit, shall not be affected thereby [NCGS 150B-23].
B. Duty to Provide Information
The Permittee shall famish to the Pert Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the
Permit Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41 (h)].
9. Duty to Reapp
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new pennit [40 CFR 122.41 (b)].
10. Expiration of Permit
The Pemtittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the Permittee shall submit such information, forts, and
fees as are required by the agency authorized to issue permits no later than 180 days prior to the expiration date.
Any Permittee that has not requested renewal at least 180 days prior to expiration, or any Permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will subject
the Permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified
[40 CFR 122.41 (k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in
charge of a principal business function, or any other person who performs similar policy or decision
[Waking functions for the corporation, or (b) the manager of one or more manufacturing, production, or
operating facilities, provided, the manager is authorized to make management decisions which govern the
operation of the regulated facility including having the explicit or implicit duty of making major capital
investment recommendations, and initiating and directing other comprehensive measures to assure long
term environmental compliance with environmental laws and regulations; the manager can ensure that
the necessary systems are established or actions taken to gather complete and accurate information for
permit application requirements; and where authority to sign documents has been assigned or delegated
to the manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or
ranking elected official [40 CFR 122.22).
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
1. The authorization is made in writing by a person described above;
2. The authorization specified either an individual or a position having responsibility for the overall
operation of the regulated facility or activity, such as the position of plant manager, operator of a well or
well field, superintendent, a position of equivalent responsibility, or an individual or position having
overall responsibility for environmental matters for the company. (A duly authorized representative may
thus be either a named individual or any individual occupying a named position.); and
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c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate
because a different individual or position has responsibility for the overall operation of the facility, a new
authorization satisfying the requirements of paragraph (b) of this section must be submitted to the Director
prior to or together with any reports, information, or applications to be signed by an authorized
representative [40 CFR 122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the
following certification [40 CFR 122.22]:
7 certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate
the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. 1 am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations. °
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned
changes or anticipated noncompliance does not stay any permit condition [40 CFR 122.41 (0].
13. Permit Modification Revocation and Reissuance or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the
permit, revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 2H .0100; and North Carolina General Statute 143-215.1 et. al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within chitty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 211.0105 (b) (4)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
Certified Operator
Upon classification of the permitted facility by the Certification Commission, the Permittee shall employ a
certified water pollution control treatment system operator in responsible charge (ORC) of the water pollution
control treatment system. Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the water pollution control treatment system by the Certification Commission. The
Permittee must also employ one or more certified Back-up ORCs who possess a currently valid certificate of the
type of the system. Back-up ORCs must possess a grade equal to (or no more than one grade less than) the grade
of the system [15A NCAC 8G.0201].
The ORC of each Class I facility must:
➢ Visit the facility at least weekly
➢ Comply with all other conditions of 15A NCAC 8G.0204.
The ORC of each Class II, III and IV facility must:
➢ Visit the facility at least daily, excluding weekends and holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 8G.0204.
Once the facility is classified, the permitter: shall submit a letter to the Certification Commission designating the
operator in responsible charge:
a. Within 60 calendar days prior to wastewater being introduced into anew system
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Within 120 calendar days of:
➢ Receiving notification of a change in the classification of the system requiring the designation of a
new ORC and back-up ORC
➢ A vacancy in the position of ORC or back-up ORC.
2. Proper Operation and Maintenance
The Permittee shall at all tunes provide the operation and maintenance resources necessary to operate the existing
facilities at optimum efficiency. The Permittee shall at all times properly operate and maintain all facilities and
systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the Permittee to install
and operate backup or auxiliary facilities only when necessary to achieve compliance with the conditions of the
permit [40 CFR 122.41 (e)].
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41
(c)]
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41 (m) (2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41 (m) (3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior
notice, if possible at least ten days before the date of the bypass; including an evaluation of the
anticipated quality and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II. E. 6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
5. ets
a. Effect of an upset [40 CFR 122.41 (n) (2)]: An upset constitutes an affirmative defense to an action
brought for noncompliance with such technology based permit effluent limitations if the requirements of
paragraph b. of this condition are met. No determination made during administrative review of claims that
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noncompliance was caused by upset, and before an action for noncompliance, is final administrative action
subject to judicial review.
b. Conditions necessary for a demonstration of upset: A Permittee who wishes to establish the
affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or
other relevant evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part H. E. 6. (b) (B) of this permit
(4) The Permittee complied with any remedial measures required under Pan II. B. 2. of this permit.
d. Burden of proof [40 CFR 122.41 (n) (4)1: The Permittee seeking to establish the occurrence of an
upset has the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States. The Permittee
shall comply with all existing Federal regulations governing the disposal of sewage sludge. Upon promulgation of
40 CFR Part 503, any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be
reopened and modified, or revoked and reissued, to incorporate applicable requirements at 40 CFR 503. The
Permittee shall comply with applicable 40 CFR 503 Standards for the Use and Disposal of Sewage Sludge (when
promulgated) within the time provided in the regulation, even if the permit is not modified to incorporate the
requirement The Permittee shall notify the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 2H.0124 —
Reliability) to prevent the discharge of untreated or inadequately treated wastes during electrical power failures
either by means of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
Rgpresentative Smpling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of
the permitted discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is
characteristic of the discharge over the entire period the sample represents. All samples shall be taken at the
monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is diluted
by any other wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority [40 CFR 122.41 0)),
2. Report
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (MR 1, 1.1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the 28th day following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of
these, and all other reports required herein, shall be submitted to the following address:
NC DENR / Division of Water Quality / Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I
of this permit and based on the manufacturers pump curves shall not be subject to this requirement.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to
NCGS 143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to
Section 304(p), 33 USC 1314, of the Federal Water Pollution Control Act (as Amended), and 40 CFR 136; or in
the case of sludge use or disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit [40 CFR 122.41).
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum
detection and reporting levels that are below the permit discharge requirements and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge requirements,
then the most sensitive (method with the lowest possible detection and reporting level) approved method must
be used.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by
a fine of not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or
by both. If a conviction of a person is for a violation committed after a first conviction of such person under this
paragraph, punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more
than 4 years, or both [40 CFR 122 41].
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge
use and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40
CFR 503), the Permittee shall retain records of all monitoring information, including.
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41].
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record
the following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d.. The individual(s) who performed the analyses;
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e. The analytical techniques or methods used; and
f. The results of such analyses.
B. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting
as a representative of the Director), upon the presentation of credentials and other documents as may be required
by law, to;
a. Enter upon the Permittee's premises where a regulated facility or activity is located or conducted, or where
records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable tithes, any words that must be kept under the conditions of this
permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the Clean Water Act, any substances or parameters at any location [40 CFR 122.41 (i)].
Section E Reporting Requirements
Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit The discharge
of any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall
constitute a violation of the permit.
2. Planned Changgs
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or
additions to the permitted facility [40 CFR 122.41 (1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42 (a) T.
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices,
and such alteration, addition or change may justify the application of permit conditions that -are different
from or absent in the existing permit, including notification of additional use or disposal sites not reported
during the permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41 (1) (2)].
4. Transfers
This permit is not transferable to any person except after notice to the Director. The Director may require
modification or revocation and reissuance of the permit to document the change of ownership. Any such action
may incorporate other requirements as may be necessary under the Clean Water Act [40 CFR 122.410) (3)].
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit (40 CFR 122.41 M (4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part H. D. 2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation and reporting of the data submitted on the DMR
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6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written
submission shall contain a description of the noncompliance, and its cause; the period of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance [40 CFR 122 41 (1) (6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone], [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II. E. 5 and 6. of this permit at
the time monitoring reports are submitted. The reports shall contain the information listed in Part II. E. 6. of
this permit [40 CFR 122.410) (7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or
submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit
such facts or information [40 CFR 122.41 (1) (8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the
Division as soon as possible, but in no case more than 24 hours or on the next working day following the
occurrence or first knowledge of the occurrence of any of the following.
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester, the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to receiving
waters without treatment of all or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following fast
knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division of Water Quality. As required by the Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may result in the imposition of criminal penalties as
provided for in NCGS 143-215.1(b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this permit, including
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not more than $25,000 per violation, or by imprisonment for not more than two years per violation, or by both
[40 CFR 122.411.
12. Annual Performance Reports
Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Permittee (NCGS 143-215.1 C).
The report shall summarize the performance of the collection or treatment system, as well as the extent to which
the facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality.
The report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon
which annual period is used for evaluation.
PART III
OTHER REQUIREMENTS
Section A. Construction
The Permittee shall not commence construction of wastewater treatment facilities, nor add to the planes treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless the Division has issued an
Authorization to Construct (AtC) perrnit. Issuance of an AtC will not occur until Final Plans and Specifications for
the proposed construction have been submitted by the Permittee and approved by the Division.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director of the Division of Water Quality, conduct groundwater
monitoring as may be required to determine the compliance of this NPDES permitted facility with the current
groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Pernittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent
basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
p) One hundred micrograms per liter 000 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms
per liter (500 µg/L) for 2.4-dinirophenol and for 2-methyl-4.6-dinirophenol; and one milligram per liter
(l mg/L) for antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or
infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the
highest of the following "notification levels';
(1) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter 0 mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Evaluation of Wastewater Discharge Alternatives
The Permittee shall evaluate all wastewater disposal alternatives and pursue the most environmentally sound
alternative of the reasonably cost effective alternatives. If the facility is in substantial non-compliance with the terms
and conditions of the NPDES permit or governing rules, regulations or laws, the Permittee shall submit a report in
such form and detail as required by the Division evaluating these alternatives and a plan of action within 60 days of
notification by the Division.
Section E. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system
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adverse impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit
continue at the permitted facility.
PART IV
SPECIAL CONDITIONS FOR MUNCIPAL FACILITIES
Section A. Publicly Owned Treatment Works (POTWs)
All POTWs must provide adequate notice to the Director of the following.
I. Any new introduction of pollutants into the POTW from an indirect discharger which would be subject to
section 301 or 306 of CWA if it were directly discharging those pollutants; and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger
as influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of
effluent introduced into the POTW, and (2) any anticipated impact of the change on the quantity or quality
of effluent to be discharged from the POTW.
Section B. Municipal Control of Pollutants from Industrial Users.
1. Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from
industries using the municipal system may be present in the Permitter's discharge. At such time as
sufficient information becomes available to establish limitations for such pollutants, this permit may be
revised to specify effluent limitations for any or all of such other pollutants in accordance with best
practicable technology or water quality standards.
2. Under no circumstances shall the Permittee allow introduction of the following wastes in the waste
treatment system:
a. Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees
Centigrade using the test methods specified in 40 CFR 261.21;
b. Pollutants which will cause corrosive structural damage to the POTW, but in no case Discharges
with pH lower than 5.0, unless the works is specifically designed to accommodate such Discharges;
C. Solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW
resulting in Interference;
d. Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow
rate and/or pollutant concentration which will cause Interference with the POTW,
C. Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in
no case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C
(104°F) unless the Division, upon request of the POTW, approves alternate temperature limits;
f. Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will
cause interference or pass through;
g. Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a
quantity that may cause acute worker health and safety problems;
h. Any trucked or hauled pollutants, except at discharge points designated by the POTW.
3. With regard to the effluent requirements fisted in Part I of this permit, it may be necessary for the
Permittee to supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to
ensure compliance by the Permittee with all applicable effluent limitations. Such actions by the Permittee
may be necessary regarding some or all of the industries discharging to the municipal system.
4. The Permittee shall require any industrial discharges sending influent to the permitted system to meet
Federal Pretreatment Standards promulgated in response to Section 307(b) of the Act. Prior to accepting
wastewater from any significant industrial user, the Permittee shall either develop and submit to the
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Division a Pretreatment Program for approval per 15A NCAC 2H .0907(a) or modify an existing
Pretreatment Program per 15A NCAC 2H .0907(b).
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved
POTW Pretreatment Program or to include a compliance schedule for the development of a POTW
Pretreatment Program as required under Section 402(b)(8) of the Clean Water Act and implementing
regulations or by the requirements of the approved State pretreatment program, as appropriate.
Section C. Pretreatment Programs
Under authority of sections 307(b) and (c) and 402(b)(8) of the Clean Water Act and implementing regulations 40
CFR Part 403, North Carolina General Statute 143-215.3 (14) and implementing regulations 15A NCAC 2H
.0900, and in accordance with the approved pretreatment program, all provisions and regulations contained and
referenced in the Pretreatment Program Submittal are an enforceable part of this permit.
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the Clean
Water Act, the Federal Pretreatment Regulations 40 CFR Part 403, the State Pretreatment Regulations 15A
NCAC 2H .0900, and the legal auihorities, policies, procedures, and financial provisions contained in its
pretreatment program submission and Division approved modifications there of. Such operation shall include
but is not limited to the implementation of the following conditions and requirements:
1. Sewer Use Ordinance (SUOI
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program.
2. Industrial Waste Survey X&S)
The Permittee shall update its Industrial Waste Survey (IWS) to include all users of the sewer collection
system at least once every five years.
3. Monitoring Plan
The Permittee shall implement a Division approved Monitoring Plan for the collection of facility specific
data to be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of
specific pretreatment local limits. Effluent data from the Plan shall be reported on the DMRs (as required
by Part II, Section D, and Section E.5.).
4. Headworks Analysis (H2A1 and Local Limits
The Permittee shall obtain Division approval of a Headworks Analysis (HWA) at least once every five
years, and as required by the Division. Within 180 days of the effective date of this permit (or any
subsequent permit modification) the Permittee shall submit to the Division a written technical evaluation
of the need to revise local limits (i.e., an updated HWA or documentation of why one is not needed) [40
CFR 122.421. The Permittee shall develop, in accordance with 40 CFR 403.5(c) and 15A NCAC 2H .0909,
specific Local Limits to implement the prohibitions listed in 40 CFR 403.5(a) and (b) and 15A NCAC 2H
.0909.
5. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all significant industrial users, permits for
operation of pretreatment equipment and discharge to the Pemuttee's treatment works. These permits
shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control
technologies to assure that their wastewater discharge will meet all applicable pretreatment standards and
requirements. The Permittee shall maintain a current Allocation Table (AT) which summarizes the results
of die Headworks Analysis (HWA) and the limits from all Industrial User Pretreatment Permits ([UP).
Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA.
Version &=003

NPDES Permit Requirements
Page 15 of 16
6. Authorization to Construct (A to Q
The Permittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable
industrial users for the construction or modification of any pretreatment facility. Prior to the issuance of
an AtC, the proposed pretreatment facility and treatment process must be evaluated for its capacity to
comply with all Industrial User Pretreatment Permit (IUP) limitations.
POTW Inspection & Monitoring of their SIUs
The Perrittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by industrial
users, compliance with applicable pretreatment standards. The Permittee must:
a. Inspect all Significant Industrial Users (SIUs) at least once per calendar year; and
b. Sample all Significant Industrial Users (SIUs) at least twice per calendar year for all permit -
limited pollutants, once during the period from January 1 through June 30 and once during the
period from July 1 through December 31, except for organic compounds which shall be sampled
once per calendar year;
8. SIU Self Monitoring and Reporting
The Pemuttee shall require all industrial users to comply with the applicable monitoring and reporting
requirements outlined in the Division approved pretreatment program, the industry's pretreatment permit,
or in 15A NCAC 2H .0908.
9. Enforcement Response Plan (ERP
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the Clean Water Act (40 CFR 405 et. seq), prohibitive
discharge standards as set forth in 40 CFR 403.5 and 15A NCAC 2H .0909, and specific local limitations.
All enforcement actions shall be consistent with the Enforcement Response Plan (ERP) approved by the
Division.
10. Pretreatment Annual Reports (PART
The Permittee shall report to the Division in accordance with ISA NCAC 2H .0908. In lieu of submitting
annual reports, Modified Pretreatment Programs developed under 15A NCAC 2H .0904 (b) may be
required to meet with Division personnel periodically to discuss enforcement of pretreatment requirements
and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual
Report (PAR) describing its pretreatment activities over the previous twelve months to the Division at the
following address:
NC DENR / DWQ / Pretreatment Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
These reports shall be submitted according to a schedule established by the Director and shall contain the
following.
a.) Narrative
A brief discussion of reasons for, status of, and actions taken for all Significant Industrial
Users (SIUs) in Significant Non -Compliance (SNC);
b.) Pretreatment Progmm Summary (PPS)
A pretreatment program summary (PPS) on specific forms approved by the Division;
c.) Significant Non -Compliance Report (; NCRI
The nature of the violations and the actions taken or proposed to correct the violations on
specific forms approved by the Division;
d.) Industrial Data Summary Forms OD54
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NPDES Permit Requirements
Page 16 of 16
Monitoring data from samples collected by both the POTW and the Significant Industrial
User (SIU). These analytical results must be reported on Industrial Data Summary Forms
(IDSF) or other specific format approved by the Division;
e.) Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules,
public notice of SIUs in SNC, and any other information, upon request, which in the
opinion of the Director is needed to determine compliance with the pretreatment
implementation requirements of this permit
11. Public Notice
The Pennittee shall publish annually a list of Significant Industrial Users (SIUs) that were in Significant
Non -Compliance (SNC) as defined in the Pemrittee's Division approved Sewer Use Ordinance with
applicable pretreatment requirements and standards during the previous twelve month period. This list
shall be published within four months of the applicable twelve-month period.
12. Record Keenine
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along
with support information including general records, water quality records, and records of industrial impact
on the POTW.
13. Funding and Financial Report
The Pemrittee shall maintain adequate funding and staffing levels to accomplish the objectives of its
approved pretreatment program.
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits
modifications, POTW monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan
modifications, shall be considered a permit modification and shall be governed by 15 NCAC 2H .0114 and
15A NCAC 2H .0907.
Version 612012003

�
State of North Carolin0' Rd
Department of Environment �� •
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor RCDENR
William G. Ross Jr., Secretary NORTH CAROLINA DEPARTMENT OF
Alan Klimek, PE, Director ENVIRONMENT AND NATURAL RESOURCES
March 7, 2003
Chris Puryear, Environmental Supervisor
International Paper Corporation
P.O. Box 580
Roanoke Rapids, North Carolina 27870
Subject:
Dear Mr. Puryear:
Permit No.
Internation;
Roanoke R
Halifax County
In response to your renewal application for continued coverage under NPDES stormwater permit
NCS000106, the Division of Water-Quathy (Division) is forwarding herewith the subject state - NPDES
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 US Environmental Protection
agency dated May 9, 1994 (or as subsequently amended).
Please note that the Division has revised the analytical monitoring strategy for individual
stormwater permits. Based on a review of the permit monitoring data received to date, the analytical
monitoring measurement frequencies have been changed and cut-off concentrations have been removed.
These changes will be implemented for all second term individual stormwater permits with analytical
monitoring requirements. For those permits with analytical monitoring requirements, Part 11-
Monitoring, Controls, and Limitations for Permitted Discharges has been modified to reflect the change
in monitoring strategy.
The qualitative monitoring strategy remains the same as the first term of the permit. Please note
that the semi-annual qualitative monitoring is a requirement of the permit. Failure to complete the
monitoring as required is a violation of the permit and any permit noncompliance constitutes a violation
of the Clean Water Act. Reference Part III, Section A, Item 2 'Duty to Comply", Item 9 'Penalties for
Tampering " and Item 10 'Penalties for Falsification of Reports" of your permit for further information.
In response to your letter of November 14, 2000, commenting on the Draft Permit, we offer the
following:
1. You had significant concern about the ability to accomplish quarterly sampling in the fourth year of
the permit. We appreciate the effort made to get all outfalls sampled and we agree that it is more
appropriate for you to have annual sampling even during the fourth year. The permit has been
modified to remove the quarterly sampling in the fourth year.
2. You had requested that the permit contain language such that representative rainfall events that only
occurred on weekends, holidays, or at night would not be required to be sampled and would not be
considered to be missed opportunities to sample. We understand the difficulty in getting a
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Page 2
representative rainfall event but since only one event per year is required at the outfalls, we believe
additional language in the pemut concerning weekends, holidays and nights is not warranted. You
may want to consider requesting representative outfall status for certain outfalls in order to reduce
the number of outfalls that must be sampled. The permit language in this regard remains unchanged.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing 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 Fled with the Office of Administrative
Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611 -7447. Unless such demand is
made, this. decision shall be final and binding.
Please take notice this permit is not transferable. Part III, B.2. addresses the requirements to be
followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be required
by the Division of Water Quality or permits required by the Division of Land Resources, 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 Bill Mills at telephone number
919/733-5083 ext. 548.
Sincerely,
S:...
IR � • -
!"11 C. MIILS
for Alan Klimek, PE
cc: Mr. Roger O. Pfaff, EPA
Raleigh Regional Office
Stormwater and General Permits Unit
Central Files
1�0101alt11orti 1

NCS000106
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
TO DISCHARGE STORMWATER 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 stormwater from a facility located at
International Paper Corp.
North Roanoke Avenue
Roanoke Rapids
Halifax County
to receiving waters designated as Roanoke River and a tributary to Roanoke River, both class C
streams, in the Roanoke River Basin
in accordance with the discharge limitations, monitoring requirements, and other conditions set
forth in Parts I, II, III, IV, V and VI hereof.
This permit shall become effective April 1, 2003.
This permit and the authorization to discharge shall expire at midnight on March 31, 2008.
Signed this day March 7, 2003.
for Alan Klimek, PE, Director
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit No. NCS000106
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B: Analytical Monitoring Requirements
Section C: Qualitative Monitoring Requirements
Section D: On -Site Vehicle Maintenance Monitoring Requirements
PART III STANDARD CONDITIONS
Section A: Compliance
and Liability
1.
Compliance Schedule
2.
Duty to Comply
3.
Duty to Mitigate
4.
Civil and Criminal Liability
5.
Oil and Hazardous Substance Liability
6.
Property Rights
7.
Severability-
8.
Duty to Provide Info '& rm�ion
9.
Penalties for Tampering
10.
Penalties for Falsification of Reports
Section B: General Conditions
1. Individual Permit Expiration
2. Transfers
H

Permit No. NCS000106
3. Signatory Requirements
4. Individual Permit Modification, Revocation and Reissuance, or
Termination
5. Permit Actions
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
1.
Representative Sampling
2.
Recording Results
3.
Flow Measurements
4.
Test Procedures
5.
Representative Outfall
6.
Records Retention
7.
Inspection and Entry
Section E: Reporting
Requirements
1.
Discharge Monitoring Reports
2.
Submitting Reports
3.
Availability of Reports
4.
Non-Stormwater Discharges
5.
Planned Changes
6.
Anticipated Noncompliance
7.
Bypass
8.
Twenty-four Hour Reporting
9.
Other Noncompliance
10.
Other Information
PART IV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS
I

Permit No. NCS000106
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited and monitored as specified in this permit.
SECTION B: PERMITTED ACTIVITIES
Until this permit expires or is modified or revoked, the permittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system which has
been adequately treated and managed in accordance with the terms and conditions of this
individual permit. All discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization or approval.
This permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
Part I Page 1 of 2

Permit No. NCS000106
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this individual permit. The Plan shall include, at a
minimum, the following items:
1. Site Plan. The site plan shall provide a description of the physical facility and the
potential pollutant sources which may be expected to contribute to contamination of
stormwater discharges. The site plan shall contain the following:
(a) A general location map (USGS quadrangle map or appropriately drafted
equivalent map), showing the facility's location in relation to transportation
routes and surface waters, the name of the receiving water(s) to which the
stormwater outfall(s) discharges, or if the discharge is to a municipal separate
storm sewer system, the name of the municipality and the ultimate receiving
waters; and accurate latitude and longitude of the point(s) of discharge.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices.
(c) A site map drawn to scale with the distance legend indicating location of
industrial activities (including storage of materials, disposal areas, process areas
and loading and unloading areas), drainage structures, drainage areas for each
outfall and activities occurring in the drainage area, building locations, existing
BMPs and impervious surfaces, and the percentage of each drainage area that is
impervious. For each outfall, a narrative description of the potential pollutants
which could be expected to be present in the stormwater discharge.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the 3 previous years and any corrective actions taken to mitigate spill
impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
accordance with the requirements found in Part III, Standard Conditions, Section
B, Paragraph 3.
2. Stormwater Management Plan. The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
nonstructural measures. The stormwater management plan, at a minimum, shall
incorporate the following:
Part 11 Page 1 of 6

Permit No. NCS000106
(a) Feasibility Study. A review of the technical and economic feasibility of changing
the methods of operations and/or storage practices to eliminate or reduce exposure
of materials and processes to stormwater. Wherever practical, the permittee shall
prevent exposure of all storage areas, material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is
not practical, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
(b) Secondary Containment Schedule. A schedule to provide secondary containment
for bulk storage of liquid materials, storage of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals, or storage of hazardous substances to prevent leaks and spills from
contaminating stormwater runoff. If the secondary containment devices are
connected directly to stormwater conveyance systems, the connection shall be
controlled by manually activated valves or other similar devices [which shall be
secured with a locking mechanism] and any stormwater that accumulates in the
containment area shall be at a minimum visually observed for color, foam, outfall
staining, visible sheens and dry weather flow, prior to release of the accumulated
stormwater. Accumulated stormwater shall be released if found to be
uncontaminated by the material stored within the containment area. Records
documenting the individual making the observation, the description of the
accumulated stormwater and the date and time of the release shall be kept for a
period of five years.
(c) BMP Summary. A narrative description shall be provided of Best Management
Practices (BMPs) to be considered such as, but not limited to, oil and grease
separation, debris control, vegetative filter strips, infiltration and stormwater
detention or retention, where necessary. The need for structural BMPs shall be
based on the assessment of potential of sources to contribute significant quantities
of pollutants to stormwater discharges and data collected through monitoring of
stormwater discharges.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or team) responsible for implementing the
SPRP shall be identified. A responsible person shall be on -site at all times during facility
operations that have the potential to contaminate stormwater runoff through spills or
exposure of materials associated with the facility operations. The SPRP must be site
stormwater specific. Therefore, a SPCC plan may be a component of the SPRP, but may
not be sufficient to completely address the stormwater aspects of the SPRP. The common
elements of the SPCC with the SPRP may be incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance program shall be developed. The program shall document schedules of
inspections and maintenance activities of stormwater control systems, plant equipment
and systems. Inspection of material handling areas and regular cleaning schedules of
these areas shall be incorporated into the program.
Part II Page 2 of 6

1 N 1[i_M6MZWICIT11UM
5. Employee Training. Training schedules shall be developed and training provided at a
minimum on an annual basis on proper spill response and cleanup procedures and
preventative maintenance activities for all personnel involved in any of the facility's
operations that have the potential to contaminate stormwater runoff. Facility personnel
(or team) responsible for implementing the training shall be identified.
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s) responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance which has a significant effect on the
potential for the discharge of pollutants to surface waters. The Stormwater Pollution
Prevention Plan shall be reviewed and updated on an annual basis.
The Director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part III, Standard Conditions, Section B, Paragraph 3) to the Director that the changes
have been made.
8. Facility Inspection Program. Facilities are required to inspect all stormwater systems on
at least a semiannual schedule, once in the fall (September -November) and once in the
spring (April - June). The inspection and any subsequent maintenance activities
performed shall be documented, recording date and time of inspection, individual(s)
making the inspection and a narrative description of the facility's stormwater control
systems, plant equipment and systems. Records of these inspections shall be
incorporated into the Stormwater Pollution Prevention Plan.
Stormwater discharge characteristic monitoring as required in Part II of this permit shall
be performed in addition to facility inspections.
9. Implementation. The permittee shall document all monitoring, measurements,
inspections and maintenance activities and training provided to employees, including the
log of the sampling data and of activities taken to implement BMPs associated with the
industrial activities, including vehicle maintenance activities. Such documentation shall
be kept on -site for a period of five years and made available to the Director or his
authorized representative immediately upon request.
Part II Page 3 of 6

Permit No. NCS000106
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater subject to the provisions of this permit.
Analytical monitoring of stormwater discharges shall be performed as specified below in Table
1.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 4 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO). The permittee shall complete the 4
analytical samplings in accordance with the schedule specified below in Table 2.
Table 1. Analvtical Monitoring Requirements
Discharge
Measurement Frequencyl
Sample
Sample
Characteristics
Units
Ty e2
Location3
Chemical Oxygen Demand
mg/1
Years 1, 2, 3, and 4
Grab
SDO
Total Suspended Solids
mgn
Years 1, 2, 3, and 4
Grab
SDO
Total Phosphorous
MRA
Years 1, 2, 3, and 4
Grab
SDO
Total Lead
m
Years 1, 2, 3, and 4
Grab
SDO
Total Rainfall4
inches
Years 1, 2, 3, and 4
Event Duration4
minutes
Years 1, 2, 3, and 4
Total Flow4
MG
Years 1, 2, 3, and 4
SDO
Footnotes:
1 Measurement Frequency: Once per year during the 1", 2, P and 4th years of the permit term. A year is defined
as the 12 month period beginning on the month and day of issuance of the Permit. See Table 2 for schedule of
monitoring periods.
2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm, then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless representative
outfall status has been granted.
4 For each sampled representative storm event the total precipitation, storm duration, and total flow must be
monitored. Total flow shall be either; (a) measured continuously, (b) calculated based on the amount of area
draining to the outfall, the amount of built -upon (impervious) area, and the total amount of rainfall, or (c)
estimated by the measurement of flow at 20 minute intervals during the rainfall event.
Part 11 Page 4 of 6

Permit No. NCS000106
Table 2 Monitoring schedule
Monitoring period
Sample Number
Start
End
Year 1
1
March 1, 2003
February 29, 2004
Year 2
2
March 1, 2004
February 28, 2005
Year 3
3
March 1, 2005
February 28, 2006
Year
4
March 1, 2006
February 28, 2007
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status and shall be performed as specified below in Table 3. Qualitative
monitoring is for the purpose of evaluating the effectiveness of the Stormwater Pollution
Prevention Plan (SPPP) and assessing new sources of stormwater pollution. No analytical tests
are required. Qualitative monitoring of stormwater outfalls does not need to be performed during
a representative storm event.
In the event an atypical condition is noted at a stormwater discharge outfall, the Permittee shall
document the suspected cause of the condition and any actions taken in response to the
discovery. This documentation will be maintained with the Stormwater Pollution Prevention
Plan.
All qualitative monitoring will be performed twice per year, once in the spring (April - June) and
once in the fall (September - November).
Table 3. Qualitative Monitoring Requirements
Discharge Characteristics
Frequency
Monitoring
Locationl
Color
Semi -Annual
SDO
Odor
Semi -Annual
SDO
Clarity
Semi -Annual
SDO
Floating Solids
Semi -Annual
SDO
Suspended Solids
Semi -Annual
SDO
Foam
Semi -Annual
SDO
Oil Sheen
Semi -Annual
SDO
Other obvious indicators
of stormwater pollution
Semi -Annual
SDO
Footnotes:
I Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall (SDO)
regardless of representative outfall status.
Part II Page 5 of 6

Permit No. NCS000106
SECTION D: ON -SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities which have any vehicle maintenance activity occurring on -site which uses more than
55 gallons of new motor oil per month when averaged over the calendar year shall perform
analytical monitoring as specified below in Table 4. This monitoring shall be performed at all
outfalls which discharge stormwater runoff from vehicle maintenance areas.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 4 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO) which discharges stormwater runoff from
vehicle maintenance areas. The permittee shall complete the 4 analytical samplings in
accordance with the schedule specified in Table 2 (Part 11, Section B).
Table 4. Analvtical Monitorine Reuttirements for On -Site Vehicle Maintenance
Discharge Characteristics
Units
Measurement
Sample
Sample
Frequencyl
Type2
Location3
H
standard
Years 1, 2, 3, and 4
Grab
SDO
Oil and Grease
mg/1
Years 1, 2, 3, and 4
Grab
SDO
Total Suspended Solids
m
Years 1, 2, 3, and 4
Grab
SDO
New Motor Oil Usagegallons/month
Years 1, 2, 3, and 4
Estimate
-
Total Flow4
MG
Years 1, 2, 3, and 4
Grab
SDO
Footnotes:
I Measurement Frequency: Once per year during the 1", 2e°, 3" and 0 year of the permit term. A year is defined
as the 12 month period beginning on the month and day of issuance of the Permit. See Table 2 for schedule of
monitoring periods.
2 If the stormwater runoff is controlled by a stormwater detention pond, a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm, then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) that discharges
stormwater runoff from area(s) where vehicle maintenance activities occur.
4 Total flow shall be; (a) measured continuously, (b) calculated based on the amount of area draining to the outfall,
the amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated by the measurement
of flow at 20 minute intervals during the rainfall event. Total precipitation and duration of the rainfall event
measured shall result from the sampled representative storm event.
Part 11 Page 6 of 6

Permit No. NCS000106
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater discharges in
accordance with the following schedule:
Existing Facilities: The Stormwater Pollution Prevention Plan shall be developed and implemented within
12 months of the effective date of the initial permit and updated thereafter on an annual basis. Secondary
containment, as specified in Part 11, Section A, Paragraph 2(b) of this permit, shall be accomplished within
12 months of the effective date of the initial permit issuance.
Proposed Facilities: The Stormwater Pollution Prevention Plan shall be developed and implemented prior to
the beginning of discharges from the operation of the industrial activity and be updated thereafter on an
annual basis. Secondary containment, as specified in Part Il, Section A, Paragraph 2(b) of this permit shall
be accomplished prior to the beginning of discharges from the operation of the industrial activity.
2. Duty to Comply
The permittee must comply with all conditions of this individual permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit upon renewal application.
a. The permittee shall comply with standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants within the time provided in the regulations that establish these
standards or prohibitions, even if the permit has not yet been modified to incorporate the
requirement.
b. The Clean Water Act provides that any person who violates a permit condition is subject to a civil
penalty not to exceed $27,500 per day for each violation. Any person who negligently violates any
permit condition is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
imprisonment for not more than 1 year, or both. Any person who knowingly violates permit
conditions is subject to criminal penalties of $5,000 to $50,000 per day of violation, or
imprisonment for not more than 3 years, or both. Also, any person who violates a permit condition
may be assessed an administrative penalty not to exceed $11,000 per violation with the maximum
amount not to exceed $137,500. [Ref: Section 309 of the Federal Act 33 USC 1319 and 40 CFR
122.41(a).]
C. Under state law, a daily civil penalty of not more than twenty-five thousand dollars ($25,000) per
violation may be assessed against any person who violates or fails to act in accordance with the
terms, conditions, or requirements of a permit. [Ref: North Carolina General Statutes 143-
215.6A]
d. Any person may be assessed an administrative penalty by the Director for violating section 301,
302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or limitation implementing any
of such sections in a permit issued under section 402 of the Act. Administrative penalties for Class
I violations are not to exceed $11,000 per violation, with the maximum amount of any Class I
penalty assessed not to exceed $27,500. Penalties for Class 11 violations are not to exceed $11,000
per day for each day during which the violation continues, with the maximum amount of any Class
11 penalty not to exceed $137,500.
Part III Page 1 of 8 Pages

Permit No. NCS000106
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this
individual permit which has a reasonable likelihood of adversely affecting human health or the environment.
4. Civil and Criminal Liability
Except as provided in Part II1, Section C of this permit regarding bypassing of stormwater control facilities,
nothing in this individual permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3,143-215.6A, 143-215.613, 143-
215.6C or Section 309 of the Federal Act, 33 USC 1319. Furthermore, the pennittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Oil and Hazardous Substance Liability
Nothing in this individual permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject to
under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this individual permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State or local laws or regulations.
7. Severabili[y
The provisions of this individual permit are severable, and if any provision of this individual permit, or the
application of any provision of this individual permit to any circumstances, is held invalid, the application
of such provision to other circumstances, and the remainder of this individual permit, shall not be affected
thereby.
8. Duty to Provide Information
The permittee shall furnish to the Director, within a reasonable time, any information which the Director
may request to determine whether cause exists for modifying, revoking and reissuing, or terminating the
permit issued pursuant to this individual permit or to determine compliance with this individual permit. The
permittee shall also furnish to the Director upon request, copies of records required to be kept by this
individual permit.
9. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate,
any monitoring device or method required to be maintained under this individual permit shall, upon
conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more
than two years per violation, or by both. If a conviction of a person is for a violation committed after a first
conviction of such person under this paragraph, punishment is a fine of not more that $20,000 per day of
violation, or by imprisonment of not more than 4 years, or both.
10. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this individual
Part III Page 2 of 8 Pages

Permit No. NCS000106
permit, including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be
punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than two years
per violation, or by both.
SECTION B: GENERAL CONDITIONS
Individual Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the permittee shall submit forms and fees as are
required by the agency authorized to issue permits no later than 180 days prior to the expiration date. Any
permittee that has not requested renewal at least 180 days prior to expiration, or any permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be
subjected to enforcement procedures as provided in NCGS § 143-2153.6 and 33 USC 1251 et. seq.
2. Transfers
This permit is not transferable to any person except after notice to and approval by the Director. The
Director may require modification or revocation and reissuance of the permit to change the name and
incorporate such other requirements as may be necessary under the Clean Water Act. Permittee is required
to notify the Division in writing in the event the permitted facility is sold or closed.
3. Signatory Requirements
All applications, reports, or information submitted to the Director shall be signed and certified.
a. All applications to be covered under this individual permit shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a
responsible corporate officer means: (a) a president, secretary, treasurer or vice president
of the corporation in charge of a principal business function, or any other person who
performs similar policy or decision making functions for the corporation, or (b) the
manager of one or more manufacturing production or operating facilities employing more
than 250 persons or having gross annual sales or expenditures exceeding 25 million (in
second quarter 1980 dollars), if authority to sign documents has been assigned or
delegated to the manager in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively, or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official.
b. All reports required by the individual permit and other information requested by the Director shall
be signed by a person described above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
responsibility, or an individual or position having overall responsibility for environmental
Part III Page 3 of 8 Pages

Permit No. NCS000106
matters for the company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Director.
C. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
4. Individual Permit Modification Revocation and Reissuance, or Termination
The issuance of this individual permit does not prohibit the Director from reopening and modifying the
individual permit, revoking and reissuing the individual permit, or terminating the individual permit as
allowed by the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122
and 123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North Carolina
General Statute 143-215.1 et. al.
5. Permit Actions
The permit may be modified, revoked and reissued, or terminated for cause. The notification of planned
changes or anticipated noncompliance does not stay any individual permit condition.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of treatment and
control (and related appurtenances) which are installed or used by the permittee to achieve compliance with
the conditions of this individual permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the operation of
back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation
is necessary to achieve compliance with the conditions of this individual permit.
2. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this individual permit.
Bypassing of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee for bypass unless:
a. Bypass was unavoidable to prevent loss of life, personal injury or severe property damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary control facilities,
retention of sormwater or maintenance during normal periods of equipment downtime or dry
Part III Page 4 of 8 Pages

Permit No. NCS000106
weather. This condition is not satisfied if adequate backup controls should have been installed in
the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal
periods of equipment downtime or preventive maintenance; and
C. The permittee submitted notices as required under, Part III, Section E of this permit.
If the Director determines that it will meet the three conditions listed above, the Director may approve an
anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
Representative Sampline
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and
nature of the permitted discharge. Analytical sampling shall be performed during a representative storm
event. Samples shall be taken on a day and time that is characteristic of the discharge. All samples shall be
taken before the discharge joins or is diluted by any other waste stream, body of water, or substance.
Monitoring points as specified in this permit shall not be changed without notification to and approval of
the Director.
2. Recording Results
For each measurement, sample, inspection or maintenance activity performed or collected pursuant to the
requirements of this individual permit, the permittee shall record the following information:
a. The date, exact place, and time of sampling, measurements, inspection or maintenance activity;
b. The individual(s) who performed the sampling, measurements, inspection or maintenance activity;
C. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
I. The results of such analyses.
3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with accepted scientific
practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of
monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published pursuant to
NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations published pursuant
to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as Amended, and Regulation
40 CFR 136.
To meet the intent of the monitoring required by this individual permit, all test procedures must produce
minimum detection and reporting levels and all data generated must be reported down to the minimum
detection or lower reporting level of the procedure.
Part III Page 5 of 8 Pages

Permit No. NCS000106
5. Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater discharges that are
required to be sampled, the permittee may petition the Director for representative outfall status. If it is
established that the stormwater discharges are substantially identical and the permittee is granted
representative outfall status, then sampling requirements may be performed at a reduced number of outfalls.
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with the Stormwater
Pollution Prevention Plan. Copies of analytical monitoring results shall also be maintained on -site. The
permittee shall retain records of all monitoring information, including all calibration and maintenance
records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all
reports required by this individual permit for a period of at least 5 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time.
Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized contractor
acting as a representative of the Director), or in the case of a facility which discharges through a municipal
separate storm sewer system, an authorized representative of a municipal operator or the separate storm
sewer system receiving the discharge, upon the presentation of credentials and other documents as may be
required by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or conducted,
or where records must be kept under the conditions of this individual permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of
this individual permit;
C. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment),
practices, or operations regulated or required under this individual permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring individual permit compliance
or as otherwise authorized by the Clean Water Act, any substances or parameters at any location.
SECTION E: REPORTING REQUIREMENTS
1. Discharge Monitoring Reports
Samples analyzed in accordance with the terms of this permit shall be submitted to the Division on
Discharge Monitoring Report forms provided by the Director. Submittals shall be received by the Division
no later than 30 days from the date the facility receives the sampling results from the laboratory.
2. Submitting Reports
Duplicate signed copies of all reports required herein, shall be submitted to the following address:
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Part III Page 6 of 9 Pages

