NC0005321_Complete File - Historical_19951127

Michael F. Easley
,,• •••• ,,, Governor
"•. �- William G. Ross, Jr., Secretary
r� North Carolina Department of Environment and Natural Resources
-i Alan W. Klimek, P. E., Director
Colleen H. Sullins, Deputy Director
Division of Water Quality
February 10, 2004
Chuck Oxendine
Buckeye Lumberton Inc.
PO Box 1305
Lumberton, North Carolina 28359
Subject: Rescission of NPDES Permit
Buckeye Lumberton Incorporated
Permit Number NC0005321
Robeson County
Dear Mr. Oxendine:
Reference is made to your request for rescission of the subject NPDES Permit. Division staff
has confirmed that the permit is no longer required. Therefore, in accordance with your request,
NPDES Permit NC0005321 is rescinded, effective immediately.
If in the future you wish to again discharge wastewater to the State's surface waters, you must
first apply for and receive a new NPDES Permit. Operating a facility without a valid NPDES
Permit will subject the responsible party to a civil penalty of up to $25,000 per day.
If you have questions about this matter, please contact Vanessa Manuel at [phone],
extension 532 or Grady Dobson in the Fayetteville Regional Office at [phone].
Sincerely,
Alan W. Klimek, P.E.
Cc: Grady Dobson, DWQ FRO - w/ attachment
Charles Weaver, NPDES Permit Unit
Ted Cashion, Technical Assistance & Certification Unit
Fran McPherson, DWQ Budget Office
Central Files - w/ original attachments
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
��n
NCDENR
Customer Service
1 800 623-7748

BUCKEYE
1000 EAST NOIR ST.. P.O. BOX 1305
LUMBERTON, NORTH CAROLINA 28359
TEL [phone] FAX [phone]
January 29, 2004
NCDENR
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Attention: Mr. Dave Goodrich
Re: Buckeye Lumberton Inc. NPDES Permit Number NC0005321
Mr. Goodrich:
This letter is in reference to NPDES Permit Number NC0005321.
The pulp mill operation located at the Buckeye Lumberton Inc. site was shut down in August
2003. The Wastewater treatment plant was subsequently emptied with the last discharge of
effluent from the treatment plant to the Lumber River occurring on 9/26/03. Since that time the
WWTP has been cleaned out and Mr. Grady Dobson from the Fayetteville Regional Office
performed an inspection on Tuesday, October 28, 2003 to verify that the plant had been properly
shut down, cleaned out and rendered inoperable. Mr. Dobson provided Buckeye Lumberton with
a copy of his inspection report and pictures showing the status of the treatment facility.
Buckeye Lumberton Inc. recently received notification from the Division of Water Quality that it
was time to submit an application for renewal of NPDES permit number NC0005321.
After much consideration, Buckeye Lumberton Inc. has elected to rescind NPDES permit
number NC0005321.
Please contact me at 910-737-3231 if you have any questions.
Sincerely,
Chuck Oxendine
Operations Manager
Buckeye Lumberton Inc.
BUCKEYE LUMBERTON INC.

Sate of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
January 31, 2002
Mr. Albert Bounds, Plant Manager
Buckeye Lumberton, Inc
1000 East Noir Street
Lumberton, North Carolina 28358
ern
NCDENR
Subject: Modification of NPDES Permit NC0005321
Lumberton Plant
Robeson County
Dear Mr. Bounds:
Division personnel have reviewed and approved your request to modify the subject permit. The Division has
granted your request to increase the permitted flow. The permit now has a 2.5 MGD effluent page, and an effluent
page for the build -out flow of 4.0 MGD. 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).
Enclosed you will find the modified permit. 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 (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 you have any questions concerning this
permit, please contact Michael Myers at telephone number [phone], extension 508.
Sincerely,
Original Signed By
David X Goodrich
Gregory J. Thorpe, Ph.D.
cc: Fayetteville Regional Office/Water Quality Section
Point Source Compliance and Enforcement Unit
EPA, Roosevelt Childress
Central Files
NPDES Files
Aquatic Toxicology Unit
Technical Assistance & Certification Unit
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 1 0% POST -CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Permit NC0005321
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 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,
Buckeye Lumberton, Incorporated
is hereby authorized to discharge wastewater from a facility located at
Buckeye Lumberton, Incorporated
1000 East Noir Street
Lumberton
Robeson County
to receiving waters designated as the Lumber River in the Lumber 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 March 1, 2002.
This permit and authorization to discharge shall expire at midnight on July 31, 2004.
Signed this day January 31, 2002.
Original Signed By
David k Goodrich
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0005321
SUPPLEMENT TO PERMIT COVER SHEET
Buckeye Lumberton, Incorporated is hereby authorized to:
1. Continue operation of an existing 2.5 MGD wastewater treatment system located at Buckeye's
Lumberton facility (1000 East Noir Street in Lumberton) in Robeson County and consisting of the
following treatment units:
• Screening
• Grit removal
• Primary clarification
• Equalization basin
• Aerobic selector
• Aeration basin with nutrient addition and methanol feed
• Final clarification
• Sludge holding tank
• Sludge press
2. After receiving an Authorization to Construct from the Division of Water Quality, increase flow to 4.0
MGD; and
3. Discharge from said treatment works at the location specified on the attached map into the Lumber
River, a class C-swamp water in the Lumber River Basin.

Facility Information
o y
Latitude: 34 36'20" Sub -Basin: 03-07-51
Longitude: 78°59'35"
Facility
Ri s
Location
Quad #: I23SE
4
Buckeye Lumberton, Incorporated
NC0005321
Stream Class: C-Swamp
Receiving Stream: Lumber River
Permitted Flow: 2.5 MGD/4.0 MGD
O N t
Robeson County

Permit NC0005321
A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (2.5 MGD)
During the period beginning on the effective date of the permit and lasting until expansion above 2.5 MGD, the
Permittee is authorized to discharge from outfall 001. 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 Locationi
Flow
2.5 MGD
Continuous
Recording
Intake or Effluent
BOD5
(April 1 — October 31)
332.0lb/day
664.0lb/day
31Week
Composite
Effluent
BOD5
(November 1 — March 31)
450.0lb/day
900.0lb/day
3/Week
Composite
Effluent
Total Suspended Residue
425.0 lb/day
850.0 lb/day
3/Week
Composite
Effluent
NH3 as N
83.0 lb/day
166.0 lb/day
3/Week
Composite
Effluent
pH2
3Meek
Grab
Effluent
Dissolved Oxygen3
3/Week
Grab
Effluent
Temperature'
3/Week
Grab
Effluent
Conductivity
3/Week
Grab
Effluent
Total Nitrogen
(NO2 + NO3 +TKN)
Monthly
Composite
Effluent
Total Phosphorus
Monthly
Composite
Effluent
Total Residual Chlorine
Quarterly
Grab
Effluent
Chronic Toxicity 5
Quarterly
Composite
Effluent
Mercurys
Quarterly
Composite
Effluent
Mercurys
Semi -Annual
Grab
Sludge
Dissolved Oxygen
Variables
Grab
Upstream, D1, D2
Temperature'
Variables
Grab
Upstream, D1, D2
Conductivity
Variables
Grab
Upstream, D1, D2
Footnotes:
1. Upstream = at NCSR 1620. D1 — Downstream at NCSR 2123, D2 — Downstream at NCSR 2121.
2. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
3. The daily average dissolved oxygen concentration in the effluent shall not be less than 5.0 mg/L.
4. The discharge shall not cause the temperature of the receiving stream to exceed 2.8-C above background
temperature and in no case cause the receiving stream to exceed 32-C.
5. Chronic Toxicity (Ceriodaphnia) P/F @ 3.1%; February, May, August, and November. See Condition A. (3.).
6. The approved detection level for mercury in the effluent is 0.2 µg/L while the approved detection level for
mercury in the sludge is 0.1 mg/kg on a dry weight basis.
7. Instream samples shall be collected three times per week during the months of June, July, August, and September
and weekly during the remainder of the year.
Definitions:
MGD — Million gallons per day
lb/day — Pounds per day
µg/L — Micrograms per liter
BOD — Biochemical Oxygen Demand

Permit NC0005321
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (4.0 MGD)
During the period beginning upon expansion beyond 2.5 MGD and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
Effluent Characteristics
Limits
Monitoring Requirements
Monthly
Avera e
Daily
Average
Measurement
Frequency
Sample
Type
Sample Location
Flow
4.0 MGD
Continuous
Recording
Intake or Effluent
BODE
(April 1— October 31
332.0lb/day
664.0lb/day
Daily
Composite
Effluent
BOD5
November 1 — March 31
450.0lb/day
900.0lb/day
Daily
Composite
Effluent
Total Suspended Residue
425.0 lb/day
850.0 lb/day
Daily
Composite
Effluent
NH3 as N
83.0 lb/day
166.0 lb/day
Daily
Composite
Effluent
H2
Dailly
Grab
Effluent
Total Residual Chlorine
28 Fr /L
Daily
Grab
Effluent
Dissolved Oxygen3
Daily
Grab
Effluent
Tem erature^
Daily
Grab
Effluent
Conductivity
Daily
Grab
Effluent
Total Nitrogen
(NO2 + NO3 +TKN)
Monthly
Composite
Effluent
Total Phosphorus
Monthly
Composite
Effluent
Chronic Toxicity 5
Quarterly
Composite
Effluent
Mercury6
Quarterly
Composite
Effluent
Mercu
Semi -Annual
Grab
Sludge
Dissolved Oxygen
Variable'
Grab
Upstream, Di, D2
Tem erature4
Variable'
Grab
Upstream, Di, D2
Conductivity
Variable'
Grab
Upstream, Di, D2
Footnotes:
1. Upstream = at NCSR 1620. D1 — Downstream at NCSR 2123, D2 — Downstream at NCSR 2121.
2. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
3. The daily average dissolved oxygen concentration in the effluent shall not be less than 5.0 mg/L.
4. The discharge shall not cause the temperature of the receiving stream to exceed 2.8oC above background
temperature and in no case cause the receiving stream to exceed 32°C.
5. Chronic Toxicity (Ceriodaphnia) P/F @ 4.9%; February, May, August, and November. See Condition A. (4.).
6. The approved detection level for mercury in the effluent is 0.2 µg/L while the approved detection level for
mercury in the sludge is 0.1 mg/kg on a dry weight basis.
7. Instream samples shall be collected three times per week during the months of June, July, August, and September
and weekly during the remainder of the year.
Definitions:
MGD — Million gallons per day
lb/day — Pounds per day
µg/L — Micrograms per liter
BOD — Biochemical Oxygen Demand

Permit NC0005321
A. (3.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) — For 2.5 MGD Permitted Flow
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 3.1%.
The permit holder shall perform at a minimum, quarteUl monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. The tests will be performed during the months of February, May August and November. 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 11 Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: NC DENR / DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will
complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number,
pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The
report shall be submitted to the Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month 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 NC0005321
A. (4.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) — For 4.0 MGD Permitted Flow
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 4.9%.
The permit holder shall perform at a minimum, u� artery monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. The tests will be performed during the months of February, May August and November. Effluent sampling for
this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit,
then multiple -concentration testing shall be performed at a minimum, in each of the two following months as
described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: NC DENR / DWQ / Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will
complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number,
pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The
report shall be submitted to the Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month 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.

RObESON COUNTY
NORTH CAROOLIN.A
Editor -
Associate Editor, of THE ROBESONIAN, a news-
PUBLIC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
paper published in Robeson County, N. C., being
COMMISSIOWNPOES UNIT
1617MailServiceCent er
_L
dully sworn, Says that at the time the attached
Raleigh, NC 27699-1617
Notification of Intent to Issue A NPDES
notice was published in THE ROBESONIAN, said
Wastewater Permit ou� review
n he of NCr Genstaff
newspaper me rt all of the requirements and uali-
q q
era
lawful ,Public law 92-500 and other
lawful standards and regulations, ,the
ficatioris prescribed by North Carolina General
%it Carolina Environmental Manage-
merit Commission proposes to issue a
Statute 1-597; that said newspaper had a general
National Pollutant Discharge Elimina-
bon System (NPDES) wastewater cis -
charge permd to the person(s) listed
circulation to actual paid subscribers: and, was
below effective 45 days from the pub -
lishdate of this ratice.
admitted to the (united States mail as second
Written comments regarding the pro -
posed permit wet be accepted uMa 30
class matter in Robeson County, N. C.; and fur-
days after ,he publish date of this no,
lice. All comments received prior to
that date are considered in the final de-
ther, that the attached notice was published in
terminations regarding the proposed
permit. The Director of the NC Division
THE ROBESONIAN once a week for _. �_.� con-
of Water ty may decide to hold a
public meeting for the proposed permit
secutive weeks on the following issue dates
should the Division receive a significant
degree ofpublic intees
of the draft permit and Omer
supporting Womradon on file used to
determine conditions present in the
draft available upon request
permit are
and payment of the costs of reproduc-
comments ardor requests
tor Mail inn
far information to the NC Division of
to
Water Quality at the above address or
Editor
call Ms. Christie Jackson at (919) 733-
5083, extension SM. Please include
.l�r-Editor-Associate
the NPDES permit number (attached)
in any communication. Interested per-
Sworn to and subscribed before me
sons may also visit the Division of Wa.
ter Quality at 512 N. Salisbury Street,
20 /
1
�da
between me
Raleigh, :0 2.m. and 8
hours of 8 00 a.m. and 5 00 p.m. to re -
this the of
.
NPDES Permit Number NC0005321.
NPDE Permitmation Nuon mber
Buckeye Lumberton, Inc., P.O. Box
6 1(
1305, Lumberton, NC 28359 has ap-
-
plied for a permit renewal for a facility
NOTARY P BLIC
located in Robeson County discharging
wastewater into the Lumber River 0
the Lumber River Basin. Currently
�`'�
B00, ammonia, and dioxin are water
,J
quality limited. This discharge may at -
— �/1``A
•
My commission expires
act future allocations in this Pon- of
the receiving stream.
June 5 NCDENR-060501