Permit No. NCS000106
3. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the Federal
Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for public inspection
at the offices of the Division of Water Quality. As required by the Act, analytical data shall not be
considered confidential. Knowingly making any false statement on any such report may result in the
imposition of criminal penalties as provided for in NCGS 143-215.613 or in Section 309 of the Federal Act.
4. Non-Stormwater Discharges
If the storm event monitored in accordance with this individual permit coincides with a non-stormwater
discharge, the permittee shall separately monitor all parameters as required under the non-stormwater
discharge permit and provide this information with the stormwater discharge monitoring report.
5. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which could significantly alter the nature or quantity of pollutants discharged. This notification
requirement includes pollutants which are not specifically listed in the individual permit or subject to
notification requirements under 40 CFR Part 122.42 (a).
6. Anticipated Noncompliance
The permittee shall give notice to the Director as soon as possible of any planned changes at the permitted
facility which may result in noncompliance with the individual permit requirements.
Bypass
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall submit
prior notice, if possible at least ten days before the date of the bypass; including an evaluation of
the anticipated quality and affect of the bypass.
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of becoming aware of an
unanticipated bypass.
8. Twenty-four Hour Reporting
The permittee shall report to the central office or the appropriate regional office any noncompliance which
may endanger health or the environment. Any information shall be provided orally within 24 hours from
the time the permittee became aware of the circumstances. A written submission shall also be provided
within 5 days of the time the permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes; the period of
noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the
anticipated time compliance is expected to continue; and steps taken or planned to reduce, eliminate, and
prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case -by -case basis if the oral report has been received
within 24 hours.
9. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour reporting at the time
monitoring reports are submitted.
Part III Page 7 of 9 Pages

Permit No. NCS000106
10. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in an application for an
individual permit or in any report to the Director, it shall promptly submit such facts or information.
Part III Page 8 of 8 Pages

Permit No. NCS000106
PART IV LIMITATIONS REOPENER
This individual permit shall be modified or alternatively, revoked and reissued, to comply with any applicable
effluent guideline or water quality standard issued or approved under Sections 302(b) (2) (c), and (d), 304(b) (2) and
307(a) of the Clean Water Act, if the effluent guideline or water quality standard so issued or approved:
a. Contains different conditions or is otherwise more stringent than any effluent limitation in the individual
permit or
b. Controls any pollutant not limited in the individual permit.
The individual permit as modified or reissued under this paragraph shall also contain any other requirements in the
Act then applicable.
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days after being billed by
the Division. Failure to pay the fee in timely manner in accordance with 15A NCAC 2H .0105(b)(4) may cause this
Division to initiate action to revoke the Individual Permit.
PART VI DEFINITIONS
Act
See Clean Water Act.
2. Arithmetic Mean
The arithmetic mean of any set of values is the summation of the individual values divided by the number of
individual values.
3. Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Non-stormwater discharges which shall be allowed in the
stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
(b) Uncontaminated groundwater, foundation drains, air -conditioner condensate without added
chemicals, springs, discharges of uncontaminated potable water, waterline and fire hydrant
flushings, water from footing drains, flows from riparian habitats and wetlands.
(c) Discharges resulting from fire -fighting or fire -fighting training
4. Best Management Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters. BMPs may take the
form of a process, activity, or physical structure.
Parts IV, V and VI Page I of 5

n
Permit No. NCS000106
5. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control facility including
the collection system, which is not a designed or established operating mode for the facility.
6. Bulk Storage of Li uid Products
Liquid raw materials, manufactured products, waste materials or by-products with a single above ground
storage container having a capacity of greater than 660 gallons or with multiple above ground storage
containers located in close proximity to each other having a total combined storage capacity of greater than
1,320 gallons.
7. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33
USC 1251, et. seq.
8. Division or DWO
The Division of Water Quality, Department of Environment and Natural Resources.
9. Director
The Director of the Division of Water Quality, the permit issuing authority.
10. EMC
The North Carolina Environmental Management Commission.
11. Grab Sample
An individual sample collected instantaneously. Grab samples that will be directly analyzed or qualitatively
monitored must be taken within the first 30 minutes of discharge.
12. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
13. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and which is not a land
treatment facility, a surface impoundment, an injection well, a hazardous waste long-term storage facility or
a surface storage facility.
14. Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such as a city or town.
15. Overburden
Any material of any nature, consolidated or unconsolidated, that overlies a mineral deposit, excluding
topsoil or similar naturally -occurring surface materials that are not disturbed by mining operations.
Part VI Page 2 of 5 Pages

Permit No. NCS000106
16. Permittee
The owner or operator issued a permit pursuant to this individual permit.
17. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited to, any pipe, ditch,
channel, tunnel, conduit, well, or discrete fissure from which stormwater is or may be discharged to waters
of the state.
18. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72 hours in which no
storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to 10 consecutive
hours of no precipitation. For example, if it rains for 2 hours without producing any collectable discharge, and then
stops, a sample may be collected if a rain producing a discharge begins again within the next 10 hours.
19. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is representative of the
discharges at multiple outfalls, the DWQ may grant representative outfall status. Representative outfall
status allows the permittee to perform analytical monitoring at a reduced number of outfalls.
20. Rinse Water Discharge
The discharge of rinse water from equipment cleaning areas associated with industrial activity. Rinse
waters from vehicle and equipment cleaning areas are process wastewaters and do not include washwaters
utilizing any type of detergent or cleaning agent.
21. Secondary Containment
Spill containment for the contents of the single largest tank within the containment structure plus sufficient
freeboard to allow for the 25-year, 24-hour storm event.
22. Section 313 Water Priority Chemical
A chemical or chemical category which
a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superf ind Amendments and
Reauthorization Act (SARA) of 1986, also titled the Emergency Planning and Community Right -
to -Know Act of 1986;
b. Is present at or above threshold levels at a facility subject to SARA title III, Section 313 reporting
requirements; and
C. That meet at least one of the following criteria:
(1) Is listed in Appendix D of 40 CFR part 122 on either Table II (organic priority
pollutants), Table III (certain metals, cyanides, and phenols) or Table IV (certain toxic
pollutants and hazardous substances);
(2) Is listed as a hazardous substance pursuant to section 31 l(b)(2)(A) of the CWA at 40
CFR 116.4; or
(3) Is a pollutant for which EPA has published acute or chronic water quality criteria.
Part VI Page 3 of 5 Pages

r
Permit No. NCS000106
23. Severe Property Damage
Means substantial physical damage to property, damage to the control facilities which causes them to
become inoperable, or substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not mean economic loss
caused by delays in production.
24. Significant Materials
Includes, but is not limited to: raw materials; fuels; materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products; raw materials used in food processing or production;
hazardous substances designated under section 101(14) of CERCLA; any chemical the facility is required to
report pursuant to section 313 of Title III of SARA; fertilizers; pesticides; and waste products such as ashes,
slag and sludge that have the potential to be released with stormwater discharges.
25. Significant Swills
Includes, but is not limited to: releases of oil or hazardous substances in excess of reportable quantities
under section 311 of the Clean Water Act (Ref: 40 CFR 110.10 and CFR 117.21) or section 102 of
CERCLA (Ref: 40 CFR 302.4).
26. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately following rainfall or as a
result of snowmelt.
27. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying stormwater and which is
directly related to manufacturing, processing or raw material storage areas at an industrial site. Facilities
considered to be engaged in "industrial activities" include those activities defined in 40 CFR 122.26(b)(14).
The term does not include discharges from facilities or activities excluded from the NPDES program.
28. Stormwater Pollution Prevention Plan
A comprehensive site -specific plan which details measures and practices to reduce stormwater pollution and
is based on an evaluation of the pollution potential of the site.
29. Ten Year Design Storm
The maximum 24 hour precipitation event expected to be equaled or exceeded on the average once in ten
years. Design storm information can be found in the State of North Carolina Erosion and Sediment Control
Planning and Design Manual.
30. Total Flow
The flow corresponding to the time period over which the entire storm event occurs. Total flow shall be
either; (a) measured continuously, (b) calculated based on the amount of area draining to the outfall, the
amount of built -upon (impervious) area, and the total amount of rainfall, or (c) estimated by the
measurement of flow at 20 minute intervals during the rainfall event.
31. Toxic Pollutant
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
Part VI Page 4 of 5 Pages

Permit No. NCS000106
32. Upset
Means an exceptional incident in which there is unintentional and temporary noncompliance with
technology based permit effluent limitations because of factors beyond the reasonable control of the
permittee. An upset does not include noncompliance to the extent caused by operational error, improperly
designed treatment or control facilities, inadequate treatment or control facilities, lack of preventive
maintenance, or careless or improper operation.
33. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, vehicle cleaning operations, or
airport deicing operations.
34. Visible Sedimentation
Solid particulate matter, both mineral and organic, that has been or is being transported by water, air,
gravity, or ice from its site of origin which can be seen with the unaided eye.
35. 25-year. 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the average, once in 25
years.
Part VI Page 5 of 5 Pages

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
Mr. Chris Puryear, Environmental Supervisor
International Paper
P.O. Box 580
Roanoke Rapids, North Carolina 27870
Dear Mr. Puryear:
VA RX)
ion
NCDENR
September 10, 2002
Subject: Authorization to Construct
ATC No. 0000752A0I
NPDES Permit No. NC0000752
Roanoke Rapids Mill
Halifax County
The Division of Water Quality's NPDES Unit has reviewed your request for an Authorization to Construct at
the Roanoke Rapids Mill. The Division finds the proposed improvements to be satisfactory and hereby grants
authorization for the following:
• Installation of six (6) 75 hp. aerators to the aeration basin.
• Installation of a nutrient addition system to assure optimum conditions for the
biological treatment system.
This Authorization to Construct is issued in accordance with NPDES Permit No. NC0000752, issued
August 25, 1997, and shall be subject to revocation unless the wastewater treatment facilities are constructed in
accordance with the terms and conditions of the permit. This Authorization to Construct in no way represents
any change to the permitted f row or capacity of the plant.
The Permittee shall notify the Water Quality Supervisor of the Raleigh Regional Office, telephone number
[phone], at least forty-eight (48) hours prior to operation of the installed facilities, so that an in -place
inspection can be made. Notification shall be made during the normal office hours of 8:00 a.m. until 5:00 p.m.,
Monday through Friday.
En ' eer's Certification Certification
Upon completion of construction and prior to operation of the modified facility, the Permittee shall provide the
Division with a certification (copy enclosed) from a professional engineer registered in North Carolina
certifying that the permitted facility has been installed in accordance with the NPDES Permit, this
Authorization to Construct, and the approved plans and specifications. The Certification should be submitted
to: NCDENR / DWQ, NPDES Unit, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617.
R�uirements for Certified O�ratorfor Certified Orator
The Permittee shall employ a certified wastewater treatment plant operator to be in responsible charge (ORC)
of the wastewater treatment facilities. The operator must hold a certificate of the type and grade at least
equivalent to or greater than the classification assigned to the wastewater treatment facilities by the
Certification Commission. The Permittee must also employ a certified back-up operator of the appropriate type
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Internet: http://h2o.enr.state.nc.us/

International Paper — Roanoke Rap s Pill
NPDES Permit No. NC0000752
ATC No. 0000752AOI
Page 2
and grade to comply with the conditions of Title 15A, Chapter 8G, .0200. The ORC of the facility must visit
each Class I facility at least weekly and each Class II, III, and IV facility at least daily, excluding weekends
and holidays; and must properly manage and document daily operation and maintenance of the facility and
comply with all other conditions of Title I5A, Chapter 8G, .0200.
Additional Requirements
The Operational Agreement between the Permittee and the Environmental Management Commission is
incorporated herein by reference and is a condition of this Permit. Noncompliance with the terms of the
Operational Agreement shall subject the Permittee to all sanctions provided by G. S. 143-215.6 for violation of
or failure to act in accordance with the terms and conditions of this Permit.
Failure to abide by the requirements contained in this Authorization to Construct may subject the Permittee to
an enforcement action by the Division of Water Quality in accordance with North Carolina General Statute
143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government agencies (local, state,
and federal) which have jurisdiction.
The Permittee shall maintain a copy of the approved plans and specifications on file for the life of the facility.
One (1) copy of the approved plans and specifications is enclosed for your records.
If you have any questions about this Authorization to Construct, please contact Natalie Sierra, at (919) 733-
5083, extension 551.
Sincerely,
an W. Klimek, P.E.
Enclosures: Project Plans and Specifications (approved)
Engineer's Certification Form
cc: Raleigh Regional Office, Water Quality
Technical Assistance and Certification Unit
Central Files
NPDES Unit Files

State of North Caroli#
Department of Enviro I dent,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
k ".
Ilk
NCDENR
December 30, 1998
JAN 14
Mr. Thomas C. Puryear
Environmental Supervisor
Champion International Corporation _
N. Roanoke Avenue
Roanoke Rapids, North Carolina 27870
Subject: NPDES Permit Modification
NPDES No. NC000075it
Roanoke Rapids Mill
Halifax County
Dear Mr. Puryear:
In accordance with the application for a discharge permit modification received on
November 19, 1998, the Division is forwarding herewith the subject NPDES permit
modification. 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 December 6, 1983.
In a letter dated November 18, 1998, Champion requested reduction or elimination of
monitoring for ammonia and mercury. After evaluating the effluent data from the Roanoke
Rapids Mill, the Division has made the following modifications to the permit:
1) The monitoring for ammonia has been reduced from 3/Week to Monthly. As discussed
with Mr. Myrl Nisely, Champion will review test procedures to identify a method that will
utilize a lower detection level that is constant month to month.
2) Monitoring for mercury has been eliminated. Based on information provided by Mr.
Nisely, the last time mercury was detected in the effluent was in 1995. The concentration of
mercury at that time was at 0.2 ug/1, which is at the detection level. Monthly mercury data
since that time has shown mercury concentrations below detection levels. Mr. Nisely
confirmed that mercury concentrations were incorrectly recorded on the DMRs without the
.1 .e"
sign.
If any parts, measurement frequencies or sampling requirements contained in this permit
are unacceptable to you, you have the right to an adjudicatory hearing 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, Post Office Drawer 27447, Raleigh, North Carolina
27611-7447. Unless such demand is made, this decision shall be final and binding.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Please take note that this permit is not transferable. Part II, EA. addresses the
requirements to be followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land
Resources, 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 Steve D. Pellei at
telephone number [phone], extension 516.
Sincerely,
A
f*"Preston Howard, Jr.,T E.
cc: Central Files
Raleigh Regional Office, Water Quality Section
Mr. Roosevelt Childress, EPA
NPDES Unit

December 29, 1998 mod.
A.(1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0000752
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:
Monthly Average
ai y Maximum
_Measurement
�
amRle
Type
Sample
Location'
How
28.0 MUD
oninuous
ecor er
or
ay,
s
Daily
ai y
e
oommppoossi
a en aSolidsay
;Liisssxygen
a
e
ai y
ra
empera ure
ai y
ra
pH
ai y
ra
on uc iwGrab
Total i rogen Z+ NQ3+
on y
omposi e
otal Phosphorus
on y
omposi e
hronic oxicity
ua e y
omposi e
Pentac orophen01
s ay
Trichlorophenol4
1.49 lbs/day
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 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
3 Chronic Toxicity (Ceriodaphnia) P/F at 3.7%; March, June, September and December; see Part I, Section A (5), Special Condition 1. .
4 Monitoring for pentachlorophenols and trichlorophenols is not required based on the information contained in the Champion Letter dated
December 15, 1988. If chlorophenolic-containing biocides are used at the facility, monitoring for pentachlorophenols and trichlorophenols
shall commence immediately on a weekly basis at the effluent by grab samples 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.
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.
Special permit conditions applicable to the subject facility are listed on the Supplement to Effluent Limitations and Monitoring Requirements
page.

December 29, 1998 mod.
A.(1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0000752
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. (Continued)
Monthly Average ai ymaximum easuremen
amp a
amp e
req nc
Type
Loca n
3 as N
onthly
Uomposite
uen
Arsenic
Quarter
omposi a
uen
chloridesQuarter
omposi a
uen
Copper
Quarterly
omposi a
uen
Footnotes:
Monitoring for metals, chlorides, and the whole effluent toxicity test shall be conducted at the same time.
is

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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Thomas C. Puryear
Environmental Supervisor
Champion International Corporation
N. Roanoke Avenue
Roanoke Rapids, North Carolina 27870
August 25, 1997
r
L
[D FE F4
AUG 2 9 1997
UHNR RALEIGH REGIONAL OFFICE
Subject: NPDES Permit Issuance
NPDES No. NC0000752
Roanoke Rapids Mill
Halifax County
Dear Mr. Puryear:
In accordance with the application for a discharge permit received on December 3, 1996,
the Division is forwarding herewith the subject NPDES 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 December 6, 1983.
In response to your comment letter of July 16, 1997, the Division submits the following:
1) The description of the treatment facilities has been revised according to your request.
2) Footnote number 4 for outfall 001 was inadvertently truncated in the draft permit. The
requirement to test for pentachlorophenols and trichlorophenols is applicable ONLY if
chlorophenolic biocidal compounds are utilized. Otherwise, no monitoring for these
constituents is required. The Ainits for these two constituents will remain in the permit, albeit
the monitoring requirement may not be applicable.
3) The ammonia levels in this effluent are significantly higher than previously assumed. In
addition, background levels of ammonia are much higher than typical values for waterbodics
such as the Roanoke River. Since ammonia is a significant oxygen consuming waste, more
frequent monitoring is necessary to assure dissolved oxygen standards are protected. Both
the Weyerhaeuser and Champion paper plants on the Roanoke River have had this
requirement added to their permits as a mechanism to assess that downstream dissolved
oxygen levels are protected. After 12 months of data, you may request a decrease in
monitoring frequency.
4) Due to the confirmed presence of mercury in the effluent, it is essential to more frequently
monitor and limit this parameter. Mercury has a significant potential to be chemically
changed instream making it readily bioaccumulative. The Division strongly encourages
Champion to identify and eliminate the source of mercury in the effluent.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

0 0
If any parts, measurement frequencies or sampling requirements contained in this permit
are unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request trust 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, Post Office Drawer 27447, Raleigh, North Carolina 27611-
7447. Unless such demand is made, this decision shall be final and binding.
Please take note that this permit is not transferable. Part II, EA. addresses the
requirements to be followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land Resources,
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 Steve D. Pellei at
telephone number [phone], extension 516.
Sincerely,
Original Signed By
Oavid A. Goodrich
A. Preston Howard, Jr., P.E.
cc: Central Files
Raleigh Regional Office, Water Quality Section
Mr. Roosevelt Childress, EPA
Permits and Engineering Unit
Facility Assessment Unit
Aquatic Survey and Toxicology Unit
Technical Assistance & Certification Group

0
0
Permit No. NC0000752
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Champion International Corporation
is hereby authorized to discharge wastewater from a facility located at
Champion International Wastewater Treatment Plant
North Roanoke Avenue
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.
The permit shall become effective October 1, 1997
This permit and the authorization to discharge shall expire at midnight on May 31, 2002
Signed this day August 25, 1997
Original Signed By
David A. Goodrich
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

0 a
SUPPLEMENT TO PERMIT COVER SHEET
Champion International Corp.
is hereby authorized to:
r n101IR1 06111Y 1i&N
1. Continue to operate the existing 28.0 MGD wastewater treatment facility (outfall 001)
consisting of a mechanical bar screen, primary clarifier, emergency holding pond, sludge
lagoon, aeration basin, three stabilization ponds, and a final bar screen to treat process
wastewater and stormwater located at the Champion International Wastewater Treatment Plant,
North Roanoke Avenue, Roanoke Rapids, Halifax County, (See Part III of this Permit), and
2. Continue to discharge non -contact cooling water from the Utilities Department (002) and the
pulp mill (003) , and
3. Continue to discharge car wash wastewater from outfall 004, and
4. Discharge from said treatment works at the locations specified on the attached map into
Roanoke River which is classified C waters in the Roanoke River Basin.

ROAD CLASSIFICATION
PRIMARY HIGHWAY LIGHT -DULY ROAD, HARD OR
HARD SURFACE IMPROVED SURFACE
SECONDARY HIGHWAY
HARDSURFACE =11111119=11 UNIMPROVED ROAD
Latitude 36028'19" Longitude 77038'14'I
Map # B28NW Sub -basin 03-02-08
Stream Class C
Discharge Class 18 14 61
i
1 000 000
FEET
i
27'30"
SCALE 1:24 000
1 1 MILE—
17000 FEET
1 1 KILOMETER
CONTOUR
QUAD LOCATION Champion International
NC0000752
Halifax County
Roanoke Plant

A.(I). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0000752
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:
EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS
Monthly Average
Daily Maximum
Measuremen
Sample
Type
Sample
Locationl
Frequency
Flow
28.0 MGD
Continuous
Recorder
I or E
BOD, 5 day, 200C
6 852 lbs/day
13,704 lbs/day
Daily
Composite
E
Total Suspended Solids
16,800 lbs/day
33,600 lbs/day
Daity
Composite
E
Dissolved Oxygen
Daily
Grab
E U D
Temperature
Daily
Grab
E U D
H2
Dailv
Grab
E
Conductivity
Grab
E U D
Total Nitrogen (NO2 + NO3 + TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Chronic Toxicit 3
Quarterly
Composite
E
Pentachloro henol4
1.63 Ibs/da
Trichloro henol4
1.49 Ibs/da
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 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
3 Chronic Toxicity (Ceriodaphnia) P/F at 3.7%; March, June, September and December; see Part I, Section A (5), Special Condition 1.
4 Monitoring for pentachlorophenols and trichlorophenols is not required based on the information contained in the Champion Letter dated
December 15, 1988. If chlorophenolic-containing biocides are used at the facility, monitoring for pentachlorophenols and trichlorophenols shall
commence immediately on a weekly basis at the effluent by grab samples 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.
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.
Special permit conditions applicable to the subject facility are listed on the Supplement to Effluent Limitations and Monitoring Requirements page.
s

A.(1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0000752
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. (Continued)
EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS
Monthly —Average
Daily Maximum
Measurement
Sample
Type
am le
Location
Frequency
NH3 as
3/Week
Composite
Effluent
Arsenic
Quarterly
Composite
Effluent
Chlorides
Quarterly
Composite
Effluent
Co er
Quarterl
Composite
Effluent
Mercu
0.32 /I
Monthly
Composite
Effluent
Footnotes:
Monitoring for metals, chlorides, and the whole effluent toxicity test shall be conducted at the same time.

A(2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL Permit No. NC0000752
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. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Freauencv
Sample
TVDe
Sample
Location
Flow
Semi-annually
Estimate
Effluent
Temperature 'C
Semi-annual)
Grab
Effluent
H
Semi-annually
Grab
Effluent
Footnotes:
There shall be no chromium, zinc or copper added to the treatment system except as pre -approved additives to biocidal
compounds.
* 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 not exceed a maximum of 29°C.
** The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
The permittee shall obtain authorization from the Division prior to any use of biocide in the cooling water (see Part I, Section A (5), Special
Condition 2).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
0

Permit No. NC0000752
A(3). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
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. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement Sample
Fre uenc Type
Sample
Location
Flow
Semi-annually Estimate
Effluent
Temperature °C
Semi-annually Grab
Effluent
H
"
Semi-annually Grab
Effluent
Footnotes:
There shall be no chromium, zinc or copper added to the treatment system except as pre -approved additives to biocidal
compounds.
* 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 not exceed a maximum of 29'C.
** The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
The permittee shall obtain authorization from the Division prior to any use of biocide in the cooling water (see Part I, Section A (5), Special
Condition 2).
0
There shall be no discharge of floating solids or visible foam in other than trace amounts. Is

A. (4). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC000752
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 004 - car wash rinse water. Such discharges shall be limited and monitored by the permittee as specified
below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow
Quarterly
Estimate
Effluent
Settleable Matter
0.1 ml/I
0.2 ml/I
Quarterly
Grab
Effluent
Total Suspended Solids
30.0 mqA
45.0 m /l
Quarterly
Grab
Effluent
Oil and Grease
1 30.0 m
45.0 mcjA
Quartedy
Grab
Effluent
H
—f—Quarterly
Grab
Effluent
Footnotes:
* The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
The permittee shall obfitin written approval from the Division prior to utilizing any detergents in the washwater.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
0
0

Part I Permit No. NC0000752
Section A (5). Special Conditions
1. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November 1995, or subsequent
versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant
mortality is 3.7% (defined as treatment two in the procedure document). The permit holder shall perform
quarterly monitoring using this procedure to establish compliance with the permit condition. The tests will be
performed during the months of March, June, September, and December. Effluent sampling for this
testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DWQ Form AT -I (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of Water Quality
4401 Reedy Creek Road
Raleigh, North Carolina 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed
in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent
toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement
will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly _
monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test
requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
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.
QCL P/F Version 9196

•
Part l Permit No. NC0000752
Section A (5)Special Conditions (continued)
2. 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.

•
�I
PART
Section B. Schedule of Com lin ante
1. The permittee shall comply with Final Effluent Limitations specified for discharges in accordance
with the following schedule:
Permittee shall comply with Final Effluent Limitations by the effective date of the permit unless
specified below.
2. Permittee shall at all times provide the operation and maintenance necessary to operate the
existing facilities at optimum efficiency.
No later than 14 calendar days following a date identified in the above schedule of compliance,
the permittee shall submit either a report of progress or, in the case of specific actions being
required by identified dates, a written notice of compliance or noncompliance. In the latter case,
the notice shall include the cause of noncompliance, any remedial actions taken, and the
probability of meeting the next schedule requirements.

lb Pan 11
Page 1 of 14
PART Il
STANDARD CONDITIONS FOR NPDES PERMITS
SECTION A. DEFINITIONS
1. Permit Issuing Authority
The Director of the Division of Water Quality.
2. DEM or "the Division"
Means the Division of Water Quality, Department of Environment, Health and Natural Resources.
3. EM
Used herein means the North Carolina Environmental Management Commission.
4. Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC
1251, et. seq.
5. Mass Day Measurements
a. The "monthly average discharge" is defined as the total mass of all daily discharges sampled
and/or measured during a calendar month on which daily discharges are sampled and
measured, divided by the number of daily discharges sampled and/or measured during such
month. It is therefore, an arithmetic mean found by adding the weights of the pollutant found
each day of the month and then dividing this sum by the number of days the tests were
reported. The limitation is identified as "Monthly Average" in Part I of the permit.
b. The "weekly average discharge' is defined as the total mass of all daily discharges sampled
and/or measured during the calendar week (Sunday - Saturday) on which daily discharges are
sampled and measured, divided by the number of daily discharges sampled and/or measured
during such week. It is, therefore, an arithmetic mean found by adding the weights of
pollutants found each day of the week and then dividing this sum by the number of days the
tests were reported. This limitation is identified as "Weekly Average" in Part I of the permit.
c. The "maximum daily discharge" is the total mass (weight) of a pollutant discharged during a
calendar day. If only one sample is taken during any calendar day the weight of pollutant
calculated from it is the "maximum daily discharge." This limitation is identified as "Daily
Maximum," in Part I of the permit.
d. The "average annual discharge" is defined as the total mass of all daily discharges sampled
and/or measured during the calendar year on which daily discharges are sampled and
measured, divided by the number of daily discharges sampled and/or measured during such
year. It is, therefore, an arithmetic mean found by adding the weights of pollutants found each
day of the year and then dividing this sum by the number of days the tests were reported. This
limitation is defined as "Annual Average" in Part I of the permit.

IP'
Page 1 of 14
6. Concentration Measurement
a. The "average monthly concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar month on
which daily discharges are sampled and measured, divided by the number of daily discharges
sampled and/or measured during such month (arithmetic mean of the daily concentration
values). The daily concentration value is equal to the concentration of a composite sample or in
the case of grab samples is the arithmetic mean (weighted by flow value) of all the samples
collected during that calendar day. The average monthly count for fecal coliform bacteria is
the geometric mean of the counts for samples collected during a calendar month. This
limitation is identified as "Monthly Average" under "Other Limits" in Part I of the permit.
b. The "average weekly concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar week
(Sunday/Saturday) on which daily discharges are sampled and measured divided by the
number of daily discharges sampled and/or measured during such week (arithmetic mean of the
daily concentration values). The daily concentration value is equal to the concentration of a
composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day. The average weekly count for
fecal coliform bacteria is the geometric mean of the counts for samples collected during a
calendar week. This limitation is identified as "Weekly Average" under "Other Limits" in
Part I of the permit.
c. The "maximum daily concentration" is the concentration of a pollutant discharge during a
calendar day. If only one sample is taken during any calendar day the concentration of
pollutant calculated from it is the "Maximum Daily Concentration". It is identified as "Daily
Maximum" under "Other Limits" in Part I of the permit.
d. The "average annual concentration," other than for fecal coliform bacteria, is the sum of the
concentrations of all daily discharges sampled and/or measured during a calendar year on
which daily discharges are sampled and measured divided by the number of daily discharges
sampled and/or measured during such year (arithmetic mean of the daily concentration
values). The daily concentration value is equal to the concentration of a composite sample or in
the case of grab samples is the arithmetic mean (weighted by flow value) of all the samples
collected during that calendar day . The average yearly count for fecal coliform bacteria is the
geometric mean of the counts for samples collected during a calendar year. This limitation is
identified as "Annual Average" under "Other Limits" in Part I of the permit.
e. The "daily average concentration" (for dissolved oxygen) is the minimum allowable amount of
dissolved oxygen required to be available in the effluent prior to discharge averaged over a
calendar day. If only one dissolved oxygen sample is taken over a calendar day, the sample is
considered to be the "daily average concentration" for the discharge. It is identified as "daily
average" in the text of Part I.
f. The "quarterly average concentration" is the average of all samples taken over a calendar
quarter. It is identified as "Quarterly Average Limitation" in the text of Part I of the permit.
g. A calendar quarter is defined as one of the following distinct periods: January through March,
April through June, July through September, and October through December.

Part 11
Page 3 of 14
7. Other Measurements
a. Flow, (MGD): The flow limit expressed in this permit is the 24 hours average flow, averaged
monthly. It is determined as the arithmetic mean of the total daily flows recorded during the
calendar month.
b. An "instantaneous flow measurement" is a measure of flow taken at the time of sampling, when
both the sample and flow will be representative of the total discharge.
c. A "continuous flow measurement" is a measure of discharge flow from the facility which occurs
continually without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for
infrequent maintenance activities on the flow device.
8. Tylms of Samples
a. Composite Sample: A composite sample shall consist of:
(1) a series of grab samples collected at equal time intervals over a 24 hour period of discharge
and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(2) a series of grab samples of equal volume collected over a 24 hour period with the time
intervals between samples determined by a preset number of gallons passing the sampling
point. Flow measurement between sample intervals shall be determined by use of a flow
recorder and totalizer, and the present gallon interval between sample collection fixed at
no greater than 1 /24 of the expected total daily flow at the treatment system, or
(3) a single, continuous sample collected over a 24 hour period proportional to the rate of flow.
In accordance with (1) above, the time interval between influent grab samples shall be no
greater than once per hour, and the time interval between effluent grab samples shall be no
greater than once per hour except at wastewater treatment systems having a detention time of
greater than 24 hours. In such cases, effluent grab samples may be collected at time intervals
evenly spaced over the 24 hour period which are equal in number of hours to the detention time
of the system in number of days. However, in no case may the time interval between effluent
grab samples be greater than six (6) hours nor the number of samples less than four (4) during a
24 hour sampling period.
b. Grab Sample: Grab samples are individual samples collected over a period of time not
exceeding 15 minutes; the grab sample can be taken manually. Grab samples must be
representative of the discharge or the receiving waters.
9. Calculation of Means
a Arithmetic Mean: The arithmetic mean of any set of values is the summation of the individual
values divided by the number of individual values.
b. Geometric Mean: The geometric mean of any set of values is the Nth root of the product of the
individual values where N is equal to the number of individual values. The geometric mean is
equivalent to the antilog of the arithmetic mean of the logarithms of the individual values.
For purposes of calculating the geometric mean, values of zero (0) shall be considered to be one
(1).
c. Weighted by Flow Value: Weighted by flow value means the summation of each concentration
times its respective flow divided by the summation of the respective flows.

• IP
Page 4 of 14
10. Calendar Dav
A calendar day is defined as the period from midnight of one day until midnight of the next day.
However, for purposes of this permit, any consecutive 24-hour period that reasonably represents
the calendar day may be used for sampling.
11. Hazardous Substance
A hazardous substance means any substance designated under 40 CFR Part 116 pursuant to Section
311 of the Clean Water Act.
12. Toxic Pollutant
A toxic pollutant is any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
SECTION B. GENERAL CONDITIONS
1. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit noncompliance
constitutes a violation of the Clean Water Act and is grounds for enforcement action; for permit
termination, revocation and reissuance, or modification; or denial of a permit renewal application.
a. The permittee shall comply with effluent standards or prohibitions established under section
307(a) of the Clean Water Act for toxic pollutants and with standards for sewage sludge use or
disposal established under section 405(d) of the Clean Water Act within the time provided in
the regulations that establish these standards or prohibitions or standards for sewage sludge
use or disposal, even if the permit has not yet been modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit condition is subject to a
civil penalty not to exceed $25,000 per day for each violation. Any person who negligently
violates any permit condition is subject to criminal penalties of $2500 to $25,000 per day of
violation, or imprisonment for not more than 1 year, or both. Any person who knowingly
violates permit conditions is subject to criminal penalties of $5,000 to $50,000 per day of
violation, or imprisonment for not more than 3 years, or both. Also, any person who violates a
permit condition may be assessed an administrative penalty not to exceed $10,000 per violation
with the maximum amount not to exceed $125,000. [Ref: Section 309 of the Federal Act 33
U.S.C. 1319 and 40 CFR 122.41 (a)]
c. Under state law, a civil penalty of not more than ten thousand dollars ($10,000) per violation
may be assessed against any person who violates or fails to act in accordance with the terms,
conditions, or requirements of a permit. [Ref: North Carolina General Statutes § 143-215.6A]
d. Any person may be assessed an administrative penalty by the Administrator for violating
section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit condition or limitation
implementing any of such sections in a permit issued under section 402 of the Act.
Administrative penalties for Class I violations are not to exceed $10,000 per violation, with
the maximum amount of any Class I penalty assessed not to exceed $25,000. Penalties for Class
II violations are not to exceed $10,000 per day for each day during which the violation
continues, with the maximum amount of any Class 11 penalty not to exceed $125,000.

. Part II
Page 5 of 14
r
The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or
disposal in violation of this permit which has a reasonable likelihood of adversely affecting
human health or the environment.
3. Civil and Criminal Liability
Except as provided in permit conditions on 'Bypassing" (Part II, C4) and "Power Failures" (Part 11,
C-7), nothing in this permit shall be construed to relieve the permittee from any responsibilities,
liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of
the Federal Act, 33 USC 1319. Furthermore, the permittee is responsible for consequential damages,
such as fish kills, even though the responsibility for effective compliance may be temporarily
suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may
be subject to under NCGS 143-215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321.
Furthermore, the permittee is responsible for consequential damages, such as fish kills, even
though the responsibility for effective compliance may be temporarily suspended.
5. Properly Rights
The issuance of this permit does not convey any property rights in either real or personal property,
or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State or local laws or regulations.
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical
structures or facilities or the undertaking of any work in any navigable waters.
7. Severability
The provisions of this permit are severable, and if any provision of this permit, or the application
of any provision of this permit to any circumstances, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit, shall not be affected thereby.
8. Duty to Provide Information
The permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any
information which the Permit Issuing Authority may request to determine whether cause exists for
modifying, revoking and reissuing, or terminating this permit or to determine compliance with this
permit. The permittee shall also furnish to the Permit Issuing Authority upon request, copies of
records required to be kept by this permit.
9. Duty to Reapply
If the permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the permittee must apply for and obtain a new permit.

*I 1
Page 6 of 14
10. Expiration of Permit
The permittee is not authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expiration date, the permittee shall submit such
information, forms, and fees as are required by the agency authorized to issue permits no later than
180 days prior to the expiration date. Any permittee that has not requested renewal at least 180
days prior to expiration, or any permittee that does not have a permit after the expiration and has
not requested renewal at least 180 days prior to expiration, will subject the permittee to enforcement
procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed
and certified.
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a
responsible corporate officer means: (a) a president, secretary, treasurer or vice president
of the corporation in charge of a principal business function, or any other person who
performs similar policy or decision making functions for the corporation, or (b) the manager
of one or more manufacturing production or operating facilities employing more than 250
persons or having gross annual sales or expenditures exceeding 25 million (in second quarter
1980 dollars), if authority to sign documents has been assigned or delegated to the manager
in accordance with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official.
b. All reports required by the permit and other information requested by the Permit Issuing
Authority shall be signed by a person described above or by a duly authorized representative of
that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or well field, superintendent, a position of equivalent
responsibility, or an individual or position having overall responsibility for environmental
matters for the company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority.
c. Certification. Any person signing a document under paragraphs a. or b. of this section shall
make the following certification:
"I certify, under penalty of law, that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the system, or those persons directly responsible for gathering
the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations."

• Part 11
Page 7 of 14
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request
by the permfttee for a permit modification, revocation and reissuance, or termination, or a
notification of planned changes or anticipated noncompliance does not stay any permit condition.
13. Permit Modification Revocation and Reissuance or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and
modifying the permit, revoking and reissuing the permit, or terminating the permit as allowed by
the laws, rules, and regulations contained in Title 40, Code of Federal Regulations, Parts 122 and
123; Title 15A of the North Carolina Administrative Code, Subchapter 2H .0100; and North
Carolina General Statute 143-215.1 et. al.
14. Previous Permits
All previous National Pollutant Discharge Elimination System Permits issued to this facility,
whether for operation or discharge, are hereby revoked by issuance of this permit. [The exclusive
authority to operate this facility arises under this permit. The authority to operate the facility
under previously issued permits bearing this number is no longer effective. [ The conditions,
requirements, terms, and provisions of this permit authorizing discharge under the National
Pollutant Discharge Elimination System govern discharges from this facility.
SECTION C. OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Certified Operator
Pursuant to Chapter 90A44 of North Carolina General Statutes, and upon classification of the
facility by the Certification Commission, the permittee shall employ a certified wastewater
treatment plant operator in responsible charge (ORC) of the wastewater treatment facilities. Such
operator must hold a certification of the grade equivalent to or greater than the classification
assigned to the wastewater treatment facilities by the Certification Commission. The permittee
must also employ a certified back-up operator of the appropriate type and any grade to comply
with the conditions of Title 15A, Chapter 8A .0202. The ORC of the facility must visit each Class 1
facility at least weekly and each Class 11, III, and IV facility at least daily, excluding weekends
and holidays, and must properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A .0202. Once the
facility is classified, the permittee shall submit a letter to the Certification Commission which
designates the operator in responsible charge within thirty days after the wastewater treatment
facilities are 50% complete.
2. 'Pr p rr Qpgration and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the permittee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also
includes adequate laboratory controls and appropriate quality assurance procedures. This provision
requires the operation of back-up or auxiliary facilities or similar systems which are installed by a
permittee only when the operation is necessary to achieve compliance with the conditions of the
permit.

0 1 I
I -age 8 of 14
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary
to halt or reduce the permitted activity in order to maintain compliance with the condition of this
permit.
4. Bypassing of Treatment Facilities
a. Definitions
(1) "Bypass' means the known diversion of waste streams from any portion of a treatment
facility including the collection system, which is not a designed or established or operating
mode for the facility.
(2) "Severe property damage" means substantial physical damage to property, damage to the
treatment facilities which causes them to become inoperable, or substantial and permanent
loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage does not mean economic loss caused by delays in
production.
b. Bypass not exceeding limitations.
The permittee may allow any bypass to occur which does not cause effluent limitations to be
exceeded, but only if it also is for essential maintenance to assure efficient operation. These
bypasses are not subject to the provisions of Paragraphs c. and d. of this section.
c. Notice
(1) Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall
submit prior notice, if possible at least ten days before the date of the bypass; including an
evaluation of the anticipated quality and affect of the bypass.
(2) Unanticipated bypass. The permittee shall submit notice of an unanticipated bypass as
required in Part II, E. 6. of this permit. (24 hour notice).
d. Prohibition of Bypass
(1) Bypass is prohibited and the Permit Issuing Authority may take enforcement action against
a permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property
damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment
facilities, retention of untreated wastes or maintenance during normal periods of
equipment downtime. This condition is not satisfied if adequate backup equipment should
have been installed in the exercise of reasonable engineering judgment to prevent a bypass
which occurred during normal periods of equipment downtime or preventive maintenance;
and
(C) The permittee submitted notices as required under Paragraph c. of this section.
(2) The Permit Issuing Authority may approve an anticipated bypass, after considering its
adverse affects, if the Permit Issuing Authority determines that it will meet the three
conditions listed above in Paragraph d. (1) of this section.

SPart II
Page 9 of 14
5. upsets
a. Definition.
"Upset " means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors beyond the
reasonable control of the permittee. An upset does not include noncompliance to the extent
caused by operational error, improperly designed treatment facilities, inadequate treatment
facilities, lack of preventive maintenance, or careless or improper operation.
b. Effect of an upset.
An upset constitutes an affirmative defense to an action brought for noncompliance with such
technology based permit effluent limitations if the requirements of paragraph c. of this
condition are met. No determination made during administrative review of claims that
noncompliance was caused by upset, and before an action for noncompliance, is final
administrative action subject to judicial review.
c. Conditions necessary for a demonstration of upset.
A permittee who wishes to establish the affirmative defense of upset shall demonstrate,
through properly signed, contemporaneous operating logs, or other relevant evidence that:
(1) An upset occurred and that the permittee can identify the cause(s) of the upset;
(2) The permittee facility was at the time being properly operated; and
(3) The permittee submitted notice of the upset as required in Part 11, E. 6. (b) (B) of this permit.
(4) The permittee complied with any remedial measures required under Part II, B. 2. of this
permit.
d. Burden of proof.
In any enforcement proceeding the permittee seeking to establish the occurrence of an upset has
the burden of proof.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of
wastewaters shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such
as to prevent any pollutant from such materials from entering waters of the State or navigable
waters of the United States. The permittee shall comply with all existing federal regulations
governing the disposal of sewage sludge. Upon promulgation of 40 CFR Part 503, any permit issued
by the Permit Issuing Authority for the utilization/disposal of sludge may be reopened and
modified, or revoked and reissued, to incorporate applicable requirements at 40 CFR Part 503. The
permittee shall comply with applicable 40 CFR Part 503 Standards for the Use and Disposal of
Sewage Sludge (when promulgated) within the time provided in the regulation, even if the permit
is not modified to incorporate the requirement. The permittee shall notify the Permit Issuing
Authority of any significant change in its sludge use or disposal practices.
7. Power Failures
The permittee is responsible for maintaining adequate safeguards as required by DEM Regulation,
Title 15A, North Carolina Administrative Code, Subchapter 2H, .0124 Reliability, to prevent the
discharge of untreated or inadequately treated wastes during electrical power failures either by
means of alternate power sources, standby generators or retention of inadequately treated effluent.

] [I
Yage 10 of 14
SECTION D MONITORING AND RECORDS
I. Revresentative Samoling
Samples collected and measurements taken, as required herein, shall be characteristic of the
volume and nature of the permitted discharge. Samples collected at a frequency less than daily
shall be taken on a day and time that is characteristic of the discharge over the entire period
which the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other
wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority.
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and
reported on a monthly Discharge Monitoring Report (DMR) Form (DEM No. MR I, 1.1, 2, 3) or
alternative forms approved by the Director, DEM, postmarked no later than the 30th day
following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case
of a new facility, on the last day of the month following the commencement of discharge.
Duplicate signed copies of these, and all other reports required herein, shall be submitted to the
following address:
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
Post Office Box 29535
Raleigh, North Carolina 27626-0535
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices
shall be selected and used to ensure the accuracy and reliability of measurements of the volume of
monitored discharges. The devices shall be installed, calibrated and maintained to ensure that the
accuracy of the measurements are consistent with the accepted capability of that type of device.
Devices selected shall be capable of measuring Flows with a maximum deviation of less than + 10%
from the true discharge rates throughout the range of expected discharge volumes. Once -through
condenser cooling water flow which is monitored by pump logs, or pump hour meters as specified in
Part I of this permit and based on the manufacturer's pump curves shall not be subject to this
requirement.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations published
pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting Acts, and to regulations
published pursuant to Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act, as
Amended, and Regulation 40 CFR 136; or in the case of sludge use or disposal, approved under 40
CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been specified
in this permit.
To meet the intent of the monitoring required by this permit, all test procedures must produce
minimum detection and reporting levels that are below the permit discharge requirements and all
data generated must be reported down to the minimum detection or lower reporting level of the
procedure. If no approved methods are determined capable of achieving minimum detection and

` # Part 11
Page I I of 14
reporting levels below permit discharge requirements, then the most sensitive (method with the
lowest possible detection and reporting level) approved method must be used.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders
inaccurate, any monitoring device or method required to be maintained under this permit shall,
upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for
not more than two years per violation, or by both. If a conviction of a person is for a violation
committed after a first conviction of such person under this paragraph, punishment is a fine of not
more than $20,000 per day of violation, or by imprisonment of not more than 4 years, or both.
6. Records Retention
Except for records of monitoring information required by this permit related to the permittee's
sewage sludge use and disposal activities, which shall be retained for a period of at least five
years (or longer as required by 40 CFR 503), the permitter shall retain records of all monitoring
information, including all calibration and maintenance records and all original strip chart
recordings for continuous monitoring instrumentation, copies of all reports required by this permit,
for a period of at least 3 years from the date of the sample, measurement, report or application.
This period may be extended by request of the Director at any time.
7. Recording_ Results
For each measurement or sample taken pursuant to the requirements of this permit, the permittee
shall record the following information:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an authorized
contractor acting as a representative of the Director), upon the presentation of credentials and other
documents as may be required by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions
of this permit;
C. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as
otherwise authorized by the Clean Water Act, any substances or parameters at any location.

0
u
rage 12 of 14
SECTION E. REPORTING REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit.
The discharge of any pollutant identified in this permit more frequently than or at a level in excess
of that authorized shall constitute a violation of the permit.
2. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned physical
alterations or additions to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for determining
whether a facility is a new source in 40 CFR Part 122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of
pollutants discharged. This notification applies to pollutants which are subject neither to
effluent limitations in the permit, nor to notification requirements under 40 CFR Part 122.42 (a)
(1).
c. The alteration or addition results in a significant change in the permittee's sludge use or
disposal practices, and such alternation, addition or change may justify the application of
permit conditions that are different from or absent in the existing permit, including notification
of additional use or disposal sites not reported during the permit application process or not
reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The permittee shall give advance notice to the Director of any planned changes in the permitted
facility or activity which may result in noncompliance with permit requirements.
4. Transfers
This permit is not transferable to any person except after notice to the Director. The Director may
require modification or revocation and reissuance of the permittee and incorporate such other
requirements as may be necessary under the Clean Water Act.
5, Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit.
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (Sce Part II. D. 2
of this permit) or forms provided by the Director for reporting results of monitoring of sludge use
or disposal practices.
b. If the permittee monitors any pollutant more frequently than required by the permit, using test
procedures specified in Part 11, D. 4. of this permit or in the case of sludge use or disposal,
approved under 40 CFR 503, or as specified in this permit, the results of this monitoring shall be
included in the calculation and reporting of the data submitted in the DMR.
c. Calculations for all limitations which require averaging of measurements shall utilize an
arithmetic mean unless otherwise specified by the Director in the permit.

Part 11
Page 13 of 14
6. Twenty-four Hour Reporting
a. The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances. The written submission shall contain a
description of the noncompliance, and its cause, the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence
of the noncompliance.
b. The following shall be included as information which must be reported within 24 hours under
this paragraph:
(1) Any unanticipated bypass which exceeds any effluent limitation in the permit.
(2) Any upset which exceeds any effluent limitation in the permit.
(3) Violation of a maximum daily discharge limitation for any of the pollutants listed by the
Director in the permit to be reported within 24 hours.
c. The Director may waive the written report on a case -by -case basis for reports under paragraph
b. above of this condition if the oral report has been received within 24 hours.
7. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under Part II. E. 5 and 6. of
this permit at the time monitoring reports are submitted. The reports shall contain the information
listed in Part II. E. 6. of this permit.
8. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in a permit
application, or submitted incorrect information in a permit application or in any report to the
Director, it shall promptly submit such facts or information.
9. Noncompliance Notification
The permittee shall report by telephone to either the central office or the appropriate regional
office of the Division as soon as possible, but in no case more than 24 hours or on the next working
day following the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of
significant amounts of wastes which are abnormal in quantity or characteristic, such as the
dumping of the contents of a sludge digester; the known passage of a slug of hazardous substance
through the facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of
adequate wastewater treatment such as mechanical or electrical failures of pumps, aerators,
compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to such
station or facility.

tI1
Page 14 of 14
Persons reporting such occurrences by telephone shall also file a written report in letter form within
5 days following first knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for
public inspection at the offices of the Division of Water Quality. As required by the Act, effluent
data shall not be considered confidential. Knowingly making any false statement on any such
report may result in the imposition of criminal penalties as provided for in NCGS 143-215.1(b)(2) or
in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per violation,
or by imprisonment for not more than two years per violation, or by both.

qb
a
PART III
OTHER REQUIREMENTS
No construction of wastewater treatment facilities or additions to add to the plant's treatment
capacity or to change the type of process utilized at the treatment plant shall be begun until Final
Plans and Specifications have been submitted to the Division of Water Quality and written approval
and Authorization to Construct has been issued.
B. Groundwater Monitoring
The permittee shall, upon written notice from the Director of the Division of Water Quality, conduct
groundwater monitoring as may be required to determine the compliance of this NPDES permitted
facility with the current groundwater standards.
C. Chan= in Discharges of Toxic Substances
The permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe:
a.That any activity has occurred or will occur which would result in the discharge, on a routine or
frequent basis, of any toxic pollutant which is not limited in the permit, if that discharge will
exceed the highest of the following "notification levels'
(1) One hundred micrograms per liter (100 ug/1);
(2)Two hundred micrograms per liter (200 ug/1) for acrolein and acrylonitrile; five hundred
micrograms per liter (500 ug/1) for 2.4-dinitrophenol and for 2-methyl4.6-dinitrophenol; and
one milligram per liter (I mg/1) for antimony;
(3) Five (5) times the maximum concentration value reported for that pollutant in the permit
application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine
or infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will
exceed the highest of the following "notification levels';
(1) Five hundred micrograms per liter (500 ug/1);
(2) One milligram per liter (I mg/1) for antimony;
(3) Ten (10) times the maximum concentration value reported for that pollutant in the permit
application.
D. itq_uirement to ContinuallyEvaluate Alternatives to Wastewater Discharges
The permittee shall continually evaluate all wastewater disposal alternatives and pursue the most
environmentally sound alternative of the reasonably cost effective alternatives. If the facility is in
substantial non-compliance with the terms and conditions of the NPDES permit or governing rules,
regulations or laws, the permittee shall submit a report in such form and detail as required by the
Division evaluating these alternatives and a plan of action within sixty (60) days of notification by the
Division.

0
PART IV
ANNUAL ADMINISTERING AND COMPLIANCE MONITORING FEE REQUIREMENTS
A. The permittee must pay the annual administering and compliance monitoring fee within 30
(thirty) days after being billed by the Division. Failure to pay the fee in a timely manner in
accordance with 15A NCAC 2H .0105(b)(4) may cause this Division to initiate action to
revoke the permit.

\O�pF W A rFRQG Michael F. Easley
Governor
rWilliam G. Ross, Jr., Secretary
—1 North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
May 9, 2007
Mr. Chris Puryear
Kapstone Kraft Paper Corporation
100 Gaston Rd.
Roanoke Rapids, North Carolina 27870
Subject: NPDES Draft Permit
Permit No. NC0000752
Roanoke Rapids Mill WWTP
Halifax County
Dear Mr. Puryear:
Please find enclosed the DRAFT permit for the subject wastewater treatment plant for your
review and comment. The draft permit includes the following modifications to your existing
permit:
Monitoring for arsenic and chloride were eliminated from outfall 001. Reasonable
potential analysis shows no reasonable potential to exceed water quality standards.
Effluent guideline limits for BOD, TSS, pentachlorophenol and trichlorophenol were
calculated based on average production data in accordance with 40 CFR 430. The
calculated limits for TSS, pentachlorophenol and trichlorophenol are more stringent
than the limits in the current permit. The permit limits were modified to reflect the more
stringent limits.
Please provide any comments you have regarding the draft permit to this office by June
16, 2007. At this time, the Division is also publishing a notice in the newspapers of general
circulation in Halifax County, inviting public comment on the draft permit.
If you have any questions concerning the draft permit or the other requirements for your
facility, please call me at [phone], extension 553.
Sincerely,
Teresa Rodriguez
Eastern NPDES Program
Cc: NPDES Files
Raleigh Regional Office — Surface Water Protection
Aquatic Toxicology Unit
EPA Region 4
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone]
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Ar6rtnative Action Employer- 50% Recyded/10 % Post Consumer Paper
tCarolina
rldbl
Customer Service
1-877-623-6748

• 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,
KapStone Kraft Paper Corporation
is hereby authorized to discharge wastewater from a facility located at the
KapStone Kraft 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.
This permit and authorization to discharge shall expire at midnight on March 31, 2012.
Signed this day.
1" I
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

0 Permit NCO000752
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.
KapStone Kraft 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
2. Continue to discharge non -contact cooling water from the B & C evaporator
(outfall 002) and the turpentine condenser (outfall 003), and
3. Discharge from said treatment works, located at the KapStone Kraft Paper
Wastewater Treatment Plant, North Roanoke Avenue, Roanoke Rapids, Halifax
County, at the locations specified on the attached map into the Roanoke River
which is classified C waters in the Roanoke River Basin.

Rohl
Indus
PoI,ds
pp
66
Outfall 003
Ilk'
Outfall 001
Q,
Outfall 002
NM
cg All,

• Permit 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:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location'
Flow
28.0 MGD
Continuous
Recorder
I or E
BOD, 5 day, 20QC
6,852 lbs/day
13,704 lbs/day
Dail
Composite
E
Total Suspended Solids
15,576 lbs/day
31,152 lbs/day
Dail
Composite
E
Dissolved Oxvqen
Dail
Grab
E, U, D
Temperature
Dail
Grab
E, U, D
Conductive
Dail
Grab
E, U, D
NH3 as N
Monthly
Composite
E
Total Nitrogen NO2+NO3+TKN
Monthly
Composite
E
Total Phos horus
Monthly
Composite
E
Chronic Toxici
Quarterly
Composite
E
Total Copper'
Quarterly
Composite
I E
H
6.0 — 9.0 standard units
Dail
Grab
E
Pentachloro henol
1.51 lbs/day
Weekly
Grab
E
Trichlorophenol
1.38lbs/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 and the whole effluent toxicity test shall be conducted at the
same time.
4. Monitoring for pentachlorophenol and trichlorophenol is not required unless
chlorophenolic containing biocides are used at the facility. If chlorophenolic-
containing biocides are used at the facility, monitoring for pentachlorophenol and
trichlorophenol 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.

• PermitNC0000752
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,
the Permttee 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:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Location
Flow
Semi-annually
Estimate
Effluent
Temperature °C
See note 1
See note 1
Semi-annual)
Grab
Effluent
pH
6.0 - 9.0 standard units'
Semi-annually
Grab
Effluent, Upstream,
Downstream
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 (5.05°F) above the natural water temperature and
does not exceed a maximum of 29°C (84.2°F).
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 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:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Montflly
AverMaximum
Daily
Measurement
Freuenc
Sample
T e
Sample Location
Flow
Semi-annuall
Estimate
Effluent
Tem erature °C
See nSee
note 1
Semi-annually
Grab
Effluent
pH
6.0-9.0 standard units2
Semi-annually
Grab
Effluent, Upstream,
Downstream
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 (5.05°F) above the natural water temperature and
does not exceed a maximum of 29°C (84.2°F).
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 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, auarterlu monitoring using test procedures outlined
in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998,
or subsequent versions or "North Carolina Phase H 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 TGP313 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.

0 Permit NC0000752
A. (5) BIOCIDE CONDITION
The permitted shall not use any biocides except those approved in conjunction with the permit
application. The permitted 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 Outfall 002 and 003,
should new information indicate water quality problems due to declining pH in this portion of the
river.

r�
u
DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0000752
Applicant/Facility Name:
racier tntormation
Ka Stone Kraft PaEr Corporation /Roanoke Rapids Mill
Ap2licant Address:
North Roanoke Avenue, Roanoke Ra ids, NC 27870
Facilit Address:
North Roanoke Avenue, Roanoke Ra ids, NC 27870
Permitted Flow
28.0 MGD
Ty2e of Waste:
Industrial (100%)
Facili /Permit Status:
Class IV /Active; Renewal
County:
Halifax Count
Miscellaneous
oanoke River Re inal Office: Raleigh (RRO)
Er
State Grid/USGS Quad: B28NW/Roanoke Ra ids
q
es Permit Writer: Teresa Rodriguez
-02-08
Date: 3/30/07
-(26)Drain
1,120
1,120
2,400
3,7% Lat. 36028' 19" N Long. 77038' 14" W
e A,384
7Q10(cfs)
30Q2 (cfs)
Aver a e Flow (cfs):
IWC (%):
BACKGROUND
Kapstone Paper Corporation purchased Roanoke Rapids Mill from International Paper in January
2007. A name change was completed to change the name of the facility to KapStone Kraft Paper
Corporation. KapStone operates a mill in Roanoke Rapids producing high quality unbleached
Kraft paper and paperboard. The mill is integrated including power generation, chemical
recovery, pulp production and final paper and paperboard manufacturing. The site operates a
WWTP to treat the wastewaters generated during the process. KapStone is permitted to discharge
28.0 MGD of process water through Outfall 001, non -contact cooling water from the evaporator
cooling tower through Outfall 002 and non -contact cooling water from the turpentine condenser
through Outfall 003. The current permit was issued on December 30, 2004 with an expiration
date of March 31, 2007.
Process wastewaters are conveyed to the WWTP through a concrete lined open channel. The
WWTP consists of a bar screen, 200 foot diameter primary clarifier, 28 million gallon emergency
pond, 21.5 acre aeration pond with 31 aerators, four stabilization ponds with a total of 370 acres,
an effluent defoamer addition system, for solids treatment sludge neutralization tank, two rotary
screen thickeners, two screw presses and a sludge lagoon. The emergency pond is used to divert
process flow in the event they have a power failure, mechanical problems or high strength waste.
The water from the emergency pond is pumped back to the influent channel at a controlled rate.
Condensate collected from the process areas is piped directly to the influent of the aeration basin.
Sludge is landitlled on site under permit WQ0000436.
Fact Sheet
NPDES NC0000752 Renewal
Page I

DMR Data Review/Compliance
Division's records show no violations for the past permit cycle.
Data for the three outfalls were summarized for the period of January 2005 to December 2006.
Tnhin r - n...fon nm
Flow
BOD
TSS
Total
Total
Ammonia
(MGD)
(lb/d)
(lb/d)
Nitrogen
Phosphorus
(mg/1)
(rn )
( )
Average
14.7
1611
2409
5.6
0.64
1.87
Max
23.4
4402
11980
13.2
1.08
5.6
Table II - Outfall 002
Flow
(MGD)
pH
(SU)
Temp
°C
Average
4.07
6.48
42.81
Max
11.9
7
52
Min
0.3
5.9
30.3
Table ITT - Ontfall MIA
Flow
(MGD)
pH
(SU)
Temp
°C
Average
0.89
6.46
26.28
Max
2.6
7.3
48
Min
0.1
5.41
7.8
Stream Monitoring
KapStone monitors upstream and downstream of the discharge for temperature, pH, dissolved
oxygen, BOD and conductivity. The upstream station is located at the bridge on Highway 48, the
downstream station is at the bridge on Highway 158. Dissolved oxygen was below 5 mg/1 during
August of 2005, with a low value of 4.3 mg/l. The Division has an ambient monitoring station
upstream at the bridge on Highway 48. Results for the ambient monitoring stations are similar to
the facility data.
Table IV - Instream manitnrina
Upstream
Downstream
Upstream
Downstream
U stream
Downstream
Temp
°C
Temp
°C
pH
SU
pH
SU
DO
DO
Average
20.6
20.1
6.8
6.7
8.4
8.1
ax
29
28.8
7.5
7.4
14.1
13.6
Min
5.4
5.1
6.21
6.3
4.3
5.1
303(d)/Basin Plan
This section of the river is listed on the 303(d) as impaired for fish consumption due to mercury
levels in fish.
PERMITTING STRATEGY
Waste Load Allocation (WLA)
The Division prepared the last WLA for the previous permit renewal in 1997. Current limits are
based on guidelines and water quality standards. The current permit includes limits for flow,
BOD5, TSS, pH, pentachlorophenol, and trichlorophenol. Monitoring for pentachlorophenol and
Fact Sheet
NPDFS NC0000752 Renewal
Page 2

trichlorophenol is no- -_zt if the facility doesn't use chot lic-containing biocides.
Based on instream data that the permit holder submitted for the 2001 permit renewal, which
reflect naturally occurring pH at levels occasionally below 6.0 standard units in this portion of
the river, DWQ included a footnote to the pH limit requirements at Outfall 002 and Outfall 003.
(These outfalis 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. The
footnote will stay in the permit.
Effluent Guidelines
Paper Mill's are regulated under effluent guidelines in 40 CFR 430. Subpart C applies to
unbleached kraft paper production.
The average production for the past three years at the Roanoke Rapids Mill was 1158.9 tons/day.
The limits in Table V were calculated based on the effluent guidelines and average production of
1158.9 tons per day (2596 thousand pounds per day).
Table V — Calculated limits
Parameter
Daily max limit
Monthly aver limit
OD'-'
14537 lb/day
7268 lb/day
SSt'3
31152 IbIday
15575 lb/day
Ht'3
6 —9 SU
enthachloro henol2
1.51 lb/day
rlchloro henol2
1.38 lb/day
1. BPT 43032
2. BAT 430.34
3. BCT 430.33 - same as BPT
Table VI—Pronosed Limits
Existing
limits
Proposed limits
Parameter
Comments
Daily max
Monthly
Daffy max
Monthly
aver
aver
Existing limits are more stringent than the
units calculated based on actual production.
BOD
13704 lb/d
6852 Ib/d
13704 lb/d
6852 lb/d
Limits will not change.
Proposed EG limits are more stringent than
units in permit now. Limits will be reduced
SS
32110lb/d
16055lb/d
31152lb/d
15576lb/d
kccordingly.
Proposed EG limits are more stringent than
units in permit now. Limits will be reduced
entachloro henol
1.55 lb/d
No limit
1.51 lb/d
No limit
accordinglv.
Proposed EG limits are more stringent than
I
1
units in permit now. Limits will be reduced
richloro henol
1.42lb/d
No limit
1.38 lb/d
No limit
accordingly.
Fact Sheet
NPDES NCO000752 Renewal
Page 3

Reasonable Potential _ _ 11 RPA) 0
Results for the reasonable potential analysis for arsenic, chloride and copper are shown in Table
VII.
Table VII — Reasonable Potential Analvsis
Allowable
Maximum predicted
Reasonable
Parameter
concentration
concentration
Potential
Comments
W/O
Chronic
Acute
Chronic
Acute
Arsenic
3,359
N/A
21.4
No
N/A
No RP, eliminate monitoring
Chloride
16,796
1 N/A
96.5
No
N/A
No RP, eliminate monitoring
Copper
223
1 7
214.7
No
Yes
Continue monitoring
SUMMARY OF PROPOSED CHANGES
Outfall 001
Pentachlorophenol, trichlorophenol and TSS limits were reduced to reflect limits
calculated based on effluent guidelines and current production data.
Monitoring for arsenic and chloride were eliminated. A reasonable potential analysis
showed there is no reasonable potential to exceed the water quality standards.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: May 9,2007
Permit Scheduled to Issue: July 2, 2007
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Teresa Rodriguez at [phone] ext. 553.
NAME: DATE:
REGIONAL OFFICE COMMENTS
NAME: DATE:
SUPERVISOR: DATE:
Fact Sheet
NPDFS NC0000752 Renewal
Page 4

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
(Phis form is best filled out on computer, rather than hard copy)
Dater un a ax
To: NPDES Discharge Permitting Unit Permitee: International Paper
Attn. NPDES Reviewer: Teresa Rodriguez Application/ Permit No.: NC0000752
Staff Report Prepared By: R. Boone
Project Name: International Paper NPDES Permit Renewal
SOC Priority Project? (Y/N) N If Yes, SOC No.
A. GENERAL INFORMATION
1. This application is (check at that apply): ❑ New ® Renewal
❑ Modification
2. Was a site visit conducted in order to prepare this report? ❑ Yes or ® No.
a. Date of site visit:
b. Person contacted and telephone number:
c. Site visit conducted by:
d. Inspection Report Attached: ❑ Yes or ❑ No.
3. Keeping BIMS Accurate: Is the following BIMS information (a. through e. below) correct?
❑ Yes or ® No. If No, please either indicate that it is correct on the current application or the
existing permit or provide the details. If none can be supplied, please explain:
Fill this section only if BIMS or Application Info is incorrect or missine
Facility
a. Location Address: OK on Application ®,
OK on Existing Permit ❑, or provide Location: 100 Gaston Road, Roanoke Rapids, NC 27870.
b. Latitude/Longitude (These are often inaccurate) OK on Application ®, (check at
hap://topozone.com ) OK on Existing Permit ®, or provide Latitude: Longitude:
c. Driving Directions OK on Application ❑,
OK on Existing Permit ❑, or provide Driving Directions (please be accurate): 64 bypass east
from Raleigh to I-95. I-95 north to Hwy 46. Hwy 46 west to Gaston, intersection of Hwy 46
(Lawrenceville Road) and Hwy 48 (Roanoke Rapids Road). Left (south) on Hwy 48 (Roanoke
Rapids Road) approximately 1.7 miles. Facility entrance is on the left.
Primary Discharge Point Location
a. USGS Quadrangle Map name and number OK on Application ❑,
OK on Existing Permit ®, or provide USGS Quadrangle Map name and number: Roanoke
Rapids, NC, B28NW
b. Latitude/Longitude of Outfall (These are often inaccurate) OK on Application ❑, (check at
httt)://toj)ozone.com ) OK on Existing Permit ❑, or provide Latitude: Longitude:

NPI)ES REGIONAL WATER-OrALITY
STAFF REPORT AND RECOMMENDATIONS
For 001, lat/long in application and permit is accurate enough that one could find the
outfall in the field but it does not appear to be exact.
c. Receiving Stream OK on Application ®,
_OK on Existin¢ Permit_E,A)LnmmWc Receiving Stream -or -affected waters:
a. Stream Classification: C
b. River Basin and Sub basin No.: Roanoke River Basin, 03-02-08
c. Describe receiving stream features and downstream uses: Controlled by Roanoke Rapids
dam. Downstream uses include fishing, secondary recreation and drinking water supply.
For NEW FACILITIES Proceed to Section C. Evaluation and Recommendations
(For renewals or modifications continue to section B)
B. DESCRIPTION OF FACILITIES AND WASTE(S) (renewals and modifications only)
1. Describe the existing treatment facility: Facility is as described in the existing permit.
2. Are there appropriately certified ORCs for the facilities? ® Yes or ❑ No.
Operator in Charge: Chris Puryear Certificate # 8275 (Available in BIMS or Certification Website)
Back- Operator in Charge: Neal Davis Certificate # 6740
3. Does the facility have operational or compliance problems? Please comment: No
Summarize your BIMS review of monitoring data (Notice(s) of violation within the last permit cycle;
Current enforcement action(s)): There are no current NOVs or enforcement actions. There were four
monitoring violations in Mar 2005 for which no action was taken. There have been no other
violations since last permit reissuance.
Are they currently under SOC, ❑ Currently under JOC, ❑ Currently under moratorium ❑? Have
all compliance dates/conditions in the existing permit, SOC, JOC, etc. been complied with? ❑ Yes
or ❑ No. If no, please explain:
4. Residuals Treatment: PSRP ❑ (Process to Significantly Reduce Pathogens, Class B) or
PFRP ❑ (Process to Further Reduce Pathogens, Class A)? N/A
Are they liquid or dewatered to a cake? Dewatered
Land Applied? Yes ® No ❑ If so, list Non -Discharge Permit No. On site, WQ0013516
Contractor Used:
Landfilled? Yes ® No❑ If yes, where? Onsite, WQ0000436
Other?
Adequate Digester Capacity? Yes ❑ No ❑ Sludge Storage Capacity? Yes ❑ No ❑
Please comment on current operational practices: There are no digesters. Sludge is thickened and pH
adjusted and then sent to sludge presses. The sludge from the presses is then sent to either an onsite
FORM: NPDES-RRO 06/03, 9/03

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
landfill or land applied. Filtrate from the presses is sent back to the headwords of the plant for
treatment.
S. Are there any issues related to compliance/enforcement that should be resolved before issuing this
permit. Lj Yes or Z No. If yes, please explain:
C. EVALUATIONAND RECOMMENDATIONS
1. Alternative Analysis Evaluation: has the facility evaluated the non -discharge options available? Give
regional perspective for each option evaluated:
Spray Irrigation:
Connect to Regional Sewer System:
Subsurface:
Other Disposal Options: There was no alternatives analysis included with the renewal application.
However, RRO staff feel there are no other practical alternatives primarily due to the high amount of flow
produced at the facility.
2. Provide any additional narrative regarding your review of the application: None
3. List any items that you would like NPDES Unit to obtain through an additional information
request. Make sure that you provide a reason for each item:
4. List specific Permit requirements that you recommend to be removed from the permit when
issued. Make sure that you provide a reason for each condition:
5. List specific special requirements or compliance schedules that you recommend to be included in
the permit when issued. Make sure that you provide a reason for each special condition:
FORM: NPDES-RRO 06/03, 9/03 3

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
6. Recommendation: []Hold, pending receipt and review of additional information by regional office;
❑ Hold, pending review and approval of required additional information by NPDES permitting
office; ® Issue; ❑ Deny. If deny, please state reasons:
Reminder: attach inspection report if Y was checked for 2 d.
n
7. Signature of report preparers
Signature of WQS regional supervisor: l )
Date: G 0 f
D. ADDITIONAL REGIONAL STAFF RE VIEW ITEMS
If next page is not used, PLEASE set printer for pages 1 through 3 to avoid wasting paper.
Use this page for facilities with more than one Discharge Pipe
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missine)
a. Location OK on Application ❑,
OK on Existing PermitEl, or provide Location: Location lat/long is good. Lat/long for 002 on
application and in BIMS is not exact but is likely good enough for one to find it while in the field.
b. Driving Directions OK on Application ❑,
OK on Existing Permit ❑, or provide Driving Directions (please be accurate): Refer to page 1.
c. USGS Quadrangle Map name and number OK on Application ❑,
OK on Existing Permit ®, or provide USGS Quadrangle Map name and number: Roanoke
Rapids, NC, B28NW
d. Latitude/Longitude OK on Application ❑, (check at http://topozone.com These are often
inaccurate) OK on Existing Permit ❑, or provide Latitude: Longitude:
e. Receiving Stream OK on Application ®,
OK on Existing Permit ®, or provide Receiving Stream or affected waters:
a. Stream Classification: C
b. River Basin and Sub basin No.: Roanoke River Basin, 03-02-08
FORM: NPDES-RRO 06/03, 9/03 4

NPDES REGIONAL WATER QLALITY
STAFF REPORT AND RECOMMENDATIONS
c. Describe receiving stream features and downstream uses: Controlled by Roanoke Rapids
dam. Downstream uses include fishing, secondary recreation and drinking water supply.
Discharge Pointe (Fill this section only if BIMS or Application Info is incorrect or missing)
a. Location OK on Application ❑,
OK on Existing Permit ❑, or provide Location: Location lat/long is good. Lattlong for 003 on
application and in BIMS is not exact but is likely good enough for one to find it while in the field.
b. Driving Directions OK on Application ❑,
OK on Existing Permit ❑, or provide Driving Directions (please be accurate): Refer to page 1.
c. USGS Quadrangle Map name and number OK on ApplicationEh
OK on Existing Permit ❑, or provide USGS Quadrangle Map name and number: Roanoke
Rapids, NC, B28NW
d. Latitude/Longitude OK on Application ❑, (check at http://topozone.com These are often
inaccurate) OK on Existing Permit ❑, or provide Latitude: Longitude:
e. Receiving Stream OK on Application ®,
OK on Existing Permit ®, or provide Receiving Stream or affected waters:
a. Stream Classification: C
b. River Basin and Sub basin No.: Roanoke River Basin, 03-02-08
c. Describe receiving stream features and downstream uses: Controlled by Roanoke Rapids
dam. Downstream uses include fishing, secondary recreation and drinking water supply.
FORM: NPDES-RRO 06/03, 9/03

Michael F. Easley. Governor
William G. Ross, Jr., Secretary
North Carolina Depertrnent of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
19 June 2006
Ms. Mary Lee Ransmeier
Manager of Environmental Quality
International Paper Corporation
100 Gaston Road
Roanoke Rapids, NC 27870
Subject: Compliance Evaluation Inspections
International Paper Corporation
Roanoke Rapids Mill
NPDES Wastewater Permit NC0000752
NPDES Stormwater Permit NCS000106
Halifax County
Dear Ms. Ransmeier.
On 25 May 2006, I, Ronald Boone of the Divison of Water Quality's (DWQ) Raleigh Regional Office
conducted wastewater and stormwater Compliance Evaluation Inspections (CEI) of the subject facility.
Your assistance and cooperation, as well as that of your Operator in Responsible Charge (ORC), Chris
Puryear and his backup ORC, Neal Davis, were helpful and appreciated. Inspection checklists are
attached for your review.
I. NPDES Wastewater Permit NC0000752
A. This permit authorizes International Paper Corporation (IP) to:
1. Continue to operate an existing 28.0 MGD wastewater treatment plant that discharges from
outfall 001 and consists of the following treatment units:
a. Mechanical bar screen
b. Primary clarifier
c. Emergency holding pond
d. Sludge lagoon
e. Aeration basins
f. Three stabilization ponds
2. Continue to discharge non -contact cooling water from the B and C evaporator at outfall 002
and from the turpentine condenser at outfall 003.
N000 Caro
turn
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Intemet h2o.enr.state.nc.us 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
IL An Equal Opportunity/Affirmative Action Employer— 50% Recydedll0% Post Consumer Paper

International Paper Corporation Compliance uation Inspections, NC0000752 and NCS0001Of 06/19/2006, Page 2 of 3
B. Wastewater from outfalls 001, 002 and 003 are discharged into the Roanoke River, a Class C
water in the Roanoke River Basin. This permit became effective on 1 February 2005 and expires
at midnight on 21 March 2007.
C. During the inspection the following items were noted:
1. All plant equipment was fully operational and properly maintained.
2. All laboratory records and operations/maintenance records were inspected and found to be
compliant.
3. The discharges appeared clear and free of solids and foam. The receiving stream showed no
detrimental impacts from these discharges.
H. NPDES Stormwater Permit NCS000106
A. This permit authorizes International Paper Corporation (IP) to:
1. Discharge stormwater to the Roanoke River and a tributary to the Roanoke River, both of
which are Class C waters in the Roanoke River Basin.
B. This permit became effective on 1 April 2003 and expires at midnight on 31 March 2008.
C. During the inspection the following items were noted:
1. The stormwater system and stormwater discharge outfalls (SDO) were inspected. Stormwater
generated at the site is collected via a system of in -ground drains and stormwater ditches. The
drains and ditches convey stormwater to three SDOs.
2. There was no visible evidence of spills, overflows or similar incidents in the system. No
significant erosion was found.
3. The discharges appeared clear and free of solids and foam. The receiving stream showed no
detrimental impacts from these discharges.
4. The site was clean and well maintained.
5. The stormwater pollution prevention plan (SP3) was reviewed and met all requirements with
the following exceptions:
a. Qualitative monitoring was being accomplished but not recorded. Please ensure that all
future qualitative monitoring events are accomplished, properly recorded and kept on file
according to permit requirements.
6. All analytical monitoring results were available on site and ready for inspection. Analytical
measurements were compliant.

` International Paper Corporation Compliance nation Inspections, NCOOD0752 and NCSOOO106 06/ 19/2006, Page 3 of 3
Please provide a response to item Hc5a above within 30 days of your receipt of this letter. Your response
should include a narrative as well as a tentative schedule for you to correct the identified deficiency. If
you or your staff has any questions regarding the inspection or this letter, please feel free to call me for
assistance at 919-791-4200.
Sincerely,
3 -
Rona ne
Environmental Technician IV
cc: Central Files
Raleigh Region
Non -Point Source Compliance Enforcement Unit
Attachments:
1. Inspection checklist for 25 May 2006 wastewater compliance evaluation inspection
2. Inspection checklist for 25 May 2006 stormwater compliance evaluation inspection

United States Environmental Protection Agency
Form Approved.
EPA Washington, D C 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires8-31.98
Section A: National Data System Coding (i.e., PCs)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I ul 2 1 51 31 NC0000752 111 12I 06/05/25 117 181 Cl 191 c1 201 I
LJ J l�l LJ 1—I
Remarks
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA Reserved
671 1 69 70I 11 71I 11 L721 NI 73� 74 75L 1 1 1 I 1 1 1 80
J
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Entry Time/Date
Permit Effective Date
Roanoke Rapids Mill
10:00 AM 06/05/25
05/02/01
Exit Time/Date
Permit Expiration Date
N Roanoke Ave
Roanoke Rapids NC 27870
02:00 PM 06/05/25
07/05/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible OfficiaVritie/Phone and Fax Number
James R Jackson,100 Gaston Rd Roanoke Rapids NC Contacted
27870//252-533-6000/2525336465 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance . Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory Other
Section D: Summary of Findin Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Ron Boone RRO WQ//919-791-4200/
oL
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yrfmo/day Inspecdon Type
3I NC0000752 I11 12I 06/05/25 117 18LI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

Permit: NC0000752 Owner - Facility: Roanoke Rapids Mill
Inspection Date: 05125/2006 Inspection Type: Compliance Evaluation
Other
Yes
No
NA
NE
Comment:
Operations & Maintenance
Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping?
■
❑
❑
❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■
❑
❑
❑
Judge, and other that are applicable?
Comment:
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
❑
■
❑
Is the facility as described in the permit?
Is
❑
❑
❑
# Are there any special conditions for the permit?
n
■
n
n
Is access to the plant site restricted to the general public?
■
n
n
n
Is the inspector granted access to all areas for inspection?
In
n
n
n
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
❑
O
❑
Is all required information readily available, complete and current?
■
❑
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
n
n
Are analytical results consistent with data reported on DMRs?
■
n
n
n
Is the chain -of -custody complete?
■
n
n
n
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Are DMRs complete: do they include all permit parameters?
■
n
n
n
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
■
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24f7 with a certified operator on each shift?
■
❑
❑
❑
Is the ORC visitation log available and current?
in
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
Page # 3

Permit: NC0000752 Owner -Facility: Roanoke Rapids Mill
Inspection Date: 05/25/2006 Inspection Type: Compliance Evaluation
Record Keeping
Yes
No
NA
NE
Is the backup operator certified at one grade less or greater than the facility classification?
■
n
n
n
Is a copy of the current NPDES permit available on site?
■
n
n
n
Facility has copy of previous year's Annual Report on file for review?
n
n
■
n
Comment:
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
■
0
O
11
Are the receiving water free of foam other than trace amounts and other debris?
■
n
n
n
If effluent (diffuser pipes are required) are they operating properly?
00
■
n
Comment:
Flow Measurement • Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
n
n
n
Is flow meter calibrated annually?
■
n
Cl
n
Is the flow meter operational?
■
Cl
n
n
(If units are separated) Does the chart recorder match the flow meter?
■
n
n
n
Comment:
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
■
n
n
❑
Is the chemical feed equipment operational?
■
n
n
n
Is storage adequate?
■
n
n
n
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
■
n
n
n
Is the site free of sludge buildup on belts and/or rollers of filter press?
■
n
n
n
Is the site free of excessive moisture in belt filter press sludge cake?
■
n
n
n
The facility has an approved sludge management plan?
■
n
n
E)
Comment:
Chemical Feed
Yes_
No
NA
NE
Is containment adequate?
■
n
n
n
Is storage adequate?
■
n
❑
n
Are backup pumps available?
■
n
C1
n
Is the site free of excessive leaking?
■
n
n
n
Comment:
Page # 4

Permit: NC0000752
Inspection Date: 05J2512006
Pump Station - Effluent
Is the pump wet well free of bypass lines or structures?
Are all pumps present?
Are all pumps operable?
Are Float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Comment:
Pump Station - Influent
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Comment:
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
Primary Clarifier
Is the clarifier free of black and odorous wastewater?
Owner - Facility: Roanoke Rapids Mill
Inspection Type: Compliance Evaluation
Is the site free of excessive buildup of solids in center well of circular clarifier!
Are weirs level?
Is the site free of weir blockage?
Yes _No NA NE
■nnn
■nnn
■nnn
■nnn
■nnn
nn■n
■nnn
n
n
Yes No NA HE
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ Cl ❑ ❑
Page # 5

Permit: NCM752 Owner - Facility: Roanoke Rapids Mill
Inspection Date: 05/25/2006 Inspection Type: Compliance Evaluation
Primary Clarifier
Yes
No
NA
NE
Is the site free of evidence of short-circuiting?
■
O
0
Is scum removal adequate?
■
n
n
n
Is the site free of excessive floating sludge?
■
n
n
n
Is the drive unit operational?
■
❑
n
n
Is the sludge blanket level acceptable?
■
n
n
n
Is the sludge blanket level acceptable? (Approximately Y. of the sidewall depth)
■
❑
❑
❑
Comment:
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
■
n
n
n
Are surface aerators and mixers operational?
■
n
n
n
Are the diffusers operational?
n
n
■
n
Is the foam the proper color for the treatment process?
■
❑
0
rl
Does the foam cover less than 25% of the basin's surface?
■
n
n
n
Is the DO level acceptable?
■
n
n
n
Is the DO level acceptable?(1.0 to 3.0 mg/1)
■
❑
❑
❑
Comment:
Lagoons
Yes
No
NA
NE
Type of lagoons?
Facultative
# Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
# Is a re -circulation line present?
■
n
n
n
Is lagoon free of excessive floating materials?
■
Q
0
11
# Are baffles between ponds or effluent baffles adjustable?
■
n
n
n
Are dike slopes clear of woody vegetation?
■
0
Q
Are weeds controlled around the edge of the lagoon?
■
❑
0
Are dikes free of seepage?
■
n
n
n
Are dikes free of erosion?
■
n
n
n
Page # 6