Whole Effluent Toxicity Testing Self -Monitoring Summary May 16, 2001
FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Briarwood Subdivision-Rayco Utilities Penn cbr lim: 49%
1997 Fail
Fail
Pass
Pass
--
--
Pass
--
--
Pass
--
-
NCO028746/001 Begin:2/1/1997 Frequency: Q P/F + Jan Apr Jul Oct
NonComp:Single
1998 Pass
-
-
Pass
--
--
Pass
--
--
Pass
--
-
County: Stokes Region: WSRO Subbasin: ROAOI
1999 Pass
--
--
NR/Pms
--
-
Pass
--
--
Pass
-
-
PF: 0.05 Special
2000 Pass
--
--
Pass
--
--
Pass
--
-
Pass
--
--
7Q10:0.08 IWC(%):49 Order:
2001 Pass
--
--
Bryson City WWTP Penn chr lim: 0.25 %
1997 at
--
-
Pass
--
--
NR/Pass
-
--
Pass
--
---
NCO026557/001 Begin:5/1/1998 Frequency: Q P/F + Jan Apr Jul Oct
+ NonComp:Single
1998 Pass
-
-
Pass
---
--
Late
Pass
--
Pass
---
--
County: Swain Region: ARO Subbasin: LTN02
1999 Pass
-
-
Pass
---
--
Pass
-
-
Pass
PF: 0.60 Special
2000 Pass
--
--
NR
Pass
--
Pass
--
--
Pass
---
--
7Q10:365.0 IWC(%):0.253 Order:
2001 Pass
--
---
Buckeye Lumberton, Inc. Penn chr lim: 2.3%; if pf 4MGD chr lint 4.90%
Y 1997 --
Pass
---
--
Pass
--
--
Pass
--
---
Pass
---
NC0005321/00I Begin:3/I/2000 Frequency: Q Feb May Aug Nov
+ NonComp:Single
1998 --
Late
Pass
---
Pass
---
--
Pass
--
---
Pass
--
County: Robeson Region: FRO Subbasin: LUM51
1999 -
Pass
-
--
Late
Bt
--
Pass
--
---
Pass
--
PF: 1.8 Special
2000 -
Pass
---
--
Pass
--
--
Pass
--
---
Pass
---
7QIO:118.28 IWC(%):2.3 Order:
2001 -
Pass
---
Bules Creek WWTP Perm 24hr ac p/flim: 90%
1997 Pass
-
---
Pass
--
--
Pass
--
--
Pass
---
--
NCO030091/001 Begin:5/l/1996 Frequency:Q + Jan Apr Jul Oct
NonComp:Single
1998 Pass
--
--
Pass
--
--
Pass,Pam
--
--
Pass
---
--
County: Haman Region: FRO Subbasin: CPF07
1999 Fail,Pass
--
--
Pass
--
-
Pass
--
--
Pass
--
--
PF: 0.50 Special
2000 Pass
--
--
Pass
--
-
Pass
--
--
Pass
--
---
7QIO:600 IWC(a/o):0.13 Order.
2001 Pass
--
--
Buncombe County MSD Penn chr lim: 12%
1997 Late
NR/Passt
--
-
Pass.Pam
--
--
Pass,Pass
--
--
Pass,Pam
--
NCO024911/001 Begin:2/1/2001 Frequency:Q Feb May Aug Nov
+ NonComp:Single
1998 --
Pass,Pass
-
--
Pass,Pam
-
--
Pass,Failt
--
-
Pass,Pass
--
County: Buncombe Region: ARO Subbasin: FRB02
1999 --
Pass
-
--
Pass
-
--
Pass
Pass
--
PF: 40.0 Special
2000 -
Fail
33.9
33.9
>48
-
-
33.9
--
--
33.9
--
7Q10:466.0 IWC(aG):12.0 Order:
2001 -
17
--
Bunn WWTP Perm chr lim: l l %
1997 Pass
-
Pass
-
-
Pass
--
--
Pass
--
--
Pass
NCO042269/001 Begin:1 l/l/2000 Frequency: Q Mar Jun Sep Dec
+ NonComp:Single
1998 --
--
Pass
--
--
Pass
--
--
Pass
--
-
Pass
County: Franklin Region: RRO Subbasin: TAROI
1999 -
-
Pass
-
--
Pass
--
-
Late
Pass
--
Pass
PF: 0.15 Special
2000 --
--
Pass
-
--
Pass
--
-
Fail
Pass
>100
>100
7QIO: 1.8 IWC(%):II Order:
2001 -
-
Pass
Burgaw V^M Penn chr lim: 90%
Y 1997 >100
-
-
63.6
>100
-
79.3
>100
-
>100
--
--
NCO021113/00I Begin:2/l/1996 Frequency: QP/F + Jan Apr Jul Oct
NonComp:Single
1998 >100
-
-
>100
-
-
>100
94.8
-
--
County: Pander Region: WIRO Subbasin: CPF23
1999 >100
-
-
>100
--
-
>100
--
-
94.8
-
---
PF: 0.75 Special
2000 >100
-
-
>100
--
--
>100
--
--
>100
---
--
7Q10:0.0 IWC(%):100 Order:
2001 >100
-
--
>100
Burlington East WWTP Penn chr lim: 36%
Y 1997 -
Pass
-
-
Pass
--
--
Pass
--
--
Pass
--
NCO023868/001 Begin:4/l/1996 Frequency: QP/F + Feb May Aug Nov
NonComp:SINGLE
1998 --
Pass
--
--
Pass
--
--
Pass
-
--
Pass
--
County: Alamance Region: WSRO Subbasin: CPF02
1999 -
Pass
Late
---
Pass
--
--
Pass
-
-
Pass
--
PF: 12.0 Special
2000 -
Pass
--
--
Pass
--
--
Pass
--
-
Pass
--
7Q10:33.6 IWC(%):36 Order:
2001 -
Pass
-
Burlington Ind. -Richmond Penn chr lim: 7%
1997 -
Pass
--
--
Pass
--
--
Pass
-
--
Pass
--
NC0043320/001 Begin:6/I/2000 Frequency: Q Feb May Aug Nov
+ NonComp:Single
1998 -
Pass
--
--
Pass
--
--
Pass
--
--
Pass
--
County: Richmond Region: FRO Subbasin: YAD16
1999 --
Pass
--
---
Pass
--
--
Pass
-
--
Pass
--
PF: 1.2 Special
2000 -
Pass
-
---
Pass
--
--
Pass
-
-
Pass
-
7Q10:25.0 IWC(%):7.0 Order:
2001 -
Pass
--
Burlington -South WWTP Penn chr lim: 86%
Y 1997 82
72
>100
>100
-
--
Pass
-
--
Fail
Fail
Pam(s)
NCO0238761001 Begin:4/l/1996 Frequency: Q P/F + Jan Apr Jul Oct
NonComp: Single
1998 Late
Pass
--
Pass
-
-
Pass
-
-
Pass
-
-
County: Alamance Region: WSRO Subbasin: CPF02
1999 Fail
Pass
Pass
Pass,Fail
--
--
Pass
--
-
Pass
--
--
PF: 12.0 Special
2000 Fail
>100
>100
Pass
--
--
Fail
88.0
>100
Pass
--
--
7QIO:3.0 IWC(%):86 Order:
2001 Pass
--
--
Burnsville WWTP Perm cbr lim: 6%
Y 1997 --
--
Pass
--
--
Pass
--
--
Pass
-
--
Pass
NCO020290/001 Begin:2/1/1997 Frequency: Q P/F + Mar Jun Sep Dec
NonComp: Single
1998 --
--
Pass
--
--
Pass
--
-
Pass
--
---
Pass
County: Yancey Region: ARO Subbasin: FRB07
1999 --
--
NR/Pass
---
--
Fail
NR/Pass
--
Pass
--
---
Pass
PF: 0.8 Special
2000 -
--
Pass
--
-
Pass
--
--
Pass
--
--
Pass
7Q10: 19.0 IWC(%):6.0 Order:
2001 -
--
Pass
LEGEND:
PERM = Permit Requirement LET = Administrative Letter - Target Frequency = Monitoring frequency: Q- Quarterly; M- Monthly; BM- Bimonthly; SA- Semiannually; A- Annually; OWD- Only when discharging; D- Discontinued monitoring requirement
Begin = First month required 7QIO = Receiving stream low flow criterion (cfs) += quarterly monitoring increases to monthly upon failure or NR Months that testing must occur - ex. Jan, Apr, Jul, Oct NonComp = Current Compliance Requirement
PF = Permitted flow (MGD) IWC% = Instream waste concentration P/F = Pass/Fail test AC = Acute CHR = Chronic
Data Notation: f - Fathead Minnow;' - Ceriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test
Reporting Notation: --- = Data not required; NR - Not reported Facility Activity Status: I - Inactive, N - Newly Issued(To construct); H - Active but not discharging; t-More data available for month in question; • = ORC signature needed
6

Re: Buckeye Lumberton
Subject: Re: Buckeye Lumberton
Date: Thu, 27 Dec 2001 14:24:21 -0500
From: [e-mail]
To: Mike Myers <[e-mail]>
CC: [e-mail]
Mike:
The NPDES Section has completed its review of the permit modification
for Buckeye in Lumberton, NC which discharges to the Lumber River. A
BOD5/NH3-N TMDL was approved in 1995 which was conditioned to develop a
swamp model for the receiving water and to complete other TMDL-related
tasks.
In response to these incomplete TMDL tasks, we requested an update on
the remaining TMDL tasks and issues. This was the State's response:
"Though the swamp study was never completed, some guidance was (19
issued for discharges to swam waters based on an initial evaluation.
That guidance states that ew discharges to swamp waters receive BOD and
ammonia limits of 15 mg/l and 4.0 mg/l, respectively. However, this is
not a new discharge. It is important to realize though, that at 4.0 MGD
the BO and ammonia concentrations are well below 15 mg/l and 4.0 mg/1."
Thus, no swamp model was developed for this receiving water. There
are several dischargers in the area which should be updated with waste
load allocations as permits are renewed. Most of the industrial permits
were based on effluent guidelines or BAT and no water quality based
effluent limits have been developed.
In regard to this specific permit modification, we will'not object
to the modification since it involves adjusting the hydraulic discharge,
but we would like to have the 1995 TMDL approval conditions fulfilled,
which would result in water quality based BOD5 and ammonia limits
developed for the dischargers in the area which could then be
incorporated into existing permits as they expire and are subsequently
renewed.
Thanks for your attention,
Caroline Ejimofor
NPDES and Biosolids Permits Section
Permits, Grants and Technical Assistance Branch
EPA Water Management Division
e-mail address: [e-mail]
phone number: 404-562-9309
fax number: 404-562-8692
Mike Myers
4w,.
1/7 /oz-
<mike.myers@n To: Caroline Ejimofor/R4/USEPA/US@EPA
cmail.net> cc:
Subject: Buckeye Lumberton
12/26/2001
11:01 AM
1 of 2 1/7/2002 10:06 AM

Re: Buckeye Lumberton
Caroline,
Sorry I haven't had time to follow up on the Buckeye Lumberton permit
modification. I haven't heard anything from you lately. How do we
stand on the permit mod.? Have we addressed all of your concerns and
can we proceed with issuing the permit?
Michael J. Myers
Environmental Engineer
NPDES Unit - Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27669-1617
[phone] x508
mailto:[e-mail]
(See attached file: mike.myers.vcf)
Name: mike.myers.vcf
Fimike.myers.vcf Type: Ward (text/x-vcard)
Encoding: base64
2 of 2 1/7/2002 10:06 AM

- Re: Buckeye Lumberton
Subject: Re: Buckeye Lumberton
Date: Thu, 27 Dec 2001 15:19:38 -0500
From: [e-mail]
To: Mike Myers <[e-mail]>
Hello,
I am sending this attached letter to you via postal mail.
Thank you.
Caroline Ejimofor
NPDES and Biosolids Permits Section
Permits, Grants and Technical Assistance Branch
EPA Water Management Division
e-mail address: [e-mail]
phone number: 404-562-9309
fax number: 404-562-9318
(See attached file: no objection letter for buckeye.wpd)
Mike Myers
<mike.myers@n To: Caroline Ejimofor/R4/USEPA/US@EPA
cmail.net> cc:
Subject: Buckeye Lumberton
12/26/2001
11:01 AM
Caroline,
Sorry I haven't had time to follow up on the Buckeye Lumberton permit
modification. I haven't heard anything from you lately. How do we
stand on the permit mod.? Have we addressed all of your concerns and
can we proceed with issuing the permit?
Michael J. Myers
Environmental Engineer
NPDES Unit - Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27669-1617
[phone] x508
mailto:[e-mail]
(See attached file: mike.myers.vcf)
Name: no objection letter for buckeye.wpd
no objection letter for buckeye.wpd Type: Winword File (application/wordperfect5.1)
Encoding: base64
Download Status: Not downloaded with message
1 of 2 U7/2002 10:40 AM

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303
December 27, 2001
Ms. Coleen Sullins, Chief
Water Quality Section
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
SUBJ: Buckeye Lumberton Wastewater Treatment Plant
NPDES Permit Number NC0005321
Dear Ms. Sullins:
In accordance with the Environmental Protection Agency/North Carolina NPDES
Program Memorandum of Agreement, we have completed the review of the draft North Carolina
Department of Environment and Natural Resources (NC DENR) National Pollutant Discharge
Elimination System (NPDES) permit referenced above and have no objections to the proposed
permit modification to the draft permit conditions.
We request that we be afforded an additional review opportunity of a proposed final
permit if significant changes are made to the permit prior to issuance, or if valid and significant
comments to the permit are received. Otherwise, please send one copy of the final permit when
issued.
If you have any questions, please do not hesitate to contact me at [phone].
Sincerely,
Caroline Ej imofor
Environmental Engineer
NPDES and Biosolids Permits Section
Permits, Grants, and Technical Assistance Branch
Water Management Division

Re: Buckeye Lumberton
Subject: Re: Buckeye Lumberton
Date: Thu, 27 Dec 2001 15:38:32 -0500
From: [e-mail]
To: Mike Myers <[e-mail]>
W/ D.r
Hello Mike: /71 Z
Please note the following deficiencies that were identified in the
Buckeye Lumberton NPDES application. Please send me an e-mail addressing
these. Thank you.
Caroline Ejimofor
NPDES and Biosolids Permits Section
Permits, Grants and Technical Assistance Branch
EPA Water Management Division
e-mail address: [e-mail]
phone number: 404-562-9309
fax number: 404-562-8692
**********************************************************************************
NC0005321 Buckeye Lumberton WWTP
Application does not contain Latitude/Longitude information: A location a
map is included but no reference to Lat/Long is made.
Outfall Description: Each outfall should have a description of the 'A
flow, sources of pollution and treatment technologies, list the�
discharge type, duration, occurrence, flow rate, operations contributing
to flow, and total volume of flow. The plant component and water use
diagram provide the majority of this information, although it is not
easily accessible.
Effluent Guideline Applicability and Production Data: The application OC.r
does reference the applicability of OCPSF guidelines, although this
information is not readily apparent. The reference is contained in the {!�i
cover letter from the facility and is not required in the NC
application, contradicting the federal application basic requirements.
NC's Application, Item 7 - Supplemental Documentation: NC requires the
inclusion of the last 3 years production data for the facility. This
information was not included in the application sent to EPA R4 for J
review. The fact sheet references an average annual flow, which wasAPQ�' `f
obtained from a source other than the application and was used to
calculate effluent guideline limitations. Production data, as required
by NC's application and federal application requirements, should be lie.
included in all applications before an application is determined to be
complete. This information is necessary to calculate appropriate
technology -based effluent guideline limitations.
-� Analysis of Pollutants: The NC application requires that wastewater
characteristics for each outfall be identified as present. The list of,,�
wastewater characteristics are substantially the same as the federal
list of wastewater characteristics, although the expanded list of
chlorinated organics and algicides was not available for review. Q
Federal requirements in the federal application are very clear that the i
permit applicant is responsible for collecting and reporting data on the
pollutants discharged for each outfall. If a pollutant is believed yam°
present the applicant must test and report for that parameter. This
information is not contained in the application. All applicants are
also required to report BOD, COD, TOC, TSS, Ammonia (as N), flow,
temperature, and pH. This information is not available in the
application. Furthermore, all metals should be reported as total 6Q'ry �`ci0
recoverable, which does not appear to be a requirement of the NC�SSI��'"
1 of 2 1/7/2002 10:07 AM

Re: Buckeye Lumberton
application.
This represents a major deficiency in the permit application. Data
characterizing the effluent is necessary to determine reasonable
potential for the effluent to exceed water quality standards and if
necessary require a limit in the permit to protect the receiving water.
Biological Toxicity Testing: No existing biological toxicity testing is
contained in the NC application, as required in the federal application.
Mike Myers
<mike.myers@n To:
cmail.net> cc:
Subject:
12/12/2001
09:21 AM
Caroline,
Caroline Ejimofor/R4/USEPA/US@EPA
Buckeye Lumberton
I was talking with Dave Goodrich about the Buckeye Lumberton permit
modification. He indicated that he thought that the Buckeye Lumberton
modification had been approved. Dave got this impression from the
conference call on Monday (12/10). Is this correct, can we go ahead and
issue the Buckeye Lumberton permit mod?
Michael J. Myers
Environmental Engineer
NPDES Unit - Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27669-1617
[phone] x508
mailto:[e-mail]
(See attached file: mike.myers.vcf)
Name: mike.myers.vcf
rimike.myers.vc Type: Ward (textN-ward)
Encoding: base64
2 of 2 U7/2002 10:07 AM

Re: RBview of Dram NPDES Permits ...NC0023876,NC0058548, and NC0001210
Subject: Re: Review of Draft NPDES Permits #NC0005321, NC0055786,
NC0023876,NC0058548, and NC0001210
Date: Fri, 29 Jun 2001 13:21:25 -0400
From: Mike Myers <[e-mail]>
To: [e-mail]
CC: [e-mail], [e-mail], [e-mail],
[e-mail]
Caroline,
The public notice for all these facilities except South Burlington published on
or around June 7, therefore the thirty day public comment period is open until
July 7th. South Burlington published on or around June 13th, therefore the
public comment period is open until July 13th. So please take a full thirty
days. Sorry for the confusion on the transmittal cover letter.
Barring any further comments within the thirty day period, I hope that this
means that we can move forward on the issuance of these permits. As you know
we are working very hard to lower the backlog and truthfully every permit
helps. If there is anything else, please let us know.
Michael J. Myers
Environmental Engineer
NPDES Unit - Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27669-1617
[phone] x508
mailto:[e-mail]
[e-mail] wrote:
> RE: Buckeye Lumberton WWTP in Robeson County
> South Burlington WWTP in Alamance County
> City of Lexington WWTP in Davidson County
> Town of Star WWTP in Montgomery County
> Monarch Hosiery Mills WWTP in Alamance County
,44 P4�
> On June 7th, I received draft NPDES Permits for the above North Carolina
> facilities.
> Your transmittal letter(s) stated that my comments on these permits are due
> today, June 29, 2001.
> This e-mail is being sent to you to request a full 30 day review time for
> this draft permit.
> My comments on these permits will be transmitted to you by Friday, July 6,
> 2001.
> Thank You.
> Caroline Ejimofor
> NPDES and Biosolids Permits Section
> Permits, Grants and Technical Assistance Branch
> EPA Water Management Division
> e-mail address: [e-mail]
> phone number: 404-562-9309
> fax number: 404-562-9318
1 of 2 7/24/2001 8:55 AM

Ice: Rdview of Dram NPDES Permits ... NCO023876,NC0058548, and NC0001210
Name: mike.myers.vcf
r) mike.myers.vc Type: Ward (text/x-vcard)
LJ Encoding: 7bit
Description: Card for Mike Myers
2 of 2 7/24/2001 8:55 AM