Permit: NC0000752 Owner - Facility: Roanoke Rapids Mill
Inspection Date: 05/252066 Inspection Type: Compliance Evaluation
Lagoons
Yes
No
NA
NE
Are dikes free of burrowing animals?
■
❑
❑
❑
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations?
■
❑
❑
❑
# If excessive algae is present, has barley straw been used to help control the growth?
❑
❑
■
❑
Is the lagoon surface free of weeds?
■
❑
❑
❑
Is the lagoon free of short circuiting?
■
❑
❑
❑
Comment:
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
❑
❑
■
❑
Is the generator tested by interrupting primary power source?
n
n
■
❑
Is the generator tested under load?
n
n
■
❑
Was generator tested & operational during the inspection?
n
n
In
❑
Do the generator(s) have adequate capacity to operate the entire wastewater site?
n
n
■
❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
❑
❑
■
❑
Is the generator fuel level monitored?
0
❑
■
❑
Comment:
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
■
❑
❑
❑
# Is the facility using a contract lab?
■
❑
❑
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
❑
❑
❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
■
❑
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees? c _ ,. 8 i
"-
/� �( t
jjT
■
❑
❑
❑
Comment:
Influent Sampling
Yes
No
NA
NE
# Is composite sampling Flow proportional?
❑
❑
■
❑
Is sample collected above side streams?
❑
❑
■
❑
Is proper volume collected?
❑
❑
■
❑
Is the tubing clean?
❑
❑
■
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
❑
❑
■
Q
Is sampling performed according to the permit?
❑
❑
■
❑
Page # 7

permit NC0000752
Inspection Date: 05252005
Owner - Facility: Roanoke Rapids Mill
Inspection Type: Compliance Evaluation
Influent Sampling
Yes
No
NA
NE
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected below all treatment units?
■
❑
❑
❑
Is proper volume collected?
■
n
❑
❑
Is the tubing clean?
■
n
❑
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ■ ❑ ❑ LJ
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ ❑ ❑ 0
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ ❑ ❑ ❑
Comment:
Page # 8

United States Environmental Protection Agency
Form Approved.
04
EPA Washington, D.C. 260
OMB No. 2040.0057
Water Compliance Inspection Report
Approval expires 831.98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 Ivl 2 I5I 31 NCS000106 '11 121 06/05/25 117 181 CI 19u 20I—I
J u u u
Remarks
21IIIIII1111IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII16
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- --Reserved-
67I 169 70I I 711 I 721 v I 731 74 75I I I I I I I 180
J LJ I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:00 AM 06/05/25
03/03/07
Roanoke Rapids Mill
Exit Time/Data
Permit Expiration Date
N Roanoke Ave
Roanoke Rapids NC 27870
02:00 PM 06/05/25
08/03/31
Names) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Officialfritie/Phone and Fax Number
Daniel Alford,PO Box 57 Riegelwood NC Contacted
28456/Manager/910-655-4106/9106559368 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Storm Water
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Ron Boo RRO WO//919-791-4200/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560.3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/na/day Inspection Type
NCS000106 I11 12I 06/05/25 I17 18I-'
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

�oF wArF9Q 1 MTV WIT%
O Y
Ms. Mary Lee Ransmeier
International Paper Company
100 Gaston Rd.
Roanoke Rapids NC 27870
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
September 13, 2006
Subject: Disposal of NORM
Permit No. NC0000752
Roanoke Rapids Mill
Halifax County
Dear Ms. Ransmeier:
Alan W. Klimek, P.E. Director
Division of Water Quality
The Raleigh Regional Office has reviewed the plan proposed by International Paper for disposing
of NORM by hydroblasting scale from pipes into the Emergency Pond. We are confident that
disposal will not cause treatability problems in the wastewater treatment plant. Likewise, after
traveling through the plant, the material would not pose water quality issues in the Roanoke
River. We find the information provided appropriately documents creation of this one-time
waste stream to the mill's wastewater system. Permission to proceed is hereby granted.
Sincerely,
C,�V
Charles Wakild, P.E.
Surface Water Protection Supervisor
Raleigh Regional Office
xc:WQ Central Files
RRO/SWP files
FWAI
44WE
Raleigh Regional Office 1628 Mail Service Center [phone] Customer Service
Water Quality Section Raleigh, NC 27699-1628 Facsimile [phone] 1 800 623-7748

NPDES STAFF REPORT AND RECOMMENDATIONS
for International Paper Regarding Disposal of NORM
Date: Sept 12, 2006
To: NPDES Permitting Unit
Water Quality Section �p
Attention: C-h� D t4�� l-xGn�tt�.
}X�� n
Through: Charles Wakild " `Vl � ql i�lbb
Raleigh Regional Office / Surface Water Protection Section
County: Halifax
Permit No. NC0000752
Subject: Approval of Request to Dispose of Naturally Occurring Radioactive Material
(NORM) Contained Inside Discarded Pipes by Hydroblasting
PART I -GENERAL INFORMATION
Facility and Address: International Paper
P.O. Box 580
Roanoke Rapids, NC 27870
2. Date of Site Visit: — Personal knowledge of site
3. Report Prepared by: Myrl Nisely
4. Persons Contacted and Telephone Number:
Mary Lee Ransmeier, 252-533-6255 or Chris Puryear, 252-533-6237
5. Directions to Site: Rt. 48 to North edge of Roanoke Rapids
6. Attach a USGS map extract and indicate treatment facility site and discharge point
on map. Photo below
7. Topography (relationship to flood plain included): The eastern end of the
"Emergency" pond where removal is proposed is a significant distance from
papermill activity. See photo below.
NPDES Staff Report
Page 1

PART II - DESCRIPTION OF PROBLEM AND PROPOSED ACTION
Naturally Occurring Radioactive Material (NORM) is deposited in piping that has transported
river water for many years, and is then eventually removed from within the papermill. Scale
gradually accumulates over time. The alpha radiation emitted from thorium and uranium
carbonates is very weak, and occurs only in short lengths of the pipes, not the entire length.
The company proposes hydroblasting (use of a high energy water jet) inside the pipes, with the
discharge going into the end of an emergency spill pond most distant from the production
facility. The blasting is expected to re -dissolve the scale. But if flakes are dislodged that do not
dissolve, they will become immobilized in the solids on the bottom of the pond. On the
infrequent times that water is pumped back into the wastewater plant from this pond, the pickup
point is at the opposite end of the pond. The returning flow would be slowly added to the 14
MGD typically coming from the papermill to the bar screen. Therefore, the NORM containing
water would be greatly diluted.
There is no concern over radiation for workers doing the hydroblasting. They will wear
protective clothing to protect breathing and to keep water from their skin.
PART III - OTHER PERTINENT INFORMATION
Photo of pond and proposed working site:
NPDES Staff Report
Page 2

PART IV - EVALUATION AND RECOMMENDATIONS
This removal of NORM is a one-time event, needed as a condition in the sale of the papermill.
There is no reason to modify wastewater permit NC0000752 in which the emergency pond is a
component. The attached letters from the Radiation Protection Section and the Division of Solid
Waste Management indicate approval by those agencies.
I recommend that permission be granted for this process. There is not expected to be any damage to
the environment or danger to public health.
Signature ogreport preparer
4//Z/o 6
Water Quality Regional Supervisor Date
NPDES Staff Report
Page 3

lision of Environmental Healt„ State olNorth Carolina
K ,Terry L. Pierce. Director Michael F. Easley, Governor
Radiation Protection Section Department of Resources and
Natural Resources
Division or Beverly O. Hall, Chief William G. Ross, Secretary
Envirommettal health
September 1 I __6U6
Myrl Nisely, Env. Spec. H
Division of Water Quality
Surface Water Protection
3800 Barrett Drive
Raleigh, NC 27609
SUBJECT: International Paper pipe scale containing naturally occurring radioactive material
Dear Mr. Nisely:
International Paper in Roanoke Rapids has approximately four to five cubic yards of pipe with a small amount of scale
containing naturally occurring radioactive material (NORM). In previous years, we have worked with North Carolina
State University in determining the specific activity of this scale.
A letter date July 16, 1996 signed by Ralton J. Harris, Environmental Health Physicist of North Carolina State University
documents results from gamma spectroscopic and gross alpha -beta analysis that the pipe scale contains — 0.006
microcurie per gram of the decay progeny of uranium and thorium.
Based on these results, we recommended that the Division of Solid Waste approve the disposal of the pipe containing this
scale into International Paper's on -site landfill. This was approved on July 24, 1996 in a letter signed by William L.
Meyer.
International Paper on -site landfill was closed and they began storing this pipe with scale containing NORM on -site for
several years. International Paper realized this waste stream would continue to grow so they implemented a procedure to
remove any scale prior to removal of any pipes from the plant and the waste water generated from this activity to be
distributed to the settling pond. Since this new procedure was implemented, it is my understanding that it has solved their
pipe scale problem.
This four to five cubic yards of pipe with scale containing NORM is still being stored on -site at International Paper. We
recommend that the Division of Water Quality, Surface Water Protection approve International Paper to remove the pipe
scale into their settling pond.
Sincerely,
Wendy B. Tingle, Health Physicist
Radioactive Waste Coordinator
Radioactive Materials Branch
Cc: Mary Lee Ransmeier, Environmental Manager
International Paper
100 Gaston Road, Roanoke Rapids, NC 27870
1645 Mail Service Center, Raleigh, North Carolina 27699-1645 NOne Carolina
Phone [phone] / Fax [phone]
http://www.ncradiation.net atirally
An Equal Opportunity / Affirmative Action Employer

State of North Car is
Department of Environment,
Health and Natural Resources 1 •
Division of Solid Waste Management
�r..i-
James B. Hunt, Jr., Governor p E H N F�
Jonathan B. Howes, Secretary
William L. Meyer, Director
July 24, 1996
Chris Puryear
Champion International
P.O.Box 580
North Roanoke Avenue
Roanoke Rapids, NC 27870
RE: Pipe Scale Management
Dear Mr. Puryear:
The Division of Waste Management appreciates Chapion International's intent and attempts to
recycle the pipe scale before considering disposal.
The Division approves disposal of approximately three to four cubic yards (1,000 lbs) of pipe
scale containing 0.006 microcuries/gm uranium and thorium in the on -site landfill, permit number
4203.
If we can be of further assistance, please contact Ben Barnes, Waste Management Specialist,
in the Raleigh Regional Office at 919/5714700.
Sincerely,
William L. Meyer /
cc: Ben Bames
Wendy Tingle, RPD
Phil Prete
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/ 10%post-consumer paper

Division of Water Quality
May 5, 2006
MEMORANDUM ---
To: Myrl Nisely
From: Matt Matthews tut"
Subject: Defoamer Use
International Paper — Roanoke Rapids
NPDES No. NC0000752
Halifax County
International Paper has requested approval for the use of GE Betz Foamtrol AF-J 60 defoamer at_iits
Roanoke Rapids Plant.
Ceriodaphnia dubia 48 hour acute testing for the product indicates an LCso of 420 mg/L. Given that
there is no half-life data available for the product, a very environmentally conservative application
factor of 0.01 was applied to generate a level protective for chronic toxicity. This resulted in a safe
level of 4.2 mg/L. Assuming an application rate of 300 ml/minute for the product, maximum permitted
effluent flow of 28 MGD, and a minimum stream flow of 1000 cfs for the Roanoke River, I calculated a
maximum instream concentration of the product of 0.17 mg/L.
The use of the product at the stated dosage rate and discharge conditions will not cause toxic impacts
to aquatic life in the Roanoke River. Therefore, the use of the product at International Paper's Roanoke
Rapids facility is acceptable.
If there are questions concerning this review, please call me at [phone], ext. 517.
cc: Chris Puryear, international Paper, Roanoke Rapids Plant, 100 Gaston Road, Roanoke Rapids, NC 27870
Aquatic Toxicology Unit Environmental Sciences Section

A �r
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
February 10, 2005
Mr. James R. Jackson, Jr.
International Paper Corporation
Roanoke Rapids Mill
100 Gaston Road
Roanoke Rapids, NC 27870
Subject: Compliance Evaluation Inspections
NPDES Permit No. NC0000752
Stormwater Permit No. NCS000106
Halifax County
Dear Mr. Jackson:
Enclosed are reports of inspections I conducted on Janury 7, 2005. The assistance of
Chris Puryear, Neal Davis, Mary Lee Ransmeier and Paul Kinnin is appreciated.
A tour of the facility was conducted at the time of the inspection. Laboratory records and
operator records were reviewed and no discrepancies were found.
Stormwater records were review and found to be complete.
A review of the data for the previous year, December 2003 through 2004 was reviewed.
The only violations noted were pH violations on May 27, 2004 for outfalls 002 and 003. This
was caused by low pH in the river and has been addressed by the Division's enforcement policy.
If you have questions concerning the inspection, please call me at [phone].
Sincerely,
IYk
Garrett
Y
Environmental Chemist
1628 Mail Service Center, Raleigh, North Carolina 27699-1628
3800 Barrett Dr.., Raleigh, North Carolina 27609
Phone: [phone] / FAX [phone] Internet:: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
Nne
orthCarolina
Nawl4a!!t,

Permit: NC0000752 Owner - Facility: International Paper Company - Roanoke Rapids Mill
Inspection Date: 01/07/05 Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
Yes
❑
No
❑
NA
0
NE
❑
Is the facility as described in the permit?
❑
0
❑
❑
Are there arty special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
E
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: Several treatment units are not described in the permit, including the Fly Ash pond, the woodyard
stormwater pond, and the sludge press building which contains 2 rotary screen thickeners and 2 sludge presses.
Operations Maintenance
Yes
No
NA
NE
&
Does the plant have general safety structures in place such as rails around or covers over tanks, pits, or wells?
E
❑
❑
❑
Is the plant generally clean with acceptable housekeeping?
E
❑
❑
❑
Comment:
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive cabins?
0
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment:
Yes
No
Prima Clarifier
Is the clarifier free of black and odorous wastewater?
0
❑
NA
❑
NE
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
E
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
■
❑
❑
❑
Is the site free of excessive Floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the sludge blanket level acceptable?
■
❑
❑
❑
Comment:
Aeration Rasing
YPs
No
NA
NF
Mode of operation
Type of aeration system
Is the basin free of dead spots?
I♦
❑
❑
❑
Are surface aerators and mixers operational?
I♦
❑
❑
❑
Are the diffusers operational?
❑
❑
0
❑
Is the foam the proper color for the treatment process?
N
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
0
❑
❑
❑
Are settleometer results acceptable?
❑
❑
0
❑
Comment: 31 surface aerators. D.O. kept around 2.5 mg/1
cons

Permit: NC0000752 Owner - Facility: International Paper Company - Roanoke Rapids Mill
Inspection Date: 01/07/05 Inspection Type: Compliance Evaluation
Lagoons Yes No NA NE
Type of lagoons? Facultative
Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
Is a recirculation line present?
❑ ❑
IN
❑
Is lagoon free of excessive floating materials?
0 ❑
❑
❑
Are baffles between ponds or effluent baffles adjustable?
0 ❑
❑
❑
Are dike slopes Gear of woody vegetation?
M ❑
❑
❑
Are weeds controlled around the edge of the lagoon?
❑
❑
❑
Are dikes free of seepage?
❑
❑
❑
Are dikes free of erosion?
0 ❑
❑
❑
Are dikes free of burrowing animals?
0 ❑
❑
❑
Are sludge levels appropriate?
0 ❑
❑
❑
Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations?
0 ❑
❑
❑
If excessive algae is present, has barley straw been used to help control the growth?
❑ ❑
0
❑
Is the lagoon surface free of weeds?
0 ❑
❑
❑
Is the lagoon free of short circuiting?
0 ❑
❑
❑
Comment: Sludge is removed from the 1st lagoon approximately every 3 years.
Laboratory
Are field parameters performed by certified personnel or laboratory?
Yes No
M ❑
NA
❑
NE
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0 ❑
❑
❑
Is the facility using a contract lab?
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
❑
❑
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
0 ❑
❑
❑
Incubator (Fecal Coliforn) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑ ❑
M
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
0 ❑
❑
❑
Comment: Checked November 04 data.
Yes No
NA
NE
Flow Measurement- Influent
Is flow meter used for reporting?
❑ 0 ❑
❑
Is flow meter calibrated annually?
M ❑
❑
❑
Is flow meter operating properly?
0 ❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑ ❑
M
❑
Comment: no chart recorder.
Flow
Yen No
NA
NF
Measurement - Effitipnt
Is flow meter used for reporting?
No
❑
❑
Is flow meter calibrated annually?
❑
❑
❑
Is flow meter operating properly?
0 ❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
0 ❑
❑
❑
Comment:
Yes No
NA
NE
Record Keeoina
Are records kept and maintained as required by the permit?
s ❑
❑
❑
Is all required information readily available, complete and current?
❑
❑
❑
Are all records maintained for 3 years (lab. mg. required 5 years)?
❑
0
0

Permit: NC0000752 Owner - Facility: International Paper Company - Roanoke Rapids Mill
Inspection Date: 01/07/05 Inspection Type: Compliance Evaluation
Record Keeoino
Are analytical results consistent with data reported on DMRs?
Yes
■
No
❑
NA
❑
NE
❑
Are sampling and analysis data adequate and include:
■
❑
❑
❑
Dales, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Plant records are adequate, available and include
■
❑
❑
❑
O&M Manual
■
As built Engineering drawings
■
Schedules and dates of equipment maintenance and repairs
■
Are DMRs complete: do they include all permit parameters?
■
❑
❑
❑
Has the facility submitted its annual compliance report to users?
■
❑
❑
❑
(If the facility is = or > 5 MGD permitted flax) Do they operate 24/7 with a certified operator on each shift?
■
❑
❑
❑
Is the ORC visitation log available and current?
■
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
■
❑
❑
❑
Is a copy of the current NPDES permit available on site?
■
❑
❑
❑
Is the facility description verified as contained in the NPDES permit?
■
❑
❑
❑
Does the facility analyze process control parameters, for example: MLSS, MCRT, Settleable Solids, DO, Sludge
■
❑
❑
❑
Judge, pH, and others that are applicable?
Facility has copy of previous year's Annual Report on file for review?
■
❑
❑
❑
Comment: They do a self -certification program for 2417 operation.
Yes
No
NA
NE
Influent Samnlina
Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected above side streams?
■
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
❑
❑
❑
Is sampling performed according to the permit?
■
❑
❑
❑
Comment:
Yes
No
NA
NE
Effluent Samnlina
Is composite sampling flow proportional?
■ ❑
❑
❑
Is sample collected below all treatment units?
■
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
❑
❑
❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
❑
❑
❑
Comment:
Yes
No
NA
NE
Upstream / Downstream Samnlina
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)?
■ ❑
❑
❑
Comment:

Permit
(If the present permit expires in 6 months or less). Has the permittee submitted anew application?
Vas
0
No
0
NA
0
NF
0
Is the facility as described in the permit?
M
0
0
0
Are there any special conditions for the permit?
M
0
0
0
Is access to the plant site restricted to the general public?
N
0
0
0
Is the inspector granted access to all areas for inspection?
M
0
0
0
Comment:
Yes
No
NA
NE
Record d Keeoina
Are records kept and maintained as required by the permit?
0
0
0
0
Is all required information readily available, complete and current?
0
0
0
0
Are all records maintained for 3 years (lab. rag. required 5 years)?
0
0
0
0
Are analytical results consistent with data reported on DMRs?
0
0
0
0
Are sampling and analysis data adequate and include:
0
0
0
0
Dales, times and location of sampling
0
Name of individual performing the sampling
0
Results of analysis and calibration
0
Dates of analysis
0
Name of person performing analyses
0
Transported COCs
0
Plant records are adequate, available and include
0
0
0
0
O&M Manual
0
As built Engineering drawings
0
Schedules and dates of equipment maintenance and repairs
0
Are DMRs complete: do they include all permit parameters?
0
0
0
0
Has the facility submitted its annual compliance report to users?
0
0
M
0
(If the facility is = or> 5 MGD permitted fiow) Do they operate 24/7 with a certified operator on each shift?
0
0
0
Is the ORC visitation log available and current?
0
0
0
Is the ORC certified at grade equal to or higher than the facility classification?
0
0
0
0
Is the backup operator certified at one grade less or greater than the facility classificatlon?
0
0
0
0
Is a copy of the current NPDES permit available on site?
0
0
0
Cl
Is the facility description verified as contained in the NPDES permit?
0
0
0
Cl
Does the facility analyze process control parameters, for example: MLSS, MCRT, Settleable Solids, DO, Sludge
0
0
0
0
Judge, pH, and others that are applicable?
Facility has copy of previous year's Annual Report on file for review?
0
0
0
0
Comment:
Yes
No
NA
NE
Effluent Pipe
Is right of way to the outfall properly maintained?
0
0
0
Are receiving water free of solids and floatable wastewater materials?
0
❑
0
Are the receiving waters free of solids / debris?
0
0
0
Are the receiving waters free of foam other than a trace?
0
0
0
Are the receiving waters free of sludge worms?
0
0
❑
If effluent (diffuser pipes are required) are they operating property?
0
0
0
0
Comment:

United States Environmental Protection Agency
Fo0n Approved.
Washington, D C 20460
EPA
OMB No. 2040-OD57
Water Compliance n Report
Approval expires 831-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/na/day Inspection Type Inspector Fee Type
�N 1 L_I 2 U 31 NCS000106 111 121 05/01/07 1 17 18Li 19u 20u
Remarks
211111111111111111111111111111111111111111111111166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 OA,�----Reserved ----
671 1 69 70 U 71 U 72 U 73 w 74 75I 1 1 1 1 I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
01:30 PM 05/01/07
03/03/07
Roanoke Rapids Mill
Exit Time/Date
Permit Expiration Date
N Roanoke Ave
Roanoke Rapids NC 27870
04:45 PM 05/01/07
08/03/31
Name(s) of Onsile Representative(s)lTitles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Plane and Fax Number
Chris C Puryear,100 Gaston Rd Roanoke Rapids NC 27870/Environmentapontaded
No
Supervisor/252-533-6237/
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Records/Reports Self -Monitoring Program 0 Effluent/Receiving Waters
Storm Water Other
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checldists as necessary)
(see attachment summary)
Names) and Signature(s) of Inspector($) Agency/Office/Phone and Fax Numbers Date
Judy E Garrett RRO WQ//919-571-4700 Ext.270/9195714718
Signature of Management O A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

NPDES yrhno/day Inspection Type
3I NCS000106 i11 12( 05/01/07 I17 181C1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checMists as necessary)

Permit: NG0000752 Owner - Facility: International Paper Company - Roanoke Rapids Mill
Inspection Date: 01/07/05 Inspection Type: Compliance Evaluation
Ves No
NA
NE
So_lidc Handling Epuipment
Is the equipment operational?
N ❑
0
❑
Is the chemical feed equipment operational?
0 0
O
❑
Is storage adequate?
❑
O
11
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
❑
0
❑
Is the site free of excessive moisture in belt filter press sludge cake?
❑
❑
O
Comment:
Yes No
NA
NF
Chemical Feed
Is containment adequate?
O
❑
Is storage adequate?
❑
❑
13
Are backup pumps available?
O
O
11
Is the site free of excessive leaking?
O
❑
0
Comment:
Yes No
NA
NE
Effluent Pipe
Is right of way to the outfall properly maintained?
N O
❑
O
Are receiving water free of solids and floalable wastewater materials?
0 El
❑
O
Are the receiving waters free of solids / debris?
O
❑
❑
Are the receiving waters free of foam other than a trace?
❑
13
El
Are the receiving waters free of sludge worms?
❑
0
O
If effluent (diffuser pipes are required) are they operating property?
❑ 0
0
❑
Comment:

Roanoke Rapids NORM ^ I C Q 0d 0720
Subject: Roanoke Rapids NORM 1 v
From: Mary Lee Ransmeier <[e-mail]>
Date: Wed, 4 Oct 2006 14:52:07 -0500
To: [e-mail]
CC: [e-mail]
Dear Ms. Tingle,
I am attaching a letter that will be mailed describing the completion
of our NORM removal from the Roanoke Rapids Mill. As we discussed, we took
some video of the process and I will be sending that separately in a couple
of days. We were very pleased that the pipe cleaned up so nicely. We have
the log sheets, etc here in our files if you should want to see them.
Thank you for your assistance in approving this process.
Sincerely,
Mary Lee
(See attached file: NORM letter complete.doc)
Mary Lee Ransmeier
Environmental Manager
International Paper
100 Gaston Road
Roanoke Rapids, NC 27870
252-533-6255
NORM letter c=omplete.docContent-Type: application/msword
NORM letter complete.doc
Content -Encoding: base64
I of 1 10/9/2006 1:57 PM

October 4, 2006
Ms. Wendy B. Tingle
Radioactive Waste Coordinator
Radioactive Materials Branch
Division of Environmental Health
1645 Mail Service Center
Raleigh, NC 27699-1645
Dear Ms. Tingle:
The purpose of this correspondence is to inform you of the disposition of Naturally
Occurring Radioactive Material (NORM) that had contaminated scrap process piping at
the International Paper Roanoke Rapids, North Carolina mill. Per approval of the plan
submitted to our Regional Water Protection Supervisor by your office dated September
11, 2006 work began on NORM scale removal from the scrap piping on September 27,
2006.
The removal process entailed hydro -blasting the NORM contaminated scale from the
piping directly into the mill Emergency Surge Basin. The Surge Basin is part of the
mill's existing wastewater treatment system. Background activity readings were
initially measured away from the pipe utilizing a Ludlum Model 3 Survey Meter.
Background activity was approximately 10 to 15 micro R/hr.
A total of 170 pieces of NORM contaminated scrap pipe were surveyed prior to and
immediately after the cleaning process. Initial activity of the NORM contaminated pipe
ranged from 20 to 150 micro R/hr. The post cleaning survey showed that the activity of
the scrap pipe was at background or below. The cleaning process was completed on
September 29,2006 and the cleaned pipe was sent to a local scrap dealer.
We greatly appreciate the effort and cooperation that we received from both the Division
of Water Quality and the Division of Environmental Health in allowing us to effectively
and safely dispose of this material. If you have any questions please feel free to contact
me at 252-533-6255
Sincerely,
Mary Lee Ransmeier
Environmental Manager

k
INTERNATIONAL® PAPER t I���'�5
Roanoke Rapids Mill
100 Gaston Road
Roanoke Rapids, NC 27870
November 15, 2006
Mr. Alan W. Klimek, Director
NC DENR
Division of Water Quality
512 N. Salisbury Street
Raleigh, NC 27604
w
9
Re: International Paper Roanoke Rapids Mill Transfer of Ownership to KapStone-
Environmental Operating Permits
Dear Mr. Klimek,
International Paper has entered into an agreement to sell the Roanoke Rapids Kraft Paper
Mill to a newly formed company, KapStone Kraft Paper and Packaging Corporation.
The mill will continue to manufacture the same products, Kraft paper and light weight
liner board at our integrated Kraft pulp and paper mill without any interruption. We are
currently awaiting final approval by the Securities and Exchange Commission, but
anticipate a closing of December 31, 2006. Therefore, the new permits must be effective
January 1, 2007. Because of a given amount of uncertainty, I wanted to give you as
much advance notice as possible and will confirm the date of closing as soon as we are
informed.
A copy of the ownership change forms are enclosed for the following envirotirgjgllyN01' 033�
permits now held by International Paper:
1. NC0000752-NPDES Wastewater Treatment Facility f 900Z I Z AM
2. NCS000106-NPDES Stormwater Permit (revision n eded) I`JI
3. WQ0021577-Land Application of Flyash F ea �„
4. WQ00013516-Land Application of Residual Solids — -
5. WQ0000436-Solid Waste Landfill
y z ppr ao (
As soon as approval of a sale finalized, I will be able to notify you and will submit
original signed and dated permit change forms. As noted above, the only permit that
needs revision is the Stormwater Permit. International Paper will retain ownership of an
on site landfill, closed in 1998, which has one stormwater monitoring discharge point
designated as "Lowground."

I look forward to working with you and your staff on this change of ownership as our
mill enters its one hundredth year of manufacturing in Eastern North Carolina. And we
anticipate many more years of continued business in the State. Please contact me if I
you have any questions at 252-533-6255
Sincerely,
Mary Lee R�ansmeier
Environmental Programs Manager
Copy: Antra Collins, Mill Manager
Chuck Wakild, Regional Supervisor, DWQ
Enclosures

State of North Caro
Department of Environment and Natural Resources
Division of Water Quality Q�+
�? PERMIT NAME/OWNERSHIP CHANGE FORM
W
', n. changes made to this form will result in the application being returned.
(THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
�o
For more information, visit our web site at. h2o.ennstate.nc.ushutpu/
1. Submit one original of the completed and appropriately executed Permit Name/Ownership Change Form. For a
change of ownership, the certification must be signed by both the current permit holder and the new applicant.
For a name change only, the certification must be signed by the applicant.
2. Provide legal documentation of the transfer of ownership (such as a contract, deed, article of incorporation, etc.)
for ownership changes. A copy of the Association Bylaws and Declarations should be submitted for a change of
ownership to a Homeowner's Association.
3. Submit a properly executed Operation and Maintenance Agreement for all Single Family Spray/Drip Irrigation
permits requesting a change of ownership.
11. CURRENT PERMIT INFORMATION
1. Permit number: W00021577
2. Permit holder's name: International Paper Corp.
3. Permit's signing official's name and title: Anitra J. Collins
(Person legally responsible for permit)
Mill Manager
(title)
4. Mailing address: 100 Gaston Road
City: Roanoke Rapids State: NC zip: 27870
Telephone number: ( 252 ) 533-6398
III. NEW OWNERINAME INFORMATION
1. This request for a permit change is a result of:
Facsimile number: ( 252 ) 533-6401
X a. Change in ownership of property/company
b. Name change only
c. Other (please explain):
FORM: PNOCF 06/00 Page 1 of 2

u
2. New owner's name (name to be used in permit): KapStone Kraft Parer Corporation
3. New owner's or signing official's name and title: Anitra J. Collins
(Person legally responsible for permit)
Mill Manager
(title)
4. Mailing address: 100 Gaston Road
City: Roanoke Rapids State: NC zip: 27870
Telephone number: ( 252) 533-6398 Facsimile number: ( 252 ) 533-6401
IV. CERTIFICATION
1. Current Permittee's Certification:
I, Anitra J. Collins , attest that this application for name/ownership change has been
reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this
application are not completed and that if all required supporting information and attachments are not included,
this application package wi be returned as incomplete. I understand I will continue to be responsible for
compliance with the cu nt7.rffpu a 'ne pernoitis issu94.
Signature:
2. Applicant's Certification:
I, Matt Kaplan , attest that this application for name/ownership change has been reviewed and is
accurate and complete to the best of my knowledge. I understand that if all required parts of this application are
not completed and that if all required supporting information and attachments are not included, this application
package wiw4retumed as ingorpplete.
Signature:
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION AND
MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
NON -DISCHARGE PERMITTING UNIT
By U.S. Postal Service:
1617 MAIL SERVICE CENTER 512 NORTH SALISBURY STREET, SUITE 1219
RALEIGH, NORTH CAROLINA 27699-1617 RALEIGH, NORTH CAROLINA 27604
TELEPHONE NUMBER: [phone]
FORM: PNOCF 06/00 Page 2 of 2

Michael F. Easley, Governor
\` William G. Ross Jr., Secretary
It r w C� 'v0Carolina uepartment of Environment and Natural Resources
+.� Alan W. Klimek, P.E. Director
l-.<u► D Division of Water Quality
SURFACE WATER PROTECTION SECTION
PERMIT NAME/OWNERSHIP CHANGE FORM
1. Please enter the permit number for which the change is requested.
NPDES Permit (or) Certificate of Coverage
N I C I S O 10 10 1 1 10 1 6 N I C I G
II. Permit status prior to status change.
a. Permit issued to (company name):
International Paper
^
b. Person legally responsible for permit:
Anitra T. Collins
='d� S2
Fast / MI / Last
o
Mill Manager
g Q
Title
0
100 Gaston Road
Permit Holder Mailing Address
w
N 0C
Roanoke Rapids, NC 27870
City State tip
z
( 252) 533-6398 (252 ) 533-6401
Phone Fax
c
oc.
Facility name (discharge):
Roanoke Rapids Mill
d. Facility address:
100 Gaston Road
Address
Roanoke Rapids, NC 27870
City State Zip
e. Facility contact person:
Neal R. Davis [phone]
First / MI / Last Phone
III.
Please provide the following for the requested change (revised permit).
a. Request for change is a result of:
4 Change in ownership of the facility
❑ Name change of the facility or owner
If other please explain:
b. Permit issued to (company name):
KapStone Kraft Paper Corporation
c. Person legally responsible for permit:
Anitra J. Collins
First / MI / last
Mill Manager
Title
100 Gaston Road
Permit Holder Mailing Address
Roanoke Rapids, NC 27870
City State Zip
[phone] [e-mail]
Phone E-mail Address
d. Facility name (discharge):
Roanoke Rapids Mill
e. Facility address:
100 Gaston Road
Address
Roanoke Rapids, NC 27870
City State Zip
f. Facility contact person:
Mary Lee Ransmeier
First / MI / last
[phone] [e-mail]
Phone E-mail Address
Revised 712005

PERMIT NAME/OWI 4113I NGE FORM
Page 2 of 2
l__I
IV. Permit contact information: (if different from the person legally responsible for the permit)
Permit contact:
First / MI / last
Mailing Address
Phone E-mail Address
V. Will the permitted facility continue to conduct the same industrial activities conducted prior to
this ownership or name change?
3 Yes
❑ No (please explain)
VI. Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE
INCOMPLETE OR MISSING:
❑ This completed application is required for both name change and/or ownership change requests.
❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill
of sale) is reouired for an ownership change request. Articles of incorporation are not sufficient for
an ownership change.
,....................................................................................................
The certifications below must be completed and signed by both the permit holder prior to the change, and the new
applicant in the case of an ownership change request. For a name change request, the signed Applicant's Certification
is sufficient.
PERMITTEE CERTIFICATION (Permit holder prior to ownership change):
I, Anitra J. Collins , attest that this application for a name/ownership
change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required
parts of this application are not completed and that if all required supporting information is not included, this
application pack will be returned as incomplete.
7
ignature Date
APPLICANT CERTIFICATION:
I, Matt Kaplan attest that this application for a name/ownership
change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required
pacts of this application are not completed and that if all required supporting information is not included, this
application package will be returned as incomplete.
v ty L4, 41.�
Signature Date
....................
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
Division of Water Quality
Surface Water Protection Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Revised 72005

•''r, Michael F. Easley, Governor
William G. Ross Jr., Secretary
�� ♦ Ma
ucpartment of Environment and Natural Resources
a 7
`� OR Alan W. Klimek, P.E. Director
Division of Water Quality
SURFACE WATER PROTECTION SECTION
PERMIT NAMEIOWNERSHIP CHANGE FORM
I. Please enter the permit number for which the change is requested.
NPDES Permit (or) Certificate of Coverage
N I C 10 10 1 0 10 17 15 12 1 N I C I G
H. Permit status prior to status change.
a. Permit issued to (company name):
International Paper
b. Person legally responsible for permit:
Anitra T. Collins
p
v
First /
Mill Manager
MI /
Last
r
L
O
Title
z
100 Gaston Road
Permit Holda Mailing Address
c
"
Roanoke Rapids, NC
27870
city
state
zip
?
0
W
[phone]
[phone]
Z
¢
ta:
Phone
Fax
z
c. Facility name (discharge):
Roanoke Rapids Mill
C
= c
d. Facility address:
100 Gaston Road
Address
Roanoke Rapids, NC
27870
City
State
Zip
e. Facility contact person:
Thomas C. Puryear
[phone]
First / MI / Last
Phoms
III. Please provide the following for the requested change (revised permit).
a. Request for change is a result of: IN Change in ownership of the facility
Cl Name change of the facility or owner
If other please explain:
b. Permit issued to (company name):
KapStone Kraft Paper Corporation
c. Person legally responsible for permit:
Anitra J. Collins
First I MI / last
Mill Manager
Tide
100 Gaston Road
Permit Holda Mailing Address
Roanoke Rapids, NC 27870
City State Zip
[phone] [e-mail]
Phone E-mail Address
d. Facility name (discharge):
Roanoke Rapids Mill
e. Facility address:
100 Gaston Road
Address
Roanoke Rapids, NC 27870
City State Zip
f. Facility contact person:
Mary Lee Ransmeier
First / MI / Last
( 252) 533-6255 [e-mail]
Phone E-mail Address
Revised W2005

PERMIT NAME/0W1 HIP NGE FORM
Page 2 of 2
9
IV. Permit contact information: (if different from the person legally responsible for the permit)
Permit contact:
Address
Phone E-mail Address
V. Will the permitted facility continue to conduct the same industrial activities conducted prior to
this ownership or name change?
3 Yes
❑ No (please explain)
VI. Required Items: THIS APPLICATION WILL BE RETURNED
INCOMPLETE OR MISSING:
IF ITEMS ARE
❑ This completed application is required for both name change and/or ownership change requests.
❑ Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill
of sale) is required for an ownership change request. Articles of incorporation are not sufficient for
an ownership change.
.....................................................................................................
The certifications below must be completed and signed by both the permit holder prior to the change, and the new
applicant in the case of an ownership change request. For a name change request, the signed Applicant's Certification
is sufficient.
PERMITTEE CERTIFICATION (Permit holder prior to ownership change):
I, Anitra 1. Collins attest that this application for a name/ownership
change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required
parts of this application are not completed and that if all required supporting information is not included, this
application age will be returned as incomplete.
Signature Date
APPLICANT CERTIFICATION:
I, _ Matt Kaplan , attest that this application for a name/ownership
change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required
parts of this application are not completed and that if all required supporting information is not included, this
application package will be returned as incomplete.
Signature Date
....................
PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO:
Division of Water Quality
Surface Water Protection Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Revised 7/2005

d State of North Carolina
'J D� Department of Environment and Natural Resources
CiD
o Division of Water Quality Q`
QQ-
I� N PERMIT NAME/OWNERSHIP CHANGE FORM
JAny changes made to this form will result in the application being returned.
THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
z
� � o
For more information, visit our web site at: h2o.enr.state.nc.us/ndpu/
I. REQUIRED ITEMS
1. Submit one original of the completed and appropriately executed Permit Name/Ownership Change Form. For a
change of ownership, the certification must be signed by both the current permit holder and the new applicant.
For a name change only, the certification must be signed by the applicant.
2. Provide legal documentation of the transfer of ownership (such as a contract, deed, article of incorporation, etc.)
for ownership changes. A copy of the Association Bylaws and Declarations should be submitted for a change of
ownership to a Homeowners Association.
3. Submit a properly executed Operation and Maintenance Agreement for all Single Family Spray/Drip Irrigation
permits requesting a change of ownership.
U. CURRENT PERMIT INFORMATION
1. Permit number: W00000436
2. Permit holder's name: International Paper Corp.
3. Permit's signing official's name and title: Antra J. Collins
(Person legally responsible for permit)
Mill Manager
(title)
4. Mailing address: 100 Gaston Road
City: Roanoke Rapids state: NC zip: 27870
Telephone number: ( 252 ) 533-6398
III. NEW OWNER/NAME INFORMATION
1. This request for a permit change is a result of:
Facsimile number:( 252 ) 533-6401
X a. Change in ownership of property/company
b. Name change only
c. Other (please explain):
FORM: PNOCF 06/00 Page 1 of 2

a,
2. New owner's name (name to be used in permit): KapStone Kraft Paper Corporation
3. New owners or signing official's name and title: Anitra J. Collins
(Person legally responsible for permit)
Mill Manager
(title)
4. Mailing address: 100 Gaston Road -
City: Roanoke Rapids State: NC zip: 27870
Telephone number: ( 252 ) 533-6398 Facsimile number: ( 252 ) 533-6401
IV. CERTIFICATION
1. Current Permittee's Certification:
I, Anitra J. Collins , attest that this application for nametownership change has been
reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this
application are not completed and that if all required supporting information and attachments are not included,
this application package will be returned as incomplete. I understand I will continue to be responsible for
complianc
Signature:
2. Applicant's Certification:
I, Matt Kaplan , attest that this application for namelownership change has been reviewed and is
accurate and complete to the best of my knowledge. I understand that if all required parts of this application are
not completed and that if all required supporting information and attachments are not included, this application
package willjV returned as
Signature:
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION AND
MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
NON -DISCHARGE PERMITTING UNIT
By U.S. Postal Service:
1617 MAIL SERVICE CENTER 512 NORTH SALISBURY STREET, SUITE 1219
RALEIGH, NORTH CAROLINA 27699-1617 RALEIGH, NORTH CAROLINA 27604
TELEPHONE NUMBER: [phone]
FORM: PNOCF 06/00 Page 2 of 2

Y�
State of North Car oIna
Department of Environment and Natural Resources
Division of Water Quality O�
PERMIT NAME/OWNERSHIP CHANGE FORM
Any changes made to this form will result in the application being returned.
(THIS FORM MAYBE PHOTOCOPIED FOR USE AS AN ORIGINAL)
For more information, visit our web site at. h2o.enr.suue.nc.us/ndpu/
I.
1. Submit one original of the completed and appropriately executed Permit Name/Ownership Change Form. For a
change of ownership, the certification must be signed by both the current permit holder and the new applicant.
For a name change only, the certification must be signed by the applicant.
2. Provide legal documentation of the transfer of ownership (such as a contract, deed, article of incorporation, etc.)
for ownership changes. A copy of the Association Bylaws and Declarations should be submitted for a change of
ownership to a Homeowner's Association.
3. Submit a properly executed Operation and Maintenance Agreement for all Single Family Spray/Drip Irrigation
permits requesting a change of ownership.
II. CURRENT PERMIT INFORMATION
1. Permit number: W00013516
2. Permit holder's name: International Paper Corp.
3. Permit's signing official's name and title: Anitra J. Collins
(Person legally responsible for permit)
Mill Manager
(title)
4. Mailing address: 100 Gaston Road
City: Roanoke Rapids State: NC Zip: 27870
Telephone number: ( 252 ) 533-6398
III. NEW OWNER/NAME INFORMATION
1. This request for a permit change is a result of:
Facsimile number: ( 252 ) 533-6401
X a. Change in ownership of property/company
b. Name change only
c. Other (please explain):
FORM: PNOCF 06/00
Page I of 7

•
2. New owner's name (name to be used in permit): KaDStone Kraft Paper Corporation
3. New owner's or signing official's name and title: Anitra J. Collins
(Person legally responsible for permit)
Mill Manager
(title)
4. Mailing address: 100 Gaston Road
City: Roanoke Rapids State: NC zip: 27870
Telephone number: ( 252 ) 533-6398
IV. CERTIFICATION
1. Current Permittee's Certification:
Facsimile number: ( 252 ) 533-6401
I, Anitra J. Collins attest that this application for name/ownership change has been
reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this
application are not completed and that if all required supporting information and attachments are not included,
this application package will be returned as incomplete. I understand I will continue to be responsible for
compliano
Signature:
2. Applicant's Certification:
1 Matt Kaplan , attest that this application for name/ownership change has been reviewed and is
accurate and complete to the best of my knowledge. I understand that if all required parts of this application are
not completed and that if all required supporting information and attachments are not included, this application
package wilA returned as incptgplete. ,
Signature:
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION AND
MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
NON -DISCHARGE PERMITTING UNIT
By U.S. Postal Service:
1617 MAIL SERVICE CENTER 512 NORTH SALISBURY STREET, SUITE 1219
RALEIGH, NORTH CAROLINA 27699-1617 RALEIGH, NORTH CAROLINA 27604
TELEPHONE NUMBER: [phone]
FORM: PNOCF 06/00
Page 2 of 2

Antra J. Collins
NO Manager
International Paper Co.
100 Gaston Rd.
Roanoke Rapids, NC
Dear Ms. Collins:
27870
• Michael F. Fasley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
October 2, 2006
Subject Receipt of permit renewal application
NPDES Permit NC0000752
Roanoke Rapids Mill
-6tekes County
RAI,f#X-
The NPDES Unit received your permit renewal application on October 2, 2006. A member of the NPDES Unit will
review your application. They will contact you if additional information is required to complete your permit renewal. You
should expect to receive a draft permit approximately 30-45 days before your existing permit expires. The requirements in
your existing permit will remain in effect until the permit is renewed (or the Division takes other action).
If you have any additional questions concerning renewal of the subject permit, please contact me at [phone],
extension 363.
cc �CE�N[IRALFILFS
Sincerely,
C
Carolyn Bryant
Point Source Branch
OCT 152006
tCarolina
urally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet h2o.enr.state.mc.us 512 N. Salisbury St Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Atfimratve Action Employer— 50% Regded110% Post Consumer Paper

n
u
NPDES STAFF REPORT AND RECOMMENDATIONS
for International Paper Regarding Disposal of NORM
Date: Sept 12, 2006
To: NPDES Permitting Unit
Water Quality Section
Attention: G-harles eavcr . t U /"J ^Wn
Through: Charles Wakild
Raleigh Regional Office / Surface Water Protection Section
County: Halifax
Permit No. NC0000752
Subject: Approval of Request to Dispose of Naturally Occurring Radioactive Material
(NORM) Contained Inside Discarded Pipes by Hydroblasting
PART I -GENERAL INFORMATION
Facility and Address: International Paper
P.O. Box 580
Roanoke Rapids, NC 27870
2. Date of Site Visit: — Personal knowledge of site
Report Prepared by: Myrl Nisely
4. Persons Contacted and Telephone Number:
Mary Lee Ransmeier, 252-533-6255 or Chris Puryear, 252-533-6237
Directions to Site: Rt. 48 to North edge of Roanoke Rapids
6. Attach a USGS map extract and indicate treatment facility site and discharge point
on map. Photo below
7. Topography (relationship to flood plain included): The eastern end of the
"Emergency" pond where removal is proposed is a significant distance from
papermill activity. See photo below.
NPDES Staff Report
Page I

PART II - DESCRIPTION OF PROBLEM AND PROPOSEb ACTION
Naturally Occurring Radioactive Material (NORM) is deposited in piping that has transported
river water for many years, and is then eventually removed from within the papermill. Scale
gradually accumulates in some piping over many years. The alpha radiation emitted from
thorium and uranium carbonates is very weak, and occurs only in a short lengths of the pipes.
The company proposes hydroblasting (use of a high energy water jet) inside the pipes, with the
discharge going into the end of an emergency spill pond most distant from the production
facility. The blasting is expected to re -dissolve the scale. But if flakes are dislodged that do not
dissolve, they will become immobilized in the solids on the bottom of the pond. On the
infrequent times that water is pumped back into the wastewater plant from this pond, the pickup
point is at the opposite end of the pond. The returning flow would be slowly added to the 14
MGD typically coming from the papermill to the bar screen. Therefore, the NORM containing
water would be greatly diluted.
There is no concern over radiation for workers doing the hydroblasting. They will wear
protective clothing to protect breathing and to keep water from their skin.
PART IH - OTHER PERTINENT INFORMATION
Photo of pond and proposed working site:
NPDES Staff Report
Page 2

0
PART IV - EVALUATION AND RECOMMENDATIONS
This removal of NORM is a one-time event, needed as a condition in the sale of the papermill.
There is no reason to modify wastewater permit NC0000752 in which the emergency pond is a
component. The attached letters from the Radiation Protection Section and the Division of Solid
Waste Management indicate approval by those agencies.
I recommend that permission be granted for this process. There is not expected to be any damage to
the environment or danger to public health.
Signature oA report preparer
9// z/0 6
Water Quality Regional Supervisor Date
NPDES Staff Report
Page 3

V,0;1" . 0
utvision of Environmental Healtrr State of North Carolina
Terry L. Pierce, Director Michael Easley, Governor
Department of Environment and
Radiation Protection Section Natural Resources
gyy�a Beverly O. Hall, Chief William G. Ross, Secretary
September 11, 2006
Myrl Nisely, Env. Spec. II
Division of Water Quality
Surface Water Protection
3800 Barrett Drive
Raleigh, NC 27609
SUBJECT: International Paper pipe scale containing naturally occurring radioactive material
Dear Mr. Nisely:
International Paper in Roanoke Rapids has approximately four to five cubic yards of pipe with a small amount of scale
containing naturally occurring radioactive material (NORM). In previous years, we have worked with North Carolina
State University in determining the specific activity of this scale.
A letter date July 16, 1996 signed by Ralton J. Harris, Environmental Health Physicist of North Carolina State University
documents results from gamma spectroscopic and gross alpha -beta analysis that the pipe scale contains — 0.006
microcurie per gram of the decay progeny of uranium and thorium.
Based on these results, we recommended that the Division of Solid Waste approve the disposal of the pipe containing this
scale into International Paper's on -site landfill. This was approved on July 24, 1996 in a letter signed by William L.
Meyer.
International Paper on -site landfill was closed and they began storing this pipe with scale containing NORM on -site for
several years. International Paper realized this waste stream would continue to grow so they implemented a procedure to
remove any scale prior to removal of any pipes from the plant and the waste water generated from this activity to be
distributed to the settling pond. Since this new procedure was implemented, it is my understanding that it has solved their
pipe scale problem.
This four to five cubic yards of pipe with scale containing NORM is still being stored on -site at International Paper. We
recommend that the Division of Water Quality, Surface Water Protection approve International Paper to remove the pipe
scale into their settling pond.
Sincerely,
Wendy B. Tingle, Health Physicist
Radioactive Waste Coordinator
Radioactive Materials Branch
Cc: Mary Lee Ransmeier, Environmental Manager
International Paper
100 Gaston Road, Roanoke Rapids, NC 27870
1645 Mail Service Center, Raleigh, North Carolina 27699-1645 None Carolina
Phone [phone] / Fax [phone]
http:/hvww.ncradiation.net Nationally
An Equal Opportunity / Affirmative Action Employer

State of North car.,... �a
Department of Environment,
Health and Natural Resources A
� 0
Division of Solid Waste Management
r k
James B. Hunt, Jr., Governor p FEE N F
Jonathan B. Howes, Secretary
William L. Meyer, Director
July 24, 1996
Chris Puryear
Champion International
P.O.Box 580
North Roanoke Avenue
Roanoke Rapids, NC 27870
RE: Pipe Scale Management
Dear Mr. Puryear
The Division of Waste Management appreciates Chapion International's intent and attempts to
recycle the pipe scale before considering disposal.
The Division approves disposal of approximately three to four cubic yards (1,000 lbs) of pipe
scale containing 0.006 microcuries/gm uranium and thorium in the on -site landfill, permit number
4203.
If we can be of further assistance, please contact Ben Barnes, Waste Management Specialist,
in the Raleigh Regional Office at 919/571-4700.
Sincerely, � J
William L. Meyer
cc: Ben Barnes
Wendy Tingle, RPD
Phil Prete
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affvmative Action Employer 50%recycled/ 1 o%post-consumer paper

'. North Carolina State University
Environmental Health and Safety Center
Office of Finance and Business
Box 8007 Director
Raleigh, NC 27695 Environmental Affairs
FAX (919) 515-M Industrial Hygiene
Health and Safety
Radiation Protection
16 July 1996
Mr. John Erdmann
Champion International Corp.
North Roanoke Avenue
P.O. Box 580
Roanoke Rapids, NC 27870
Dear Mr. Erdmann :
515-4238
515-8859
515-M
515-M
5155207
Enclosed are the results of the gamma spectroscopic and gross alpha -beta
analysis performed on the filter paper and clay nodules which I received
from you. In brief, your samples contain the decay progeny of the U-238
and Th-232 series. The specific activity of the clay is - 0.006 microCurie
per gram.
Since this analysis was performed at the request of Ms. Wendy Tingle of
the State of N.C. Division of Radiation Protection, I am sending a duplicate
of these results to her office.
Sincerely,
Ralton J. Harris
Environmental
Health Physicist
xc: Ms. Wendy Tingle
Attachments
North Carolina State University is a (and -grant university and a constituent institution of The Unversity of North Carolina.

IU C 0o0v
INTERNATIONAL@ PAPER
April 12, 2006
Matt Mathews
Aquatic Toxicology Unit
DWQ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, N.C. 27699- 1621
Dear Mr. Mathews
1�Z
ROANOKE RAPIDS MILL
100 GASTON ROAD
ROANOKE RAPIDS, NC 27870
PHONE: [phone]
Per a request made by Mr. Myrl Nisely of the Raleigh DWQ regional office I am
sending you information relating to a chemical we plan to use in our wastewater effluent
for foam control. International Paper Company has developed strategic alliances with
several chemical manufacturers which offer economic benefits over previous suppliers.
The defoamer that we presently use in our effluent is Callaway A187 made by Vulcan
Performance Chemicals. The 48 hour LC50 for Ceriodaphnia Dubia when using the
Vulcan material is greater than 500 mg/l. The replacement for the Vulcan chemical is
manufactured by Betz Chemical (Foamtrol 3560) and has a LC50 of 420 mg/l. When
using the Vulcan product the maximum application rate was approximately 300 mUmin.
The Betz product appears to be more efficient than the Vulcan material but if we have to
feed at the same 300 ml/min rate the maximum concentration in the river should not be
greater than 5.7 mg/l. This is based on a minimum river flow of 1000 (dam permit).
Attached you will find a copy of the toxicity test report conducted on the Betz/Hercules
Foamtrol AF 3560. If you have any questions, please feel free to contact me at (252)
533-6237 or email me at chris.purvear@ipar)er.com.
Sin ly,
Chris Puryear
Environmental Engineer III
xc: Paul Kinnin
Neal Davis
Mary Lee Ransmeier
Myrl Nisely (Raleigh DWQ office)

Sb t ca.r.M K Ld
118 Nkhdas Beater Road RR3
Guelph ON NIH 6H9
Tef (519) 7634412 F¢ (519) 7634419
sfattEee.Corn
Work Order: 208929
Sample Number: 14867
TOXICITY TEST REPORT
Ceriodaphnia dubia
Page 1 of 2
SAMPLE IDENTIFICATION
Company: Hercules Incorporated Sample Ty
pe: : Chemical
Location: Wilmington DE Date Submitted : 2006-01-31
Substance: Foamtrol AF3560 Date Received: 2006-01-31
Submitted By: W. Hartgrove Date Tested: 2006-02-15
Sample Description: Opaque white liquid
Test Method: U.S. EPA Office of Water, 2002. Methods for Measuring the Acute Toxicity of Effluent
and Receiving Water to Freshwater and Marine Organisms. Fifth Edition.
EPA-821-R-02-012, modified for chemical testing by Stantec.
TEST RESULTS
Effect Result 95%Confidence Slope Calculation Method
48-h LC50 420 mg/L 368 - 481
48-h EC50 354 mg/L 250 - 500
The results reported relate only to the sample tested.
SODIUM CHLORIDE REFERENCE TOXICANT DATA
Organism Batch:
Cd06-02
Date Tested (y/m/d) :
2006-02-09
Test Duration :
7 days
Analyst(s):
RD/KI/AS/SW
Spearman-Karber
Binomial
IC25 Survival :
1.38 g/L
95% Confidence Limits:
0.90-1.56
Historical Mean IC25:
1.23 g/L
Warning Limits (t 2SD) :
0.80 - 1.93
Statistical Method:
Linear Interpolation
PREPARATION OF TEST SOLUTIONS
Testing followed the general conditions of the test method cited above, with modifications appropriate for the testing
of chemicals. A 1000 mg/L stock solution was prepared by diluting the test substance with control/dilution water.
Appropriate amounts of the stock were diluted with control/dilution water to achieve the remaining exposure
concentrations. Test solutions were mixed thoroughly prior to test initiation. Replicate data were pooled to calculate
the reported results.
Test Organism:
Source :
Organism Batch:
Life Stage (on Test Day 0)
Sample Treatment
pH Adjustment:
Ilardness Adjustment:
Test Aeration :
TEST CONDITIONS
Certodaphnia dubia
Stantec in-house culture
Cd06-02
Neonate (Q4 hours old)
None
None
None
None
Test Vessel:
Volume per Replicate:
Organisms per Replicate
Replicates per Test Level
Organisms per Test Level
Organism Loading Rate:
Photoperiod(h):
Feeding During Test:
Control/Dilution Water.
50 mL Pyrex beaker
50 mIJorganism
10
20
5 mIJorganism
16 light / 8 dark
None
Well water (no chemicals added)
Date:�2�6 —02 —13 Approved by:
Proj t Manager

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[Fwd: ATC]
Subject: [Fwd: ATC]
From: Myrl Nisely <[e-mail]>
Date: Fri, 17 Mar 2006 11:04:40 -0500
To: Myrl Nisely <[e-mail]>
CC: Judy Garrett <[e-mail]>
� •wC 00007S�
The old meter measures velocity for a specific sized pipe. There is turbulence at that location. The
new meter will also measure velocity with 5 sensors around the pipe, and averages the values. The
new location should provide better reading with laminar flow and a smaller pipe diameter so that
velocity is faster.
Tom Belnick and I advise that this is a Replacement in Kind change that will not require an AtC.
The defoamer is added after the Toxicity sampling site. Chris Puryear recognized the need to
document any toxicity threat from the new defoamer, so has had comparative tox tests run. The new
one showed slightly less tox (LC50 of 493 mg/l vs. 500 mg/l for the old defoamer). He will mail a
letter to RRO repo mg this study.
Myrl Nisely ► of 0
------- Original Message--------
Subject:ATC
Date:Thu, 16 Mar 2006 17:32:29 -0500
From:Chris Puryear <Chris.Puryear(aDipaper.com>
To:Myrl Nisely <myrl.nisely(a,ncmail.net>
CC:Neal Davis <Neal.Davispipaper.com>
Myrl,
We finally convinced management that we need to relocat our effluent
flowmeter downstream from the gate valve. We want to install a multi
sensor velocity flow meter made by Marsh McBirney. Do we need a ATC before
we can install it? I almost forgot to ask. Our present meter (as you
know) is before the effluent gate valve and right before the line reduces
from 54 inches to 36 inches. We want to replace our existing single sensor
velocity probe with a multi -sensor unit and place it about 10 pipe
diameters downstream from the flow meter. We know the pipe flows full and
the flow should be laminar in that location. Also we have switched
defoamer suppliers (corporate edict) so who do I need to call about
switching defoamers? Sorry to bother you but thanks for your help.
Chris.
Myrl A. Nisely
Environmental Chemist II
NC DENR - Div. Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Telephone: [phone] or x4255
Fax: [phone]
myrl.nisely®ncmail.net
1 of 1 3/17/2006 11:05 AM

Antra J. Collins
Mill Manager
International Paper Co.
100 Gaston Rd.
Roanoke Rapids, NC
Dear Ms. Collins:
27870
October 2, 2006
J'- 67 Michael F. Easley, Governor
William G. Ross Jr., Secretary
00, Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
OCT 0 5 2006
A,n5wr5aa—
Reg.o�at Office
Subject: Receipt of permit renewal application
NPDES Permit NC0000752
Roanoke Rapids Mill
The NPDES Unit received your permit renewal application on October 2, 2006. A member of the NPDES Unit will
review your application. They will contact you if additional information is required to complete your permit renewal. You
should expect to receive a draft permit approximately 30-45 days before your existing permit expires. The requirements in
your existing permit will remain in effect until the permit is renewed (or the Division takes other action).
If you have any additional questions concerning renewal of the subject permit, please contact me at [phone],
extension 363.
cc: CENTRAL FILES
Raleigh Regional Office/Surface Water Protection
NPDES Unit
PlU 9
Sincerely,
CU.'Xzw
Carolyn Bryant
Point Source Branch
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617
Internet h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 2709
An Equal OpportuOylAt ffredNe Action Employer —50%Reryded110% Post Consumer Paper
rT
tCarolina
ura!!il
Floe [phone] Customer Service
FAX [phone]D-6748

INTERNATIONAL@ PAPER
September 25, 2006
Mr. Charles Weaver
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, N.C. 27699- 1617
Attn: Carolyn Bryant
re: Renewal Notice
NPDES Permit No. NC0000752
Roanoke Rapids Mill
4Wifax County,*
Dear Mr. Weaver:
ROANOKE RAPIDS MILL
100 GASTON ROAD
ROANOKE RAPIDS, NC 27870
PHONE: [phone]
GkuvLt
LO
pu - 2 06
Pursuant to Federal (40 CFR 122.41) and North Carolina (15A NCAC 2H.0105(e))
regulations NPDES permit renewal applications must be submitted at least 180 days
prior to the expiration of the existing permit (March 31, 2007). The Purpose of this
correspondence is to request renewal of NPDES Permit No. 0000752 for the
International Paper mill I N 'in Roanoke Ra #North Carolina. Enclosed you will
find the following information (one original and two copies):
• EPA Form 3510-1 (General Information Form)
• Topographic Map of Mill Site and Discharge Points
• Application Form 2C — Wastewater Discharge Information
• Mill Water Balance Diagram
• Wastewater Treatment System Diagram
• Wastewater Treatment System Narrative Description
• Sludge Management Plan Narrative Description
• Results of Priority Pollutant Analysis
• Results of Analysis Required under Part V-B and V-C of Form 2C
If you have any questions regarding the permit renewal application please don't
hesitate to call Mary Lee Ransmeier at 252-533-6255 or Chris Puryear at 252-533-
6237.
Sincerely,
�Anitra .Collins
Mill Manager
xc: Neal Davis
Mary Lee Ransmeier
Chris Puryear
Paul Kinnin (w/o attachments)

International Paper, Roanoke Rapids Mill
NPDES Permit NCO000752 Renewal Application
Table of Contents
EPA Form 3510-1 (General Information Form)
Topographic Map of Mill Site and Discharge Points -
Application Form 2C — Wastewater Discharge Information -
General Facility/Outfall Information
Outfall 001
Outfall 002
Outfall 003
Mill Water Balance Diagram -
Wastewater Treatment System Diagram -
Wastewater Treatment System Narrative Description
Sludge Management Plan Narrative Description —
Results of Priority Pollutant Analysis -
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Results of Analysis Required under Part V-B and V-C of Form 2C -

Please print or type in the unshadO . ems of'
(fill-in areas are spaced for elite fvc 12 ctarUnrh)
For Appr," , O lo. 2040.0086. ADDroval expires 5-31-92
FORM U.S. ENVIRONMENTAL PROTECTION A
I. EPA I.D. NUMBER
GENERAL INFORMA N
1
5
F NCDO44737807
T/A
C
D
\-EPA Consolidated Permits Program
GENERAL (Read the "General Instructions" before starting.)
1
2 13
1 14
15
LABEL ITEMS - - --
GENERAL INSTRUCTIONS
1. EPA I.D. NUMBER
If a preprinted label has been provided,
affix It in the designated space. Review the
information
carefully; it any of it is
III. FACILITY NAME
incorrect cross through it and enter the
correct data in the appropriate fill-in area
below. Also, if
any of the preprinted data is
absent rthe area to the left of the label
V. FACILITY PLEASE PLACE LABEL IN THIS SPACE
space lists se information that should
provideit in
MAILING LIST
in arearsjlbelow fvtthhe ispcomepflete
and correct you need not complete Items
I, 111. V, and VI(except VI-B which must be
VI. FACILITY
completed regardless). Complete all items
if no label has been proved. Refer to the
LOCATION
instructions for detailed item descriptions
and for the legal authorization under which
this data is collected.
II. POLLUTANT CHARACTERISTICS
Complete A through to etermine whether you nee to submit any permit application orms
to the PA. I you answer 'yes.. to any
questions, you must submit this form and the supplemental from listed in the parenthesis following the question.
Mark'X' in the box in the third column if
the supplemental torn is attached. If you answer 'no" to each question, you need not submit any of these fortes.
You may answer 'no' t your activity is
excluded from rmit r uirements; see Section C of the instructions. See also Section D of the instructions
for definitions of bold-faced terms.
SPECIFIC QUESTIONS
MARK X.
SPECIFIC QUESTIONS
MARK'X'
FORM
FORM
YES
NO
ATTACHED
YES
NO
ATTACHED
A. Is rs auhty a publicly owned treatment works
Does or wi th s facility (ed err ewsling or
which results in a discharge to waters of the
❑
)(
❑
proposed) Include a conce 18d animal
❑
X
❑
U.S.? (FORM 2A)
feeding operation or aquatic animal
production facility which results in a discharge
to waters of the U.S.? (FORM 28)
to
17
to
19
20
21
C. Is this facility which currently resu to in
X
X
s this proposal acihty ( er Man those described
X
discharges to waters of the U.S. otter than
in A or B above) which will result In a discharge
those described in A or B above' FORM 2C
22
23
24
to waters of the U.S.? FORM 2D
25
26
27
s or wal t is aci ty treat, store, a tllspose
you or wal you inject at Mrs acdiry iMustrial or
hazardous wastes? (FORM 3)
❑
X
❑
municipal effluent below the lowermost stratum
❑
X
❑
containing, within one quarter mile of the well
bore, underground sources of drinking water?
(FORM 4)
28
29
30
31
32
33
you or will you at this laa9ty any
o you or will you inject at this facility fluids for
fin
produced water other fluids which are brought to
tie surface in connection with conventional oil or
❑
X
❑
special processes such as mining of suffer by the
Frasch in
process, solution mining of minerals,
X
❑
natural gas production, inject fluids used for
situ combustion of fossil fuel, or recovery of
enhanced recovery of oil or natural gas, or inject
geothermal energy? (FORM 4)
fluids for storage of liquid hydrocarbons?
FORM 4
34
35
38
37
38
39
I. Is this aclilty a propose eta ovary source s his facility a proposed slat onary source
which is one of the 28 industrial categones listed which is NOT one of the 28 industrial categories
in the instructions ❑ X ElEl
❑
and which will potentially emit listedin the instructions and which will potentially
100 tons per year of any air pollutant regulated emit 250 tons per year of any air pollutant
under the Clean Au Act and may affect or be regulatetl under the Clean Air Aq antl may atea
4a 45
located in an atafnmenl areal FORM 5 40 a 42 or be located in an attainment are? FORM 5 43
III. NAME OF FACILITY
o SKIP International Paper, Roanoke Rapids Mill
1
t5 1629 3o s9
IV. FACILITY CONTACT
A. NAME & TITLE last, first, & title B. PHONE area code & no.
C Puryear, Chris, Environmental Engineer///
252 533 6237
2
46 48 1 49 51 1 52 55
15 1 16 45
V. FACILITY MAILING ADDRESS
A. STREET OR P.O. BOX
D. ZIP CODE
27870
100 Gaston Road
s
IS
1 15 45
B. CITY OR TOWN
C. STATE
Ea Roanoke Rapids NC
is 1 18 40 41 42 1
47 51
VI. FACILITY LOCATION
A. STREET ROUTE NO. OR OTHER SPECIFIC IDENTIFIER
C
100 Gaston Road
5
15
1 1s 45
B. COUNTY NAME
Halifax
4570
C. CITY OR TOWN
D. STATE
I E. ZIP CODE
F. COUNTY CODE
s
Roanoke Rapids
NC
27870
11
15 1
18 40
tl 62
47 51
52 51
EPA FORM 3510.1 (8.90)
CONTPIUED ON REVERSE

CONTINUED FROM THE FRONT
VII. SIC CODES 4-di it, in of
A B. SECOND
C 26 (specify)
7 2611 (specify)
s Paper and Allied Products
s Pulp Mill
,e 17
,a a
C. THIRD D. FOURTH
c 2621 (specify) 7 2631 (specify)
Paper mill Paperboard Mill
19 78 17 Is 1e 19 1
Vlll. OPERATOR INFORMATION
A. NAME B. Is the name listed In Item
C International Paper Company VIII-A also the owner?
B
X YES E] NO
19
19 yr
C. STATUS OF OPERATOR Enter the appropriate letter into the answer box; if 'Other,'s eci
D. PHONE area code 8 no.
F = FEDERAL M = PUBLIC (other than federal or state) P
(specify)
c
252
533
6000
A
S = STATE O = OTHER (speciy)
P=PRIVATE 58
15
7s Is
1g 27 1
22 25
E. STREET OR PO BOX
100 Gaston Road
26 55
F. CITY OR TOWN
G. STATE H. ZIP CODE IX. INDIAN LAND
c
Roanoke Rapids
NC 27870 Is the facility located on Indian lands?
B
az 42 a s1 E] YES X NO
15 16 a
X. EXISTING ENVIRONMENTAL PERMITS
A. NPDES (Discharges to Surface Water
D. PSD Air Emissions from Proposed Sources
9
N
I NC0000752
s P°
15 78 1 17 1 19 30
15
18
171 18 30
B. UIC (Underground Injection of Fluids
E. OTHER s 1
(Specify)
Storm Water
c
I T
I
°
°
Air Ouality (01649T34)
9
s
u
(NCS000106
15
IB
17
19 70
15
18
17
la 30
C. RCRA Hazardous Wastes E. OTHER (specify) (specify)
c T ° ° Landfill (W00000436) Land Application
9 R T7 18 30 75 78 17 18 JO (W00013516)
XI. MAPim
Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must
show the outline of the facility, the location of each of its existing and proposed intake and discharge structures, each of its
hazardous waste treatment, storage, or disposal facilities, and each well where it injects fluids underground. Include all springs,
rivers and other surface water bodies in the map area. See instructions for precise requirements.
XII. NATURE OF BUSINESS(provide a brief description)
The International Paper, Roanoke Rapids mill produces high quality unbleached Kraft paper and
paperboard. The mill is integrated including power generation, chemical recovery, pulp production and final
paper and paperboard manufacture.
XIII. CERTIFICATION see instructions
I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and
all attachments and that, based on my inquiry of those persons immediately responsible for obtaining the information contained in
the application, I believe that the information is true, accurate and complete. I am aware that there are significant penalties for
submitting false information, including the sibili of fine and timprisontrieffl.-N
A. NAME & OFFICIAL TITLE (type or print) B. SIG RE
C. DATE SIGNED
Anitra J. Collins, Mill Manager tiv\,
-1 —aG C-6�
COMMENTS FOR OFFICIAL USE ONLY
c
C
15
16 55
EPA FORM 3510-1 (8-90)

Appendix A

Appendix B

C�
Please print or type in the unshaded areas only
EPA I.D. NUMBER (rnpi-f or Item l of i nit l) Form Approved.
NCD044737807 OMB No. 2040-0086.
dmmrnoet a..;_ a_11 m
FORM
2C
NPDEB
L OUTFALI LOCATION
U.S. ENVIRONMENTAL PROTECTION AGENCY
APPLICATION FOR PERMIT TO DISCHARGE WASTEWATER
.EPA EXISTING MANUFACTURING, COMMERCIAL, MINING AND SILVICULTURE OPERATIONS
Consobdafed Permits Program
For each oudall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
A OUTFALL NUMBER
B. LATITUDE
C. LONGITUDE
D. RECEIVING WATER (name)
1. DEC.
2. MIN.
3. SEG.
1. DEC.
2. MIN.
a. SEC.
01
N36
28
18.6
W77
38
12.8
Roanoke River
02
N36
28
18.8
W77
38
20.5
Roanoke River
03
N36
28
41.0
W77
38
30.4
Roanoke River
II. FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES
A. Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater to the effluent, and treatment units
labeled to correspond to the more detailed descriptions in Item B. Construct a water balance on the line drawing by showing average flows between intakes, operations,
treatment units, and outlalls. If a water balance cannot be determined (e.g., for certain mining activdres), provide a pictorial description or the nature and amount of any
sources of water and any collection or treatment measures.
B. For each oudall, provide a description of: (1) All operations contributing wastewater to the affluent, including process wastewater, sanitary wastewater, cooling water,
and storm water runoff; (2) The average flow contributed by each operation; and (3) The treatment received by the wastewater. Continue on additional sheets if
races sary.
i. OUT.
2. OPERATION(S) CONTRIBUTING FLOW
3. TREATMENT
FALL
NO. (/&I)
a. OPERATION (list)
b. AVERAGE FLOW
(include units)
a. DESCRIPTION
b. LIST CODES FROM
TABLE 2C4
001
Condensateen Collection
o.r xoo
ear scre
1_z
ping Kill Area
1.2 HGD
Primary Clarification
1-u
papermill uea
8.0 tt®
ration Food
3-e
utility Area
5.3 Koo
stabilization Pan
3-G
Defoamer addition
AA
Di.chatge to River
4-A
sludge Neutralisation
rr
cbeeical conditioning
5-H
Rotary screen thickener
5-L
sorer Preesee
sludge Ggoon
s-T
GMfill
e-Q
oil water separator
Zx
002
H+c svaporator cool" water
1.85 Map,
single Pas. akin -contact. Np l esteem
003
Turpentine Condenaor cooling water
3 95 Map
Pa.. Non-contaet, No reateent
t
OFFICIAL USE ONLY (¢/fluent yuidelims sub-ruragories)
EPA Form 3510-2C (8-90) PAGE 1 of 4 CONTINUE ON REVERSE

0
CONTINUED FROM THE FRONT
C. Except for sto mm runoff, leaks, or spills, are any of the discharges described in Items II -A w 8 intermittent or seasonal?
❑ YES (romp/ete the /olloMing (able) m NO (go tP sm.. III)
3. FREQUENCY
4, FLOW
0, DAYS PER
B. TOTAL VOLUME
2. OPERATION(a)
WEEK
b. MONTHS
a. FLON RATE (m mg,h
btnrA niN vniu)
1. OUTFALL
NUMBER (It,,)
CONTRIBUTING FLOW
(hn)
Iron, "b'
vruXA
PER YEAR
Gpn,h m.'rnxe)
C. DURATION
1. LONGTERM
2. MtUQMUM
1, LONGTERM
2. MAXIMUM
AVERAGE
DAILY
AVERAGE
DAILY
0.4 ")
III. PRODUCTION
A. Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility?
® YES (,..plate hem //1-B) ❑ NO (go ro Seerian lV)
B. Are the limitations in the applicable effluent guideline expressed in terms of production (or other measure of operationp
m YES (mmplem Oem lI/-Q ❑ NO (go m Seerion IV)
C. If you answered -Yes- to Item III-B. list the quantity which represents an actual measurement of your level of production, expressed in the terms and units used in the
applicable effluent guideline, and indicate the affected outhalls.
1. AVERAGE DAILY PRODUCTION
2, AFFECTED OUTFACES
(but oatfall numhers)
a. QUANTITY PER DAY
b. UNITS OF MEASURE
c. OPERATION, PRODUCT, MATERIAL, ETC.
(rvNih')
1158.91
Tons
Unbleached Kraft Paper
001, 002, 003
IV. IMPROVEMENTS
A. Are you now required by any Federal, State or local authority to meet any implementation schedule for the construction, upgrading or operations of wastewater
treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited to,
perm t conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations. court orders, and grant or ban conditions.
❑ YES (romplae rhe/ollawing table) ❑ NO (gn m It,. IV-B)
1. IDENTIFICATION OF CONDITION,
AGREEMENT, ETC.
2. AFFECTED OUTFALLS
3. BRIEF DESCRIPTION OF PROJECT
4. FINAL COMPLIANCE DATE
a. NO.
b. SOURCE OF DISCHARGE
a. REWIRED
b. PROJECTED
B. OPTIONAL: You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect your
discharges) you raw have underway or which you plan. Indicate whether each program is now underway or planned, and indicate your actual or planned schedules fw
construction.
❑ MARK -X- IF DESCRIPTION OF ADDITIONAL CONTROL PROGRAMS IS ATTACHED
EPA Form 3510-2C (8-90) PAGE 2 of 4 CONTINUE ON PAGE 3

EPA I.D. NUMBER (ooPr/mm Item I a/Farm 1)
CONTINUED FROM PAGE 2 NCD044737807
V. INTAKE AND EFFLUENT CHARACTERISTICS
A. B. 8 C. Sea instructwns before proceeding - Complete one set of tables for each outfall -Annotate the oudall number in the space provided.
NOTE. Tables V-A, V-8, and V-C are included on separate sheets numbered V-1 through V-9.
D. Use the space below to list any of the pollutants listed in Table 2c-3 of the instructions, which you know or have reason to believe is discharged or may be discharged
from any curtail. For every pollutant you list, briefly describe the reasons you believe it to be present and report any analytical date in your possession.
1.POLLUTANT
2. SOURCE
1.POLLUTANT
2. SOURCE
VI. POTENTIAL DISCHARGES NOT COVERED
BY ANALYSIS
Is any pollutant listed in Item V-C a substance
❑ YES (list ell sueh pallurenn
or a component of a substance which you
heM.,) m NO
currently use or manufacture as an intermediate
(go rn /reni VI-H)
or final product or byproduct?
EPA Form 3510-2C (8-90) PAGE 3 of 4 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
Al. BIOLOGICAL TOXICITY TESTING DATA
Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a recanting water in
relation to your discharge within the last 3 years?
mYES (identgv the tows) and describe their purposes below) NO (go to Section Vll!)
The North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure is performed on effluent discharge 001 on
a quarterly basis (March, June, September and December).
All. CONTRACT ANALYSIS INFORMATION
Were any of the analyses reported in Item V performed by a contract laboratory or consulting firm4
® YES (lot the name. address, and telephone number of. and polletnnts analyzed by, ❑ NO (go to Section Lk)
each such laboratory or firm below)
A.NAME B.ADDRESS C. TELEPHONE D. POLLUTANTS ANALYZED
(urea rode &re.) (list)
Oxford Laboratories 1316 South 50h street 910-763-9993 Priority Pollutant scan
Wilmington, N.C. 28401
Test America 2960 Poster Creighton Road 800-565-0980 Purgeable Organic Compounds
Nashville, TN 37204 (EPA Method 624)
Acid and Base/Neutral
Extractables
(EPA Method 625)
Organochlorine Pesticides
and/or PCBs
(EPA Method 608)
r.Test 6/01 Conference Drive 919-834-6497 semivolatiles
Raleigh, NC 27607 (EPA Method 8270)
volatile Organic Compounds
(EPA Method 82608)
IX. CERTIFICATION
I certify under penalty of law that this document and art attachments were prepared under my direction or supervision in accordance with a system designed to assure that
quali personnel property gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons
directly responsible forgathering the information, the information submitted is, to the best of my knowledge and belief, bue, accurate. and complete. I am aware that there
are significant penalties for submitting false inlormation, including me possibility of fine and imprisonment fw knowing violations.
A. NAME 8 OFFICIAL TITLE (type or print) B. PHONE NO. (area e.k & tr )
Anitra J. Collins, Mill Manager [phone]
C. SIGNATU D. DATE SIGNED
C' � q-a�- o
EPA Form 3510-2C (8.90) PAGE 4 of 4

Appendix E

L
Appendix C

4:1M (�x ����� Laborator No 259 F.
1316 S. Fifth Street Page 2 of 2
Telephone: [phone] Wilmington, NC 28401
Faic 910-343-9688 NC/WW Cert p:075
www.oxfordlaboratory.com NC/DW Cart 8: 37721
Laboratory Report
WorkOrder*. 060553102
^10. Sample ID Date Sampled Time Sampled Matrix Sample Type Condition
004 FLOW TO RNER 6/6/2006 8:40 WW Composite 4 +1- 2 deg C
Analyzed
Test Performed Method Results Date Time Qualifier
EPA 8270 Semlvolatiles EPA 8270 Attached 6/12/08 8:00
Method 8260 reported under work order # 606-53807.
Reviewe by
4 � /
for Oxford Laboratory

AUb. I L LUUb 4: IdYM (Al-00 LkNO. 289 P. 4
b
C
7G3oTEST
6701 Conference Drive
Raleigh, NC 27607
Telephone: [phone]
Fax: [phone]
Laboratory Report
-- Prepared for —
MARY GODLEY
OXFORD LABS
1316 SOUTH Sth STREET
WILMINGTON, NC 28401
Page 1 of 4
NCl1NW Cert M 067
NCIDW Cert. #: 37731
Report Date: 6119/2006
Date Received: 6/8/2006
Work Order #: 060"0415
Project No.: Cust. Code: OX9793
ProjectlD: 605-53102r1 / SEMNOLATILES Cust P O.#:
No. Sample ID Date Sampled Time Sampled Matra Sample Type Condition
001 6OS-53102.4 616/2006 8:40 WW Composite 4 +/. 2 deg C
Analyzed
Test Performed Method Results Date Time Qualifier
8270 (A&B/N)
6112106 8:0a
Acenaphthens
EPA 8270C
<10 ug/L
6/12/06 8:00
1
Acenaphthylene
EPA 8270C
<10 ug/L
6/12106 8:00
j
Acetophenone
EPA 8270C
<10 ug/L
6112106 8:00
j
2-Acetylaminofluorene
EPA 8270C
<20 ug/L
6/12/08 8:00
j
4-Aminobipherryl
EPA 8270C
<20 ug/L
6/12/D8 8:00
1
Aniline
EPA 8270C
<10 ug/L
6/12/06 8:00
j
Anthracane
EPA 8270C
<10 ug/L
6112108 8:00
1
Benzo(a)anthracens
EPA 8270C
<10 ug/L
6/12103 8:00
j
Benzo(b)fluoranthene
EPA 8270C
<10 ug/L
6/12108 8:00
1
eenzo(k)fluoranthene
EPA 8270C
<10 ug/L
6/12106 8:00
j
Benzo(a)pyrene
EPA 8270C
<10 ug/L
6/12/06 8:o0
j
Benzo(g,11J)perylene
EPA 8270C
<10 ug/L
6/12106 8:00
1
Benzoic acid
EPA 8270C
<50 ug/L
6/12/0e 8:00
1
Senzyl alcohol
EPA 8270C
<10 ug/L
6/12/09 8:00
1
Benzyl butyl phthalate
EPA 8270C
<10 ug/L
6112/06 8:00
1
Bis(2-chloroethyl)ether
EPA 8270C
<10 ug/L
6/12100 8:00
j
B1s(2-chloroethoxy)methane
EPA 8270C
<10 ug/L
6112106 8;00
1
Bls(2-chlorolsopropyl)ether
EPA 8270C
<10 ug/L
6112106 8:00
j
Bis(2-othylhexyl)phthalats
EPA 8270C
<10 uglL
6/12/06 8:00
1
4-Bromophenyl phenyl ether
EPA 827DC
<10 uglL
6112/06 8;00
1
Carbazole
EPA 8270C
<10 ug/L
6/12106 8;00
It
4-Chloroaniline
EPA 8270C
<20 ug/L
6n2106 8:00
1
2-Chloron2phth2lene
EPA 8270C
<10 uq/L
G112/05 8:00
1
4-Chloro-3-methyl phenol
EPA 9270C
<10 ug/L
6/12108 8:00
1
2-Chlorophenol
EPA 8270C
<10 ug/L
6/12/06 8:00
1
4-Chlorophenyl pherryl ether
EPA 8270C
<10 ug/L
6/12/08 8:00
1
Chrysene
EPA 8270C
<10 ug/L
6112106 8:00
i
Olbenzo(a,h)anthracene
EPA 8270C
<10 ug/L
61121'06 8:00
j
Dibenzofuran
EPA 0270C
<10 ug/L
6/12106 8:00
1
DI-n-butyl phthalate
EPA 8270C
<10 ug/L
6112106 8:CO
J
3,3'•01chlorobenzidine
EPA 8270C
<20 ug/L
6/12/06 8:00
1
1,2-Dichlorobenzens
8270C
<10 ug/L
6112106 8:00
1
1,3-1)lchlorobenzene
8270C
<10 ug/L
6112/06 8:00
j
enYni.
..n .. _,.
.....,._ - --

Appendix D

NUG. 1 I. [UUO 4: IOPP HX1*01) I.AbS NC. 239 F, G
4
0
` ROOTEST'
3909 Beryl Road Page 2 of 4
Raleigh, NC 27607
Telephone: [phone] NGWW Cert. #: 067
Fax [phone] NC/DW Cert, #: 37731
No. Sample ID
001 605.53102-4
Laboratory Report
Work Order#: 0606-00415
Date Sampled Time Sampled Matrix Sample Type Conditlon
6/6/2006 8:40 WW Composite 4+/-2deg C
Analyzed
Test Performed
Method
Results
Date Time
Qualifier
2,4-01chlorophenol
EPA 8270C
410 ug/L
611210E 8:00
J
Diethyl phthalate
EPA 8270C
<10 ug/L
611210E 8:00
1
2,4-Dim ethyl phenol
EPA 827oC
<10 ug/L
6/12/06 8:00
J
Dimethyl phthalate
EPA 8270C
<10 ug/L
6112/06 8;00
J
2,4•Dinitrophenol
EPA 8270C
<50 ug/L
6112/06 8:00
1
2,4-Dlnitrotoluene
EPA 8270C
<10 ug/L
6/12106 8:00
J
2,6•Dinitrotoluene
EPA 32700
<10 ug/L
6112/06 8:00
1
Dl-n-octyl phthalate
EPA 8270C
<10 ug/L
6112106 8:00
J
Fluoranthene
EPA 8270C
<10 ug/L
6112109 8:00
1
Pluorene
EPA 8270C
<10 ug/L
6112106 8:00
J
Hexachlorobenzene
EPA 8270C
<10 ug/L
6112/06 8:00
1
Hexachlorobutadiene
EPA 3270C
<10 ug/L
6112106 8:00
J
Hexachlorocyclopentsdiene
EPA 0270C
<10 ug/L
6112/06 8:00
d
Hexachloroethans
EPA 8270C
<10 ug/L
6/12/06 8:00
J
Indeno(1,2,3-c,d)pyrene
EPA 8270C
<10 ug/L
6112/06 8:00
J
Isophorone
EPA 8270C
<10 ug/L
6112/06 8:00
J
2-Methyi-4,6-dinitrophenol
EPA 8270C
<50 ug/L
6/12/06 8:00
1
1-Methylnaphthalene
EPA 8270C
<10 ug/L
6112/06 8:00
J
2-Methyinaphthalene
EPA 8270C
<10 ug/L
6112/06 8:00
J
2-Methyiphenol
EPA 8270C
<10 ug/L
6112/06 8:00
J
3. 8 4-Methylphenol
EPA 82700
<20 ug/L
6/12/06 8:00
J
Naphthalene
EPA 8270C
<10 ug/L
6/12/06 8:00
J
2-Nitroenitine
EPA 8270C
<10 ug/L
6/12J06 8:00
J
3-Nltro2nlllne
EPA 9270C
<20 ug/L
6112/O6 8:00
J
4-NltroanOlne
EPA 8270C
<20 ug/h
6/12106 8:00
J
Nltrobenzene
EPA 8270C
c10 ug1L
W12/08 8:00
J
2-Nitrophenol
EPA 8270C
<10 ug/L
6/12/06 8:00
J
4-Nitrophenol
EPA 8270C
<10 ug/L
6/12/06 8:00
J
N-Nitrosodimethylamine
EPA 8270C
<10 ug/L
6/12106 8:00
1
N-Nitroso diphenylam Ina
EPA 8270C
<10 ug/l-
6/12/06 8:00
J
N-Nitrosodl-n-propylamine
EPA 8270C
<10 ug/L
6112I08 8:00
1
Pentachlorophenol
EPA 8270C
<30 ug/L
6/12/06 8:00
J
Phenanthrens
EPA 8270C
<10 ug/L
6/12/06 8:00
J
Phenol
EPA 8270C
<10 ug/L
6112/06 8:00
J
Pyrene
EPA 8270C
<10 ug/L
6/12/06 8:00
J
Pyridine
EPA 8270C
<10 ug/L
6/12/06 8:00
J
1,2+Trichloroberaene
EPA 8270C
<10 ug/L
6112/06 8:00
J
2,4,5-Trlchlorophenol
EPA 8270C
<20 ug/L
6112/06 8:00
1
2,4,6•Trichlorophenol
EPA 8270C
<10 ug/L
6112106 8:00
J
Extraction, 8270 Waters
EPA 3510
DONE
6/12106 8:00

AUU. 1 I. LUDO 4: ItlrM
Telephone: [phone]
Fa.)c [phone]
Reviewed by.
OMO LA6J • NO. 289 P. E
0
0
[ pT . ST
3909 Beryl Road Page 3 of 4
Raleigh, NC 27607
Laboratory Report
Work Order # 0606-00415
NCMIW Cert M. 067
NC/DW Cert M. 37731
1 cX
for TrftsA Inc.