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0005321
Facility Information
Applicant/Facility ame:
Buckeye Lumberton, Incorporated
ApplicantAddress:
1000 East Noir Street, Lumberton, NC 28358
FacilityAddress:
1000 East Noir Street, Lumberton, NC 283M
Permitted ow
and 4.0 MGD
Type of Waste:
o n ustrta
act sty ermitStatus:
Renewal
ounty:
Robeson
Miscellaneous
ecetvtngStream:
Lumber River
egtona ice:
Fayetteville
Stream Classification:
- wamp
opo Quad:
Listed?:
Yes, Hg
Permit rater:
Michael Myers
u astn:
- -
ate:
May 21, 2001
Drainage Area (mi2):
712
`
ummer c s
Winter c s :
verage Flow c s :
853
lWC o
rimary SIC Code:
2611
BACKGROUND
Buckeye Lumberton, Incorporated operates a high quality paper manufacturing facility (formerly owned
and operated by Alpha Cellulose). The facility was originally put into service in 1968 with the U.S.
Environmental Protection Agency (EPA) issuing the original National Pollutant Discharge Elimination
System (NPDES) permit. The facility processes cotton linters into pulp for use in high quality paper
products. The linters are cooked, bleached, and dried in the pulp making process. Bleaching is achieved
via elemental chlorine addition 95% of the time and sodium hypochlorite 5% of the time.
In 1996, Alpha Cellulose was issued a Special Order by Consent (SOC# 96-004 AdII). The facility was
having difficulty meeting effluent Total Suspended Solids (TSS or TSR) and Biochemical Oxygen
Demand (BOD) limitations. The facility contracted Eckenfelder, Inc. to complete a treatability study and
make treatment system modification recommendations. It was concluded that elevated TSS and BOD
values in the effluent were the result of bulking sludge caused by excessive filamentous bacteria growth.
It was further determined that a short hydraulic residence time upstream of the treatment facility would
effectively select against excessive filamentous growth. An Authorization to Construct (project number
005321ACD) was issued for the project on April 9, 1998. The engineer's certification signifying
completion of construction was received on January 6, 1999. The facility was granted an extension of the
SOC until June 30, 2000. The extension was granted to give the facility time to review the performance
of these new facilities. The SOC expired in June 2000, and the facility has achieved compliance.
As mentioned previously, this permit was originally developed by EPA. Limitations were established to
protect water quality as no effluent guidelines applicable to this specific manufacturing process are
available. A water quality model for the Lumber River was completed in the mid-70s. The results of that
modeling effort indicated that the discharges from Alpha Cellulose and the City of Lumberton interacted
making the river water quality limited. As such, the Lumber River Basinwide Management Plan
recommended (and continues to do so) that existing discharges be held at existing load.
The facility received a hydraulic expansion from 1.8 MGD to 4.0 MGD in 1992. The expansion to 4.0
MGD held pollutant mass loading constant. The modification requested by Buckeye Lumberton, is for a
flow expansion of the 1.8 MGD Effluent Limitation and Monitoring page to 2.5 MGD. Since the basin
plan continues to make the recommendation of no increase in mass loading, the pollutant mass loading
shall remain unchanged for this modification.
Buckeye Lumberton Fact Sheet
NPDES Renewal
Page t

PERMIT DEVELOPMENT
BOD, TSS and Ammonia
As discussed above, the mass loading for these parameters shall remain constant. Monitoring frequencies
are consistent with the requirements set forth in T15A 213 .0500 for water quality limited Paper and Allied
Products category.
Chlorine
As is the case with many pulp mills performing bleaching using elemental chlorine, residual chlorine and
dioxin have the potential to be present in quantities capable of degrading water quality and/or the
instream biological community. A review of effluent data for residual chlorine indicated that none has
been detected in over 500 sampling events. All values have been reported as less than 10 ❑g/L. Since
chlorine continues to be used in the bleaching process, quarterly total residual chlorine monitoring shall
continue to be required.
Mercury
The Lumber River is currently listed on the State's 303(d) list as impaired due to mercury. Additionally,
there is a fishing advisory in the Lumber due to mercury contamination. The Division is currently
developing a TMDL for mercury in the Lumber.
As the Lumber River is listed for mercury impairment and since the facility doesn't seem to have
mercury data available (with the exception of a single APAM submitted in 1997 — mercury not detected),
monitoring shall continue to be conducted on a quarterly basis. During the nest permitting renewal cycle
in 2004, mercury data will be evaluated and limitations may be established in accordance with an
approved TMDL.
Temperature
In order to control the thermal component of the discharge, a temperature limit shall be required.
Monitoring frequencies are consistent with the requirements set forth in T15A 2B .0500 for water quality
limited Paper and Allied Products category.
pH
The hydrogen ion concentration is a general measure of water quality. Therefore, limitations on pH are
applied to individually permitted discharges. Monitoring frequencies are consistent with the requirements
set forth in T15A 213 .0500 for water quality limited Paper and Allied Products category.
Dissolved oxygen and Conductivity (Effluent)
As stipulated in T15A 213 .0500 for water quality limited Paper and Allied Products category effluent
monitoring of dissolved oxygen and conductivity shall be conducted. Monitoring frequencies are
consistent with the requirements set forth in T15A 213 .0500.
Dioxin
During the previous permit cycle, the facility was required to meet a dioxin limit and monitor that
parameter quarterly at both the influent and effluent. Additionally, the facility was required to conduct a
fish tissue study. A review of Discharge Monitoring Reports (DMRs) did not reveal influent dioxin data.
The pulp and paper specialist with EPA Region IV indicated that dioxin would not be expected in the
bleaching of the cotton linters. Therefore, the final permit did not include a requirement for dioxin.
TOXICITY TESTING
Current Requirement: Chronic P/F @ 2.3% at 1.8 MGD using Ceriodaphnia
Chronic P/F @ 4.9% at 4.0 MGD using Ceriodaphnia
The facility has been in compliance with its toxicity limit over the past four years.
The Division defines the wastewater generated at this facility as a complexwastestream. As stipulated in
T15A 213 .0500, a toxicity limit shall continue as a requirement for the permit.
Recommended Requirement: Chronic P/F @ 3.1% at 2.5 MGD using Ceriodaphnia
Chronic P/F @ 4.9% at 4.0 MGD using Ceriodaphnia
Buckeye Lumberton Fact Sheet
NPDES Renewal
Page 2

COMPLIANCE SUMMARY
The SOC for TSS and BOD expired in June 2000 and the facility has been in compliance since that time.
INSTREAM MONITORING
As stipu ated in T15A 2B .0500 for water quality limited Paper and Allied Products category, this facility
is required to monitor dissolved oxygen, temperature, and conductivity instream. Upstream monitoring is
conducted at NCSR 1620. There are two downstream locations designated in the permit. The first is at
NCSR 2123 and the second is at NCSR 2121.
During the last renewal, the Division noted that upstream and downstream data suggested that this facility
is impacting receiving stream water quality. The instream data was reevaluated as part of the
modification. Elevated levels of conductivity are evident downstream of the effluent while DO shows a
decline, sometimes by more than I mg/L, from upstream to downstream. On 12 sampling occasions
during the months of May, June, July, and August of 1999, the discharge apparently caused downstream
excursions below the water quality standard of 5.0 mg/L (this does not include times when the upstream
DO reading was already below the standard).
PROPOSED CHANGES
Deletion of 1.8 MGD Effluent Limitations and Monitoring Page.
Addition of 2.5 MGD Effluent Limitations and Monitoring Page.
Toxicity limit modified to reflect the increased flow limit.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: June 6, 2001
Permit Scheduled to Issue: July 23, 2001
STATE CONTACT
If you have any questions on any of the above information or on the attached permit, please contact
Michael Myers at [phone] ext. 508.
NPDES SUPS VISOR
NAME: DATE:
Buckeye Lumberton Fact Sheet
NPDES Renewal
Page 3

REGIONAL OFFICE COMMENT
NAME: DATE: L Z17,10
tiuck,.,,,c himim.,on Faci Ywt

REGIONAL OFFICE SUPERVISOR
JJ4��/-7 - d::�?
NAME: DATE: �' z
Buckeye Lumberton Fact Sheet
NPDES Renewal
Page 6

r a1llING PERIVU
AESON COUNTY
,NORTH CAROLINA
-, 4me"4 A&A� Mmm„ iter
Assoiliate Editor, of THE ROBESONIAN, a news•
paper published in Robeson County, N. C., Ding
duly sworn, says that at the time the attached
notice was published in THE ROBE'SONIAN, sold
newspaper met all of the requirements and quali-
fications prescribed by North Carolina General
Statute 1-597; that said newspaper had a 9"r41
circulation to actual paid subscribers; and, was
admitted to the United States mail as second
class matter in Robeson County, N. C.; and fur»
ther, that the attached notice was published in
THE ROBE5ONIAN once a week for ,._,. —iii-con,
secutive ks on the following issue date$
--.Associate Editor
Sworn to and subscribed efore me
this the .-L.=_day of 2001.
NOTAR UBLIC
My commission expires: �� �c�CQ(/-2
9.7..7 are rrste of tt+ie tq.
tics: A. ix nxha) fs scare mor to
that aate ere crosdwed in the Nmj da-
tarminabM fegarl*g ft PtoWsed
Wink the osecta of W D^risiari
2LW<luadlX Ds y decide to halo a
r_
me r.umoer _Krver asset. Currerhly
c0
o. emmana, artd daxet are water
Quality limrtert. This discharge may a1-
fact future alfocatione n this pationd
me receiving stream.
JuneSNCDEtVH-060SOk
AOL
NAM
aL

# Q15Z7/
BUCKEYE
1000 EAST NOIR ST.. P.O. BOX 1305
LUMBERTON. NORTH CAROLINA 28359
TEL [phone] FAX [phone]
January 19, 2001
Charles Weaver
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Buckeye Lumberton Inc., Lumberton, North Carolina (NPDES Permit #NC0005321)
Dear Mr. Weaver:
Enclosed is a permit application for the modification of NPDES Permit #NC0005321 for the Buckeye
Lumberton facility in Lumberton, NC. Buckeye requests your consir�eration of an increase in our current
effluent flow limitation from 1.8 million gallons per day (mgd) tg2.5)mgd. This request involves only a
flow increase. We are not requesting any changes to other existing permitted limitations (BOD, TSS, etc).
As we have previously communicated to Mr. Michael Meyers in your office and Ms. Belinda Henson in the
Fayetteville Regional Office, Buckeye is working on a project to install a new processing operation at the
Lumberton facility. This new process involves cleaning and purification of cotton fibers in a manner
similar to textile and cotton linter pulping operations. The new process is expected to initially add
approximately 300,000 gallons per day to Buckeye's current effluent flow. The major processing
chemicals for the new process (sodium hydroxide, hydrogen peroxide, and sulfuric acid) are also used in
the existing mill process. The concentrations and quantities used in the new process will be much lower
than those currently used so we do not expect any change in the effluent characteristics. Due to the nature
of Buckeye's processes and the necessity for extremely clean water, reuse of this waste stream is not a
practical alternative.
Included with this permit modification request are two additional documents. One is a Hydraulic Capacity
Study of the facility's wastewater treatment system (then called Alpha Cellulose Corporation) completed by
Law Engineering. This study concludes that the wastewater treatment system is capable of handling a flow
of 2.5 mgd. Additionally, we have included a summary table of recent Whole Effluent Toxicity (WET)
results done at Instream Waste Concentrations higher than that the 3.1% we would expect from the
requested flow increase. As indicated, there were no toxicity effects present.
Finally, assuming that this would be a major modification to Buckeye's current NPDES permit, we have
included a check for $860 for the permitting fee.
If you have any questions or need additional information, please contact either Dave Weeden at (850) 584-
1398 or Bryan Laney at [phone].
Sincerely,
Albert A. Bounds
Plant Manager
BUCKEYE LUMBERTON INC.
F E 8 1 5 2001
DENR - WATER QUALITY
POINT SMIRCE BRANCH
Vcq I e.r

L L. � j 2 �001

PROCESS FLOW
I----
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2

BUCKEYE LUMBERTON INC.
FIBERLINE
Cake Press City Water
1 I
Filtrate 1
T� Purification
I I
...... 0....:........
Existing
Water Heater I Process
1
Centrifuge 1
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.—.........
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I I I
Effluent Line from
New Process 1
I I
1.8 MGD------+
0.3MGD—..—..—..—..—..—..—..�
EPrimary Basin
Existing Line
2.1 MGD
W WTP
....................... City Water
Process Water
— - • — • • — WWTP Effluent
ISCHEMATIC OF WATER FLOW FOR NEW FIBERLINE
ES PERMIT NUMBER: NC0005321
NOTE:
The new process will add one tie in
to the existing primary basin.
Buckeye Lumberton Inc.
Lumberton, North Carolina
01 /25/2001

LAW
ENGINEERING AND ENVIRONMENTAL SERVICES
February 1, 1995
Mr. Ronald D. Hilbelink
Alpha Cellulose Corporation
1000 East Noir Street
Lumberton, North Carolina 28359
Subject: Report - Hydraulic Capacity of the
Wastewater Treatment System
Alpha Cellulose Corporation
Lumberton, North Carolina
Law Engineering Project 673-10809-01
Dear Mr. Hilbelink:
tr
E
.�� F F R 15 2001
DENR - WATER QUALITY i
POINT SOURCE BRANCH
Law Engineering is pleased to provide Alpha Cellulose Corporation (ACC) with this report
concerning the hydraulic rapacity of its wastewater treatment system. The purpose of this
work was to assess the hydraulic capacity of the treatment system in order to increase the
permitted discharge rate. This report includes our understanding of project information,
scope of work, results and conclusions.
PROJECT INFORMATION
Project information was provided by Mr. Ronald Hilbelink and Mr. Jim'Israelson of ACC.
ACC provided curves for the system pumps and drawings of the system upgrade dated July
of 1991.
ACC operates a pulp manufacturing plant which includes a wastewater treatment system in
Lumberton, North Carolina. ACC desires to increase its current permitted discharge rate
of 1.8 million gallons per day (mgd) to 2S mgd. The North. Carolina Department of
Environment, Health and Natural Resources, Division of Environmental Management
LAW ENGINEERING, INC.
bC�6%�lOSU9-f)1 5710 OLEANDER DRIVE, SUME 110 • WXNR1GTON. NC 2UM
[phone] • FAX [phone]
ONE OF THE IAM wwIYES

Alpha Cellulose CaWrUdon Ftbncmy 1, 199I
Law Engineoing Project No. 673-10M"I �°1Ol
(NC DEM) agrees with the flow increase provided that the system can hydraulically handle
the greater flow. NC DEM requested that ACC demonstrate the hydraulic capacity of the
system and provide necessary backup information in a letter dated September lb, 1994, to
Mr. Hilbelink.
ACC then requested Law Engineering's assistance in verifying the hydraulic capacity of its
wastewater treatment system.
SCOPE OF WORK
Law Engineering has reviewed the drawings and pump curve information that was submitted
by ACC. The drawings were of improvements made to the wastewater treatment plant in
July of 1991.
A main flow path through the system was established and the system's capability to handle
2.5 mgd was assessed. The main flow path through the system is illustrated in the attached
Figure 1. The purpose of Figure 1 is to graphically illustrate the main flow path and to
show how water moves from one treatment unit to the next.
RESULTS
This section of the report discusses the components of ACC's wastewater system, the main
flow path and the calculation of the hydraulic capacity.
The main components of the wastewater treatment system include an equalization or
primary basin., a flocculation tank, a primary clarifier (formerly dissolved air flotation unit),
an aeration basin, a flocculation/splitter box and three secondary clarifiers. As shown in
Figure 1, the equalization basin is drained by the primary pump. The primary pump feeds
to the primary clarifier which gravity feeds the aeration basin. The aeration basin then
gravity feeds the flocculation/sputter box. Splitter boxes 1 and 2 gravity feed secondary
bc\673-1aW.01 2

I
I
,4pha Cellulose Corporation February 1, 1995
Law Engineering Project No. 673-10809-01 Fwa
clarifiers 1 and 2_ Splitter box 3 feeds secondary clarifier 3 by force main_ The three
secondary clarifiers then tie into a flume which discharges to the Lumber River.
Listed below is a summary of the individual treatment units, their volumes and calculated
detention times. The detention time is based on a flow rate of 2.5 mgd which equates to
approximately 1740 gallons per minute.
Unit Volume (gal.! Detention Time
Equalization Basin 75,000 43 min.
Primary Clarifier (former DAF unit) 147,000 1 hr., 24 min.
Aeration Basin 5,451,000 2 days, 4 hr., 15 min.
Floc/Splitter Box 21,500 12 min.
Secondary Clarifiers 1 and 2 267,000 each 2 hr., 33 min.
Secondary Clarifier 3 212,000 2 hr., 2 min.
The primary pump for transferring liquid from the primary basin to the floc tank and
primary clarifier is a Gorman Rupp 30 Hp model T8A3-B self -priming centrifugal pump.
As shown on the attached pump curve, the total head capacity of this model at 1740 gpm
is approximately 42.5 feet. The head calculation from the equalization or primary basin to
the primary clarifier includes approximately 242 feet elevation difference and various
lengths of 8, 10 and 12-inch ductile iron pipe. The elevation difference assumes the water
level in the sump of the equalization basin is two feet from the bottom_ We assumed this
was the worst -case elevation difference. The tosses from fittings in the ductile iron pipe
were accounted for by using equivalent lengths of straight pipe. The calculated total head
from the equalization basin to the primary clarifier, including factor of safety, is 37 feet,
which is less than the total head capacity of the pump.
The pump for transferring liquid from splitter box 3 to secondary clarifier 3 is a Fairbanks
Morse 10 Hp model 8-B 5444 centrifugal pump. We assumed that box 3 would receive
three -eighths of the flow based on the width of the sliding weirgate and assuming that the
weirgate was raised above the level of water. This assumption gives a flow rate of 650 gpm
to secondary clarifier 3. As shown on the attached pump curve, the total head capacity of
nc\673-10809-01
3

Alpha OXulau Goo pomtion
f , Law Engineering Pmjea Na 673-10809-01
Fd wuary 1, IM
-Fecal
this model turning 705 RPM at 650 gpm is approximately 24 feet The head calculation
between these two units was approximately 8.1 feet, which is less than the head capacity.
CONCLUSIONS
Law Engineering has prepared these conclusions based on information and drawings
provided by ACC. Our assessment of the hydraulic capacity of the system did not include
the sludge handling capability, chemical feed rates, or alternate routes for wastewater flow.
Our conclusions are:
• The system is capable of hydraulically handling the targeted flow of 2.5 mgd.
• If flow is increased to 4.0 mgd, as stated in NC DEM's letter, the system is not
capable of handling the flow hydraulically with the existing pump being used between
the equalization basin and the. primary clarifier.
Law appreciates the opportunity to be of service to ACC in this matter. If you have any
questions concerning this report please contact us at [phone].
Sincerely,
LAW ENGINEERING, INC.
David B. Mayes, P.E.
Project Engineer
DBM/DCS:bsc
Daniel C. Shields, P.E.
Principal Engineer
C l!
SEAS
so-, 0.
bc\sr310W9-M 4