Ll
ANALYTICAL PERSPECTIVES
26 September 2006
Fran Godley
Oxford Labs
1316 S. Fifth Street
Wilmington, NC 28401
Ph: 910.763.9793
Email: fxodim-"xfordlabontorvcom
Subject: Certificate of Results
Dear Fran;
Attached to this narrative are the analytical results you requested on the sample submitted
for the determination of 2,3,7,8-tetrachlorodibenzo p-dioxin. The insert below
summarizes the relevant information pertaining to your project. In particular, the QC
annotations bring to your attention specific analytical observations and assessments made
during the sample handling and data interpretation phases. A brief description of the
report's components is provided on the next page.
Project Information Summary
When applicable. see QC Annotations for details
Client Project No.
AP Project No.
P7074
Analytical Protocol
Method 1613B
No. Samples Submitted
1
No. Samples Analyzed
1
No. Laboratory Method Blanks
1
No. OPRs I Batch CS3
1
No. Outstanding Samples
0
Date Received
19-Sep-2006
Condition Received
Good
Temperature upon Receipt (C)
4
Extraction within Holding Time
Yes
Analysis within Holding Time
Yes
Data meet CIA/QC Requirements
Yes
Exceptions
None
Analytical Difficulties
None
2714 EXCHANGE DRIVE
WILMINGTON
NORTH CAROLINA 2840E
TEL; 910-794-1613 FAX [phone]
W W W. U LTRATRACE.COM
1/2

0
QC Annotations:
I. None.
Analytical Perspectives remains committed to serving you in the most effective manner.
Should you have any questions or need additional information and technical support,
please, do not hesitate to contact us. We wanted to thank you for choosing Analytical
Perspectives as part of your analytical support team.
Sincerely,
Todd Vilen
Project Manager
2/2

P7074 - TEQ
Project ID: General Analytical HRMS
Sample Summary
ANALYTICAL PERSPECTIVES
'
Part 1 Method 1613
Analyte
MB1_4372_DF_SPE
0609-68064
pg/L
L
2,3,7,8-TCDD
(1.21)
() = DL Reviewer
[j=EMPC -
146
Date
Is

Sample
ID: MB1_4372_DF_SPE
Method 1613
Client Data
Sample Data
Laboratory Data
Name.
OXFORD LABS
Matrix:
Aqueous
Project No.: P7074
Date Received: n/a
Project ID.
General Analytical HRMS
Weight/Volume.
1.00 L
Sample ID: 0 4372 MB001
Date Extracted: 21 Sep 06
Date Collected
n/a
pH:
5
QC Batch No.. 4372
Date Analyzed: 23 Sep 06
Analyte
Conc. (pg/L)
Split:
DL (P91L)
-
EMPC (pg/L)
Dilution: -
Qualifiers Standard
Time Analyzed: 23:19:33
ES Recoveries Qualifiers
2,3,7,8-TGDD
ND
1.21
13C-2,3,7,8-TCDD
84.9
CS Recoveries
7062,3.7,8-TCDD
110
ANALYTICAL PERSPECTIVES
. Wilmington, NC 28405
USA
Tel [phone], Toll -Free 866 846-8290 info@ultratr m
Fax [phone] w .uHrat
rw
`00101%
•

Sample
ID: 0609-58064
Method 1613
Client Data
Name:
Project ID:
Date Collected:
Analyte
2,3,7,8-TCDD
OXFORD LABS
General Analytical HRMS
18 Sep 06
Conc. (pg/L)
NO
Sample Data
Matrix:
Weight/Volume:
pH:
Split:
DL (pg/L)
1.88
Aqueous
1.00 L
7
-
EMPC (pg/L)
Laboratory Data
Project No.: P7074
Sample ID: P7074_4372_001
OC Batch No.: 4372
Dilution: -
Qualifiers Standard
13C-2,3,7,8-TCDD
Date Received: 19 Sep 06
Date Extracted: 21 Sep 06
Date Analyzed: 24 Sep 06
Time Analyzed: 1:49:59
ES Recoveries Qualifiers
47.1
CS Recoveries
37C42,3,7,8•TCDD
105
. ANALYTICAL PERSPECTIVES Wilmington, NC 28405
USA
Tel: [phone]; Toll -Free 866 846-8290 [e-mail]
Fax: [phone]
www.ultratrace.com
AP 2006 Rev. F fyG
Reviewer ....... .................. /
•
Date ...

TestAmerica
ANALYTICAL TESTING CORPORATION
September 28, 2006
Client: Oxford Labs (2860)
1316 S. 5th Street
Wilmington, NC 29401
Attn: Denise Stalvey
SAMPLE IDENTIFICATION
609-57909
2960 Foslar Creighlon Road Naa U, TN 37204. 600-765-0980 - Fax [phone]/
Work Order:
NP12163
Project Name:
Oxford Labs
Project Nbr:
609-57909
NO Nbr.
Date Received:
09/19/06
LAB NUMBER COLLECTION DATE AND TIME
NP12163-01 09/18/06 07:35
An executed copy of the chain of custody, the project quality control data, and the sample receipt form are also included as an
addendum to this report. If you have any questions relating to this analytical report, please contact your Laboratory Project Manager at
1-800-765-0980. Any opinions, if expressed, are outside the scope of the Laboratory's accredidation.
This material is intended only for the use of the individual(s) or entity to whom it is addressed, and may contain information that is
privileged and confidential. If you are not the intended recipient, or the employee or agent responsible for delivering this material to
the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this material is strictly prohibited. If
you have received this material in error, please notify us immediately at 615-726-0177.
North Carolina Certification Number: 387
The Chain(s) of Custody, 2 pages, are included and are an integral part of this report.
These results relate only to the items tested. This report shall not be reproduced except in full and with permission of the laboratory.
Report Approved By:
JDO-rv, ��,Uu
Jennifer Gambill
Project Manager
Page I of 7

TestAmerica
ANALYTICAL TESTING CORPORATION
29W Foster Creghtoo Road Nashvi0e, TN 31204 - 600465-0980' Fax [phone]
Client Oxford Labs (2860)
Work Order:
NP12163
1316 S. 5th Street
Project Name:
Oxford Labs
Wilmington, NC 28401
Project Number:
609-57909
Arm Denise Stalvey
Received
09119/0609:45
ANALYTICAL REPORT
Analyse Result Flag Units
Sample ID: NP12163-01 (609-57909 - Water) Sampled: 09/18/06 07:35
General Chemistry Parameters
Sulfite NO HTI mg/L
Dilution .Analysis
MRL Factor Date/Time Method Batch
5.00 1 09/19/06 23:00 EPA 377.1 M 6093367
Page 2 of 7

r'1
u
Test merica
ANALYTICAL TESTING CORPORATION
2960 Faster Creighton Road Nashville, TN 37204' 800-766-0980 - Fax [phone]
Client Oxford Labs (2860)
Work Order:
NP12163
1316 S. 5th Street
Project Name:
Oxford Labs
Wilmington, NC 28401
Project Number:
609-57909
Arm Denise Stalvey
Received
09119/0609:45
PROJECT QUALITY CONTROL DATA
Blank
Analyrc Blank Value Q Units Q.C. Batch Lab Number Malyzcd Date/Time
General Chemistry Parameters
6093367-BLK1
Sulftc -0,900 mg/L 6093367 6093367-BLKI 09/19/06 23:00
Page 3 of 7

Testl�merica
ANALYTICAL TESTING CORPORATION 2960 Foster Creighton Road Nashville. TN 37204.800-7654)980 - Fax [phone]N
Client Oxford Labs (2860)
Work Order:
NPI2163
1316 S. 5th Street
Project Name:
Oxford Labs
Wilmington, NC 28401
Pmject Number:
609-57909
Arm Denise Stalvey
Received
09/19/0609:45
Analytc
General Chemistry Parameters
6093367-DUPI
Sulfite
PROJECT QUALITY CONTROL DATA
Duplicate
Sample Analyzed
Orig, Val. Duplicate Q Units RPD Limit Batch Duplicated Datc,Time
NO ND mg/L 10 6093367 NP12163-01 09/19/06 23:00
Page 4 of 7

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs (2860)
1316 S. 5th Street
Wilmington, NC 2840I
Arm Dcnise Smlvey
2960 Fmtw Creighton Road Nasinallo, TN 37204 • WO-765-0980 - Fax [phone]
Work Order
NP12163
Project Name:
Oxford Labs
Pmject Number:
609-57909
Received
09/19/06 09:45
PROJECT QUALITY CONTROL DATA
LCS
Target Analyzed
Analytc Known VaL Analyzed Val Q Units °'e Rm. Range Bamh DataTime
General Chemistry Parameters
6093367-BSI
Sulfite 40.0 38.4 ug/mL 96% 90- 110 6093367 09/19/06 23:00
Page 5 of 7

0
TestAmerica
ANALYTICAL TESTING CORPORATION
2960 Foster Creighton Road Nashville, TN 37204' 800-765-0980 - Fax [phone]
Client Oxford Labs (2860)
Work Order:
1316 S. 5th Street
Project Name:
Wilmington, NC 28401
Project Number:
Ann Denise Stalvey
Received
CERTIFICATION SUMMARY
TestAmerica - Nashville, TN
Method Matrix
AIHA Nelac
EPA 377.1 M Water
N/A X
NP12163
Oxfwd Labs
609-57909
09/ 19106 09:45
North Carolina
Page 6 of 7

0
TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs(2860)
1316 S. 5tb Street
Wilmington, INC 28401
Aron Denise Stalvey
296C Faster Creighton Road Nashville, TN 37204 • 800 765-0980 - Fax [phone]
Work Order:
Project Name:
Project Number:
Received
NP12163
Oxford Labs
609-57909
09/19/06 09.45
DATA QUALIFIERS AND DEFINITIONS
HTI The holding time for this test is immediate. The laboratory measurement, therefore, may not be suitable for compliance purposes.
METHOD MODIFICATION NOTES
SulOite 377.1 M - Sulfite method modified for use of Hach method 8216.
Page 7 of 7

• • •• •• N • • • •• •• ••
1316 S. Fifth Street Page 1 of 1
Wilmington, NC 28401
Telephone: [phone] NC/WW Cert, 0: 075
Fax: [phone] NC/DW Carl. s: 37721
www.oxfordlaboratory.com
Laboratory Report
-- Prepared for --
Neal Davin
Report Date:
International Paper
Date Received:
9/7812006
100 Gaston Road
Roanoke Rapids, NC 27870
Work Order k:
0609-57909
Project No.:
Cust. Code:
IPROAN
Project ID: Flow-Br/Sulfite
09/18/06
Cust. P.O.#:
S060903375
No. Sample ID
Date Sampled
Time Sampled Matrix
Sample Type
Condition
001 FLOW TO RIVER
911812006
7:35 W W
Grab
4 +/- 2 deg C
Analyzed
Test Performed
Method
Results
Date Time
Qualifier
Bromide
EPA 300.1
0.030 mg/L
9120/06 8:00
Sulrite
Attached
9119/06 23:00
Reviewed by:
for Oxford Laboratory

TestAmerica
ANALYTICAL TESTING CORPORATION
2960 Foster Creighton Road NashviAe, TN 37204 • 800-765-0980 - Fax [phone]
September 15, 2006
Client: Oxford Labs (2860)
Work Order:
1316 S. 5th Street
Project Name:
Wilmington, NC 28401
Project Nbr.
Attu: Laurie Kelly
P/O Nbr:
Date Received:
SAMPLE IDENTIFICATION
LAB NUMBER
608-57369-1
NPH2807-01
608-57369-2
NPH2807-02
608-57369-2
NPH2807-03
Trip Blank
NPH2807-04
NPH2807
Oxford Labs
[none)
08/19/06
COLLECTION DATE AND TIME
08/18/06
08/18/06 10:45
08/18/06 10:45
08/18/06
An executed copy of the chain of custody, the project quality control data, and the sample receipt form are also included as an addendum
to this report. If you have any questions relating to this analytical report, please contact your Laboratory Project Manager at
1-800-765-0980. Any opinions, if expressed, are outside the scope of the Laboratory's accredidation.
This material is intended only for the use of the individual(s) or entity to whom it is addressed, and may contain information that is
privileged and confidential. If you are not the intended recipient, or the employee or agent responsible for delivering this material to the
intended recipient, you are hereby notified that any dissemination, distribution, or copying of this material is strictly prohibited If you
have received this material in error, please notify us immediately at 615-726-0177.
Additional Laboratory Comments:
Revised 15 Sept 06: Benzidine added to sample NPH2807-02.
North Carolina Certification Number: 387
The Chain(s) of Custody, 9 pages, are included and are an integral part of this report.
These results relate only to the items tested. This report shall not be reproduced except in full and with permission of the laboratory.
Report Approved By:
b�UAL /' �n�
Roxanne Connor
Senior Project Manager
Page I of24

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs(2860)
1316 S. 5th Street
Wilmington, NC 28401
Ann Laurie Kelly
Analyte
2960 Faster Creighton Road Nashville. TN 37204 •800465-0980' Fax [phone]
Work Order:
NPH2807
Project Name:
Oxford Labs
Project Number:
[none]
Received:
08/ 19/06 08:00
ANALYTICAL REPORT
Result Flag Units
Sample ID: NPH2807-01 (608-57369-1 - Water) Sampled: 08/18/06
Purgeable Organic Compounds by EPA Method 624
Acrolein
NO
ug(L
Acryloninile
ND
ug/L
Benzene
ND
ug/L
Bromobenzene
NO
ul/L.
Bromochloromethane
ND
ug/L.
Bromodichloromethanc
ND
ug/L
Bromofonn
NO
ug/L
Bromomethane
ND
ug/L
n-Butylbenzene
NO
ug/L.
sec-Butylbenzene
NO
ug/L
tert-Butylbenzene
NO
ug(L
Carbon disulfide
ND
ug(L
Carbon Tetrachloride
NO
ug/L
Chlorobenzene
ND
ug(L
Chlorodibromomethane
ND
ug(L
Chlomethane
ND
ug/L
2-Chloroethylvinyl ether
ND
ug(L
Chloroform
NO
ug(L
Chlwomethane
ND
ug(L
2Chlomtoluene
NO
U91L
4Chlorotoluene
NO
ug(L
1,2-Dibromo-3-chloropropane
NO
ug(L
1,2-Dibromoethane (EDB)
NO
ug/L
Dibromomethane
ND
ug/L
12-Dichlorobenzene
NO
ug/L
1,4-Dichlombenzene
NO
ug/L
1,3-Dichlorobenzene
NO
ug/L
Dichlorodifluoromethane
NO
ug/L
1.2-Dichlomethane
ND
ugh
I,1-Dichlomethane
ND
ug(L
cis-1,2-Dichloroethene
ND
ug(L
trans-1,2-Dichloroethene
NO
ug(L
1,2-Dichlomethene (total)
ND
ug/L
I,I-Dichloroethene
NO
ug/L
1,2-Dichlompropane
NO
ug/L
1,3-Dichloropropane
ND
ug/L
2,2-Dichloropropene
ND
ug/L
cis-1.3-Dichloropropene
NO
ug/L
trans-1,3-Dichloropropene
NO
ug(L
LI-Dichloropropene
ND
ug(L
Ethylbenzene
NO
ug(L
Hexachlorobutadicne
ND
ug(L
Isopropylbenzene
NO
ug(L
Dilution Analysis
MRL Factor Date/Time Method Batch
%0
1
08/24/06 03:46
EPA 624
6084428
10.0
1
08/24/06 03:46
EPA 624
6094428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/0603:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/0603:46
EPA 624
6084428
1.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
5.00
1
0824/0603:46
EPA 624
6084428
1.00
1
0824106 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6094428
1.00
1
08/24/06 03:46
EPA 624
6094428
1.00
1
08/2410603:46
EPA 624
6084428
5.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
08/24/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
2.00
1
0824/06 03:46
EPA 624
6084428
1.00
1
0824/06 03:46
EPA 624
6084428
Page 2 of 24

Tes tAmerica
ANALYTICAL TESTING CORPORATION
29W Foster Creighton Road Nashville, TN 37204 '800-765-0980' Fax [phone]/
Client Oxford Labs (2860)
Work Order:
NPH2807
1316 S. 5th Street
Project Name:
Oxford Labs
Wilmington, NC 28401
Project Number:
[none]
Arm Laurie Kelly
Received:
08/19/0608:00
ANALYTICAL REPORT
Analyte Result Flag Units
Sample ID: NPH2807-01 (608-57369-1- Water) - coat. Sampled: 09/19/06
Purgeable Organic Compounds by EPA Method 624 - cont.
p-Isopropyholuene
NO
ugh
Methyl ten -Butyl Ether
ND
ug/L
Methylene Chloride
NO
ug(L
Naphthalene
ND
ug/L
n-Propylbenzene
NO
ug/L
Styrene
NO
ug/L
1, 1, 1,2-Tetrachlomedume
NO
ug/L
1, 1.2,2-Tetmchlomethane
ND
ug/L
Tetrachlomethene
NO
ug/L
Toluene
NO
ug/L
1,2,3-Trichlombenzwe
NO
ug/L
1,2,4-Trichloroben me
ND
ug/L
1,1,2-Trichlomethane
NO
ugh
1,1,1-Trichloroethane
NO
ug/L
Trichlomethcne
ND
ug(L
Trichlorollumomethane
NO
ugh
1,2.3-Trichlompropane
NO
ug/L
1, 1,1-Trichlomtri0uormthme
NO
ug/L
05-Trimethylbenzene
NO
ug/L
1,2,4-Trimethylbenzcne
NO
ug/L
Vinyl acetate
NO
ug/L
Vinyl chloride
NO
ug/L
o-Xylcne
NO
ug/L
m,p-Xylme
ND
ug/L
Xyleies, total
NO
ug/L
Surf: 1,2-Dichloroethane-d4 (81-11646)
107 %
Sun: Di6romoJluoromethane (88-12096)
104 %
Sun: Toluene-d8 (85-1300A)
100 %
Sum 4-8romoJluorobenzene(80-124%)
103 %
urM,
1.00
1.00
5.00
5.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
2.00
1.00
1.00
5.00
1.00
1.00
1.00
2.00
Dilution Analvsis
Factor Dale/Time Method Batch
1 08/24/06 03:46
EPA 624
6084428
1 08/24/06 03:46
EPA 624
6084428
1 0824/0603:46
EPA 624
6OW28
1 0824/06 03:46
EPA 624
6084428
1 0824/0603:46
EPA 624
6084428
1 082410603:46
EPA 624
6084428
1 0824/06 03:46
EPA 624
6084428
1 0824/06 03:46
EPA 624
6084428
1 082410603:46
EPA 624
6084428
1 0824/0603:46
EPA 624
6084429
1 0824/06 03:46
EPA 624
6084429
1 08/24/06 03:46
EPA 624
6084428
1 0824/06 03:46
EPA 624
6084428
1 0824/06 03:46
EPA 624
6084428
1 0824/06 03:46
EPA 624
6084428
1 0824/0603:46
EPA 624
6084428
1 0924/0603:46
EPA 624
6084428
1 0824/06 03:46
EPA 624
6084428
1 0824/06 03:46
EPA 624
6084428
1 08/24/06 03:46
EPA 624
6084428
1 0124/0603:46
EPA 624
6084428
1 0824/06 03:46
EPA 624
6084428
1 0824/06 03:46
EPA 624
6084428
1 09/2410603:46
EPA 624
6084428
1 0824/06 03:46
EPA 624
6084428
08124106 03:46
EPA 624
6084428
08124106 03:46
EPA 624
6084428
08124106 03:46
EPA 624
6084428
08124106 03:46
EPA 624
6084428
Page 3 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs (2860)
1316 S. 5th Street
Wilmington, NC 28401
Atm Laurie Kelly
Analyte
2960 Foster Creighton Road Nashvine, TN 37204 -800-765.OM • Fax [phone]
Work Order:
NPH2807
Project Name:
Oxford Labs
Project Number:
[none]
Received:
08/ 19/06 08:00
ANALYTICAL REPORT
Result Flag Units
Sample ID: NPH2807-02 (608-57369-2 - Water) Sampled: 08/18/06 10:45
General Chemistry Parameters
Sulfite NO H3 mg/L
Acid and Base(Neutral Extractables by EPA Method 625
Acenaphthene
NO
Acenaphthylene
NO
Anthracene
ND
Benzo (a) anduacene
ND
Benzo (a) pymne
NO
Benzo (b) fluoranthene
NO
Benzo(g,h,i) perylene
NO
Benzo (it) flumunthene
NO
4-Bromophenyl phenyl ether
NO
Butyl benzyl phthalate
NO
4-Chlor -3-methylphenal
ND
Bis(2<1doroethoxy)methane
NO
Bis(2-chlomethyl)ether
NO
Bis(2-ehloroisopropyl)ether
NO
2-Chlomnaphthalene
NO
2-Chlorophenol
NO
4-Chlorophenyl phenyl ether
NO
Chrysene
NO
Dibenz (a,h) anthrecene
NO
Di-n-butyl phthalate
NO
1,3-Dichlombemene
ND
1,4-Dichlorobenzene
NO
1,2-Dichlombenzene
ND
3,3'-Dichlombenzidine
NO
2,4-Dichlomphmol
NO
Diethyl phthalate
NO
2,4-Dimethylphenol
NO
Dimethyl phthalate
ND
4,6-Dinitm-2-methylphenol
NO
2,4-Dinitrophenol
NO
2,6-Dinitrotoluene
ND
2,4-Dinitrotolume
NO
Di-n-octyl phthalate
NO
Bis(2-ethylhexyl)phthalate
NO
Flumstathene
ND
Fluorene
NO
Hexachlorobenzene
NO
Hexachlorobutadiene
ND
Hexachlorocyclopentadiene
ND
Hezachloroethane
NO
Indeno (1.2,3-cd) pyrene
NO
Dilution Analysis
MRL Factor Date/Time Method Batch
5.00 1 09/01/0623:02 EPA 377.1 M 6086128
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ugh
10.4
1 08/23/06 22:20
EPA 625
6094500
ug/L
10.4
1 0823/0622:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10A
1 0823/06 22:20
EPA 625
6094500
ug/L
10A
1 08/23/0622:20
EPA 625
6094500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6094500
ug/L
10.4
1 0923/0622:20
EPA 625
6084500
ugh
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ugh
10.4
1 0823/06 22:20
EPA 625
6094500
ug/L
10.4
1 0823/06 22:20
EPA 625
6094500
ug/L
10.4
1 0823/0622:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/0622:20
EPA 625
6084500
ug/L
10.4
1 0823/0622:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6094500
ug/L
10.4
1 09/23/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6094500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ugh
10.4
1 0823/06 22:20
EPA 625
6084500
ugh
26.0
1 0823/0622:20
EPA 625
6094500
ug/L
26.0
1 08/23/06 2120
EPA 625
6084500
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/0622:20
EPA 625
6084500
ug/L.
10.4
1 0823/06 22:20
EPA 625
6094500
ug/L
10A
1 0823/06 22:20
EPA 625
6084500
ug/L
10.4
1 0823/0622:20
EPA 625
6084500
ug(L
10.4
1 0823/06 22:20
EPA 625
6084500
ug(L
10.4
1 0823/06 22:20
EPA 625
6084500
118/1-
10.4
1 0823106 22:20
EPA 625
6094500
ug/L
10.4
1 0823/0622:20
EPA 625
6084500
ug/L
10.4
1 09/23/06 22:20
EPA 625
6084500
ugh
10.4
1 0923106 22:20
EPA 625
6084500
Page 4 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs (2860)
1316 S. 5th Street
Wilmington, NC 28401
Arm Laurie Kelly
2960 FosterCreighton Road Nashville, TN 37204 - 800465-0980' Fax [phone]
Work Order:
NPH2907
Project Name:
Oxford Labs
Project Number:
[none]
Received:
08/ 19106 08:00
ANALYTICAL REPORT
Analyte Result Flag Units MRL
Sample ID: NPH2807-02REI (608-57369-2 - Water) - con(. Sampled: 08/18/06 10:45
Acid and Base/Neutral Extractables by EPA Method 625 - cont.
Dilution Analysis
Factor Date/Time 3lethod Batch
Isophomme
ND
ug/L
10.4
1 OW3/06 22:20
EPA 625
6084500
Naphthalene
ND
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
Nitrobenzene
NO
ug/L
10.4
1 OSn3/0622:20
EPA 625
6094500
2-Nitrophenol
ND
ug/L
10.4
1 0823/0622:20
EPA 625
6084500
4-Nitrophenol
NO
ug/L
26.0
1 0823/0622:20
EPA 625
6084500
N-Nitrosodimethylamine
NO
ugh
10.4
1 0823/0622:20
EPA 625
6084500
N-Nitrosodiphenylamine
ND
ugh
10.4
1 08/23/0622:20
EPA 625
6084500
N-Nitrosodi-n-propylamine
NO
ug/L
10.4
1 08/23/0622:20
EPA 625
6084500
Pentachlorophenol
NO
ugh
26.0
1 0823/0622:20
EPA 625
6084500
Phenanthrene
NO
ugh
10.4
1 0823/0622:20
EPA 625
6084500
Phenol
ND
ugh
10.4
1 08/23/06 22:20
EPA 625
6084500
Pyrene
NO
ugh
10.4
1 0823/0622:20
EPA 625
6084500
1,24-Trichlorobenzene
NO
ug/L
10.4
1 0823/06 22:20
EPA 625
6084500
2,4,6-Trichlomphenol
ND
ug/L
10.4
1 08/23/0622:20
EPA 625
6094500
Benzidine
ND
ug/L
52.1
1 0823/0622:20
EPA 625
6084500
1,2-Diphenylhydmzine
ND
ug/L
10.4
1 08n3/06 22:20
EPA 625
6084500
2-Methylnaphthalene
NO
ug(L
10.4
1 08/23/0622:20
EPA 625
6084500
Surf: Terphenyl-d14 (34-116%)
81 %
08123106 22:20
EPA 625
6084500
Sun: 2.4.6-Tribromophenol (16-130%)
88 %
08123106 21:20
EPA 625
6084500
Sun: Phenol-& (10-66%)
17 %
08/13106 21: 20
EPA 625
6084500
Sun: 2-Fluorobiphenyl (32-99•Ao)
74 %
08123106 22:20
EPA 625
6084500
Sun: 2-Fluorophenol (10-81 %)
35 %
08123106 22:20
EPA 625
6084500
Sun., Nitrobenzene-dS (19-116%)
74 %
08123106 22:20
EPA 625
6084500
Sample ID: NPH2807-03 (608-57369-2 - Water) Sampled:
08/18/06 10:45
Organochlorine Pesticides and/or PCBs by EPA Method 608
Aldrin
NO
ug/L
0,0500
1 08/24/06 19:37
EPA 608
6084464
delta-BHC
NO
ug/L
0.0500
1 08/24/06 19:37
EPA 608
6084464
alpha-BHC
ND
ugh
0.0500
1 0824/06 19:37
EPA 608
6084464
beta-BHC
NO
ug/L
0.0500
1 08/24/06 19:37
EPA 608
6084464
gamma-BHC(Lindane)
NO
ug/L
0.0500
1 0924/0619:37
EPA 608
6084464
Chlordane
ND
ugh
3.00
1 08/24106 19:37
EPA 608
6084464
4,4'-DDD
ND
118/1-
0.0500
1 08/24/06 19:37
EPA 608
6084464
4,4'-DDE
NO
ug/L
0.0500
1 08/24/06 19:37
EPA 608
6084464
4,4'-DDT
ND
ug/L
0.0500
1 08124/06 19:37
EPA 608
6084464
Dieldrin
ND
ug/L
0.0500
1 08/24106 19:37
EPA 608
6084464
Endosulfan I
NO
ugh
0.0500
1 0824106 19:37
EPA 608
6084464
Endosulfan II
ND
ug/L
0.0500
1 0824/06 19:37
EPA 608
6084464
Endosullen sulfate
NO
ug/L
0.0500
1 08/24/06 19:37
EPA 608
6084464
Endrin
ND
ug/L
0.0500
1 0824/06 19:37
EPA 608
6084464
Endrin aldehyde
NO
ug/L
0.0500
1 0824/06 19:37
EPA 608
6084464
Endrin ketone
NO
ugh
0.0500
I 08/24/06 19:37
EPA 608
6084464
Heptachlor
ND
ugh
0.0500
1 08/24/06 19:37
EPA 608
6084464
Heptachlor epoxide
NO
ugh
0.0500
1 08/24/06 19:37
EPA 608
6084464
Page 5 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs (2860)
1316 S. 5th Street
Wilmington, NC 28401
Ann Laurie Kelly
2960 Foster Creighton Road Nashville, TN 37204 •800-165-0980 - Fax [phone]
Work Order:
NPH2807
Project Name:
Oxford Labs
Project Number:
[none]
Received:
08/19/06 08:00
ANALYTICAL REPORT
Analyte Result Flag Units
Sample ID: NPH2807-03 (608-57369-2 - Water) - cont. Sampled: 08/18/0610:45
Organochlorine Pesticides and/or PCBs by EPA Method 608 - cont.
Mcthoxychlor
NO
ug/L
Toxaphene
NO
ug/L
PCB-1016
NO
ug/L
PCB-1221
NO
ug/L
PCB-1232
ND
ugh
PCB-1242
NO
ug/L
PCB-1248
NO
ug/L
PCB-1254
ND
ug/L
PCB-1260
NO
ug/L
PCB-1262
NO
ug/L
PCB-1268
NO
ugh
Sun., Tetrochloro-mela-xylene (44-131 %)
85 %
Surr: Telrachloro-meta-xylene (58-117Y)
72 %
Surr: Decachloroblphenyl (24-110%)
101 %
Sun: Decachlorobiphenyl (22-115%)
19 %
Sample ID: NPH2807-04 (Trip Blank - Water) Sampled: 08/18/06
Purgeable Organic Compounds by EPA Method 624
Acrolein
ND
ugh
Acrylonitrile
ND
ug/L
Benzene
ND
ug/L
Bromobenzene
ND
ug/L
Bromochloromethane
ND
ug/L
Bromodichlommethane
ND
ug/L
Bmmoform
ND
ug/L
Bromomethane
ND
ugh
n-Butylbenzene
ND
ug/L
sec-Butylbenzene
NO
ugh
tert-Butylbenzene
ND
ugh
Carbon disulfide
NO
ugh
Carbon Tetrachloride
NO
ug/L
Chlorobenzene
ND
ugh
Chlorodibromomethane
NO
ug/L
Chloroethane
NO
ugh
2-Chlomethylvinyl ether
ND
ug/L
Chlomform
NO
ug(L
Chloromethane
NO
ugh
2-Chlorotoluene
ND
ug/L
4Chlorotolume
NO
ug/L
1,2-Dibromo-3-chloropropane
ND
ugh
1,2-Dibromoethane(EDB)
ND
ug/L
Dibromomethane
NO
ugh
1,2-Dichlorobemcne
ND
ug/L
1,4-Dichlorobenzene
ND
ug/L
Dilution Analysis
MRL Factor Date/Time Method Batch
0.0500
1 08/24/06 19:37
EPA 608
6084464
5.00
1 08/24/06 19:37
EPA 608
6084464
0.500
1 08/26(06 02;14
EPA 608
6084463
0.500
1 08/26/06 02:14
EPA 608
6084463
0.500
1 08/26/06 02:14
EPA 608
6084463
0.500
1 08/26/06 02:14
EPA 608
6084463
0.500
1 0826/06 02:14
EPA 608
6084463
0.500
1 08/26/06 02:14
EPA 608
6084463
0.500
1 0826/06 02:14
EPA 608
6084463
0.500
1 0826/06 02:14
EPA 608
6084463
0.500
1 08/2610602:14
EPA 608
6084463
08126106 02:14
EPA 608
6084463
08/24/06 19:37
EPA 608
6084464
08126106 02:14
EPA 608
6084463
0812410619:37
EPA 608
6084464
50.0
1 0823/06 22:17
EPA 624
6084428
10.0
1 0823/06 22:17
EPA 624
60W28
1.00
1 0823/06 22:17
EPA 624
6084428
1,00
1 08/23/06 22:17
EPA 624
6084428
1.00
1 0823/06 22:17
EPA 624
6084428
1.00
1 0823106 22:17
EPA 624
6084428
1.00
1 08/23/06 22:17
EPA 624
6084428
1.00
1 0823/0622:17
EPA 624
6084428
1.00
1 08/23/06 22:17
EPA 624
6084428
1.00
1 08/23/06 22:17
EPA 624
6084428
1.00
1 0823/06 22:17
EPA 624
6084428
1.00
1 0823/06 22:17
EPA 624
6084428
1.00
1 0823/06 22:17
EPA 624
6084428
1.00
1 0823/06 22:17
EPA 624
6084428
1.00
1 08/23/06 22:17
EPA 624
6084428
1.00
1 08/23/06 22:17
EPA 624
6084428
5.00
1 0823/06 22:17
EPA 624
6084428
1.00
1 082310622:17
EPA 624
60W28
1.00
1 08/23/06 22:17
EPA 624
6084428
1.00
1 0823/06 22:17
EPA 624
6084428
1.00
1 08/23/06 22:17
EPA 624
6084428
5.00
1 08/23/06 22:17
EPA 624
6084428
1.00
1 09/23/06 22:17
EPA 624
6084428
1.00
1 08/23/06 22:17
EPA 624
60W2a
I.00
1 0823/06 22:17
EPA 624
6084428
1.00
1 0823/06 22:17
EPA 624
6084428
Page 6 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs (2860)
1316 S. Sill Street
Wilmington, NC 28401
Arm Laurie Kelly
2960 Foster Creighton Road Nashville. TN 37204' 800-765-0980' Fax [phone]
Work Order:
NPH2807
Project Name:
Oxford Labs
Project Number:
[none]
Received:
08/ 19/06 08:00
ANALYTICAL REPORT
Aaalyte Result Flag Units
Sample ID: NPH2807-04 (Trip Blank- Water) - coot Sampled: 08/18/06
Purgeable Organic Compounds by EPA Method 624 - cont.
0-Dichlorobenzene
ND
ug/L
DichlorodiFluoromethane
NO
ug(L
1,2-Dichloroethane
NO
ug/L
I,t-Dichloroorohane
NO
ug/L
cis-1,2-Dichlorcethene
NO
ug(L
trans-1,2-Dichlorcethene
NO
ug(L
1,2-Dichloroethene (total)
NO
ug/L
1,1-Dichloroethene
ND
ug/L
1,2-Dichloropropane
NO
ug(L
1,3-Dichloropropane
NO
ug/L
2,2-Dichloropropane
ND
ug/L
cis-1,3-Dichlompropene
ND
ug/L
trans-1,3-Dichloropropene
NO
ug(L
1,1-Dichlompropene
ND
ug/L
Ethylbenzene
ND
ug/L
Hexachlorobutadiene
NO
ug/L
Isopropylbenzene
NO
ug(L
p-Isopropylmluene
NO
ug/L
Methyl ten -Butyl Ether
NO
ug/L
Methylene Chloride
ND
ug/L
Naphthalene
NO
ug/L
n-Propylbenzene
ND
ug/L
Styrene
NO
ug/L
1, 1, 1,2-Tetrachlorcethane
NO
ug(L
1,1,2,2-Tenrachloroethane
NO
ug/L
Tetrachloroethene
ND
ug/L
Toluene
NO
ug/L
1,2,3-Trichlorobenzene
NO
ug/L
1,2,4-Trichlombenzene
ND
ug/L
1,1,2-Trichloroethanc
NO
ug/L
1,1,1-Trichlorcethane
ND
ug(L
Trichlomethene
ND
ug/L
Triehloro0uoromethane
NO
ug/L
1,2,3-Tichloropropane
ND
ug/L
1, 1, 1-Trichlorotrifluormthane
ND
ug/L
1,3,5-Trimethylbenzene
NO
ug/L
1,2,4-Trimethylbenzene
NO
ug/L
Vinyl acetate
NO
ug/L
Vinyl chloride
NO
ug(L
o-Xylene
ND
118/L
m,p-Xylcne
NO
ug/L
Xylenes, total
NO
ug/L
Sum. l.2-Dich1oroelhane-d4 (81-1164'0)
108 %
Ssi Dibromajiuoromethane (88-12011)
108 %
NIRL
1.00
1.00
1,00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
2.00
1.00
1.00
1.00
5.00
5.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
2.00
1.00
1.00
5.00
1.00
1.00
Loo
2.00
Dilution Analysis
Factor Date/Time Method Batch
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 08/23/06 22:17
EPA 624
6OW28
1 0823106 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823106 22:17
EPA 624
6084428
1 0823106 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084429
1 0823/06 22:17
EPA 624
6084428
1 08/23/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6094428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
I 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0923/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0923/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6094428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 08/23/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
60W28
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0923/0622:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
1 0823/06 22:17
EPA 624
6084428
08123106 22:17
EPA 624
6084428
08123106 22:17
EPA 624
6084428
Page 7 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
2960 Foster Creighton Road NashviNs, TN 37204' 800-765-0980' Fax [phone]
Client Oxford Labs (2860)
Work Order:
NPH2807
1316 S. 5th Street
Project Name:
Oxford Labs
Wilmington, NC 28401
Project Number:
(none)
Arm Laurie Kelly
Received:
08/19/0608:00
Analyte
ANALYTICAL REPORT
Result Flag Units
Sample ID: NPH2807-04 (Trip Blank - Water) - coot. Sampled: 08/18/06
Purgeable Organic Compounds by EPA Method 624 - cont.
Surc Toluene-d8 (85-130e0) 98 %
Sum: 4-BromoJluorobenzene (80-124%) 103 %
Dilution AnahrSiS
MRL Factor Date/Time Method Batch
08/23/06 22:17 EPA 624 6084428
08123106 21:17 EPA 624 6084428
Page 8 of 24

•
TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs (2860)
1316 S. 5th Street
Wilmington, NC 28401
Ann Laurie Kelly
2960 Faster Creighton Road Nashville. TN 37204. 800-765-0980' Fax [phone]
Work Order:
NPH2807
Project Name:
Oxford Labs
Project Number.
[none]
Received:
08/19/06 08:00
SAMPLE EXTRACTION DATA
Wt/vol
Extraction
Parameter Batch
Lab Numbcr
Extracted
Extracted Vol
Date
Analyst
Method
Acid and Base/Neutral Extmctables by EPA Method 625
EPA 625 6083992
NPH2807-02
%5.00
1.00
08/21/0609:30
KLG
EPA 625
EPA 625 6094500
NPH2807-02REI
960.00
1.00
011/23/06 11:00
DRH
EPA 625
Organochlorine Pesticides and/or PCBs by EPA Method 608
EPA 609 6084464
NPH2807-03
500.00
5.00
08/23/06 08:15
AEB
EPA 608
EPA 608 6094463
NPH2807-03
500.00
2.00
08/23/06 08:15
AEB
EPA 608
Page 9 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs(2860)
1316 S. 5th Street
Wilmington, NC 28401
Arm Laurie Kelly
29M Foster Creighton Road Nashville, TN 37204 - BW-765-0980 - Fax [phone]N
Work Order:
Project Name:
Project Number.
Received:
PROJECT QUALITY CONTROL DATA
Blank
NPH2807
Oxford Labs
(none]
08/ 19/06 08:00
Analyte Blank Value Q Units Q.C. Batch Lab Number Analyzed DatrRime
General Chemistry Parameters
6086128-BLKI
Sulfite <0.900 mg/L 6086128 6096128-BLKI 09AI/06 23:02
Organochlorine Pesticides and/or PCBs by EPA Method 608
6084463-BLKI
PCB-1016
<0.190
ug/L
6094463
6084463-BLKI
0826/06 01:03
PCB-1221
<0.270
ug/L
6084463
6094463-BLKI
0926/06 0193
PCB-1232
-0.110
ug/L
6084463
6084463-BLKI
0826/06 01:03
PCB-1242
<0.180
ug/L
6084463
6084463-BLKI
0826106 01.03
PCB-1249
<0.0900
ug/L
6084463
6084463-BLKI
0826/06 01:03
PCB-1254
<0.100
ug/L.
6084463
6084463-BLKI
08/26/06 01:03
PCB-1260
<0.0900
ug/L
6084463
6OM463-BLKI
0826/06 01:03
PCB-1262
<0.160
ug/L
6094463
6084463-BLKI
0826/06 01:03
PCB-1268
<0.120
ug/L
6084463
6084463-BLKI
0826106 01:03
Surrogate: retrachloro-melu-xylene
78%
6084463
6094463-BLKI
0826/06 01.03
Surrogute.' Detuchlorohiphenyl
54%
6084463
6084463-BLKI
0826/06 0193
608446443LKI
Aidr(n
<0.0100
ug/L
6084464
6094464-BLKI
0824/06 16:48
delta-BHC
<0.0200
ug/L
6094464
6084464-BLKI
0824106 16:49
alpha-BHC
<0.0100
ug/L
6084464
6084464-BLKI
08/24/06 16:48
beta-BHC
<0.0300
ug/L
6084464
6084464-BLKI
08/24/06 16:49
gamma-BHC (Lindano)
<0.0100
ug/L
6094464
6094464-BLKI
0824/06 16:48
Chlordane
<0.490
ug/L
6094464
6084464-BLKI
0924/06 16:49
4,4'-DDD
<0.0400
ug/L
6084464
6094464-BLKI
0824/06 16AS
4,4'-11DE
<0.0300
ug/L
6084464
60SM64-BLKI
08/24/06 16:48
4,4'-DDT
<0.0300
ug/L
6094464
6094464-BLKI
08/24/06 16:49
Dieldrin
<0.0100
ug/L
6084464
6084464-BLKI
09/24/06 16:48
EndosWfan 1
<0.0200
ug/L
6084464
6084464-BLKI
08/24/06 16:48
Endosulfm II
0.0300
ug/L
6094464
6084464-BLKI
0824/06 16:48
Endosulfan sulfate
<0.0200
ug/L
6094464
6084464-BLKI
08/24/06 1648
Endrin
<0.0200
ug/L
6084464
6084464-BLKI
08/24/06 16:48
Endrin aldehyde
<0.0300
ug/L
6084464
6084464-BLKI
0924/06 16:48
Endrin ketone
<0.0200
ug/L
60W64
6084464-BLKI
08/24/06 16:48
Heptachlor
<0.0200
ug/L
6094464
6084464-BLKI
09/24/06 16:48
Hepiachlorcpoxide
<0.0100
ug/L
6094464
6094464-BLKI
0824/06 16:48
Methoxychlor
<0.0200
ug/L
6084464
6084464-BLKI
0824106 16:49
Toxaphenc
<1.80
ug/L
6084464
6084464-BLKI
08/24/06 16:48
Surrogale: retry hloro-meta-sylerte
83%
6084464
6084464-BLKI
0824/06 16:48
Sumagale: Decachlorohiphenvi
77%
6094464
60W64-BLKI
08/24/06 16:48
Purgeable Organic Compounds by EPA Method 624
6084428-BLKI
Page 10 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs (2860)
1316 S. 5th Street
Wilmington, NC 28401
Ann Laurie Kelly
Analyte Blank Value
Purgeable Organic Compounds by EPA Method 624
608"28-BLKI
Acrolcin
<1.19
Acryloniuilc
<0.520
Benzene
<0.290
Bromobenzcne
<0.290
Bromochloromcthenc
<0.190
Bmmodichloromethane
<0.370
Hoo.form
<0. 140
Bremomethanc
e0.320
n-Butylbenrene
<0. 120
sm-Butylbcnzene
<0. 160
tcn-Butylbcnzcnc
<0.240
Carbon disulfide
<0.120
Carbon Tetrachloride
<0.150
Chlceobcnzcnc
<0.310
Chlmodibromomcthane
<0.130
Chlorocthane
<0.170
2{Tlorcethylvinyl ether
<0.510
Chloroform
<0.130
Chloromethane
<0.110
2{Tlorotoluene
<0.110
4-Chlorotoluene
< A10
1,2-13ibromo-3-chloropropane
<1.30
1,2-Dibrommlhene(EDB)
<0.110
Dibromomethane
<0.110
42-Dichlorobenzene
<0.170
1,4-Dichlorobcnzcne
<0.310
1,3-Dichlorobenzcne
<0.120
Dichlorodi0uemencbane
<0.470
1,2-Dichloroethane
<0.560
I,I-Dichloroethane
<0.310
cis-1.2-Dichloroethene
<0.130
trans-1,2-Dichloroethene
<0.130
1.2-Dichloroethene(total)
<0A30
1,1-Dichloroethene
<0.100
1,2-Dichloropropane
<0.150
I j-Dichloropropane
<0.310
2,2-Dichlmopropanc
10.100
cis-1,3-Dichloropropene
<0.250
Irans4.3-Dichloropropene
<0.100
I,1-Dichlmapmpene
<0.100
Ethylbcnzcnc
<0.230
Hexachlorobutadiene
<0.160
29M Foster Creighton Road Nashville, TN 37204-800-765-0980 - Fax [phone]
Work Order.
NPH2907
Project Name:
Oxford Labs
Pmject Number:
[none]
Received:
08/ 19/06 08:00
PROJECT QUALITY CONTROL DATA
Blank - Cont.
Q Units
Q.C. Batch
Lob Number
Analyzed Datelfime
ug/L
6094428
6084428-BLKI
0823106 21:01
ug/L
6084428
6094428-BLKI
0823/06 21:01
ug/L
6084429
6084428-BLKI
08/23/06 21:01
ug/L
6094428
6084421i-BLKI
0923/06 21:01
ug(L
6084428
6084428-BLKI
0823106 2"1
ug/L
6084428
6084428-BLKI
0823/06 21:01
ug/L
6094428
6094428-BLKI
0823/06 2101
ug/L
6094429
6084428-BLK)
0823/06 2101
ug/L
6084428
608442&BLKI
0823/06 2"1
ug/L
6094428
6094428-BLKI
0823/06 2101
ug/L
6084428
6084428-BLKI
08/23/06 21:01
ug/L
6084428
6084429-BLKI
0823/06 2101
ug/L
6OW28
6084428-BLKI
0823/06 21.01
ug/L
6094428
6084428-BLKI
08/23/06 21!01
ug/L
6094428
6084428-BLKI
0923106 21:01
ug/L
6094428
6094429-BLKI
0823/06 21:01
ug/L
6084428
6094428-BLKI
0823/06 21:01
ug/L
6084428
608442&BLKI
0823106 21:01
ug/L
6094428
6094428-BLKI
0823106 21:01
ug/L
6084428
6084429-BLKI
08/23/06 21:01
ug/L
6084428
6084428-BLKI
0823/06 2101
ug/L
6094429
6094429-BLKI
0823/06 2101
ug/L
6084428
6084428-BLKI
0823/06 21:01
ug/L
6094428
608442&BLK1
0823/06 2101
ug/L
6094428
6094428-BLKI
0823/06 21:01
ug/L
6094428
6084428-BLKI
0823/06 21:01
ug/L
6094428
6094428-BLKI
OW3/06 21:01
ug/L
6094428
6084428-BLKI
0823/06 2101
ugfL
6084428
6084428-BLKI
0823/06 21:01
ug/L
6094428
6094428-BLKI
0823/06 21:01
ug/L
6084428
6084428-BLKI
0823/06 21:01
daft.
6084428
6084428-BLKI
09/23/06 21:01
ug/L
6084428
6084429-BLKI
0823/06 21:01
ug/L
6084429
6084428-BLKI
0823/06 21:01
ug/L
60W28
6084428-BLKI
0823/06 21:01
u8/L
6094428
609442&BLKI
0823/06 21:01
ug(L
6084428
6084428-BLKI
09/23/06 21:01
ug/L
6084428
6084428-BLKI
0823/06 21:01
ug/L
6084428
6084428-BLKI
08/23/06 21:01
ug/L
6084428
608a428-BLKI
08/23/06 2101
ug/L
6084428
6094428-BLKI
0823/06 21:01
ug/L
6084428
6084428-BLKI
011/23/06 21:01
Page I I of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs (2860)
1316 S. Sth Street
Wilmington, NC 28401
Arm Laurie Kelly
Analyle Blank Value
Purgeable Organic Compounds by EPA Method 624
6084428-BLK1
Isopmpylbenzene
<0.230
p-lnopropyltolucne
<0.200
Methyl ten -Butyl Ether
<0.110
Methylene Chloride
<0.210
Naphthalene
<0.200
n-Propylbenzene
<0.120
Styrene
<0.100
I,I,L2-Tetrachloroethane
<0.110
1,1,2,2-Tetrachloroethane
<0.130
Temaehlereethene
<0.110
Toluene,
<0.280
1,2,3-Trichlorobcnzcne
<0.290
1 2,4-Trichlombenzene
<0.230
1,1,2-Trichlomcthane
<0.240
I,I,1-Trichlomcthane
<0.110
Triehkooethene
<0.100
Trichloro0uommcthane
<0.120
1,2,3-Trichlompropane
<0.370
1.1.1-Trlchlomm0uoroethane
<0.120
1,3,5-Trimethylbenzene
<0.150
1,2,4-Trimethylbcnzene
<0.200
Vinyl accrete
<0.950
Vinyl chloride
<0.370
c-Xylene
<0.150
m,p-Xylrne
<0.530
Xylencs, total
<0.680
Surrogule: 1.2-Dichloreethane-44
109a/
Surrogute: DibmmoJluoromefhone
106%
Surrogale. Tal insc-J8
99%
Surrogade 4-Bmmn/luorobenzene
103%
2960 Fanner Creighton Road Nashville, TN 37204-800-76M980 - Fax [phone]
Work Order:
NPH2807
Project Name:
Oxford Labs
Project Number:
[none]
Received:
08/19/06 08:00
PROJECT QUALITY CONTROL DATA
Blank - Coot.
Acid and Base(Neutral Extractables by EPA Method 625
6084500-BLKI
Acenaphthene
<2.90
Acenaphrhylene
3.55
Anthracene
<.80
Benin (a) antivecene
12.60
Benin (a) Pyre"
<2,90
Benzo (b) Fluoranthem
<3.00
Benno (g,h,t) perylene
<2.90
Benzo(k) Buoranflune
<3.70
Q Units
Q.C. Batch
Lab Number
Analyzed Daterrime
ug/L
6OW28
6094429-BLKI
0823/06 21:01
ug/L
6084428
6084429-BLKI
08/23/06 21:01
ug/L
60W28
6084428-BLKI
0823/06 21:01
ug/L
6084428
6084429-BLKI
0823/06 21:01
ug/L
6084428
6094429-BLKI
0823/06 21:01
ug(L
6084428
6084428-BLKI
0823/06 21:01
ug/l.
6094428
6094429-BLKI
0823/06 21:01
ug/L
6094428
6084428-BLKI
08/23/06 21:01
ug/L
6084428
6094428-BLKI
08/23/06 21:01
ug/L
6084428
6084428-BLKI
0923106 21:01
ug/L
6084428
6084428-BLKI
O9/23/06 21:01
ug/L
6084428
6094428-BLKI
0823/06 21:01
ug/L
6084428
6084428-BLKI
0823/06 21:01
ug/L
6084428
6084428-BLKI
0923106 21:01
ug/L
608028
6084429-BLKI
0823/06 21:01
ug/L
6084428
6084428-BLKI
0823106 21:01
ug/L
6084428
6094428-BLKI
0823/06 21.01
ug/L
6094428
6084429-BLKI
09/23/06 21 d11
ug/L
6084428
6094428-BLKI
0823/06 2I:01
ug/L
6084428
6084428-BLKI
0823/06 21:01
ug/L
6094428
6084428-BLKI
0823/06 21:01
nail.
6094428
6084428-BLKI
08/23/06 21:01
ug/L
6084428
6094428-BLKI
0823/06 21:01
ug/L
6084428
6094428-BLKI
OW3/06 21.01
nail.
6084428
6094429-BLKI
O8/23/06 21:01
ug/L
6084428
6084428-BLKI
0823/06 21:01
6084429
6094428-BLKI
0823/06 21:01
6084428
6084428-BLKI
0823/06 21:01
6094428
6084428-BLKI
0823/06 21:01
6084428
6084428-BLKI
O9/23/06 21:01
ug/L
6094500
6094500-BLKI
0823/06 20:35
ug/L
6094500
608450bBLKI
0823/06 20:35
ug/L
6084500
6084500-BLKI
0823/06 20:35
ug/L
6084500
6094500-BLKI
0823/06 20:35
ug/L
6094500
6084500-BLKI
0823106 20:35
ug/L
6094500
6084500-BLKI
0823/06 20:35
ug/L
6084500
60845MOLKI
0823/06 20:35
ug/L
6084500
6084500-BLKI
0823/06 20:35
Page 12 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs (2860)
1316 S. 5th Street
Wilmington, NC 28401
Arm Laurie Kelly
Analym Blank Value
2960 Foster Creighton Road NBShOft, TN 37204 - 800-765-0980 - Fax [phone]
Work Order:
Project Name:
Project Number:
Received:
PROJECT QUALITY CONTROL DATA
Blank - Cont
Acid and Base/Neutral Extractables by EPA Method 625
6084500-BLKI
4-Bromophcoyl phenyl ether
<2.20
Butyl benzyl phthalate
<2.70
"hloro-3-methylphenol
<2.40
Bis(2-chloroethoxy)mcthane
<3.40
Bis(2-chlovo:thyl)ethcr
<1.90
Bis(2chlomisopropyl)cthcr
<4.50
2-Chlororuphthalme
<3.00
2-Chlorophcnol
<2.00
4-Chlorophenyl phenyl ether
<2.50
Chrysc.
Q,40
Dibenz(a,h) anthracene
<2.90
Di-n-butyl phthalate
<2.60
1,3-Dichlorobenzeme
<1.50
1,4-Dichlorobenzene
<1.70
1,2-Dichlorobenzene
<1.70
3,3'-Dichlorobenzidine
<2.70
2,4-Dichlorophcnol
<3.10
Diethyl phthalate
<2.60
2,4-Dimethylphcnol
<5.20
Dimethyl phthalate
<2.40
4,6-Dinitro-2-methylphcnol
<3.30
2,4-Dinitrophenol
<2.90
2,6-Dinitrotoluene
<2.W
2,4-Dinitrotoluene
<2.50
Di-n-uctyl phthalate
<2.80
Bis(2-ethylhexyl)ph1hslete
<3.50
F3uomnthene
<2.50
Fluorene
<2.70
Hexachlombenzene
<2.40
Hcxachlorobutadicne
<3.20
Hexachlorocyclopenradiene
<5.50
Hcxachlomcthenc
<1.80
Indeno(1.2,3-cd)pytene
<2.90
Isopharone
Q,40
Naphthalene
<2.90
Nitrubmzcnc
<4.50
2-Nitrophcool
<2.50
4-Niorphenol
<430
N-Nitrosodimcthylatnine
<170
N-Nivosodiphenylemine
<3.80
N-Nitrosodi-n-propylarnmc
<2.00
Penmchlorophenol
<3.00
NPH2807
Oxford Labs
[none]
08/19/06 08:00
Q Units
Q.C. Batch
Lab Number
Analyzed Date/Time
ug/L
6094500
6084500-BLKI
08/23/06 20:35
ug/L
6084500
608450D-BLKI
0823/06 20:35
ug/L
6084500
6084500-BLKI
0823/06 20:35
ug/L
6084500
6084500-BLKI
09/23/06 20:35
ug/L
6084500
6094500-BLKI
08/23/06 20:35
ug/L
6094500
609450D-BLKI
08/23/06 20J5
ug/L
6084500
6084500-BLKI
0823/06 20J5
ug/L
6094500
6094500-BLKI
0823/06 20:35
ugh
6094500
60845MBLKI
08/23/06 20:35
ug/L
6084500
6094500-BLKI
0923/06 20:35
u9/1-
6094500
6084500-BLKI
0823/06 20J5
ug/L
6084500
6094500-BLKI
08/23/06 20:35
ug/L
6094500
6094500-BLKI
08/23/06 20:35
ug/L
6094500
6084500-BLKI
0823106 2015
ug/L
6084500
6094500-BLKI
09/23/06 20:35
ug/L
6094500
60845MBLKI
0823/06 20:35
ug/L
6084500
6094500-BLKI
0823/06 20:35
ug7L
6094500
6094500-BLKI
08/23/06 20:35
ug/L
6094500
60845WBLKI
09/23/06 20:35
ug/L
6084500
60945MBLKI
0823/06 20:35
ug/L
6094500
6094500-BLKI
0823/06 20:35
ug/L
6094500
6084500-BLKI
08/23/06 20:35
ug/L
6094500
6094500-BLKI
0823/06 20:35
ug/L
6004500
60945WBLKI
0823/06 20:35
ug/L
6094500
6094500-BLKI
0823/06 20:35
ug/L
6094500
6084500-BLKI
0823/06 20J5
ugh
6094500
6094500-BLKI
08/23/06 2035
ug/L
6084500
6084500-BLKI
0823/06 20:35
ugh
6094500
6094500-BLKI
0823/06 20:35
ug/L
6094500
6084500-BLKI
0823M 20:35
ug/L
6094500
6094500-BLKI
0823/06 20:35
ugh
6084500
6084500-BLKI
0923106 20:35
ug/L
6094500
6094500-BLKI
08/23/06 20:35
ugh
6084500
6084500-BLKI
0823106 20:35
ug/L
6084500
6094500-BLKI
0823106 20:35
ug/L
6084500
6084500-BLKI
0823/06 20:35
ug/L
6084500
60845MBLKI
0823/06 20:35
ug/L
6084500
6084500-BLKI
0823/06 20:33
ug/L
6084500
60845MBLKI
0823/06 20J5
ug/L
6084500
60845WBLKI
08/23/06 20:35
ugh
6084500
6094500-BLKI
0823/06 20:35
ug/L
6094500
6084500-BLKI
0823106 20:35
Page 13 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs(2860)
1316 S. 5th Street
Wilmington, NC 2840i
Arm Laurie Kelly
Analyte Blank Value
2960 Foster Creighton Road Nashville, TN 37204 -800-765-0980 *Fax 61S-726.3404
Work Order:
NPH2807
Project Name:
Oxford Labs
Project Number:
[none]
Received:
08/ 19/06 08:00
PROJECT QUALITY CONTROL DATA
Blank - Coot
Acid and Base/Neutral Extractablea by EPA Method 625
6094500-BLKI
Phcnanthrene
<2.40
Phenol
0.60
Pytene
<2.70
1,44-Trichlombenzenc
Q.70
2,4,6-Trichlomphcnol
<2.90
Benzidine
<34.0
1,2-Diphenylhydmzine
<2.90
2-Methylnaphthalene
<1.50
Sunogale: Terphenyl-d14
111%
Surrogate: 2,4,6-Tribmmophenol
1 15s%
Sur gwe: Phenol-dS
36%
Surrogate: 2-Fluoroblphenyl
88%
Surrogate: 2-Fluorophenol
49%
Surrogate: Mimbemene-d3
91%
Q Units
Q.C. Batch
lab Number
Analyzcd Datc/Time
ug/L
6094500
6084500-BLKI
0823/06 20:35
ug/L
6084500
6094500-BLKI
08/23/06 20:35
ug/L
6084500
6084500-BLKI
0823/06 20:35
ug/L
6084500
6084500-BLKI
0823/06 20:35
ug/L
6084500
6084500-BLKI
0823/06 20:35
ug/L
6084500
6094500-BLKI
O923106 20-35
ug/L
6084500
6094500-BLKI
0923/06 20:35
ug/L
6084500
6084500-BLKI
0823/06 20:35
6094500
6084500-BLKI
0823106 20:35
6084500
6084500-BLKI
O8/23/06 20:35
6094500
6084500-BLKI
08/23/06 20:35
6084500
6094500-BLKI
0823/06 20:35
6084500
6094500-BLKI
On3/06 20:35
6084500
6094500-BLKI
0823/06 20:35
Page 14 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION 2960 Foster Creighton Road Nashville. TN 37204-600-765-0g80 • Faa 615-7263/01
Client Oxford Labs (2860) Work Order: NPH2907
1316 S. 5th Street Project Name: Oxford Labs
Wilmington, NC 28QI Project Number: [none]
Arm Laurie Kelly Received: 08/19/0608:00
PROJECT QUALITY CONTROL DATA
Duplicate
Bamplc Ansi
Analyze Orig. Val. Duplicate Q Units RPD Limit Batch Duplicated DatNTime
General Chemistry Parameters
60861284)UP1
Sulfite 1.40 1.60 R4 mg/L 13 10 6086128 NPH2807-02 09/01/06 23:02
Page 15 of 24

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TestAmerica
ANALYTICAL TESTING CORPORATION 2960 Foster Creighton Road Nashville, TN 37204' 800-765-0980' Fax [phone]
Client Oxford Labs (2860)
Work Order:
NPH2807
1316 S. 5th Street
Project Name:
Oxford Labs
Wilmington, NC 28401
Project Number:
[none]
Arm Laurie Kelly
Received:
08119/0608:00
Analyte Known Val.
Purgeable Organic Compounds by EPA Method 624
6084428-BSI
Bmmuchloromcthanc
20.0
Bmmodichloromethane
20.0
Bromoform
20.0
Bmmomcthane
20.0
u-Butylbcnzcne
20.0
sec-Butyl6enzene
20.0
tert-Butylbenzene
20.0
Carbon disulfide
20.0
Carbon Tcnachloridc
20.0
Cht..bcnzcne
20.0
ChlUrodibromomcthanc
20.0
Chloroethenc
20.0
2-Chloroethylvinyl ether
too
Chloroform
20.0
Chl.mrnethane
20.0
2-Chlorotoluenc
20.0
4-Chlormoluene
20.0
1,2-Dibromo-3<hloropropane
20.0
1,2-Dibromocthanc (EDB)
20.0
Dibmmomcthane
20.0
42-Dichlorol,cmcne
20.0
1.4-Dichlombenzcne
20.0
1,3-Dichlombcnzene
20.0
DichlorodiBuoromethane
20.0
1,2-Diehlomethane
20.0
I,I-Dichlorocthcne
20.0
cis-1,2-Dichlorocthcne
20.0
t 1.2-Dichlorocthcne
20.0
1,2-Dichloraethene (total)
40.0
1.1-Dichloroct1cne
20.0
1.2-Dichloropropane
20.0
0-Dichloropropane
20.0
2,2-Dichloropropene
20.0
cis-1,3-Dichlo..prop=
20.0
tram-1,3-Dichloropropcnc
20.0
1,1-Dichlompropene
20.0
Ethylbcnzcm
20.0
Hesachlombumdiene
20.0
Isopropylhcnzenc
20.0
p-Isopropyholuene
20.0
Methyl tert-Butyl Ethcr
20.0
PROJECT QUALITY CONTROL DATA
LCS - Coat.
Target Analyzed
Analyzed Val Q Units %Rec. Range Batch DatwTime
21.0
ug/L
105%
71 - 127
6084429
0823/06 20:11
22.0
ug/L
110%
35 - 155
6094429
08/23/06 20:11
21.1
ug/L
106%
45- 169
6094428
09/23/06 20:11
31.9
ug/L
160%
1 - 242
6094428
0923/06 20:I t
22.0
ug/L
110%
56- 138
6084428
08/23/06 20:11
22.0
ug/L
110%
56- 136
60SU29
08/23/06 20:11
21.9
ug/L
1100%
66 - 131
6084428
0823/06 20:11
19.3
ug/L
96%
81- 127
6094429
08/23/06 20:11
23.3
ug/L
116%
70- 140
6084428
OR23/06 20:11
20.7
ug(L
104%
37- 160
6084428
0823/06 20:11
22.5
ug/L
112%
53- 149
6084428
0823/06 20:11
20.8
ug/L
104%
14-230
6084428
0823/06 20:11
17.7
ug/L
18%
1-305
6084429
0823/0620:11
20.9
ug/L
tO4%
51 -139
6084428
08/23/06 20:11
16.0
ug/L
80%
1 - 273
6084428
0823/06 20:11
20.0
ug/L
100%
61 - 144
6094428
0823/06 20:11
20.9
ug/L
104%
77 - 127
6084428
08/23/06 20:11
18.7
ug/L
94%
55 - 140
6094428
0823/06 20:11
20.6
ug/L
103%
77. 122
6084428
0823106 20:11
21.2
ug/L
106%.
81 - 121
6084428
0823/06 20:11
22.3
ug/L
112%
is- 190
6094428
0823/06 20:11
20.2
ug(L
101%
18 - 190
6084428
0923/06 20:11
21.2
Usti.
106%
59- 156
6084428
0823/06 20:11
24.5
ug/L
122%
33- 142
6084429
08/23/06 20:11
21.3
ug(L
106%
49- 155
6084428
0823/06 20:11
1911
ug(L
%-/.
59-155
6084428
0923/0620:11
20.0
ug/L
IOON.
54- 156
6094428
08/23/06 20:11
19.5
ug/L
98%
54- 156
6084428
0823106 20:11
39.5
ug/L
99 %
54 - 156
6OW28
0823/06 20:11
20.1
ug(L
100-/.
1 -234
6094428
0823/06 20:11
19.4
ug/L
97%
1-210
6094428
082310620:11
19.5
ug/L
98%
80-121
6094428
0823/0620:11
21.4
ug/L
107%
30-157
6084428
08/23/0620:1.1
20.0
us/L
100%
1 - 227
6094428
0823106 20:11
20.5
ug/L
102%
17- 193
6084428
0923/06 20:11
21.1
ug/L
106%
70- 131
6084428
0823/06 20:11
21.5
ug/L
108%
37-162
6084428
08/23/06 20:11
19.3
ug(L
96%
41- 129
6084428
0823/06 20:11
22.1
ug/L
110%
69- 129
6084428
0823/06 20:11
22.4
ug/L
112%
62-129
6094428
0823/06 20:11
20.6
ug/L
103%
53 - 144
6OW28
08/23/06 20:11
Page 17 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION 2960 Foster Greghton Road Nashville, TN 37204 - 8CO-7654980 - Fax [phone]
Client Oxford Labs(2860)
Work Order:
NPH2807
1316 S. 5th Street
Project Name:
Oxford Labs
Wilmington, NC 28401
Project Number:
[none]
Arm Laurie Kelly
Received:
08/19/0608:00
PROJECT QUALITY CONTROL DATA
LCS - Cont.
Anxlyte Known Val.
Purgeable Organic Compounds by EPA Method 624
6084428-BSI
Methylene Chloride
20.0
Naphthalene
20A
n-Propylbenzcne
20.0
Styrene
20.0
1,1,1,2-Tenechlomethene
20.0
I,1,2,2-Tetrachlamcthane
20.0
Tetrechl.methere
20.0
Toluene
20.0
1,2,3-Trichlombenzene
20.0
1,2,4-Trichlorobenzene
20.0
1, 1,2-Trichlorocthane
20.0
I,1,1-Trichlorocthane
20.0
Trichlomethene
20.0
Trichloro0uoromcthanc
20.0
1,2,3-Trichlompropane
20.0
1,3,5-Trimethylbenzene
20.0
L2,4-Trimethylbenzene
20.0
Vinyl acetate
100
Vinyl chloride
20.0
oXylene
20.0
m,P-Xylene
40.0
Xylwm total
60.0
Surrogale: 1.2-Dlehloroethane-d4
30.0
Swpgale Dibromoffuorome/hane
30.0
Su,vgale: Toluene-d8
30.0
Surragme: 4-Bromo/luorobenzene
30.0
Acid and Base/Neutral Extractables by EPA Method 625
6084500-BSI
Aeenaphthcne
50.0
Acenaphthylene
50.0
Anthracene
50.0
Benzo (a) anthmcene
50.0
Benzo (a) pyrene
30.0
Benzo lb) Ouoranthene
50.0
Bcnze(g,h,i) perylene
50.0
Benzo (k) Buomnthenc
50.0
4-Bmmophmyl phenyl ether
50.0
Butyl benzyl phthalate
50.0
4-Chlom-3-methyll,knol
50.0
M92-chlorocthoxy)mcthanc
50.0
Target
Analyzed
Analyzed Val
Q Units
%Rec.
Range
Batch
Date/rime
19.0
ug/L
95%
1 - 221
60SU28
08M/06 20:11
12.7
ug/L
64%
1.172
6084428
08/23/06 20:11
20.1
ug/L
IoD%
71 - 128
6084428
0923/06 20:11
21.4
u9/L
107%
74-132
6094429
0823/06 20:11
21.9
ug/L
110%
82 - 125
6094428
08/23/06 2091
16.0
ug/L
80%
46-157
6084429
0103/06 20:11
21.9
ug/L
110%
64- 148
6094428
0823/06 20:11
21.9
ug/L
110%
47 - I50
6OW29
08/23/06 20:11
I8.1
ug/L
90%
18 - 142
6084429
0823/06 20:11
13.8
ug/L
69%
32- 134
60SU29
0823/06 20:11
19.6
ug/L
98%
52- 150
6084428
08/23/06 20:11
22.4
ug/L
112%
52 - 162
6084428
0923/06 20:11
21.3
ug(L
106%
71 - 157
6094428
09/23/06 20:11
25.1
ug/L
126%
17-181
6084428
08/23/06 20:11
16.3
ug/l.
82%
33 - 149
6084429
0823/06 20:11
21.5
ug/L
108%
73- 129
6OW28
O9/23/06 20:11
21.8
ug/L
109%
70-133
6084428
0923/06 20:11
99.5
ug/L
99%
34-166
6084428
0123/0620:11
20.0
ug/L
100%
1-251
6094429
0823/06 20:11
22.0
ug/L
110%
80-127
6094428
0823/06 20:11
45.2
ug/L
113%
77-129
6084428
09/23/06 20:11
67.2
ug/L
112%
SO- 125
6094428
0923/06 2011
30.7
102%
81 - 126
6084428
0823/06 20:11
31.5
105%
88 - 120
6094428
0823/06 20:11
29.8
99%
85- 130
6084428
09/23/06 20:11
28.4
95%
80-124
6084428
09/23/06 20:11
57.9
MNRI
ug/L
116%
47-145
6084500
09/23/06 18:05
58.3
MNRI
ug/L
117%
33-145
6094500
0823/06 18:05
61.2
MNRI
ug/L
122%
27-133
6084500
0823/0618:05
55.2
MNRI
ug/L
110%
33. 143
6084500
0823/06 18:05
61.3
MNRI
ug/L
123%
17-163
6094500
0823/06 18:05
53.0
MNRI
ug/L
106%
24-159
6084500
08/23/06 18:05
51.3
MNRI
ug/L
103%
1-219
6094500
0823/06 18:05
66.1
MNRI
ug/L
132%
11 - 162
6094500
0823/06 18:05
53.8
MNRI
ug/L
108%
53.127
6084500
0923/06 18:05
55.2
MNRI
ug/L
110%
1 - 152
6084300
OW23/06 19:05
49.3
MNRI
ug/L
99-14
22 - 147
6084500
09/23/06 18:05
51.8
MNRI
ug/L
104%
33- 184
6094500
08/13/06 18:05
Page 18 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
29N Foster Creighton Road Nashville. TN 37204 - 800.76&0980 - Fax [phone]
Client Oxford Labs (2860)
Work Order:
NPH2807
1316 S. 5th Street
Project Name:
Oxford Labs
Wilmington, NC 28401
Project Number:
[none]
Arm Laurie Kelly
Received:
08/19/0608:00
PROJECT QUALITY CONTROL DATA
LCS - Cont.
Analyte Knom Val.
Acid and Base/Neutral Extractables by EPA Method 625
6084500-B37
Bis(2-chloroethyl)ether
50.0
Biv(2-ehlomiropropyl)cther
50.0
2Chlomnaphthalene
50.0
2Chlorophawl
50.0
4Chlurophenyl phenyl ether
50.0
Chrysene
50.0
Dibenz (a,h) anthmcene
50.0
Di-n-butyl phthalate
50.0
1,3-Dichlorobemcne
50.0
1,4-Dichlomberecne
50.0
1,2-Dichlorobeozene
50.5
3Y-Dichlorobenzidine
50.0
2.4-Dichlorephenol
50.0
Diethyl phthalate
50.0
2,4-Dimethylphcnol
50.0
Dimcthyl phthalate
50.0
4."inino-2-mcthylphenol
50.0
2,4-Dinioophenol
50.0
2,6-Dinimetolucne
50.0
2,4-Dininotoluene
50.0
Di-noctyl phthalate
50.0
Bis(2-ethylhexyi)phthalate
50.0
Fluorenthene
50.0
Fluomne
50.0
Hexachlorobenzene
50.0
Hexachlorobutadiene
50.0
Hexachlorocyclopentadiene
50.0
Nexachlomohane
50.0
lndeno (1.2,3MA) pyrene
50.0
Isophomne
50.0
Naphthalene
50.0
Nitmbcnecne
50.0
2-Nitrophenol
50.0
4-Nitrephenol
50.0
N-Nitmsedimethylamine
50.0
N-Ninorodiphcnylamine
50.0
N-Nitmsodi-n-propylamine
50.0
Pentachlomphenal
50.0
Phenanducne
50.0
phenol
50.0
Pyrene
50.0
Target Analyzed
Analyzed Val Q Units %Ree. Range Batch Datc)Time
48.5
MNRI
ug(L
97%
12-158
6094500
08/23/06 18:05
52.3
MNRI
ug/L
105%
36-166
6084500
08/23/06 19:05
56.6
MNRI
ug/L
113%
60-118
6094500
09/23/0618:05
46.3
MNRI
ug/L
93%
23-134
6094500
0823/0618:05
59.3
MNRI
ug/L
119%
25-158
6094500
08/23/06 18:05
58.3
MNRI
ug(L
117%
17-168
6084500
0823/06 18:05
48.8
MNRI
ug/L
99%
1-227
6094500
01IM/0618:05
57.4
MNRI
ug/L
115%
1-Its
6084500
08/23/06 18:05
50.9
MNRI
ug/L
102%
1 - 172
6094500
0823106 18:05
51.6
MNRI
ug/L
103%
20-124
6084500
08/23/0618:05
51.8
MNRI
ug/L
103%
32-129
6084500
08/23/06 19:05
64.7
MNRI
ug/L
129%
1-262
6094500
09/23/0618:05
53.1
MNRI
ug/L
106%
39-135
6084500
0WN%18:05
57.8
L, MNRI
ug/L
116%
1 - 114
6094500
08/23/06 18:05
50.2
MNRI
ug/L
100%
32-119
6084500
09/23/06 18:05
59.4
L, MNRI
ug/L
119%
1 - 112
6084500
0823/06 18:05
54.1
MNRI
ugh
108%
1 - 181
6084500
0923/06 18:05
57.9
MNRI
ugh
116%
1 - 191
6094500
0823/06 18:05
63.9
MNRI
ug/L
128%
50-159
6094500
0823/0618:05
63.0
MNRI
ug/L
126%
39-139
6084500
0823106 19:05
49.6
MNRI
ug(L
99%
4-146
6084500
08/23/06 18:05
56.4
MNRI
ug/L
113%
8-158
6094500
0823/0618:05
56A
MNRI
ug/L
113%
26-137
6094500
08/23/06 18:05
59.7
MNRI
ug/L
119%
59-121
6084500
08/23/06 18:05
63.6
MNRI
ug/L
127%
1 - 152
6084500
0823/06 18:05
58.6
L. MNRI
ug(L
117%
24- 116
6084500
0823/06 18:05
41.4
MNRI
ug/L
93%
23 - 86
6084500
0823/06 18:05
50.2
MNRI
ug/L
100%
40-113
6094500
0823/06 18:05
50.0
MNRI
ugh
100%
1 - 171
6094500
0823/06 18:05
56.1
MNRI
ugh
1129.
21 - 196
6094500
08/23/06 19:05
51.8
MNRI
ug/L
104%
21 - 133
6084500
0823/06 18:05
52.2
MNRI
ug/L
104%
35-180
6094500
0823/0619:05
51.1
MNRI
ug/L
102%
29-182
6084500
08/23/06 18:05
23.2
MNRI
ug/L
46%
1 - 132
6094500
0823/06 18:05
29.2
MNRI
ug/L
56%
23-69
6094500
08/23/06 18:05
85.6
L, MNRI
ug/L
171%
42-111
6084500
0823/0618:05
52.2
MNRI
ug/L
104%
1-230
6084500
0823/0619:05
64.2
MNRI
ug/L
128%
14-176
6084500
08/23/0618:05
56.6
MNRI
ug/L
113%
54- 120
6094500
0923/06 19:05
19.2
MNRI
ug/L
38%
5-112
6084500
0823/06 I8:05
60.4
L. MNRI
ug/L
121%
52 - 115
6084500
0823/06 18:05
Page 19 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
29W Foster Creighton Road NashOle, TN 37204' 800-765-0980 -Fax [phone]
Client Oxford Labs (2860)
Work Order:
NPH2807
1316 S. 5th Street
Project Name:
Oxford Labs
Wilmington, NC 28401
Project Number:
(none]
Ann Laurie Kelly
Received:
08/19/0608:00
PROJECT QUALITY CONTROL DATA
LCS - Coot
Anelyte
Known Val.
Analyzed Val
Acid and Base/Neutral Extractables by EPA Method 625
6084500-BSI
1,2,4-Trichlombenzene
50.0
54.5
2,4,6-Trichlomphenol
50.0
56.8
Benzidine
50.0
12.8
1,2-Dipheny1hydrazine
50.0
63.7
2-Methylnaphthalene
50.0
59.3
Surrogate: Terphenyl-d14
50.2
60.4
Surrogate: Z4.6-THbromopheno1
50.2
63.8
Surrogate: Phermld5
50.2
19.2
Surrogate: 2-Plunrobiphnryl
50.2
$1.8
Surrogate: 2-P/uaropheno1
50.2
27.2
Surrogate.: NitrobenzenedS
50.2
50.1
Target Analyzed
Q Units %Rec. Range Batch Date/Time
MNRI
ug/L
109%
44-142
6094500
08/23/0618:05
MNRI
ug/L
114%
37-144
6094500
0823/0618:05
MNRI
ugh
26%
1 - 122
6094500
0823/06 18:05
L, MNRI
ug/L
127%
47- I17
6094500
09/23/06 18:05
L. MNRI
ug/L
119%
34-110
6084500
0823/0618:05
Z2
120%
34-116
6094500
0823/0618:05
127%
16-130
608450D
0823/0618:05
38%
10 - 66
6094500
0823106 18:05
Z2
103%
32-99
6094500
0823/06 18:05
54%
10- 81
6094500
08/23/06 18:05
100%
19-116
6094500
003/0618:05
Page 20 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
2960 Fester Creighton Road Nashville, TN 37204' gW-765-0980 - Fu 615-726-3404
Client Oxford Labs (2860)
Work Order:
NPH2907
1316 S. Sth Street
Project Name:
Oxford Labs
Wilmington, INC 28401
Project Number:
[role]
Aun Laurie Kelly
Received:
08/1910608:00
Analyte Chg. Val.
Purgeable Organic Compounds by EPA Method 624
6084428•MS1
Acralein
NO
Acrylonimle
NO
Benzene
2.86
Bromel,cmene
NO
Bromochlaromethanc
NO
Bromodtchlommethane
ND
Bromoform
NO
Bmmomethane
NO
n-Butylbenzcne
NO
sec-Butylbenzene
NO
tort-Burylbenzrne
ND
Carbon disulfide
NO
Carbon Tetrachloridc
NO
Chlorolso zere
NO
Chlotodibromomethane
NO
Chloroethane
NO
2-Chlomethylvinyl ether
NO
Chloroform
NO
Chlommcthanc
ND
2-Chlorotoluenc
NO
4{Tlomtoluene
ND
1,2-Dibromo-3-chloropropane
NO
1.2-Dibrommularee(EDE)
NO
Dibromammhere
ND
1,2-Dichlombenzene
NO
1,4-Dichlorobenzene
NO
1,3-Dichlorolimcne
NO
Dichlorodi0uaromcthene
NO
12-Dichlomethane
1.30
I,I-Dichloroethnne
ND
cis-12-Dichlomethcne
NO
trans-1,2-Dichloroethcnc
ND
12-Dichloruethene(total)
NO
LI-Dichloroelhene
ND
12-Dichloropmpane
NO
I J-Dichlompropanc
NO
2,2-Dichlompropane
NO
PROJECT QUALITY CONTROL DATA
Matrix Spike
Target Sample Analyzed
MS Val Q Units Spike Cone %Rae. Range Batch Spiked DatNfime
193
ug/L
250
77%
19- 196
6084428
NPH2012-02
0824/06 04:36
203
ug/L
250
81%
73- 132
6084428
NPHNIM2
0824/06 04:36
52.2
ug/L
50.0
99%
37- 151
6084428
NPH2012-02
0824/06 04:36
47.5
ug/L
50.0
95%
77- 125
6084428
NPH2012-02
08/24/06 04:36
55.0
ug/L
50.0
I lly%
71 - 127
6084428
NPH2012-02
08/24/06 04:36
55.1
ug(L
50.0
110%
35-155
6084428
NPH2012-02
08/24/06 04:36
58.1
ug/L
50.0
116%
43- 169
6084428
NPH2O12-02
08/24/06 04:36
63.5
ug/L
50.0
127%
1 - 242
6084428
NPH2012-02
0824/06 0436
63.6
ug/L
50.0
127%
56 - 138
6084429
NPH2O12-02
0824/06 04:36
63.9
ug/L
50.0
128%
56- 136
6094428
NPH2012-02
08/24/06 04:36
65.0
ug/L
50.0
130%
66 - 131
6084428
NPH2O12-02
0824106 04:36
53.7
ug/L
50.0
107%
81 - 127
6094428
NPH2012-02
08/24/06 04:36
60.6
ug/L
50.0
121%
70-140
6094428
NPH2012-02
08124/0604:36
52.0
ug(L
50.0
104%
37- 160
6084428
NPH2O12-02
0824/06 04:36
56.6
ug(L
50.0
113%
53 - 149
6084428
NPR2012-02
0824/06 04:36
47.8
ug/L
50.0
96%
14 - 230
6084428
NPH2O12-02
0824/06 04:36
0.00
M2 ug(L
250
0%
1.305
6084428
NPK2012-02
0924/06 0496
51.7
ug/L
50.0
103%
51 - 138
6084428
NPH2O12-02
0824/06 04:36
50.2
ug/L
50.0
100%
1 -273
6084428
NPH2O12-02
0824/06 04:36
55.0
ug(L
50.0
110a/e
61 - 144
6094428
NPH2012-02
0824/06 04:36
55.8
ug/L
50.0
112%
77 - 127
6084428
NPH2O12-02
09/24/06 04:36
49.0
ug/L
50.0
98%
55 - I40
6084428
NPH2012-02
0824/06 04:36
52.5
ug/L
50.0
105%
77-122
6084428
NPH2012-02
0924/0604:36
52.4
ug/L
50.0
105%
81 - 121
6084428
NPH2O12-02
08/24/06 04:36
56.6
ug(L
50.0
113%
18-190
6084428
NPH2012-02
09/24/0604:36
53.8
ug/L
50.0
109%
is-190
6084428
NPH2O12-02
08/24/06 04:36
57.0
ug/L
50.0
1140/9
59- 156
6084428
NPH2O12-02
0824/06 04:36
68.6
ug/L
50.0
137%
33 - 142
6084428
NPH2O12-02
0824/06 04:36
50.6
ug/L
50.0
99%
49-155
6094428
NPH2O12-02
0824/0604:36
49.0
ug/L
50.0
98%
59-155
6084428
NPH2O12-02
08/24/06 04:36
49.9
ug/L
50.0
100%
54- 156
6084429
NPH2O12-02
0824106 04:36
51.4
ug/L
50.0
103%
54 - 156
6084428
NPH2012-02
0824/06 04:36
101
ug/L
100
101%
54- 156
6084428
NPH2O12-02
08/24/06 04:36
55.6
ug/L
50.0
111%
1 -234
6084428
NPH2O12-02
08/24/06 04:36
48.3
ug/L
50.0
97e
1 - 210
6094428
NPH2O12-02
08/24/06 04:36
47.0
ug/L
50.0
94%
80-121
6084428
NPH2O12-02
08/24/06 04:36
49.6
ug/L
50.0
99%
30- 157
6084428
NPH2O12-02
0824,'06 04:36
Page 21 of 24