Buckeye Lumberton
Whole Effluent Toxicity Results
Chronic Value
Date
10/18/2000
10/ 19/2000
ChV > 5.1
10/20/2000
10/21 /2000
10/25/2000
10/26/2000
10/27/2000 ChV = 14.4%
10/28/2000
10/29/2000
11 /01 /2000
11/02/2000
1ChV =14.4%
1/03/2000
11 /04/2000
J E E B 15 2001
DENR - WATER QUALITY
POINT SOURCE BRANCH

DEC-13-01 12:13 FROM=WATER ENF SECT`^'-- Tn-apa R62 6692 PAGE 1/7
�NITZD Z74TESc
_ opnoNg-FOW 99l7-9% # of pages �
FAX TRANSMITTAL
pgptJAgency _ 7 a f /\ Pt1Dne 2
y, Fax filly -1. .. ,f V ! i Fax# t fij 6 It6 94
Mr. SteveTedder, Chief N5N 7$40'01 17.7,s 5pg¢101 GENERAL$ERVIGES ADMUNIVMAT10N
� .
Water Quality Section
NC Division of Envi-onmental M naaement
2.0_ Box 29535
Raleigh, ycrt" Carolina 27626-0535
D„ 4� MY • Tad�i'3r _
am pleased. to infor- you of EPA's action on the Total
Maximum Daily Load (TN- DL) Manageme>7.t Strategies for the Lumber
River The T,.NML strategies are for specific waterbodies in
the Lubber 'River '3asin. The NC Division of Bz�virormental
Management (NCL02M) st:bmitted the final 'I'MDL strategies as part of
the ;�4.�' ±�'= River Basinw?de Wales Quality Manage:' L!mr— plan, by Way
Of cover letter dated December S, 1-994.
We are approving these l�T. strategies for the Lumber River
Basle as beinc in Full compliance with Section 303(d) of the
Clean Wale_ Act, which reVires teat T:OLS be established at
levels n�cessa,y to inplement the applicable water Llality
_-andards, tak-.ng into account seasonal variations and an
aoegwate tG-g�y'� vL Sai?Cy. We are also aware that �� some cages,
G romp _te Maragyt,e�,t strategy has r-ot yet been developed due to
ac^i4�cna� worK being required. wt iS anticipated that 7NOLS for
�h =s? Segments w- 1 be Completed during chfe next basirwide update
of t :e u�. Mbe= RJ v`r Basirwide Management Plan scheduled for 1999 .
- res areas o= additional work to develop complete T4%ML
*aracsment strategies `or t e Lumber River $a.sin are planned or
werway- 7'--se include: 4) 4nitiaz:in
g st tidies to develop a 4---
vette r tool to evaivate a swamp syscemrs ability to assimilate
waste G1_ow, sit:ce 85?9 of the waters in the Lumber River Basin ar,
c'_assifizd as Swamps and c,icical cor_ditions may not be related
co _`_ow based o:z observed data. 2) recomm-nending interagency
:corM;:.ation be increased 4o develop a corrrton und�rstar_ding of
`re �xtTn4 and-^-aC�.:: ? of shelifiS`1 water C105t1reS, t0 identify
?XiS�„IC weaknesses iP. ShellFzSh water orotecCion, and to outline
s==at"gy of w^a:. would be required to protect and reopen_ these
wet-rs nc= g :Ih- Teed For Pew rules or legislation and 3)
w ,r i' S with e gat !ral Resources Conse*-vat4 on Service (forr,•.erly
Sci� �cnsecvation Service) to develop hydrologic :maps for
taintai"i„g agrica?t�re b_st manager;ent practice data compatiblevas__. _aP :�_ts7l.:sed by NCDHy:. -
,..
rz
-rl-

DEC-13-01 12:14 FROM:WATER ENF SECTION ID:404 562 e692 PAGE 3/7
Ch.2prer 6 - GoaiS, COrterru and �'larsagemen; Srras�gies
this creek- Thew two creeks may be considered for a HQW classification. Lake Waccamaw and
the Waccamaw River have been nominated for reclassfication to ORW. Results of studies are
pe,lding on those reclassifzcarions.
Irt addition, where waters are known to support state or federally listed ends-ngemd or rhrear .-=3
species or species of concern, but where water quality is not Excellent and there is no state-
designared critical habitat, consideration will be given during NPDES rmittinto minimize
impacts to these habitat areas consistent with the requirmuencs of the federal Endangered Species
Act and North Carolina's endangered species statutes. Of note is the fact that Labe Waccamaec es
its entirety, and Big Creek, from its mouth at Lake Waccamaw upstream approximately 0.4 mile to
ill
the state road 1947 bridge is a federally -designated critical habitat for the federally endangered
Waccamaw Silverside (i,eWda extPnsa,The federal designation of critical habitat at ties location is
especially significant because there are only three such critical habitat designations for aquatic
endangered species in North Carolina. This area aLso supports two state -threatened molluscs, the
Savannah lilliput and Waccarraw spike_ Possible point -source related protection measures may
iuclude effluent derhlorination or alternative disinfection,
ced tertiary treatment,
outfall relocation, backup power provisions to minimize accidental dental planor t sp llsand rhers'I1�e
need for special pravisions will be determined on a case -by -case basis during review of individual
permit applications and take into account the degree of impact and the costs of protection_
6.2.3 Managing Problem Pollutants to Maintain 'Water Quality Standards and
Existing Uses
In addition to restoring impaired waters, protection of other waters which currently meet their
Standards and are considered supporting of their uses is a basic responsibility of the scare's water
quality program and a primary goal of basinwide management. Protecting standards and uses rests
on DEM's ability to control the causes and sources of water pollution from point and uses
rests
sources. Existing paint and nonpoint source programs are ount
tlined in Chapter 5. Oxygen_
demanding wastes and sediment are the most widespread problem pollutants Ln the Lumber basin.
Metals (primarily mercury), fecal coliform bacteria (in sheMsh waters) and nuuients (in lakes and
impoundments) are other important pollutants, requiring management. Point -source oriented
control strategies for oxygen -demanding wastes are further addressed in section 6.3_ Nutrients are
addressed in section 6-4 and toxic substances (including metals, ammonia and chlorine) are
addressed in section 6.5. Sediment control is discussed in section 6.6.
The management strategies outlined below are the results of comprehensive evaluations of all
previously summarized data. It is the intention of NCDEM that the following recommendations
serve the public of North Carolina for long-term plann.izlg purposes General, nonpoint source
management strategies are discussed thoroughly in Chapter 5. Point source controls are
implemented through limiting wastewater parameters in NPDES permits_
6-3 RECOMMENDED MANAGENI.ENT STRATEGIES FOR OXYGEN
DEMANDING WASTES
Oxygen demanding wastes wetly described in Chapter 3. BOD and ammonia nitrogen (NH3) are
generally the types of oxygen -co wastes of greatest Concern. Therefore, NTPDES permits
generally limit BOD5 (or CBODS) and I H3 in point source discharge efauents to control the
effects of oxygen depletion in receiving water&
In most surface water systems throughout the State of NC, the lowest concentrations of dissolved
oxygen usually occur during surmraertime conditions when temperature is high and strearsi flo�y is
low. During these periods point source discharges have their greatest i�u is h while stmar rlt input
is generally low. Nonpoim loads aT,- typically delivered at high flow during and after storm
events, but may have residual effects on water quaLty through runoff and sediment oxygen
Z, r

DEC-13-01 12:14 FROM:WATER ENF SECTION ID:404 562 6692 PAGE
4/7
Chapter 5 - Goals. Concerns and Mancge,nent Strategies
the tributaries. Giver, the inability to determine assimilative capacity with any decree of accuracy,
DEM will initiate srudies to develop a better tool to evaluate a swamp systems ability to assimilate
waste flow_ Since the large influx of floe, from a pipe may have a larger impact on these sysrcros
than actual trea"ent levels, DEM will also be investigating the potential for innovative outfall
designs which will allow a slower release of effluent to the system. Until these studies are
completed, new discharges will not be permitted at limits greater than 15 mgll BOD5 and 4 mg/l
N'H3-N (NH3-N may be lower if dilution is low). On occasion more stringent limits may be given
if staff believe that adverse impacts will occur or if discharge is to HQw or zero flow swam_ Existing facilities will receive existing limits unless they expand. Upon expansion they will receive
existing loading (mass basis). The following subbasin summaries further describe point source
discharges and areas which are designated HQW whc a this general, strategy does not pertaim
Subbasin 03-07-51 (Lumber Rift Mainstem)
The Lumber River subbasin 030751 makes up the entire mainstern of the Lumber River. Except
for three small discharges (one school, one Depar=ent of Corrections, and one municipality) all of
the facilities in this basin with oxygen consuming wastes discharge directly to the Lumber River.
Below, are listed in order from the upper most segment of the River to the end of the Lumber River
in NC, the faciJlties that discharge to the Lumber River main stem (all of the listed facilities have
oxygen consuming wastewater (BOD), but made up of different sources).
�iM
West Point Pe ereil-Wa -,�� • 1 2�_'
pP gmm Lumber River
Laurinburg-Maxion Airport Commission "
Pembroke WW-M
Deep Branch. School ..
Alpha Cellulose Corporation ft
West Poffit Pepperell, Inc.
Lumberton WWI „
The above facilities, with the addition of the Fairbluff WWIP which discharges to a small UT just
above the confluence of the River, were all included in an intensive modeling analysis .for the
Lumber River. Further discussion on the River strategy is discussed below. The additional
facilities located in this subbasin are:
�TC�OC McCain Hosp. Unnamed tribu to M
` Orrum High School UT Flowcr5 swamp ) 4iint2trr Cr.
Town of Fairbiuff UT Lumber River
t
The Lumber River experiences low dissolved oxygen concentrations throughout its course fromm
the West Point Pepperell-W agram discharge location in Scotland County to the NClSC border
Robeson County. As pact of the evaluation of the River, immnsive self -monitoring data have beet
gathered to help assess the origin of the oxygen consuming matter in the River.
Currently there are six major dischargers on the River. West Point Pepperell-Waaram,
Lauriuburg(maxton Airport, and Pembroke all discharge above Lumberton proper, West Point
Pepperell, Alpha Cellulose, and Lumberton WwT15 discharge below Lumberton proper (Figure
-1). The three facilities above Lumberton are scattered along the River but below Lttrubertoa the
three major facilities are very close together (within 1.5 miles).
Historical DO data (1975 to 1992) show no significant mend in DO concentration (Figure 6.3).
Conductivity data since 1982 shows a steady increase over the last 10 years (Fig
conductivity is dependent on flow, it exhibits no clear relationship to the dissolved oxyg n)sagle
6-7

DEC-13-01 12:15 FROM:WATER ENF SECTION ID:404 562 6652 PAGE
5/7
Chapter 6 - Goa!s. Concerns rand tV=agenw z Strategies
Subbasin 03-07-50 (Drowning/Naked Creeks - Upper Lumber Watershed)
This subbase, constitutes the headwaters of the Lumber River mainstem. Drowning Cs4 k and its
tributaries drain the enure subbasin_ The following dischargers of oxygen -consuming wastes
discharge into or close to the receiving waters classified HQW.
S Manor I0CAjjQN
Drowning Creek (uppermost headwaters)
Camp Mackall Drowning Creek
Moore Co. WPC PIant Aberdeen Creek
Take. Diamond Deep Creek
The permitting strategy for HQW per NCAC 213.0201(d)(1) is no increase in permitted loading to
the stream, Most facilities in this subbasin will fall under this regulation. New domestic
wastewater facilities discharging into HQW classified water will receive limits of 5 Ingtl 13OD5, 2
mgn ;`'H3-N, and 6 m_zl DO. No new toxicants will be introduced to waters classified HQW.
Subbasin 03.07-52. (Raft Swamp - Lumber River Watershed)
Raft Swamp is L%c main stream which drains the entire subbasin of 03-07-52. 'Two oxygen
consuming discharges are Iocated in this subbasin. The Converse discharge through pipe 001
recently begu discharging to the Lumberton WWTP. pipes 002 and 003 are cooling water
discharges and remain in Holly Swamp. The characteristics of Little Raft Swamp and Raft Swamp
which it feeds into are swamp -like (slow movieg with low dissolved oxygen values). The self -
monitoring irisrrearm data for Little Raft Swamp show extremely low dissolved oxygen (down to 2
mg/l) values above and below the discharge location. In addition, sediment oxygen demand tests
were performed on Raft Swap and revealed very high rates. The permitting strategy in Table 6.1
will apply to this subbasin.
FA rr-Y WCAMN,
Red Springs W''V`TP Little Raft Swamp
Converse Inc. Holly Swamp
Subbasin 03-07-53 (Big Swamp - Lumber River Watershed)
The Big Marsh Swamp mairstem and its tributaries make up this entire subbasin_ Big Marsh
Swamp has thr= dischargers located on its mai.ustem, but they are not considered interacting. self
mortitoring instream data show these receiving waters to be typically swamp -like with low (below
5 mg/1) dissolved oxygen values above and below the discharge location. The permittinsrratcgy
g in Table 6.1 will apply to this subbasin. The discharges in this subbasin are as follows:
Piedmont Poultry
Croft Metals Inc.
Saint Pauis WWTP
Parkton WWTTP
Bladenboro WWT'p
Littlefield High School
Subbasin 03-07-54 (Ashpole
LOCATTON
Big Marsh Swamp
Big Marsh Swamp
Big Marsh Swamp
Dunn's Marsh
Bryant Swamp
Abram Branch
Swamp - Lumber River Watershed)
There is one discharge in the Ashpole Swamp subbasin. The Fairmont WWTP discharge to
Pirnuan Mill Branch goes directly to Old Field Swamp which feeds into Hog Swamp 1.5 miles
X- 15

DEC-13-01 12=15 FROM=WATER ENF SECTION ID=404 562 6692 PAGE
6/7
CFaprer 6 - Goal. Concerns and Management Srra egies
6.3.3 Waccarnaw River Watershed (Subbasins 03-07-56 to 03.07.58)
These basins are made up of Streams and rivers that are mostly swamp and have characteristics
representing swarrlp-like syg�m. The dissolved oxygen Concentrations collected frorn se;f-
monitoring reports of instream data reflect low dissolved oxygen levels above and below
discharges (below 1 rnSA in some casts). Existing facilities in some of these basins have been
given limits Iess: stringent than 15 mull BOD5 and 4 mg/1 NH3-N based on previous analyses and
recorded substandard DO values. A federally endangered sprfiies is also k;zown to occur in the
Waccarnaw River drainage basin. Therefore, since this system appears to be stressed, new
discharges to these subbasins will be required to meet limits of 5 Ingli GODS and 2 stremVlssed,
3-N-
The fallow-ino subbasin summaries further describe the r=xvmg sueams.
Subbasin U,5-U7-5b (Lake Wacca=W - Waccamaw River Watershed)
This subbasin includes LatCe WacCamaw and the upper Waccamaw River, which drains the lake -
Both the lake and river are being considered for the supplemental classi icadon of ORW. This
wpald affect future and expanding discharges in this subbasin. Specific strategies and Fits may
be modified if this additional classification is given. Endangered species occur in this subbasin,
and special consideration to these waters.should be afforded for that reason. However, specific
strategies for this consideration are also pending. There are two discharges in this subbasin:
FACIL,ra
Council Tool Company
Lake waccamaw WWTP
WCAMN
LIT to fake Waccaruaw
UT to Bogue Swamp
Council Tool Company is an izdustrial discharger which has r the a general non -contact cooling waters. Lake Waccamaw W ;TP is a mt fo
iCipalitty whoeffluenta fluent is ip0-'o
domestic -'waste- The instream DO values above and below the Lace Waccamaw WWTp than 5 mgli, although not atypical of a swamp stream_ are less
lehe Town of Lake Waccaluaw is currently
aking improvements to its plant under a special order by consent, but it is not increasing its
permitted flow_ Any future expansionilt b s we in consonance with stated policies.
Subbasin 03-07-57 (Lower Waceamaw River )
This drainage area delineates the lower Waccarnaw River watershed excluding the White Marsh
{ drainage area.. There are five discharges in this subbasin: one municipality,
ee
schools. No clusters of discharges exist in this subbasin, and there would seem to be no chance of
regionalizadon in the near future because of the somewhat isolated location of the non -municipal
discharges.
Tabor City WWTp discharges to Town Canal which is a tributary to Grissett Swam
rnacroinvertebrate data collected downstream from this discharge indicated poor watper qua tyc
However, it is unlikely that Tabor City is contributing to significant degradation to the water
quality at this site given that these results are less reliable in swampy arm, and the diffusive nature
Of the rwelving stream should buffer effects from this point source. Nevertheless, future WZ„pt
{ analyses for the Town of Tabor City should concentrate On toxicants in the discharge.
EAMM
Tabor Citv Wr p
wal
i Williarns Township School
To Am CCan&
ki
Nana I3igh School
Old Dock ,Elementary School
UT to Gu= Sw=m
UT to Big Cypress Swamp
Carolina Shores vcrWTP
UT to Gum Swamp Run`
CTI' to Persimmon Swamp

DEC-13-01 12:16 FROM=WATER ENF SECTION ID=404 562 8692 PAGE 7/7
C�xer 6 - Goals. Corcerr-r aru{ Mviagemenr Srr=egies
HQW waters will be dealt with or, a case -by -case basis. As implied above, the charade '
this arat s O represent a sensitive ecosystem, 'therefore, since art abundance of point -source
rzstics of
�s of oxygen-consuing wastes have not been evaluated in this Subbasin, t source
recommend that discharge pernut applicants Pe ot7n a special water quality DEM will their proposed discharge is to be Iocated. q ty study in the area where
6-4 NUNA.GEMENT STRA-rEGIES FOR NUTRIENTS
CozztrOI of nutrients is necessary, to limit algal
chlorophyll a standard, and to avoid the devpruent of nuisance conditions in the
wth potential, to assure protection of the instream
waterways. Point source controls are t icall
(TP) and total nitrogen (T,N). N'onpointcontrols ofn trieuts eneraMES
ll storus
Permit limitations on total phosphorus
practices ($Mps) to control nutrient loadingfromm g Y include best management
. areas such as agricultural Ian and urban areas.
6.4.1 Assimilative Capacity
The Dumber liver basin does not have a large nutrient problern. There are not an
sensitive streams but there are a few eutrophic ponds. The conditiorLs of these
directly attributed to point source discharo Y nutrient
A P ponds cannot be
err and are considered to � noripoirlt source related.
6.4.Z Control Stz-ategies
Subbasin 03-07-40 (Drowning Faked Creek - Lumber River Waters
One lake has been sampled in this subbasirz for chlorophyll a and that is Pa Watershed)
point source discharges in or upstream of the lake. € L.ake• There are no
thought to be urban -run In
in the u Therefore, thein this basin..source of exceeded nutrients is
nutrients in Pates Lake should take placejr,on unc DLMIstorm water re�uIauons.
Implementation for controlling
Subbasin 03-07-53
(Big Swamp - Lumber River Watershed)
One pond from this subbasin, Seal Pond, w
an algal bloom was noted. No y as monitored for phytoplarzkton in July, I991 since
be from agdcuinzal nuioff pomt source discharge is attributed to the bloom and it is thought to
Subbasin 03-07-55 (Little Pee Dee Headwaters Watershed)
Algal bloom conditions were found in three
Pond, and �taxton Pond. John's Pond located on Lei
ths Ponds
sampled in this subbasin - John's Pond. Dunn's
and Maxton Pond was found to be eutrophic. The r7nburk was found to be hypereutrophie
Maxton Pond on Shoe Heel Creek, but it is unknown whether re V azge is cared upstream of
eutrophicarion. It is assumed that 4 thrive of these
to e
Should undergo ponds th
are influenced by non -point soturces and
g further monitoring and control by agencies controlling non -point sources.
Subbasin 03-07-56 (Lake Waccamaw _
W$ccamaw River Watershed)
The canals around the northern and, western
have high concentrations of aquatic weed.,
related res of T.aICe Wacraraaw have
related to exf`lltration of sewage -sediment and nutrients. nted to
Some of a problems were
�from the lake yVaccamaw collection system. A ten -inch force
rziain was replaced recently, but continuin
�geted for improvements through issuance of an SOC, MOnitogroblems with � h d continue
have been
if water quality improves as a result of these improvements_ to determine

Buckeye Lumberton
Whole Effluent Toxicity Results
Chronic Value
Date
10/18/2000
10/19/2000 ChV > 5.1%
10/20/2000
10/21 /2000
10/25/2000
10/26/2000
10/27/2000 L C' h V 14.4%
10/28/2000
10/29/2000
11/01/2000
11 /02/2000
ChV =14.4%
11 /03/2000
11 /04/2000
FEB159(w
WATER QUALITY
DENR -
CE BRAWN RAN
POINT SOUR

State of North Carolina
Department of Environment w
fi
and Natural Resources A o
Division of Water Quality NCDENR
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
January 31, 2002
Mr. Albert Bounds, Plant Manager
Buckeye Lumberton, Inc
1000 East Noir Street
P.O. Box 1305
Lumberton, North Carolina 28358
Subject: Authorization to Construct
ATC No. 005321A01
Permit Number NC0005321
Lumberton Plant
Robeson County
Dear Mr. Bounds:
The Division of Water Quality's NPDES Unit has reviewed your request for an Authorization to Construct at
the Buckeye Lumbeton Plant. The Division finds the proposed rerating to be satisfactory and hereby grants
authorization for a re -rating of the facility from 1.8 MGD to 2.5 MGD.
This Authorization to Construct is issued in accordance with NPDES Permit No. NC0005321, issued January
31, 2002, and shall be subject to revocation unless the wastewater treatment facilities are constructed and
operated in accordance with the terms and conditions of the permit.
Requirements for Certified Operator
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 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 15A, 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.
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/

Buckeye Lumbeton, Inc.
NPDES Permit No. NC0005321
ATC No. 005321A01
Page 2
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.
If you have any questions about this Authorization to Construct, please contact Mike Myers, at [phone],
extension 508.
Sincerely,
Gregory J. Thorpe, Ph.D.
Acting Director
cc: Fayetteville Regional Office, Water Quality
Technical Assistance and Certification Unit
Central Files
NPDES Unit Files

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
February 4, 2000
Mr. Albert Bounds, Plant Manager
Buckeye Lumberton, Inc
1000 East Noir Street
P.O. Box 1505
Lumberton, North Carolina 28558
I fflk�W;WAA
T 0
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit Issuance
Permit Number NC0005521
Lumberton Plant
Robeson County
Dear Mr. Bounds:
In accordance with the application for discharge permit received on June %, 1999, the Division is
forwarding herewith the subject state - NPDES permit. This permit is issued pursuant to the requirements of
North Carolina General Statute 145-215.1 and the Memorandum of .agreement between North Carolina and
the U.S. Environmental Protection .agency dated December 6, 1985.
The attached NPDES permit has been finalized with a number of changes as compared to the previous
permit. Significant changes are summarized below:
• As settleable solids has not been detected in the effluent, the monitoring requirement has been
deleted.
• .all dioxin limits and monitoring requirements have been deleted. Given the facility's compliance
history for dioxin and the fact that dioxin is not a by product of cotton linter bleaching, continued
monitoring is neither appropriate nor necessary.
• Because of the use of elemental chlorine for bleaching, the potential continues to exist for total
residual chlorine (TRC) to be present in the effluent. However, given the facility's compliance
history for TRC, the effluent limitation has been deleted and the monitoring frequency has been
reduced from 5/week to quarterly.
• There are currently 11 waters in the Lumber River Basin that have fish consumption advisories
for mercury and appear as impaired waters on the North Carolina 1998 505(d) list. In order to
evaluate the relative contribution of mercury from NPDES point source dischargers, mercury
monitoring of effluent and sludge has been added to this permit. This data will be used to develop
a mercury management strategy by allocating allowable mercury loads to known sources (both
point and non -point). The ultimate goal of the mercury management strategy is to reduce fish
tissue mercury concentrations and eliminate the need for fish -consumption advisories in this basin.
Recent changes to the treatment plant classification rules have prompted a change in monitoring
frequencies at the subject facility. The 1.8 MGD flow constitutes a grade Ill facility while the 4.0 MGD
1617 MAIL SERVICE CENTER, PALEIGH, NORTH CAROLINA 27699-1617 -TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 10% POST -CONSUMER PAPER
VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES

constitutes a grade IV facility. Accordingly, 5/week monitoring (reflective of grade III) has been installed for
the 1.8 MGD flow where daily monitoring was previously required.
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, 6714 Mail
Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be
final and binding.
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 permits which may be required.
If you have any questions regarding the attached draft permit, please do not hesitate to contact me at
telephone number (919) 70-5-5083, extension 555.
Sincerely,
Original Signed By
David A. Goodrich
Kerr T. Stevens
Cc: Central Files
106ES Permj) of
Fayette\ille Regional Office
EPA, Roosevelt Childress
Point Source Compliance/Enforcement Unit

Permit No. NC0005321
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE V'hASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 145-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Buckeye Lumberton, Incorporated
is hereby authorized to discharge Nvaste-%vater from a facility located at
Buckeye Lumberton, Incorporated
1000 East Noir Street
Lumberton
Robeson County
to receiving waters designated as the Lumber River in the Lumber 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 March 1, 2000.
This permit and authorization to discharge shall expire at midnight on July 51, 2004.
Signed this day February 4, 2000.
Original Signed By
David A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NCO005321
SUPPLEMENT TO PERMIT COVER SHEET
Buckeye Lumberton, Inc.
is hereby authorized to:
1. Continue operation of an existing 1.8 \lGD wastewater treatment system consisting of
screening, grit removal, primary clarification, equalization basin, aerobic selector, aeration
basin with nutrient addition and methanol feed, final clarification, sludge holding tank, and
sludge press located at Buckeye's Lumberton facility. 1000 East Noir Street, Lumberton,
Robeson County;
2. After receiving an Authorization to Construct from the Division of Water Quality, increase
flow to 4.0 .,\IGD; and
5. Discharge from said treatment works at the location specified on the attached map into the
Lumber River, a class C-swamp water in the Lumber River Basin.

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
Permit No. NC0005321
During the period beginning on the effective date of the permit and lasting until expansion above 1.8 MGU, the Permittee is authorized to discharge from outfall(s)
serial number 001- Wastewater Treatment Plant Effluent. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE
LIMITATIONS
MONITORING REQUIREMENTS
Monthly Average
Daily Maximum
Measurement
Frequency
Sample Type
Sample
Locations
Flow (MGU)
?, SS
Continuous
Recording
I or E
BOU; (April 1 -October 31)
552 lb/day
664 lb/day
k
Composite
E
BOD,- (November 1 - March 31)
450 lb/day
900 lb/day
3/\\ eek
Composite
E
TSS
425 lb/day
850 lb/day
5/ \\ eels
Composite
E
NH--N
83lb/day
166lb/day
3/weelt
Composite
E
Total Residual Chlorine
OLlarterlY
Grab
E
Total Nitrogen (NO. + NO, +TKN)
Montlik
Composite
E
Total Phosphorus
Monthly
Composite
E
Mercury'
Quarterly
Composite
E
Mercury2
Semi -Annual
Grab
Sludge
Chronic Toxicity''
Quarterly
Composite
E
pH 4
3/Week
Grab
E
Dissolved Oxygen-'
3/Weeks
Grab
E. U, U1, U2
Temperature'
3/Weeltl
Grab
E, U, DI, D2
Conductivity
3/\Veek'
Grab
E. U. D1, D2
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
NOTES:
s Sample Locations: I — Intake, E — Effluent. U — Upstream at NCSR 1620, DI — Downstream at NCSR 2125, D2 — Downstream at NCSR 2121. Instream samples shall be grab
samples collected three times per week during the months of June, July, August, and September and weekly during the remainder of the year.
2 -I'he approved detection level for mercury in the effluent is 0.2 µg/L while the approved detection level for mercury in the sludge is 0.1 nig/kg on a dry weight basis.
Chronic Toxicity (Ceriodaphnia) P/F @2.5�February, Nlay, August, and November. See Condition A(5) of this permit.
4 1`he pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
J -I he daily average dissolved oxygen concentration in the effluent shall not be less than 5.0 ntg/L.
6 The discharge shall not cause the temperature of the receiving stream to exceed 2.8"C above background temperature and in no case cause the receiving stream to exceed 52"C.

A (2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
Perinit No. NC0005321
During the period beginning upon expansion to 4.0 MGD and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001-
Wastewater Treatment Plant Effluent. Such discharges shall be limited and monitored by the Perniittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE
LIMITATIONS
MONITORING
REQUIREMENTS
Monthly Average
Daily Maximum
Measurement
Frequency
Sample Type
Sample
Locations
Flow (MGD)
4.0
Continuous
Recording
I or E
BOD; (April 1 - October 31)
332 lb/day
664 lb/day
Daily
Composite
E
BOD, (November 1 -March 31)
450 lb/day
900 lb/day
Daily
Composite
E
TSS
425lb/day
850lb/day
Daily
Composite
E
NH--N
83lb/day
1661b/day
Daily
Composite
E
Total Residual Chlorine
Quarterly
Grab
E
Total Nitrogen (NO. + NO; +TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Mercury
Quarterly
Composite
E
Mercury'
Semi -Annual
Grab
Sludge
Chronic Toxicity''
Quarterly
Composite
E
pH 4
Daily
Grab
E
Dissolved Oxygen
DailyI
Grab
E, U, D1, D2
Temperature"
Daily'
Grab
E. U, D1, D2
Conductivity
Daily
Grab
E, U, DI, D2
THERE SHALL BE NO DISCHARGE OF FLOATING: SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
NOTES:
i Sample Locations: I - Intake, E - Effluent, U - Upstream at NCSR 1620, D 1 - Downstream at NCSR 2123, D2 - Downstream at NCSR 2121. Instream samples shall be grab
samples collected three times per week during the months of June, July, August, and September and weekly during the remainder of the year.
2 The approved detection level for mercury in the effluent is 0.2 µg/L while the approved detection level for mercury in the sludge is 0.1 nig/hg on a dry weight basis.
5 Chronic Toxicity (Ceriodaphnia) P/F @ 4.9%; February, May, August, and November. See Condition A(4) of this permit.
4 Tlie pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5 "I'he daily average dissolved oxygen concentration in the effluent shall not be less than 5.0 mg/L.
6 "I he discharge shall not cause the temperature of the receiving stream to exceed 2.8"C above background temperature and in no case cause the receiving stream to exceed 32°C.

Permit No. NC0005321
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A (5). CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) — 1.8 MGD
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia duhia at an effluent concentration of 2.5%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent
versions or "North Carolina Phase I1 Chronic Whole Effluent Toxicity Test Procedure" (Revised -February
1998) or subsequent versions. The tests will be performed during the months of February, May. August, and
November. 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 11 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
\lonitoring Form (1\114-1) for the months in which tests were performed, using the parameter code TGPJB for
the pass/fail results and THP5B for the Chronic Value. Additionally, D\WQ Form AT-5 (original) is to be sent
to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
1621 Nlail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will
be required during the following month.

Permit No. NC0005321
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS - Continued
A (3). CONTINUED...
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.
A (4). CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY) - 4.0 MGD
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia duhia at an effluent concentration of 4.9%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent
versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February
1998) or subsequent versions. The tests will be performed during the months of February, May. August, and
November. 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 \\hole 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 TGPJB for
the pass/fail results and THP,SB for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent
to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30
days after the end of the reporting period for which the report is made.

Permit No. NC0005321
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS - Continued
A (4). CONTINUED...
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow. in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above.
Should the permittee fail to monitor during a month 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.

BUCKEYE
1000 EAST NOIR ST., P.O. BOX 1305
LUMBERTON, NORTH CAROLINA 28359
TEL [phone] FAX [phone]
January 3, 2000
Mark McIntire, NPDES Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
I ~
i�
DEHR - *'ATc R f 1, ;1.JTY
PO!MT S J - rr.-
Re: Buckeye NPDES Permit (Permit No. NC0005321), Lumberton Plant, Robeson County
Dear Mr. McIntire:
Buckeye is pleased to submit the following comments on its draft NPDES permit dated November 24, 1999.
Total Residual Chlorine — Buckeye continues to believe that this monitoring requirement is not appropriate.
Your note in the cover letter indicates that we have been using an unapproved analytical method to monitor Total
Residual Chlorine and that our long history of "non -detects" cannot therefore be used to justify removing this
requirement from our permit. Our discussions since that letter was written have concluded that the method we
use (Method 4500-Cl Electrode, Orion Model 97-70 Electrode), is an approved method (40CFR 136.3). We have
been monitoring for Total Residual Chlorine daily and now have a history of more than three years of continuous
"non -detect" results. This history shows that on a continuous basis, including all production grades and
operating conditions and seasons of the year, that residual chlorine is just not present in our effluent. Continuing
this monitoring involves time and effort and is just not appropriate.
Dioxin: Buckeye would still request that Dioxin monitoring requirements be removed from the permit for the
following reason:
As stated in the original permit renewal letter, Buckeye maintains that effluent analyses show that this facility
does not present a source of dioxin to the Lumber River. After an additional review of the September 6, 1994
Fact Sheet written by DENR for the NPDES permit issued January 27, 1995, Buckeye Lumberton believes a
dioxin limit should not have been established in the permit.
The September 6, 1994 Fact Sheet states that the dioxin limit was established under the Clean Water Act Section
304(l). This reference states:
"(I) Individual Control Strategies for the Toxic Pollutants
1 each State shall submit to the Administrator...
A. a list of those waters within the State which after the application of effluent
limitations ... cannot reasonably be anticipated to attain or maintain (i) water
quality standards... due to toxic pollutants, or (h) that water quality which shall
assure protection of public health, public water supplies, agricultural and
industrial uses...
B. a list of all navigable waters in such State for which the State does not expect
the applicable standard... will be achieved... due entirely or substantially to
discharges from point sources of any toxic pollutants...
BUCKEYE LUMBERTON INC.