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TestAmerica
ANALYTICAL TESTING CORPORATION
Client Oxford Labs (2860)
1316 S. 5th Street
Wilmington, NC 28401
Ann Laurie Kelly
Teatrltnerlea - Nashville, TN
2960 Faller Creighton Road NashviNs, TN 37204 '80046"980' Fax etS7263404
Work Order:
Project Name:
Project Number:
Received:
CERTIFICATION SUMMARY
NPH2807
Oxford labs
[none]
08/19/06 08:00
Method
Matrix
AMA
Nelac
North Carolina
EPA 377.IM
Water
N/A
X
EPA 608
Water
N/A
X
X
EPA 624
Water
N/A
X
X
EPA 625
Water
N/A
X
X
Page 23 of 24

TestAmerica
ANALYTICAL TESTING CORPORATION
2960 Foster Creighton Rose Naslrvl6e, TN 37204' 804765-M0' Fax [phone]COe
Client Oxford Labs (2860)
Work Order:
NPH2807
1316 S. 5th Street
Project Name:
Oxford Labs
Wilmington, NC 28401
Pmject Number:
[none]
Aim Laurie Kelly
Received:
08/1910608:00
DATA QUALIFIERS AND DEFINITIONS
H3 Sample was received and analyzed past holding time.
L Laboratory Control Sample and/or Laboratory Control Sample Duplicate recovery was above the acceptance limits. Analyte not
detected, data not impacted.
L2 Laboratory Control Sample and/or Laboratory Control Sample Duplicate recovery was below acceptance limits.
Mi The MS and/or MSD were above the acceptance limits due to sample matrix interference. See Blank Spike (LCS).
M2 The MS and/or MSD were below the acceptance limits due to sample matrix interference. See Blank Spike (LCS).
MNRI There was no MS/MSD analyzed with this batch due to insufficient sample volume. See Blank Spike.
R4 Due to the low levels of analyte in the sample, the duplicate RPD calculation does not provide useful information.
Z2 Surrogate recovery was above the acceptance limits. Data not impacted
METHOD MODIFICATION NOTES
Sulfite 377.1 M - Sulfite method modified for use of Hach method 8216.
Page 24 of 24

" °. °0 4: 11 C" 161 6, Laborat@r -
1316 S. Fifth Street Page 1 of 2
Wilmington, NC 28401
Telephone; 910-763-9793 NC/WW Cert #:075
Fax: [phone] NC/DW Cert #: 37721
www, oxfordla boratory. com
Laboratory Report
— Prepared for —
Neal Davis
International Paper Report Date: 7/612006
100 Gaston Road Date Received: 6/612006
Roanoke Rapids, NC 27370 Work Order#: 090553102
Project No.: Cust Code: IPROAN
Project ID: Priority Pollutant 06/06/06 Cust P.O.# S060903375
No. Sample ID Date Sampled Time Sampled Matrix Sample Type Condition
001 FLOW TO RIVER G/G/2006 8:40 WW Grab 4 +1- 2 deg C
Analyzed
Test Performed Method Results Date Time Qualifier
Cyanide SM 4500 C8E <0.005 mg/L 6/•7/06 9;55
No. Sample ID
Date Sampled
Time Sampled Matrix
Sample Type Cond lion
002 FLOW TO RIVER
6/6/2006
8:40 WW
Composite 4 +1-2 deg C
Analyzed
Test Performed
Method
Results
Date Time Qualifier
Antimony
EPA 200.8
<0.005 mg/L
6/30/OB 13:38
- Arsenic
EPA 200,8
.019 mg/L
6M/06 15:30
Beryllium
EPA 200.8
<0.005 mg/L
6/28/o6 15:30
Cadmium
EPA 200.8
<0.002 mg/L
6/28/06 16:30
Chromium
EPA 200.8
<0.005 mg/L
6/28/06 15:30
Copper
EPA 200.8
.007 mg/L 9
6/30/06 13:38
Lead
EPA 200.8
<0.003 mg/L
6/28/06 15:30
Nickel
EPA 200.8
<0.005 mg/L
6128/06 15:30
Selenium
EPA 200.8
<0.005 mg/L
W28/06 15:30
Silver
EPA 200.8
<0.002 mg/L
6/28/06 15:30
Thallium
EPA 2001
<0.005 mg/L
6128108 15:30
Znc
EPA 200.8
.029 mg/L
6130/06 13:38
Mercury
EPA 245.1
<O.000Z mg/L
6/8106 9:38
Total Hardness Calc. (Wvtr)
114.8 mg/L
6113/06 13:00
Calcium
SM 3111B
35.6 mg/L
6/13/09 13:00
Magnesium
SM311/B
6.29mg/L
6/13106 14:50
In. Sample ID Date Sampled Time Sampled Matrix Sample Type Condition
r03 FLOW TO RIVER 6/6/2006 8:40 WW Composite 4 +1- 2 deg C
Analyzed
Test Performed Method Results Date Time Qualifier
Phenol SM 510 A•B 006 mg/L 6/12/06 9:00

INTERNATIONAL@ PAPER
c
ROANOKE RAPIDS MILL
OANOKE RAPIDS. NC 27870
PHONE: [phone]
July 21, 2005't
Attention:
QA`tc Jc
Aquatic Toxicology Unit
'NN
DWQ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, N.C. 27699- 1621
Dear Sir or Madame:
Enclosed is an original AT-1 form for effluent chronic toxicity analysis performed in
June 2005. Results of the test indicate that we passed. If you have any questions, please
feel free to contact me at [phone].
Si�Y
Chris Puryear
Environmental Supervisor
xc: Paul Kinnin
Neal Davis
Mary Lee Ransmeier
Judy Garrett - DE+NR

ZY •onmental Testing Sed i, Inc.
PO Box 7565 Phone: [phone]
Asheville, NC 28802 Fax: [phone]
E-mail: [e-mail]
Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LCso Date: June 28, 2005
Facility: International Paper NPDES #: NC- 0000752 Pipe #: 001 County: Halifax
Roanoke Rapids
Laboratory Performing Test: Environmental Testjgg Solutions,
Signature of Operator in Responsible Charge:
Signature of Laboratory Supervisor: ,I ( a
Mail Original To: North Carolina Department of Environment and Natural Resourm:
DWQ/ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
North Carolina Ceriodaphnia Chronic Pass/Fail Reproduction Toxicity Test
r•.,..re..i n.oa..xa...e 1 7 7 d 5 I; 7 R 9 10 11 12
Commence .
pwjaet: 1907
Sanplec 050608.03. 050611 M4
Number of Yaung Produced
125
131129
124
132
130
32
131123
129
126
27
Adult Survival: (1.)ive, (D)ead
I L
I L
I L
I L
I L
I L
L
I
L
Effluent Percentage 3.7%
1 2 3 4 5 6 7 8 9 10 11 12
PH (S.U.) Ist Sam le 1st Sam le 2nd Sample
Control 7.48 7.48 7.49 7.27 7.08 7.43
Treatment 2 7.61 7.67 7.73 7.48 7.34 7.54
Vi l+i y a: y W
D.O. (mg/L) 1st Sam le 1st Sample 2nd Sa le
Control 8.1 7.7 8.0 7.7 7.7 7.9
Treatment 2
LC.,./Acute Toxicity Test
(Mortality expressed as %, combining replicates.)
Concentration ('9 )
Mortality (%1
Chronic'rest Results
Calculated 1. _3.344
Tabular t 2508
% Reduction: -15.0
Percent
Average
Morality
Rrylrodaction
Control
Cmarol
0.0
28.3
Treatneta 2
Trea u.nt 2
0.0
32.5
Control CV
11.2
Pass Fail
4aaolapWu
pem.V YObwJ
100
StartDate: 06-08-05
Alection (Start) Date:
Sample 1 06-06-05 Sample 2 06-W-05
Sample Type/Duration
Gab ca Our�ua+
Senple I X 21 c —
b L—_
Sanple2 X
O
Alkafioity (ng CnCO3/1.)
Hwduc. 06 CsCO,/LI
Conductivity kpid alc+n)
Total Residual LLlorila: mgyl-
Sanpk Tcnp. a Remipt (T I
�""
I5;
1670 I'l I0
u.:re�"
Gn.11l GIL IU
LC50 - Method of Determinution
950h• Confidence LimitsTrimmed Spearman Karber a J 's
to Probit
Other t'uunol
11
fall..
Organism'rested: Cerimlaphniaa dahia Duration: 7-days p11 (SA I.) DO (ulg/lA
DWQ foram AT-] (3187) rep. 11/95

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
February 10, 2005
Mr. James R. Jackson, Jr.
International Paper Corporation
Roanoke Rapids Mill
100 Gaston Road
Roanoke Rapids, NC 27870
Subject: Compliance Evaluation Inspections
NPDES Permit No. NC0000752
Stormwater Permit No. NCS000106
Halifax County
Dear Mr. Jackson:
Enclosed are reports of inspections I conducted on Janury 7, 2005. The assistance of
Chris Puryear, Neal Davis, Mary Lee Ransmeier and Paul Kinnin is appreciated.
A tour of the facility was conducted at the time of the inspection. Laboratory records and
operator records were reviewed and no discrepancies were found.
Stormwater records were review and found to be complete.
A review of the data for the previous year, December 2003 through 2004 was reviewed.
The only violations noted were pH violations on May 27, 2004 for outfalls 002 and 003. This
was caused by low pH in the river and has been addressed by the Division's enforcement policy.
If you have questions concerning the inspection, please call me at [phone].
Sincerely,
J��ett
Y
Environmental Chemist
1628 Mail Service Center, Raleigh, North Carolina 27699-1628
3800 Barrett Dr.., Raleigh, North Carolina 27609
Phone: [phone] FAX [phone] Internet:: h2o.encstate.nc.us
An Equal Opportunity/Affirmative Action Employer— 50% Recycledl10% Post Consumer Paper
On
e
NCarolina
wra!!y

Permit: NC0000752 Owner - Facility: International Paper Company- Roanoke Rapids Mill
Inspection Date: 01/07/05 Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted anew application?
Yes
❑
No
❑
NA
0
NE
❑
Is the facility as described in the permit?
❑
N
❑
❑
Are there any special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment. Several treatment units are not described in the permit, including the Fly Ash pond, the woodyard
stormvvater pond, and the sludge press building which contains 2 rotary screen thickeners and 2 sludge presses.
Yes
No
NA
NE
Operations B Maintenance
Does the plant have general safety structures in place such as rails around or covers over tanks, pits, or wells?
E
❑
❑
❑
Is the plant generally clean with acceptable housekeeping?
0
❑
❑
❑
Comment:
Bar Screens
Yes
No
NA
NE
Type of bar screen
a Manual
❑
b.Mechanical
Are the bars adequately screening debris?
❑
❑
❑
Is the screen free of excessive debris?
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in goad condition?
0
❑
❑
❑
Comment:
Yes
Primary Clarifier
Is the clarifier free of black and odorous wastewater?
0
No
❑
NA
❑
NE
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
E
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the sludge blanket level acceptable?
❑
❑
❑
Comment:
Aeration Basins
Yes
No
NA
NF
Mode of operation
Type of aeration system
Is the basin free of dead spots?
❑
❑
❑
Are surface aerators and mixers operational?
❑
❑
❑
Are the diffusers operational?
❑
❑
E
❑
Is the foam the proper color for the treatment process?
N
❑
❑
❑
Does the foam cover less than 25 % of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
E
❑
❑
❑
Are settleometer results acceptable?
❑
❑
0
❑
Comment: 31 surface aerators. D.O. kept around 2.5 mg/I
cons

Permit: NC0000752 Owner - Facility: International Paper Company - Roanoke Rapids Mill
Inspection Date: 01/07/05 Inspection Type: Compliance Evaluation
Lacco s Yes No NA NE
Type of lagoons? Facultative
Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
Is a recirculation line present?
❑
❑
0
❑
Is lagoon free of excessive floating materials?
IN
❑
❑
❑
Are baffles between ponds or effluent baffles adjustable?
N
❑
❑
❑
Are dike slopes clear of woody vegetation?
E
❑
❑
❑
Are weeds controlled around the edge of the lagoon?
0
❑
❑
❑
Are dikes free of seepage?
0
❑
❑
❑
Are dikes free of erosion?
N
❑
❑
❑
Are dikes free of burrowing animals?
E
❑
❑
❑
Are sludge levels appropriate?
0
❑
❑
❑
Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations?
E
❑
❑
❑
If excessive algae is present, has barey strew been used to help control the growth?
❑
❑
0
❑
Is the lagoon surface free of weeds?
■
❑
❑
❑
Is the lagoon free of short circuiting?
0
❑
❑
❑
Comment: Sludge is removed from the 1st lagoon approximately every 3 years.
Laboratory
Are field parameters performed by certified personnel or laboratory?
Yes
0
No
❑
NA
❑
NE
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
m
❑
❑
❑
Is the facility using a contract lab?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
E
❑
❑
❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
E
❑
Incubator (BOD) set to 20.0 degrees Celsius +1- 1.0 degrees?
E
❑
❑
❑
Comment: Checked November 04 data.
No
NA
N
Flow Measurement - Influent
Is flow meter used for reporting?
Yes
❑
0
❑
❑
Is flow meter calibrated annually?
❑
❑
❑
Is flow meter operating properly?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment: no chart recorder.
Yes
No
NA
NF
Flow Meacm mrement - Fffluent
Is flow meter used for reporting?
N
❑
Cl
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is flow meter operating properly?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
❑
Comment:
Yes
No
NA
NE
Record Keepiria
Are records kept and maintained as required by the permit?
E
❑
❑
❑
Is all required Information readily available, complete and current?
N
❑
❑
❑
Are all records ma rtained for 3 years (lab. mg. required 5 years)?
0
❑
❑
❑

Permit: NC0000752 Owner - Facility: International Paper Company - Roanoke Rapids Mill
Inspection Date: 01/07/05 Inspection Type: Compliance Evaluation
Record Keeoino
Are analytical results consistent with data reported on DMRs7
Yes No
❑
NA
❑
NE
❑
Are sampling and analysis data adequate and include:
coo
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Plant records are adequate, available and include
❑
❑
❑
O&M Manual
As built Engineering drawings
Schedules and dates of equipment maintenance and repairs
Are DMRs complete: do they include all permit parameters?
❑
❑
❑
Has the facility submitted its annual compliance report to users?
N
❑
❑
❑
(If the facility is = or> 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
0
❑
❑
❑
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
0
❑
❑
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Is the facility description verified as contained in the NPDES permit?
0
❑
❑
❑
Does the facility analyze process control parameters, for example: MLSS, MCRT, Settleable Solids, DO, Sludge
❑
❑
❑
Judge, pH, and others that are applicable?
Facility has copy of previous year's Annual Report on file for review?
0
❑
❑
❑
Comment: They do a selfcertfication program for 24/7 operation.
Yes
No
NA
NF
Influent Samrlino
Is composite sampling flow proportional?
E
❑
❑
❑
Is sample collected above side streams?
0
❑
❑
❑
Is proper volume collected?
❑
❑
❑
Is the tubing clean?
❑
❑
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
❑
❑
❑
Is sampling performed according to the permit?
0
❑
❑
❑
Comment:
Yes
No
NA
NE
Fffli ni r amolino
Is composite sampling ftow proportional?
❑
❑
❑
Is sample collected below all treatment units?
❑
❑
❑
Is proper volume collected?
E
❑
❑
❑
Is the tubing clean?
Cl
❑
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
❑
❑
❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
❑
❑
Cl
Comment:
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? 0 ❑ ❑ ❑
Comment

Permit
(If the present permit expires in 6 months or less). Has the permitted submitted a new application?
Yes No
❑ ❑
NA NE
M ❑
Is the facility as described in the permit?
❑
❑
❑
Are there any special conditions for the permit?
❑
❑
❑
Is access to the plant site restricted to the general public?
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0 ❑
❑
❑
Comment:
Record Keep no
Yes No
NA
NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
M
❑
❑
❑
Are all records maintained for 3 years (lab. mg. required 5 years)?
M
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
❑
❑
M
❑
Are sampling and analysis data adequate and include:
0
❑
❑
❑
Dates, times and location of sampling
❑
Name of individual performing the sampling
❑
Results of analysis and calibration
❑
Dates of analysis
❑
Name of person performing analyses
❑
Transported COCs
❑
Plant records are adequate, available and include
❑
❑
0
❑
O&M Manual
❑
As built Engineering drawings
❑
Schedules and dates of equipment maintenance and repairs
❑
Are DMRs complete: do they include all permit parameters?
❑
❑
0
❑
Has the facility submitted its annual compliance report to users?
❑
❑
0
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
E
❑
❑
❑
Is the ORC visitation log available and current?
M
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
Cl
❑
6
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
M
❑
Is a copy of the current NPDES permit available on site?
M
❑
❑
❑
Is the facility description verified as contained in the NPDES permit?
0
❑
❑
❑
Does the facility analyze process control parameters, for example: MLSS, MCRT, Settleable Solids, DO, Sludge
❑
❑
M
❑
Judge, pH, and others that are applicable?
Facility has copy of previous years Annual Report on file for review?
❑
❑
0
❑
Comment:
Yes
No
NA
NE
Fffltient Pine
Is right of way to the outfall properly maintained?
0
❑
❑
❑
Are receiving water free of solids and floatable wastewater materials?
■
❑
❑
❑
Are the receiving waters free of solids / debris?
0
❑
❑
❑
Are the receiving waters free of foam other than a trace?
❑
❑
❑
Are the receiving waters free of sludge worms?
❑
❑
❑
If effluent (diffuser pipes are required) are they operating property?
❑
❑
M
❑
Comment:

United States Ervironmental Protection Agency
FormApproved.
EPA Washington, D C 20460
OMB No. 2040-0057
OMB
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/no/day Inspection Type Inspector Fee Type
1 U 2 U 31 NCS000106 111 121 05/Ol/07 117 18u 19u 20u
Remarks
211111111111111111111111lllllllllllllllllllllllll6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
67 I 169 70 U 71 u 72 u 73 u J 74 75I M I L L I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
01:30 PM 05/O1/07
03/03/07
Roanoke Rapids Mill
Exit Time/Date
Permit Expiration Date
N Roanoke Ave
Roanoke Rapids NC 27870
04:45 PM 05/01/07
08/03/31
Names) of Onsite Representative(s)/)-dles(s)/Phone and Fax Numbers)
Other Facility Data
Name, Address of Responsible OfficiaVTitle/Phone and Fax Number
C
Chris C Puryean,100 Gaston Rd Roanoke Rapids NC 27870/EnvironmentaFontacted
Supervisor/252-533-6237/ NO
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Records/Reports Self -Monitoring Program . Effluent/Receiving Waters
Storm Water Other
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checldists as necessary)
(See attachment summary)
Names) and Signatures) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Judy E 6acrett RRO WQ//919-571-4700 Ext.270/9195714718
Signature of Management Q A Reviewer Agency/Office/Phones and Fax Numbers Date
EPA Form 356D-3 (Rev 9-94) Previous editions are obsolete.

NPDES
31 NCS000106 ill 12
yr/mo/day Inspection Type
75/O1/0� �17 18 LCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checldists as necessary)

P
Permit: NC0000752 Owner - Facility: International Paper Company -
Roanoke Rapids Will
Inspection Date: O1/07/05 Inspection Type: Compliance Evaluation
Yes
No
NA
NE
Solids_ Handling Eauioment
Is the equipment operational?
■
❑
❑
❑
Is the chemical feed equipment operational?
■
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum fitters?
■
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
■
❑
❑
❑
Is the site free of excessive moisture in belt filler press sludge cake?
■
❑
❑
❑
Comment:
Yes
No
NA
NE
Chem .al Feed
Is containment adequate?
■
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Are backup pumps available?
■
❑
❑
❑
Is the site free of excessive leaking?
■
❑
❑
❑
Comment:
Yes
No
NA
NE
Fffluent Pipe
Is right of way to the curtail properly maintained?
■
❑
❑
❑
Are receiving water free of solids and floatable wastewater materials?
■
❑
❑
❑
Are the receiving waters free of solids / debris?
■
❑
❑
❑
Are the receiving waters free of foam other than a trace?
■
❑
❑
❑
Are the receiving waters free of sludge worms?
■
❑
❑
❑
If effluent (diffuser pipes are required) are they operating property?
❑
❑
■
❑
Comment:

• Michael F. Easley, Governor
I William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
r Alan W. Klimek, P.E. Director
Division of Water Quality
January 27, 2005
5149
Mr. Chad Leinbach
Conner Consulting, LLC
1284 Windy Ridge Rd.
Chapel Hill, NC 27517-
SUBJECT: Wastewater/Groundwater Laboratory Certification <�
Dear Mr. Leinbach:
We are requesting discharge monitoring report sheets and corresponding bench sheet data packets for the month of July 2004
for a minimum of two commercial or municipal clients for our review. The purpose of the data review inspection will be to verify
documented quality control/quality assurance procedures and adequacy in meeting the requirements of 15A NCAC 2H .0800. The scope
of the data review inspection will include all methods marked on Attachment I of the field operations current North Carolina Wastewater
/Groundwater Certificate and for marked on the application for NC Wastewater/Groundwater Laboratory Certification. A copy of the current
Attachment I is enclosed for your reference.
The complete data packets should include all of the supporting documentation for data analysis. This requires, but is not limited
to: copies of final reports, instrument calibration logs, calibration curves, bench sheets, standard preparation logs, reagent preparation logs,
calibration curves and sample receipt/chain of custody forms. These data sets will be used to assess the quality of your data. The
requested monitoring report sheets and data packets are to be received by this office on or before February 11, 2005. We will
contact your facility at a later dale to schedule an on -site inspection.
Thank you for your time and cooperation. I can be contacted at [phone] (extension 272), if you have questions.
Sincerely,
Edith He derson
Laboratory Section
cc: James Meyer
Raleigh Regional Office
' Carolina
Laboratory Section 1623 Mail Service Center, Raleigh, NC 27699.1623
4405 Reedy Creek Road; Raleigh, NC 27607
Phone [phone] / FAX [phone] / Internet: w Awglab.org
An Equal Opportunity/Affirmative Action Employer - 50% Recyded/10% Post Consumer Paper

of wArF9
\11 QG North Carolina Departmenl
h
O '�
January 6, 2005
Mr. Thomas C. Puryear, Environmental Supervisor
International Paper Corporation
P.O. Box 580
Roanoke Rapids, NC 27870
Subject: Compliance Evaluation Inspection
International Paper Roanoke Rapids Plant
NPDES Permit No. NC0000752
Halifax County
Dear Mr. Puryear:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
vironment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Attached is a checklist of an inspection which I conducted at the subject
facility on June 17, 2003. The assistance of Mr. Neal Davis was appreciated.
The Pipe 002, 003 and 004 discharges were also inspected during the inspection.
The facility was found to be compliant. A review of the data submitted
for the facility during the previous 12 month period indicated compliance with the
NPDES Permit.
If you have questions concerning the inspection, please call me at (919)
571-4700.
Sincerely
Id
lG -�
y Garrett
Environmental Chemist
Raleigh Regional Office 1628 Mail Service Center phone [phone]
Water Quality Section Raleigh, NC 27699-1628 facsimile [phone]
Customer Service
1-877-623-6748

0
United States Environmental Protection Agency
_j
Form Approved.
EI7 AA Washington D C 204W
r
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fee Type
1 U 2 151 31 N00000752 111 121 03/06/17 117 18u 19U 201 I
U
Remarks
211111111111111111111111111111111111111111111111166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 OA Reserved
67 L_____j 69 70 U 71 U 72 U 73 w 74 75I I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
Roanoke Rapids Mill
09:00 AM 03/06/17
97/10/01
Exit Time/Date
Permit Expiration Date
N Roanoke Ave
Roanoke Rapids NC 27870
12: 30 PM 03/06/17
02/05/31
Name(s) of Onsile Representative(syTdles(s)/Phone and Fax Number(s)
Other Facility Data
Neal R Davis/ORC/252-533-6295/
Name, Address of Responsible Official/Title/Phone and Fax Number
William J Cooper, Jr,100 Gaston Rd Roanoke Rapids NC Contacted
27870/Vice-President/252-533-6000/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit ■ Flow Measurement ■ Operations & Maintenance Records/Reports
Self -Monitoring Program ■ Sludge Handling Disposal ■ Effluent/Receiving Waters ■ Laboratory
Storm Water ■ Other
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Judy EEGarrett RRO WQ//919-571-4700/919-571-4718
Signature of Management O A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3550-3 (Rev 9-94) Previous editions are obsolete.

0
NPDES ydmo/day Inspection Type
NC0000752 11 12I 03/06/1� 17 18 U
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checldists as necessary)

r�
Permit: NC0000752 Owner - Facility: International Paper Company - Roanoke Rapids Mill
Inspection Date: 06/17/03 Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
Yes
❑
No
❑
NA N
0 ❑
Is the facility as described in the permit?
0
❑
❑ ❑
Are there any special conditions for the permit?
❑
IN
❑ ❑
Is access to the plant site restricted to the general public?
N
❑
❑ ❑
Is the inspector granted access to all areas for inspection?
0
❑
❑ ❑
Comment: Also 2 pipes for cooling water discharges(002 and 003) and a carwash rinse water discharge(004).
Doerabons & Maintenance
Yes
Nn
NA NI
Does the plant have general safety structures in place such as rails around or covers over tanks, pits, or wells?
E
❑
❑ ❑
Is the plant generally clean with acceptable housekeeping?
E
❑
❑ ❑
Comment:
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
❑
❑
❑
Is the screen free of excessive debris?
❑
❑
❑
Is disposal of screening in compliance?
E
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment:
Primary Clarif r
Is the clarifier free of black and odorous wastewater
Yes
No
❑
NA
❑
NE
❑
Is the site tree of excessive buildup of solids in center well of circular clarifier
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
❑
❑
❑
Is the site free of evidence of short-circuiting?
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the sludge blanket level acceptable?
0
❑
❑
❑
Comment:
Yes
Nn
NA
NF
Lagoons
Type of lagoons?
Number of lagoons in operation at time of visit?
3
Are lagoons operated in?
Series
Is a re -circulation line present?
❑
N
❑
❑
Is lagoon free of excessive floating materials?
E
❑
❑
❑
Are baffles betvveen ponds or effluent baffles adjustable?
E
❑
❑
❑
Are dike slopes clear of vvoody vegetation?
0
❑
❑
❑
Are weeds controlled around the edge of the lagoon?
0
❑
❑
❑
Are dikes free of seepage?
0
❑
❑
❑
Are dikes free of erosion?
0
❑
❑
❑
Are dikes free of burrovnng animals?
E
11
❑
❑

0
Permit: NC0000752 Owner - Facility: Intemational Paper Company - Roanoke Rapids Mill
Inspection Date: 06/17/03 Inspection Type: Compliance Evaluation
La000ns
Are sludge levels appropriate?
Yes
E
No
❑
NA
❑
NF
❑
Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations?
No
❑
❑
If excessive algae is present, has barley straw been used to help control the growth?
❑
❑
0
❑
Is the lagoon surface free of weeds?
0
❑
❑
❑
Is the lagoon free of short circuiting?
❑
❑
❑
Comment:
I ahnratory
Are field parameters performed by certified personnel or laboratory?
Yes
0
No
❑
NA
❑
NE
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
Is the facility using a contract lab?
E
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
11111
❑
❑
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
0
❑
❑
❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius+/- 1.0 degrees?
0
❑
❑
❑
Comment
Flow Measurement - Effluent
Is flow meter used for reporting?
Vac
0
No
❑
NA
❑
NIP
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is flow meter operating properly?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
❑
Comment:
Record Keep no
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (labreg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Are sampling and analysis data adequate and include:
0
11011
Dates, times and location of sampling
❑
Name of individual performing the sampling
❑
Results of analysis and calibration
❑
Dates of analysis
❑
Name of person performing analyses
❑
Transported CCCs
❑
Plant records are adequate, available and include
E0130
CAM Manual
❑
As built Engineering drawings
❑
Schedules and dates of equipment maintenance and repairs
❑
Are DMRs complete do they include all permit parameters?
N
❑
❑
❑
Has the facility submitted its annual compliance report to users?
❑
❑
00
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
0
❑
❑
❑
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
E
0
0
0

P
Permit: NC0000752 Owner - Facility: Intemational Paper Company - Roanoke Rapids Mill
Inspection Date: 06/17/03 Inspection Type: Compliance Evaluation
Is the backup operator certified at one grade less or greater than the facility classification?
011
0
0
Is a copy of the current NPDES permit available on site?
0
0
0
Is the facility description verified as contained in the NPDES pernit?
0
0
0
Does the facility analyze process control parameters, for example: MLSS, MCRT, Settleable Solids, DO, Sludge
Judge, pH, and others that are applicable?
Facility has copy of previous years Annual Report on file for review?
0
0
N
0
Comment:
Influent Samnlina
Is composite sampling flow proportional?
Yes No
0
NA
0
NE
0
Is sample collected above side streams?
0
0
0
Is proper volume collected?
0
0
0
Is the tubing clean?
0
0
0
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
0
0
0
Is sampling performed according to the permit?
0
0
0
Comment:
Ye=
No
NA
NE
FfflFffl me_y nt Samnl no
Is composite sampling flow proportional?
0 0
0
0
Is sample collected below all treatment units?
E
0
0
0
Is proper volume collected?
0
0
F-
Is the tubing clean?
0
0
0
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
0
0
0
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
0
0
0
Comment:
Yes
No
NA
NE
Fffluent Pine
Is right of way to the outfall properly maintained?
0
0
L7
Are receiving %rater free of solids and floatable wastewater materials?
0
0
0
Are the receiving waters free of solids / debris?
0
0
0
Are the receiving waters free of foam other than a trace?
0
0
0
Are the receiving waters free of sludge worms?
0
0
0
If effluent (diffuser pipes are required) are they operating properly?
0
0
0
Comment:

STORMWATER DISCHARGE MONITORING REPORT (DMR)
Part A: Facility Information
Samples Collected In Quarter: i © (beginning) and
Certificate Of Coverage No. Al 114
Facility Name 313 A Tr-U r- k 5 G,D PQ
Facility Contact S' �,nr lei V�ULkayesn
Facility Contact Phone No. (9 11
Part B: Snecihc Monitoring Reauirements
P1 © :� (ending,
County of Facility C. kci. �m
Name of Laboratory !>t TEL
Lab Certification # 9 2
Outfatl=
Date.::. ; - 50050'-" .`
OO400p ,"..
00556- .:;
0090•-:.-
No.:,>
samplae Total.
Collected Flow _
...
.
TRc6
Total
swpmded
Solid:
T tq1+
meldd/ r MG
unit
m
m
oor
0 0 2
-23-a
b
rA
Indeterminate off -site drainage area. Point chosen to quantify any downstream impacts
Outfall No. I is roadside ditch down gradient from the vegative strip.
Outfall No. 2 is across U. S. # I and the railroad tracks.
1 JAN - 5 2005
�_hNR R,eLE�
SWU263-081701 Page 1 ot2

A J ATEL
Aqua Twh Environmental Laboratories, Inc.
- CERTIFICATE OF ANALYSIS -
Client#: S1042
B & B Mulch
Report Date: 06-Dec-04
6991 Old U.S. i
New Hill, NC 27562-
Phone: [phone] Ext:
Attn: Charles Buchanan FAX: [phone]
Our Lab #: MAR04-22531 Your Sample ID: Site # 1
Date Logged -In: 11/29/04 Sample Source: Stormwater
Sample Type: Stormwater Client Project #:
Project #: 2592 Date Submitted to Lab: 11/23/2004 PO#; CM-1208
- COLLECTION INFORMATION -
Date/Time/By: 11/23/04 9:30 AM Charles Buchanan
EPA Method Analyst Analysis Date Parameter Result Units PQL
SM4500-NO3-F JEL
12/3/04 Nitrogen, Nitrate + Nitrite (as N)
0.10
mg/L 0.05
Calculation
Nitrogen, Total
1.89
mg/L
351.2 TLL
12/1/04 Nitrogen, Total Kjeldahl, TKN
1.79
mgfL 0.50
SM4500-P-E2 JEL
12/2/04 Phosphorus, P
0.62
mg/L 0.02
�E/nd of Report
Report Approved By: /(
Deborah K.Johnson
This report shall not be reproduced, except in its entirety, without the written approval ofthe laboratory. The results presented on t erafcate of
Analysis only reflect those parameters that were requested by the client on the chain ofcustody or other documentation received wit the sample(s). The analytical results relate only to the items tested. Certifications: NCDWQ263WCDEH39700A20071,M71071A21A-102325-PB
Your Sample ID: Site it I
Page I
Lab NumberUAR04-22531
1776 MARION-WALDO RD, a P.O. BOX 436 • MARION, OH 43301-0436
PHONE [phone] • 1-800-873-2835 e FAX [phone]

ATEL ,t-'; .
. 100810V
Aqua Tech Environmental Laboratories Inc
.
- CERTIFICATE OF ANALYSIS -
Attn: Chad Watkins
B & B Mulch
6991 Old USl
New Hill, NC 27562-
Client #: S1042
pEC 15 200Q
Report D te: Dec-04
Phone: [phone] Ext:
FAX: [phone]
ATEL Lab #:
SAN04-02592
- COLLECTION INFORMATION -
Date Received:
11/23/2004
Sample ID:
Site #1
Date Logged -In:
11/23/04
Collection Date:
11/23/2004
Quote #:
Collection Time:
9:30 AM
Client PINT:
2592
Collected By:
Charles Buchanan
Client Project #:
Matrix:
Source Water
Sample Source:
Source Water
Test Group Test
Method Result Units Analysis Date Analyst WS#
SS
160.2
22442
Residue, Nonfilterable (Suspended)
700
mg/L 11/30/2004 MAj
BOD
405.1
22436
BOD, 5 Day
4
mg/L 11/24/2004 MAI
INORG-MAR
Inorganic Analysis To Marion
12/07/2004 rlc
--- QC Related To Sample ---
WS# QC Lab#
QC Test lD Result Units
Amount - QC Calculations-
- QC Calculations- Lower Upper
Code
Of Spike Oct
QCI Limit Limit
22436 SAN04-02592
D BOD 4 ni,01,
0 8 %D
20
Report Approved
By:
End of Report
North Carolina Certifications: NCDWQ #332 / NCDEH #37742
Lab Number SAN04-02592:Page I
936 N. HORNER BLVD. - SANFORD, NC 27330
PHONE [phone] - FAX [phone]

Aqua Tech Environmental Laboratories, Inc.
- CERTIFICATE OF ANALYSIS -
Attn: Chad Watkins
B & B Mulch
6991 Old US
New Hill, NC 27562-
Client#: S1042
i! JAN - 5 20C�
Report Date: 09-Dec-04
Phone: [phone] Ext:
FAX: (919)361-nnA7
ATEL Lab #: SAN04-02593
- COLLECTION INFORMATION -
Date Received: 11/23/2004
Sample ID:
Site# 2
Date Logged -In: 11/23/04
Collection Date:
11/23/2004
Quote #:
Collection Time:
9:45 AM
Client PO#:
Collected By:
Charles Buchanan
Client Project M
Matrix:
Source Water
Sample Source:
Source Water
I Test Group Test
Method Result Units Analysis Date Analyst WS#
SS 160.2 22442
Residue, Nonfilterable (Suspended) 17.0 mg/L 11/302004 MAJ
BOD 405.1 22436
BOD, 5 Day 4 mg/L 11242004 MAj
INORG-MAR
Inorganic Analysis To Marion 12/092004 rlc
Report Approved By:
End of Report
North Carolina Certifications: NCDWQ #332 / NCDEH #37742
Lab Number SAN04-02593:Page I
936 N. HORNER BLVD. • SANFORD, NC 27330
PHONE [phone] • 1-800-522-2832 • FAX [phone]

"ITHTEL
Aqua Tech Environmental Laboratories, Inc.
D}
2005
JAN 5
t
- CERTIFICATE OF ANALYSIS -
Client #: S 1042
B Nc B Mulch Report Date: 06-Dec-04
6991 Old U.S.1
New Hill, NC 27562-
Phone: [phone] Ext:
Attn: Charles Buchanan FAX: [phone]
Our Lab #: MAR04-22532 Your Sample ID: Site # 2
Date Logged -In: 11/29/04 Sample Source: Stormwater
Sample Type: Stormwater Client Project #:
Project #: 2593 Date Submitted to Lab: 11/23/2004 PO#: CM-1208
- COLLECTION INFORMATION -
Date/Time/By: 11/23/04 9:45 AM Charles Buchanan
EPA Method Analyst Analysis Date Parameter
Result Units PQL
SM4500-NO3-F JEL
12/3/04 Nitrogen, Nitrate + Nitrite (as N)
< 0.05
mg/L 0.05
Calculation
Nitrogen, Total
1.21
mg/L
351.2 TLL
12/1/04 Nitrogen, Total Kjeldahl, TKN
1.21
mg/L 0.50
SM4500-P-E2 JEL
12/2/04 Phosphorus, P
0.08
mg/1, 0.02
End of Report
Report Approved By:
7Debor4a.hnson
Thisreport,shall not be reproduced, exceptin its emirery, without the written approvalof the laboratores iltspresentedon this ifteate of
Analysis only reflect those parameters that were requested by the client on the chain ofcustody or otheocumentation received with a sample(.$). The
analytical results relate only to the items tested. Certifications: NCDWQ263.NCDEN39700,AZ0071,NY1I07I,A2LA-102325-PB
Your Sample ID: Site # 2 Page 1 Lab NumberAIAR04-22532
1776 MARION-WALDO RD. a P.O. BOX 436 a MARION, OH 43301-0436
PHONE [phone] a 1-800-873-2835 • FAX [phone]