C. for each segment of the navigable waters included on such lists, a determination
of the specific sources discharging any such toxic pollutants which is believed to
be preventing or impairing such water quality and the amount of each such toxic
pollutant discharged by each such source; and
D. for each such segment, an individual control strategy which the State determines
will produce a reduction in the discharge of toxic pollutants from point sources
identified by the State under this paragraph through the establishment of effluent
limitations..."
However, we have not been able to locate a list of such waters developed by NCDENR Under Section 303(d) of
the CWA, all States are required to develop a list of waters which do not meet water quality standards for
conventional parameters under CWA 301(b)(1)(A-B). The 303(d) list also includes information for other
pollutants the Administrator identifies under CWA 304(a)(2) which are "factors necessary to restore and
maintain the chemical, physical, and biological integrity of all navigable waters, ground waters, waters of the
contiguous zone and the ocean ... and for the purpose of Section 303, on the identification of pollutants suitable
for maximum daily load measurement correlated with the achievement of water quality objectives." Therefore, it
is believed that the waters which are required to be listed under CWA 304(I) are included in the North Carolina
303 (d) list.
While DENR's 303(d) list last updated May 15, 1998 does include the Lumber River Subbasin 30751, only
mercury is listed as a problem parameter. Since Lumber River Subbasin 30751 is not included on the 303(d) list
for dioxin and Buckeye Lumberton was not listed as a specific point source for this contaminant, it is our belief
that an individual control strategy for the control of dioxin from the Buckeye Lumberton discharge was not and is
not warranted.
Secondly, DENR has proposed a limit of 4.3 pg/1 for dioxin. As stated in section A(5) of the draft permit, the
detection level for dioxin is 10 pg/l. Buckeye Lumberton questions why a limit was established below the
regulatory detection level and we request that NCDENR provide documentation showing how the 4.3 pg/1 limit
was derived.
Buckeye Lumberton requests that NCDENR reevaluate the proposed dioxin limit and monitoring requirements.
We would be happy to meet with you to discuss this item and address your concerns with this parameter.
Minor Tyweranhical Error — In Section A(5), the third paragraph, third line down — the word "part" is
misspelled. "The monitoring plan is an enforceable part of this permit."
Buckeye appreciates this opportunity to submit these comments and we look forward to working with you on
these issues. If you should have any questions or comments, please don't hesitate to call me at 910-737-3225.
Sincerel ,
..
c
Eric Bolin
Environmental Manager ,.
k0-��
�s� y,

Draft permit for Buckeye Lumberton NC0005321
Subject: Draft permit for Buckeye Lumberton NC0005321
Date: Tue, 21 Dec 1999 10:00:53 -0500
From: Kristie Robeson <[e-mail]>
To: Mark McIntire <[e-mail]>
Hey Mark.
The only error I found in this draft was in Special Condition A(4). The
last 2 paragraphs in that tox language were left out. These would be
the paragraphs that say "Should any test data from this monitoring
requirement .... indicate potential impacts to the receiving stream, this
permit may be reopened...."
The other paragraph is the one about retesting after an invalid tox
test. "NOTE: Failure to achieve test conditions.....".
If you have any questions call me.
1 of 1 01/31/2000 10:02 AM

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO005321
Facility Information
Applicant/Facility Name:
Buckeye Lumberton, Incorporated
Applicant Address:
1000 East Noir Street, Lumberton, NC 28358
Facility Address:
1000 East Noir Street, Lumberton, NC 28558
Permitted Flow
1.8 MGD and 4.0 MGD
Type of Waste:
100% Industrial
Facility/Permit Status:
Renewal
County:
Robeson
Miscellaneous
Receiving Stream:
Lumber River
Regional Office:
Fayetteville
Stream Classification:
C-Swamp
USGS Topo Quad:
I25SW
303(d) Listed?:
Yes, Hg
Permit Writer:
Mark McIntire
Subbasin:
03-07-51
Date:
October 14, 1999
Drainage Area (mi2):
712
q�
Summer 7Q 10 (efs)
120
Winter 7Q10 (efs):
191
Average Flow (efs):
853
IWC (%) 1.8/4.0 MGD:
2.3/4.9
Primary SIC Code:
2611
SUMMARY OF FACILITY AND WASTELOAD ALLOCATION
Buckeye Lumberton, Incorporated operates a high quality paper manufacturing facility (formerly owned and
operated by Alpha Cellulose). The facility was originally put into service in 1968 with the U.S. Environmental
Protection Agency issuing the original NPDES permit. The facility processes cotton linters into pulp for use in
high quality paper products. The linters are cooked, bleached, and dried in the pulp making process.
Bleaching is achieved via elemental chlorine addition 95% of the time and sodium hypochlorite 5% of the time.
In 1996 Alpha Cellulose was issued a Special Order by Consent (SOC# 96-004 AdII, attached). The facility
was having difficulty meeting effluent TSS and BOD limitations. The facility contracted Eckenfelder, Inc. to
complete a treatability study and make treatment system modification recommendations. The results of the
treatability study were presented to Division staff at the Fayetteville Regional Office on June 13, 1997. It was
concluded that elevated TSS and BOD values in the effluent were the result of bulking sludge caused by
excessive filamentous bacteria growth. It was further determined that a short hydraulic residence time aerobic
selector upstream of the treatment facility would effectively select against excessive filamentous growth. An
Authorization to Construct (project number 005321ACD) was issued for the project on April 9, 1998. The
engineer's certification signifying completion of construction was received on January 6, 1999. Since
completion of construction, the facility has been granted an extension of the SOC until June 30, 2000. The
extension was granted to give the facility time to review the performance of these new facilities.
The Lumber River is currently listed on the State's 303(d) list as impaired due to mercury. Additionally, there
is a fishing advisory in the Lumber due to mercury contamination. The Division is currently developing a
TMDL for mercury in the Lumber.
As mentioned previously, this permit was originally developed by EPA. Limitations were established to protect
water quality as no effluent guidelines applicable to this specific manufacturing process were available. A water
quality model for the Lumber River was completed in the mid-70s. The results of that modeling effort
indicated that the discharges from Alpha Cellulose and the City of Lumberton interacted making the river water
quality limited. As such, the Lumber River Basinwide Management Plan recommended (and continues to do so)
that existing discharges be held at existing load. The facility did receive a hydraulic expansion from 1.8 MGD
to 4.0 MGD in 1992. The expansion did not allow for an increase in organic loading. As the basin plan
continues to make the recommendation that no increase in load be allowed, and based on my review of
Buckeye L irnberion kit i Sheet
NPl)F=,S Pciwv-1!
Pa gk- i

downstream dissolved oxygen data (see Instream Monitoring portion of this report), limits will remain
unchanged in this renewal.
The permit renewal application package made the following specific permit related requests:
• Elimination of the effluent limitation and monitoring requirement for total residual chlorine;
• Removal of monitoring requirement for settleable solids;
• Reduction of the monitoring frequency for effluent dioxin from quarterly to annually and elimination of the
requirement to conduct influent dioxin monitoring; and
• No installation of limits or monitoring frequencies for mercury.
As is the case with many pulp mills performing bleaching, residual chlorine and dioxin have the potential to be
present in quantities capable of degrading water quality and/or the instream biological community. A review of
effluent data for residual chlorine indicated that none has been detected in over 500 sampling events. All
values have been reported as less than 10 µg/L. In that this facility utilizes elemental chlorine for 95% of its
bleaching operation, the less than detection values prompted the writer to investigate the test method employed
for residual chlorine. Eric Bolin of Buckeye informed me on October 14, 1999 that their laboratory was using
method 4500-Cl I: lodometric Electrode Technique. The Water Quality Laboratory indicated to me that this
method is not approved. Further discussions with Eric Bolin indicated that they in fact use method 4500-Cl G,
which is approved. Although TRC has not been detected, elemental chlorine is added for bleaching purposes.
As a result, some infrequent monitoring will remain to insure continued non -detection. The monitoring
frequency has been reduced from 5/week to quarterly.
The facility is currently required to meet a dioxin limit and monitor that parameter quarterly at both the
influent and effluent. Additionally, the facility is required to conduct a fish tissue study once per permit cycle
for dioxin. A review of Discharge Monitoring Reports (DMRs) did not reveal influent dioxin data. Although
this facility uses elemental chlorine for the vast majority of its bleaching, the potential for dioxin to be present
in the effluent is extremely low given that the pulp being bleached is derived from cotton linters. According to
Kerry Jo Shell of EPA Region, IV in Atlanta, these linters are apparently not a high source of lignin and
therefore dioxin is not expected to be in the effluent. Self -monitoring data supports the lack of dioxin in the
effluent. As such, the dioxin monitoring requirements have been deleted from the permit.
A review of DMR data indicated that settleable solids has not been detected in the effluent. As such, there is
no need for continued monitoring in the effluent. The monitoring requirement for settleable solids will be
eliminated.
The facility also requested that neither monitoring nor limits be installed for mercury. As the Lumber River is
listed for mercury impairment, a TMDL is currently under development. As the facility doesn't seem to have
mercury data available (with the exception of a single APAM submitted in 1997 — mercury not detected), at a
minimum monitoring should be conducted on a quarterly basis. There is no justification for a limitation at this
time, however, should the monitoring data suggest that mercury is present, limitations may be established in
accordance with an approved TMDL.
TOXICITY TESTING:
Current Requirement: Chronic P/F @ 2.5% at 1.8 MGD using Ceriodaphnia
Chronic P/F @ 4.9% at 4.0 MGD using Ceriodaphnia
No change to the toxicity testing condition is recommended at this time. This facility has passed all toxicity
tests since at least January of 1997.
COMPLIANCE SUMMARY:
As discussed in the summary section of this report, this facility is currently under an SOC for BOD and TSS.
Construction has been completed on a new system to solve the problem. This system is still in the startup
mode. The SOC requires compliance with final permit limits by April of 2000. The facility appears to have
been in compliance with the limits established in the SOC since it was issued.
1311clie}oe l_umberton Fact Sheet
Pitge

INSTREAM MONITORING:
This facility is required to monitor dissolved oxygen, temperature, and conductivity instream. Upstream
monitoring is conducted at NCSR 1620. There are two downstream locations designated in the permit. The
first is at NCSR 2123 and the second is at NCSR 2121. A review of upstream and downstream data seems to
suggest that this facility is impacting receiving stream water quality. Elevated levels of conductivity are evident
downstream of the effluent while DO shows a decline, sometimes by more than 1 mg/L, from upstream to
downstream. On 12 sampling occasions during the months of May, June, July, and August of this year, the
discharge apparently caused downstream excursions below the water quality standard of 5.0 mg/L (this does
not include times when the upstream DO reading was already below the standard). Given that the receiving
stream is classified as C-Swamp, this may not be a problem as the 5.0 mg/L is a non -swamp standard.
Regardless, this fact underscores the need to maintain effluent limitations for oxygen -consuming wastes at
existing levels.
PROPOSED CHANGES:
Settleable Solids: As this parameter has never been detected, monitoring will be deleted with this draft permit.
Influent Dioxin Monitoring: As dioxin has not been detected in the effluent since at least the beginning of
1997, influent monitoring is not necessary. Effluent monitoring and fish tissue sampling will remain in place
unchanged.
Mercury Monitoring: As the Lumber River is listed for mercury impairment, and given that the facility does not
have a body of mercury data, quarterly monitoring has been installed in support of current TMDL development
efforts.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: November 17, 1999
Permit Scheduled to Issue: January 3, 2000
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please contact Mark
McIntire at [phone] ext. 555.
REGIONAL OFFICE COMMENT: /V Ors¢ c.; 4 &U c- ,6,nc, �„ �(.�e,r.� �t a?ci1
Sac- re
EPA REGION IV COMMENT:
NAME: DATE:
Bmke.);e Lumberton Fact Sheet
Ni?10,'S Renewal
1'age 3

NORTH CAR( NA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
- -
NCEXNR
September 29, 1999
Albert A. Bounds, Plant Manager
JAMESB. HUNTJR.
Buckeye Lumberton, Inc.
GOVERNOR
P. O. Box 1305
Lumberton, NC 28359-1305
Subject: Special Order by Consent
47
.. WAYNE MCDEVITT
Buckeye Lumberton, Inc.
Y
.;,, SECRETARY
EMC WQ 96-004 Ad 11
9,
Robeson County
Dear Mr. Bounds:
KERR T. STEVENS
;- DIRECTOR
Attached for your records is a copy of the signed Special Order by Consent
approved by the Environmental Management Commission.
The terms and conditions of the Order are in full effect, and you are reminded that
all final permit limits contained in the permit must be met except those modified by
the conditions of the Order. Additionally, as specified in paragraph (2) (d) of the
Order, submittal of written notice of compliance or non compliance with any
schedule date is required to be submitted to this office.
Pursuant to amended North Carolina General Statute 143-215.3D, effective January
1, 1999, water quality fees have been revised to include an annual fee for any permit
covered under a Special Order by Consent in addition to the annual fee for the
permit. The treatment plant will be subject to a fee of $500.00 on a yearly basis
while under this order, in addition to an annual permit fee of $2,865. The Company
will be billed for this at a later date.
If you have questions concerning this matter, please contact Marcia Lieber at (919)
733-5083 ext. 530.
Sincerely,
r
Kerr T. Stevens
Attachment
cc: Regional Office, FRO
Mike Hom, EPA
i~
SOC Files
-"'
Central Files
Jeanne Phillips
P.O. BOX 29535, RALEIGH, NORTH CAROLINA 27626-0535
PHONE [phone] FAX [phone]
=. -
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST -CONSUMER PAPER

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF ROBESON
IN THE MATTER OF
NORTH CAROLINA ) SPECIAL ORDER BY CONSENT
NPDES PERMIT ) EMC SOC WQ 96-004 ADII
NUMBER NC0005321 )
HELD BY BUCKEYE LUMBERTON, INC. )
Pursuant to provisions of North Carolina General Statute (G.S.) 143-215.2, this Special Order by
Consent is entered into by Buckeye Lumberton, hereinafter referred to as the "Company", and
the North Carolina Environmental Management Commission, an agency of the State of North
Carolina created by G.S. 14313-282, and hereinafter referred to as the "Commission":
The Company and the Commission hereby stipulate the following:
(a ) The Company holds North Carolina NPDES Permit No. NC0005321for operation of an
existing wastewater treatment works and for making an outlet therefrom for treated wastewater to
the Lumber River, Class "C-swamp" waters of this State in the Lumber River Basin, but is
unable to consistently comply with final effluent limitations for BOD and TSS as set forth in
NPDES Permit NC0005321. Compliance will require preparation of plans and specifications for
construction and operation of additional treatment works.
(b) Noncompliance with final effluent limitations constitutes causing and contributing to
pollution of the waters of this State named above, and the Company is within the jurisdiction of
the Commission as set forth in G.S. Chapter 143, Article 21.
(c) Since this Special Order is by Consent, neither party will file a petition for a contested case
or for judicial review concerning its terms.
2. The Company desiring to comply with the Permit identified in paragraph 1(a) above,
hereby agrees to do the following:
(a) Comply with all terms and conditions of the Permit except those effluent limitations
identified in paragraph 1(a) above. See attachment "A" for all current monitoring requirements
and effluent limitations. The permittee may also be required to monitor for other parameters as
deemed necessary by the Director in future permits or administrative letters.
(b) Undertake the following activities in accordance with the indicated time schedule:
1) Buckeye Lumberton, Inc. has winter of 1996 through March 1997, to evaluate it's production
process and treatment system and to perform such pilot studies as may be necessaryto test/
analyze any change or modification needed to achieve compliance. (met)

2) Buckeye Lumberton, Inc. will submit a report and/ or plans for modifications or additions by
May 31, 1997. (met)
3) DWQ will complete the review of the materials submitted by August 31, 1997. If the
evaluation and studies required in item 2(b)(1) conclude the defined permit limits are not
technologically or economically achievable, DWQ will consider a modification of the permit
limits consistent with existing water quality standards upon proper permit modification
application. (met)
4) Buckeye Lumberton, Inc. will submit all necessary requests for an Authorization to Construct
by January 1, 1998. (met)
5) Buckeye Lumberton, Inc. will complete all required construction by January 1, 1999. (met)
6) Buckeye Lumberton, Inc. will submit a progress report to the Division of Water Quality on or
before February 15, 2000 which details the performance of WWTP since January 1999. The
report will include an evaluation of removal rates for BOD and TSS and a summary of the
effectiveness of the modifications had on achieving compliance with final NPDES effluent
limitations.
7) Buckeye Lumberton, Inc. will comply with Final NPDES permit limits by April 1, 2000.
(c) During the time in which this Special Order by Consent is effective, comply with the interim
effluent limitations contained in Attachment A. The following reflects only the limitations that
have been modified from NPDES requirements by this Order:
Permit Limits Modified Limits (SOC)
Parameters
Unit
Monthly Avg.
Daily Max.
Monthly Av-g.
Daily Max.
BOD (summer)
lbs/day
332
664
415
830
BOD (winter)
lbs/day
450
900
563
1125
TSS (wider)
lbs/day
425
850
738
1476
TSS (winter)
lbs/day
425
850
738
1476
(d) No later than fourteen (14) calendar days after any date identified for accomplishment of anv
activity listed in 2(c) above submit to the Director of the North Carolina Division of Water
Quality (DWQ) written notice of compliance or noncompliance therewith. In the case of
noncomlliance, the notice shall include a statement of the reason(s) for noncompliance, remedial
action(s) taken and a statement identifying the extent to which subsequent dates or times for
accomplishment of listed activities may be affected.
3. The Company agrees that unless excused under paragraph four (4), The Company will pay the
Director of DWQ, by check payable to the North Carolina Department of Environment and
Natural Resources, according to the following schedule for failure to meet the deadlines set out
in paragraphs 2(b) and 2(d), or failure to attain compliance with the effluent
limitations/monitoring requirements contained in Attachment A

Failure to meet a schedule date $ l 00/day for the first ,
7 days; $500/day
thereafter
Failure to maintain compliance with
any modified limit contained in the SOC
Failure to achieve compliance with
limitations at final compliance
deadline
Monitoring frequency violations
Failure to submit progress reports
$ 1 000/monthly violation
$250/ daily violation
$10,000
$100 per omitted value
per parameter
$50/day for the first 7
days; $250/day thereafter
4. The Company and the Commission agree stipulated penalties are not due if the Company
satisfies the Division of Water Quality noncompliance was caused solely by:
a. An act of God;
b. An act of war;
c. An intentional act or omission of a third party but this defense shall not be available if the act
or omission is that of an employee or agent of the defendant or if the act or omission occurs in
connection with a contractual relationship with the Permittee;
d. An extraordinary event beyond the Permittee's control. Contractor delays or failure to obtain
funding will not be considered as events beyond the Permittee's control; or
e. Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand to pay the penalties, or challenge
them by a contested case petition pursuant to G.S. 150B-23, will be grounds for a collection
action, which the Attorney General is hereby authorized to initiate. The only issue in such an
action will be whether the thirty (30) days has elapsed.
5. Noncompliance with the terms of this Special Order by Consent is subject to enforcement
action in addition to the above stipulations, including injunctive relief pursuant to G.S. 143-
215.6.(C).
6. This Special Order by Consent and any terms, conditions, and interim effluent limitations
contained herein, hereby supersede any and all previous Special Orders, Enforcement
Compliance Schedule Letters, terms, conditions, and limitations contained therein issued in
connection with NPDES Permit No. NC00532. In the event of an NPDES Permit modification
or renewal, any effluent limitations or monitoring requirements contained therein shall supersede
those contained in Attachment A of this Special Order by Consent, except as modified and
contained in paragraph 2(d) above.

7. The Permittee, upon signature of this Special Order by Consent, will be expected to comply
with all schedule dates, terms, and conditions of this document.
8. This Special Order by Consent shall expire June 30, 2000.
For the Buckeye Lumberton, Inc.
Print Name and Title of Signing
"Iz 12� A e 6—
Signature of Signing Official
Date 71
Z,31,9-9
For the North Carolina Environmental Management Commission
X----�._ Date
Chairman of the Commission

Attachment A Winter Limits (November 1 to March 31)
A. O Effluent Limitations and Monitoring requirements Final Permit No. NC0005321
During the period beginning upon execution of the Order and lasting until April 1, 2000, the Permitee is authorized to discharge from outfall(s) serial number 001,
process wastewaters. Such discharges shall be limited and monitored by the Permitee as specified below:
Effluent characteristics
Flow
BOD, 5 Day, 20°C
Total Suspended Residue
NH3 as N
Dissolved Oxygen (+)
Temperature*
Total Nitrogen (NO2+ NO3
+TKN)
Total Phosphorus
Total Residual Chlorine
Conductivity
Dioxin (2378-TCDD) ***
Chronic Toxicity****
Setttleable Solids
Discharge Limitations
Monitoring requirements
Lbs. da
Units (specify)
Measurement
Sample
*Sample
°
Frequency
Type
Location
Monthly
Daily Max.
Monthly Daily
Ave.
Ave. Max.
1.8 MGD
Continuous
Recorder
E, I
563
1125
Daily
Composite
E
738
1476
Daily
Composite
E
83.0
166.0
Daily
Composite
E
Daily
Composite
E, U, D
Daily
Grab
E, U, D
Monthly
Composite
E
Monthly
Composite
E
28 µg /I
Daily
Grab
E
Daily
Grab
E, U, D
4.3 pg /1
Quarterly
Composite
E
Quarterly
Grab
E.
Weekly
Grab
E
*Sample Locations: E-Effluent, I- Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be collected three times per week during June, July, August, and September and once per week during the other months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8°C above background temperatures and in no case cause the receiving stream to exceed
32.0°C.
*** See Attachment B.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%, February, May, August and November; see attachment C.
(+)The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0
There shall be no discharge of floating solids or visible foam in other than trace amounts.

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GKEX88/MP
03/18/1999
COMPLIANCE EVALUATION ANALYSIS
REPORT
PAGE 2
PERMIT--NC0043320
PIPE--001
REPORT
PERIOD:
9702-9801
LOC
--- E
FACILITY--BURLINGTON KLOPMAN FABRICS
DESIGN FLOW--
1.2000
CLASS--2
LOCATION--CORDOVA
REGION/COUNTY--06
RICHMOND
TGP3B
00010
00095
00400
00545
00600
00665
00940
MONTH CERI7DPF
TEMP
CNDUCTVY
PH
RES/SET
TOTAL N
PHOS-TOT
CHLORIDE
LIMIT NOL
NOL
NOL
9.0 6.0
NOL
NOL
NOL
NOL
97/02 1
9.00
180.0
6.9-6.9
.0
1.940
.7000
18.30
97/03
12.40
167.2
6.9-6.8
43.30
97/04
14.00
149.0
6.9-6.8
.0
18.00
97/05 1
15.25
125.0
6.9-6.8
4.600
.6000
28.50
97/06
19.60
121.0
6.9-6.8
.0
21.00
97/07
22.40
117.4
6.9-6.5
.0
14.40
97/08
23.00
110.2
6.9-6.7
.0
3.900
1.0600
20.10
97/09
21.20
117.0
6.9-6.7
.0
24.40
97/10
16.50
123.2
6.9-6.7
.0
30.00
97/11 1
13.00
135.0
6.9-6.8
.0
4.320
.3800
36.20
97/12
9.60
137.2
6.8-6.7
.0
23.80
98/01
8.50
119.2
6.9-6.6
.0
14.80
AVERAGE 1
15.37
133.4
.0
3.690
.6850
24.40
MAXIMUM 1
24.00
188.0
4.600
1.0600
43.30
MINIMUM 1
8.00
101.0
6.500
1.940
.3800
14.40
UNIT PASS/FAI
DEG.0
UMHOS/CM
SU
ML/L
MG/L
MG/L
MG/L
4 1

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GKEX88/MP
03/18/1999
COMPLIANCE EVALUATION ANALYSIS
REPORT
PAGE 1
PERMIT--NC0043320
PIPE--001 REPORT PERIOD:
9702-9801
LOC
--- E
FACILITY--BURLINGTON
KLOPMAN FABRICS
DESIGN FLOW--
1.2000
CLASS--2
LOCATION--CORDOVA
REGION/COUNTY--06
RICHMOND
50050
00310
00530
00610
31616
50060
00300
00340
MONTH
Q/MGD
BOD
RES/TSS
NH3-N
FEC COLI
CHLORINE
DO
COD
LIMIT F
1.2000
F 430.00
F 413.0
F 50.00
F 200.0
NOL
NOL
F 1902.0
97/02
.5003
67.75
83.0
.55
.0
62.000
5.20
1024.2
97/03
.5707
61.75
74.0
1.32
.0
60.000
5.22
830.5
97/04
.5280
51.80
49.2
.95
.0
60.000
5.25
763.8
97/05
.5549
70.25
61.0
2.34
.0
60.000
5.22
802.2
97/06
.5287
71.75
57.7
5.48
.0
64.761
5.20
851.0
97/07
.5032
81.60
99.8
6.38
.0
61.739
5.24
774.6
97/08
.6162
41.65
61.7
1.38
.0
62.857
5.25
587.0
97/09
.5741
36.40
127.2
.32
.0
60.909
5.26
638.4
97/10
.5910
44.25
87.7
.46
.0
61.739
5.22
881.5
97/11
.5756
50.25
75.7
.36
.0
63.000
5.25
762.7
97/12
.4289
32.80
119.4
.46
.0
57.391
5.24
442.6
98/01
.5481
32.00
110.0
.31
.0
63.636
5.20
363.0
AVERAGE
.5433
53.52
83.8
1.69
.0
61.502
5.22
726.7
MAXIMUM
.8550
123.00
298.0
10.10
LESSTHAN
80.000
5.30
1245.0
MINIMUM
.0890
8.00
12.0
LESSTHAN
LESSTHAN
40.000
5.20
92.0
UNIT
MGD
LBS/DAY
LBS/DAY
LBS/DAY
#/100ML
UG/L
MG/L
LBS/DAY

DIVISION OF WATER QUALITY
August 23, 1999
MEMORANDUM
TO: Dave Goodrich, Supervisor
Permitting and Engineering Unit
FROM: Grady Dobson, Environmental Engineer
Fayetteville Regional Office
THRU: Paul E. Rawls
Water Quality Regional Supervisor
SUBJECT: Renewal of NPDES Permit No. NC0005321
Buckeye Lumberton, Inc.
Robeson County
A k4
Please find enclosed the staff report and recommendations of the Fayetteville Regional
Office concerning the renewal of subject NPDES Permit.
If you have any questions or require further information, please advis
GD:PER/bs O
Enclosure D �'

SOC PRIORITY PROJECT: YES_ NO X
If Yes, SOC No.
To: Permits and Engineering Unit
Water Quality Section
Attention: Charles Weaver
Date: August 23 1999
NPDES STAFF REPORT AND RECOMMENDATION
COUNTY: Robeson
Permit No. NC 0005321
PART I - GENERAL INFORMATION
1. Facility and Address: Buckeye Lumberton, Inc.
1000 East Noir Street, Box 1305
Lumberton, NC 28359
2.
3.
4.
5.
6.
7.
Date of Investigation: July 8, 1999 1 1 )/ ov�
Report Prepared by: Grady Dobson, Environmental Engineer, FRO I . --�j
Persons Contacted and Telephone Number: Eric Bolin - 910-737-3225
Directions to Site: Facility is located at 1000 Noir Street, Lumberton, NC.
Discharge Point(s), List for all discharge points:
Latitude 340 36' 20"
U.S.G.S. map attached.
U.S.G.S. Quad No.
I 23 SW
Longitude: 780 59' 35'
U.S.G.S. Quad Name:
SW Lumberton, NC
Site size and expansion area consistent with application:
Yes No (If No, explain)
Application makes no reference of expansion area. Any expansion would
be within the flood plain. Adequate land is available if flood protection is
employed.
Topography: (relationship to 100-year flood plain included):
Entire WWTP is within Lumber River flood plain. Primary clarifier and
aeration basin/elevated. Secondary clarifiers are not.
arcs

PART I - GENERAL INFORMATION (continued)
9. Location of nearest dwelling: Greater than 500 feet.
10. Receiving stream: Lumber River
a. Classification: C-Swamp
b. River Basin and Subbasin No.: Lumber River Basin 03-07-51
C. Describe receiving stream features and pertinent downstream uses:
Fishing, boating, fishing and wildlife propagation.
PART II - DESCRIPTION OF WASTES AND TREATMENT WORKS
1. a. Volume of wastewater to be permitted: 1.8 MGD (Ultimate Design Capacity)
b. What is the current permitted capacity of the Wastewater Treatment facility?
1.8 MGD
C. Actual treatment capacity of the current facility (current design capacity).
1.8 MGD
d. Date(s) and construction activities allowed by previous Authorization to Construct
issued in the previous two (2) years: April 9, 1998 (see attached)
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities:
The existing wastewater treatment facility consists of the following:
Screening, manual grit removal, influent equalization,
influent pH adjustment, influent pumps, one (1) primary
clarifier, equalization basin with nutrient addition, three (3)
secondary clarifiers [two (2) 55' diameter, one (1) 60'
diameter], continuous recording effluent flow meter, one
(1) 1,500 gallon capacity sludge holding tank, one (1) 2-
meter sludge press and one (1) 1-meter sludge press.
f. Please provide a description of proposed wastewater treatment facilities:
g. Possible toxic impacts to surface water:
Facility currently monitors dioxin (2, 3, 7, and 8 TCDD); the writer
has no knowledge of dioxin being a concern.

PART II - DESCRIPTION OF WASTES AND TREATMENT WORKS (continued)
h. Pretreatment Program (POTWs only): N/A
In development Approved
Should be required Not needed
2. Residuals handling and utilization/disposal scheme:
a. Land application Permit No.: WQ0002932
3,300 dry ton/yr land application program managed by facility.
b. Residuals stabilization: PSRP_, PFRP Other
3.
4.
C. Landfill: N/A
d. Other disposal/utilization scheme (specify):
BFI Landfill, if to wet to and apply.
Treatment plant classification (attach completed rating sheet):
rating sheet)
SIC Code(s): 2621
Wastewater Code:
Primary18 Secondary
Main Treatment Unit Code: 0 4 0 0 4
PART III - OTHER PERTINENT INFORMATION
1
2
3.
Grade IV (see new
Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? N/A
Special monitoring or limitations (including toxicity) requests:
In keeping with Basin Wide Strategy (see Part IV)
Important SOC, JOC, or Compliance Schedule dates (please indicate):
EMC SOC WQ 96-004 ADII
Date
Submission of Plans and Specifications May 31, 1997 (met)
Begin Construction
Complete Construction January 1, 1999 (met)
Compliance with NPDES Permit April 1, 2000

PART III - OTHER PERTINENT INFORMATION (continued)
4. Alternative Analysis Evaluation: Has the facility evaluated all of the nondischarge
options available. Please provide regional perspective for each option evaluated.
N/A - this is a permit renewal.
Spray Irrigation: N/A (existing)
Connection to Regional Sewer System: N/A (existing)
Subsurface: N/A (existing)
Other disposal options: N/A (existing)
5. Other Special Items: N/A
PART IV - EVALUATION AND RECOMMENDATIONS
As part of the NPDES renewal package, the applicant has requested that specific
monitoring parameters be evaluated for elimination or reduced monitoring frequency.
The parameters for consideration as follows:
(1) Total Residual Chlorine,
(2) Settleable Solids,
(3) Dioxin, and
(4) Mercury.
It is suggested that past data for the subject monitoring parameters be reviewed; and if
appropriate, the parameters should be modified for frequency only. It is our
recommendation that the Total Residual Chlorine, Settleable Solids, and Mercury
parameters be retained. It is also our recommendation that the Dioxin limitation be
retained and given monitoring limitations consistent with other similar facilities.
It is the recommendation of this office that other Permit conditions and parameters be
reissued in keeping with the Lumber River Basin - Basin Wide Strategy.
Signature of Repo reparer
Water Quality Regional Supervisor
Date

sk
BUCKEYE
1000 EAST NOIR ST., P.O. BOX 1305
LUMBERTON, NORTH CAROLINA 28359
TEL [phone] FAX [phone]
June 3, 1999
Mr. Charles H. Weaver, Jr.
NC Department of Environment and Natural Resources
Division of Water Quality, NPDES Unit
Post Office Box 29535
Raleigh, North Carolina 27662-0535
Subject:
NPDES Permit Renewal Application for Buckeye Lumberton, Inc.
NPDES Permit Number NC0005321
Dear Mr. Weaver,
Buckeye Lumberton, Inc. respectfully submits the enclosed renewal application for the National Pollutant
Discharge Elimination System (NPDES) permit.
Introduction
Buckeye Lumberton, Inc. operates an existing industrial facility located in the City of Lumberton, North
Carolina. The facility processes cotton linters into pulp for use in high quality paper products. Buckeye
Lumberton, Inc. is currently authorized to discharge industrial process wastewater to the Lumber River
under the National Pollutant Discharge Elimination System (NPDES) permit number NC0005321 modified
September 18, 1996. The permit was originally effective December 1, 1994 and will expire on November
30, 1999. Therefore, Buckeye Lumberton, Inc. respectfully submits this permit application for the renewal
of the NPDES permit. Additionally, Buckeye Lumberton, Inc. is operating under a Special Order by
Consent (SOC) issued January 24, 1997 and revised January 4, 1999. The SOC will expire October 1,
1999.
Permit Requests
Total Residual Chlorine
A permit limit for total residual chlorine was established in the permit based on an action level for non -trout
waters under 15A NCAC 2B .0211(3)0). Action levels are limited in NPDES permits if sufficient
information exists to indicate that the substances may be a significant causative factor resulting in toxicity
of the effluent (15A NCAC 2B .0211(4)). Through daily compliance monitoring as required under the
NPDES permit and the SOC, Buckeye Lumberton, Inc. has collected over 789 data points where total
residual chlorine is below the detection level (10 µe), and well below the 28 µfl permit limit.
Buckeye Lumberton, Inc. believes that a reasonable potential to contaminate does not exist for total
residual chlorine and asks that effluent limitations and monitoring requirements for this parameter be
removed from the permit. The data collected under the NPDES permit and the SOC constitutes new
information which was not available at the time of permit issuance. Buckeye Lumberton, Inc. believes that
had this data been available at the time of the original permit development, a limit for total residual chlorine
BUCKEYE LUMBERTON INC.

would not have been included in the permit. Therefore, the removal of the total residual chlorine effluent
limitations and monitoring requirements would not be considered anti -backsliding under 40 CFR
122.44(1)(2)(i)(B).
Settleable Solids
A rationale for the inclusion of monitoring requirements for settleable solids has not been found in the fact
sheets or other documents included in the administrative record for Buckeye Lumberton, Inc. However,
narrative criteria limiting floating or settleable solids or sludge deposits in Class C water found at 15A
NCAC 2B .0211(3)(c) do not allow for any amount of these contaminants which will impair the safety or
suitability for aquatic life and wildlife or impair other designated uses. Monitoring requirements under the
NPDES permit and SOC has resulted in over 32 sampling events in which no settleable solids were found
in the effluent. Buckeye Lumberton, Inc. believes that Outfall 001 does not contribute settleable solids to
the Lumber River which would impact fish, wildlife, or other uses. Further, this data shows the average
solids concentration for Outfall 001 is below the 5.0 mUl level at which DENR is required to establish
settleable solids limits under 15A NCAC 2B 0.0406 (d). Buckeye Lumberton believes DENR intended to
remove the settleable solids monitoring requirements. The waste load allocation developed June 16, 1994
states that monitoring for settleable solids may be removed "after a year of data if found negligible".
Therefore, Buckeye Lumberton, Inc. requests the monitoring requirements for settleable solids be removed
from the permit.
Dioxin
An effluent limitation with quarterly monitoring has been established in the permit for dioxin.
Additionally, Buckeye Lumberton, Inc. is required to monitor the influent to the wastewater treatment
facility and sludge quarterly and fish tissue once during the life of the permit. The effluent analyses and
fish tissue analyses show that Buckeye Lumberton does not present a source of dioxin to the Lumber River.
Effluent discharge monitoring reports from January 1997 to December 1998 show all analytical results
were below the detection limit of 10 pg/L established in Part III, Condition G of the permit. And the report,
"Dioxin Monitoring Study of the Fish Tissues from the Lumber River, North Carolina", submitted to
DENR in January 1998 by Buckeye Lumberton showed dioxin concentration in 24 composite fish samples
to be below detection for 2,3,7,8-TCDD. Moreover, the Staff Report and Recommendations dated July 25,
1994 developed by DENR personnel notes that the facility monitors for 2,3,7,8-TCDD although "the writer
has no knowledge of dioxin being a concern". The writer went on to suggest that the permit may be
modified to reduced dioxin monitoring in light of past testing.
Buckeye Lumberton, Inc. requests DENR consider reducing the monitoring frequency of the effluent to
once per year and removing monitoring requirements for influent analyses.
Mercury
Buckeye Lumberton, Inc. wishes to cite the attached letter from Darlene Kucken of DENR regarding
Mercury limits in the Lumber Basin. Per the letter from Ms. Kucken, only facilities that have detected
Mercury in recent years will be issued limits. Since there is no record of Mercury being present in the

r

effluent, Buckeye Lumberton, Inc. requests that Mercury limits or monitoring requirements not be added to
the new permit.
Closing
It is anticipated that an application addendum may be necessary to provide all of the administrative and
technical information required for the issuance of a renewal permit. Buckeye Lumberton, Inc. appreciates
the opportunity to work with the Department of Environment and Natural Resources in the preparation of
this permit.
Should you have any questions regarding the permit renewal application submitted today or the facility,
please feel free to contact Mr. Eric Bolin at [phone]. 3 Z Z S
7 j 3 z ?-r
Sincerely,
Albert A. Bounds
Plant Manager
Buckeye Lumberton, hic.
/ o !
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.............
Location Map
ko Buckeye Lumberton, Inc.
Lumberton, North Carolina
2000 0 2000 4000 Feet Figure
AGE' 58urc85: 1
1:2I,,9WDJDha Aasarr GWAk
WlumLarrort YX -US(IS, 1996 h.VAr �ecrA)ickeye&,lE.aprmr
SELumJuvmn,JVC-US OS, 1986 J9'9
Page 1 of 1
S W L umaarnn, J9 c - us as, t 9az NC0399S3 !]000 t10002

PROCESS FLOW
T i Losr AS srTAM
BOILER �'
r_—_ Z TO POiW , —_—_—_ SANITARY
PROCESS WASTEWATER
' DIGESTERS 142
- ..... -_
CTIY WATER -
--1094
--....... PROCESS WASTEWATER
�— — B.S. WASHER ..... --- --- 1541
I
WELL WATER I I Z66
t;os COOLING
PRIMARY REFININ '
I
I
CLEANERS
i I CLEAN WATER
SYSTEM
i 1ST BLEACH
i I
i � I
I
�- ----
i y2 WASHER
(CHLORINATION)
TANK BROWN
i Teo
WATER
2ND BEACH
I
i
I
f
i i
i
Z.432
! i T
i
i
L---- 'ov—
252
TANK WHITE
i
I
WATER
i I
LING tDe
F
AL WATER
i
L.._..�I�.._.._.17
3
._.._
— LANEOUS 4L-----�--
FSLUDGE
WATERS
PROCESS WASTEWATERWWTP
PRESS
3.m
E�Tlgl
—_—_—_—
CDT WATER
1659.40
—.._.._.._.._..—
WELL WATER
_
CLEAN WATER SYSTEM
VOTES.
-- --- --- .--. ..
TARN BROWN WATER
1. FLOW VALUES ARE THOUSAND GALLONS PER OATS
<--e--.--moo---
TAW 1141E WATER
FL THE PROCESS SYSTEM HAVE BEEN ED.
2. FLOWS INTO S
SIP FFF1AlflIT
TREATMENT
DISCHARGE ROW FROM THE WASTEWATER TREATMENT PLANT 6 THE LONG TERM AVERAGE FOR 7MS FLOW.
3. CHA
/3 WASHER RECYCLE
MISCELLANEOUS U 0NER5, VACUUM PU11P5,
WNTERS INCLUDE DISCHARGES AN FROM R MAKE
4. MISLEUANEOUS HEAT
HEAT EfOC1SIMN AND COOLERS, AND BdLER PANE UP.
YSCRECYC
------
/2 WYl4iER RECYCLE
E F
S. ALL RECYCLE ROWS ARE SHOWN AS DASHED ONES.
DATE:
DRAWN:
PROJECT MANAGER:
CHECKED:
d
"®
5-26-99
GRM
MMM
MMM
DRAWING FlLE: —
NCOJ9983-01
CAD FILE:
BNC039983-01
—
ARCADIS
SCHEMATIC OF
a
GERAGHTY&MILLER
WATER FLOW
Lu °`� `UNorth &ml no
PROJECT NUMBER:
DRAWING NUMBER:
OW
VAfAR N0. BAEQW
ATM RRMNX. U T0627
NPDES PERMIT NUMBER
NC039983.0001
2
Tr. txs-m-TDa
vsc aim-stt0
NC0005321

-,-NCDENR
JAMES B. HUNT JR.
--GOVERNOR
.79
VAYNE MCDEvITT
Kerr T. Stevens
Director
a
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
April 12, 1999
Mr. Eric Bolin
1000 East Noir St.
PO Box 1305
Lumberton, NC 28359
Dear Mr. Bolin;
Thank you for your comments on the Draft Lumber River Basinwide Water Quality Plan.
Based on the concerns expressed in your letter, we have altered the wording of the Lumber
River Basinwide Water Quality Plan to more accurately reflect the intention of the Division
of Water Quality concerning the 'TMDL Study: Mercury Loads to Impaired Waters in the
Lumber River Basin, North Carolina".
DWQ does not intend to place mercury limits of zero or less than detectable levels in the
discharge permit of all dischargers in the basin. Therefore, the wording on page 64 of the
February 1999 draft plan as been changed to:
"...In addition, current and future NPDES discharges in the Lumber and
Waccamaw River watershed should not be allowed to increase the total
mercury already present in the system. Therefore, zero or less than
detectable (based on NC's currently accepted measurement standards)
mercury levels in NPDES effluent should be allowed. However, during
this basin cycle permit limits will be issued to facilities that have detected
mercury in effluent in recent years. Other facilities may be asked to monitor
�fflucnt for mercury if it is likely that mereury is present in the effluent.
DWQ and DAQ have formed a team that will attempt to address controls on
mercury sources in the Lumber River basin..."
Michelle Woolfolk has developed the TMDL Study for mercury in the Lumber River basin.
Michelle can be reached at [phone], ext. 505. Please feel free to call me also at
[phone], ext. 354.
Sincerely,
Darlene Kucken
Basinwide Planner
P.O. Box 29535, RALEIOH, NORTH CAROLINA 27626-0535
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 O a POST -CONSUMER PAPER

JAN-11-2000 TUE 12:53 PM ROBESONIAN FAX NO, 9107396553
ROBESON COUNTY
NORTH CARO�-14NIo*\
PuBLIC NOTICE
STATE OF NORTH CAROUNA
ENVIRONMENTCOMIMSNTAL 90WSE
i 5—soclt—e Editor, of THE ROBESONIAN, a news-
NPOESUhpT
1617 MAIL SERVICE CENTER
paper published in Robeson CnUCtly, N. C.r being
RAL .1511
NOTIFICIA7400FBN$rENTTO
dulyPDES
Sworn Sa S that at tits'' N17116 the atfaCW
r Y
IS5UEA WASTEWATER
WASTEWATER PERMIT
notice was published in THE itORFSONIAN, said
p
On The basis d tih ra
NO General
wow and applicalton oDI G
newspaper Met all Of M-, requirOMe.nts and quali-
aptoIWl33wfulsulndaN Publio andxtByu
fications prescribed b North Carolina General
p Y
a'letalrr, lm Nosh ent Colful miss n
mental Nanagomern Commission
Statute 1-597, that said newspaper had a general
�
�t Disc w issue F a National ystePoll•
and OtsOharga Elunnatlon System
c'rculatlort to rctual paid s1.bsrlbers; and, was
} wastewater dicarge per,
mi to the per"(s) M41e4 on tits el-
a tilYlitteci to ties Untled SWes mail m second
cached pages effective 45 days
Irom the publ.shed Bale Of this n01190,
rrrat?er in Robeson Ct vn , H. C.- and fvr-
r
MitteclaSS N norogaltllrp wthe unii•
�a permit wta oe ecceplou untA
pow permit
30 day3 after IN dale a
Cher, that the attached n0ice waz ubliah" in
�
imentn
this natir.�B, All gonvnenla rpeerved
THE ROBESONIA,N once a wcQk for —Con-prior
to lhal dale are considered lhn fin91 dOlOrminalion9 regarding
sccullvo eKs on t''he i•attowin 4-sue dathes
the tNA permit. The DIrBCtor of
the NCo DtMhtion of Water Oualily
Vic" j 9 90.
may decide to hold a puWk meeting
for the propotod perms should the
Division rnme a splttlWI degree
_. ,
a pubic interest
Copies o1 the Bran permtl ner
the9 u Di
rt on bed to
^T R1ie 31r -Associate Editor
supocnin0 inlormalio
drah ppormil are RVila� porn to -
quest and payment of me costs of
reproduction. Mae oanyrtsnla endror
Sworn t* and a.ubscribed before nrA
requeam for initifnie ion to Inc NO
Divishm Ot water quality at the
1_�.-_day !S1\ /r`i
spore Vr address c91 Ms, Chnalia
Jackson at (9191 733.6OB3, oKlan-
ihic tics _ •� ( ia3•..
ewn 538. PIGOae mdudo the NPDES
l
permit number (attached) airy
/l/
nmunicaho0. InlOreylad pa/BOnS
,e
. _-- V �f
may also visit the aViSlon of Water
NOTARY UaLIC
Ouahry at 512 N. SalhsburV Street.
Raleigh, NC 27W4-t178 between
Mdrd
the hours of 8:00 am, And 5:00 p.m.
terevlewmbrmalion011%.
contred%Fian expires-
NPDES Potent Nurribar .
W, B�Ya t,OrnbeM
BMW,
Inc., 1305. LUmoerlcn, NO
26359 hes apWieo fora perms rene,
lot lacl6ry, located In Rob —
wall a
Wanly tlischargginy treated weslC
water info the LtNnt>er RlVer in the
lumbar River a tin, Currently SOD,
ammonia, and duum are water quak-
ry emlted. This dtscharga may aaect
lulure aaocatnns in this porttan 01
;he receiving waam_
NPpES Pormll Number
NCOO58801. Cogenirtx Energy,
INC„ 9405 Arrowpotnt Boulevard,
Charlotte, NO 28273 has led kN
8 pemulrort"al for a lac
5"M
in Robeson COIAtty disr�eg Ueat-
ed wastewater Into Inc Lushest river
to the Lam* River B8941, Currently
no patamulera are waler cwGAY tim-
100, This discharge may a?IW 10,
ur le dlootions In this poNnr. Ofthe
raeelvmg stream.
Dec6Mber1, 000NCDE121400 ,

•APR-15-199E 10:10 FROM DEM WATER QUALITY SECTION TO 92338031 P.04iO4
Permit No. NCO005321
Authorization to Construct
Alpha Cellulose
April 9, 1998
Page 3
Eayiaeer's_Certification (Project Number ACD005321)
I, THOr10 E, CIes/* ANt as a duly re istered Professional Engineer in the State of North
Carolina, having been authorized to observe n tc weekly, full time) the construction of the
project, #JS4061C yFcf.TM dASlnt f 4440-I aA45 , &4K6YC for the
Project Name Location
Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction was observed to be built within substantial compliance and
intent of the approv plans and specifications.
Signature G� a �`/?E . Registration No.
leaoam-oovw
/ /9 9
.t SEAL i
0 20428 ei
4 � �•.....•• per a`
186i�p����
Upon completion of construction and prior to operation of this permitted facility, a certification must be
received from a professional engineer certifying that the permitted facility has been installed in accordance
with the NPDES Permit, this Authorization to Construct and the approved plans and specifications. Mail
the Certification to the NPDES Unit, P.O. Box 29535, Raleigh, NC 27626-0535.
Please mail this engineer's certification to the attention of Mark McIntire.

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
April 9, 1998
Mr. Al Bounds
Buckeye Lumberton Corporation
Post Office Box 1305
Lumberton, North Carolina 28359
NCDENR
Subject: Permit No. NC0005321
Authorization to Construct
Former Alpha Cellulose facility
Robeson County
Dear Mr. Bounds:
A letter of request for an Authorization to Construct was received December 31, 1997 by the
Division and final plans and specifications for the subject project have been reviewed and found to be
satisfactory. Authorization is hereby granted for the construction of facilities at Buckeye Lumberton's
Alpha Cellulose facility in Robeson County discharging into the Lumber River in the Lumber River Basin.
Specifically, authorization is granted for the construction of:
• a 56,500 gallon aerobic selector basin with diffused aeration;
• surface skimmers for all three secondary clarifiers;
• methanol feed facilities for supplying an alternative carbon source; and
• all piping and appurtenances.
This Authorization to Construct is issued in accordance with Part III, Paragraph A of NPDES
Permit No. NC0005321 issued November 14, 1994, and shall be subject to revocation unless the
wastewater treatment facilities are constructed in accordance with the conditions and limitations specified in
Permit No. NC0005321.
The sludge generated from these treatment facilities must be disposed of in accordance with G.S.
143-215.1 and in a manner approved by the North Carolina Division of Water Quality. .
In the event that the facilities fail to perform satisfactorily, including the creation of nuisance
conditions, the Permittee shall take immediate corrective action, including those as may be required by this
Division, such as the construction of additional or replacement wastewater treatment or disposal facilities.
The Fayetteville Regional Office, telephone number [phone], shall be notified at least forty-
eight (48) hours in advance of operation of the installed facilities so that an in -place inspection can be
made. Such notification to the regional supervisor shall be made during the normal office hours from 8:00
a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays.
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

Permit No. NC0005321
Authorization to Construct
Alpha Cellulose
April 9, 1998
Page 2
Upon completion of construction and prior to operation of this permitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been installed in
accordance with the NPDES Permit, this Authorization to Construct and the approved plans and
specifications. Mail the Certification to the NPDES Unit, P.O. Box 29535, Raleigh, NC 27626-0535.
Upon classification of the facility by the Certification Commission, 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 and grade to comply with
the conditions of Title 15A, Chapter 8A, .0202. 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 must comply with
all other conditions of Title 15A, Chapter 8A, .0202. Once the facility is classified, the Permittee must
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.
A copy of the approved plans and specifications shall be maintained on file by the Permittee for the
life of the facility.
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.
One (1) set of approved plans and specifications is being forwarded to you. If you have any
questions or need additional information, please contact Mr. Mark McIntire, telephone number (919) 733-
5083, extension 553.
Sincerely,
Z"�'9a, --
Preston Howard, Jr., P.E.
cc: Central Files
NPDES Unit, Permit File
Fayetteville Regional Office, Water Quality
Technical Assistance and Certification Unit

JAMES B. HUNT JR
GOVERNOR
WAYNE MCDEVITT slk
SECRETARY
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Buckey�Lumberton Corp
Al Bounds
P O BOx 1305
Lumberton, NC 28359
Subject:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
June 18, 1998 DIVISION OF WATER QUALITY
Classification of Water Pollution Control System
Buckeye Lumberton Corp
Permit No. NC0005321
Robeson County
Dear Mr. Bounds:
A. PRESTON HOWARD, In accordance with North Carolina General Statute § 90A-37, the Water Pollution Control
JR., P.E. System Operators Certification Commission is required to classify all water pollution control
DIRECTOR systems. The Rating Scale for classification of wastewater treatment facilities, found at 15A
NCAC 8C .0002, was adopted by the Commission to classify water pollution control
systems. The classification of a facility is determined by definition or by the total number of
points for all components of the treatment process.
The Water Pollution Control System Operators Certification Commission has determined
that the subject facility is classified as a Grade. 4 Wastewater Treatment Plant.
As required by 15A NCAC 8A .0202 and your permit, you must designate a Grade 4
Operator in Responsible Charge (ORC) and back up operator with at least a Grade 1
certification once construction is 50% complete. Please submit to this office by
July 22, 1998 a projected date when the facility will be 50% complete. Failure to
designate a properly certified operator and back-up operator constitutes a violation of the
_,permit issued for this facility.
If you have any questions concerning this classification or the designation of an ORC,
please contact Tony Arnold at 919/733-0026 ext. 315.
Sincerely, 'X. 4,
Joseph B. McMinn, Supervisor
Technical Assistance and Certification Unit
'j sb/Class. Let
Od
mobt:, cc: Permits and Engineering
Water Quality Files
Fayetteville Regional Office
TAC Files
Enclosure
P.O. BOX 29535, RALEIGH, NORTH CAROLINA 27626-0535
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 Oq POST -CONSUMER PAPER

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. Henry P. Doggrell
Buckeye Lumberton, Inc.
P O Box 1305
Lumberton NC 28359
Dear Mr. Doggrell:
EDEHill1=1
January 19, 1998
Subject: Permit Modification -Name Change
Buckeye Lumberton, Inc.
(formerly Alpha Cellulose Corporation)
Permit No. NC0005321
Robeson County
In accordance with your request received January 15, 1998, the Division is forwarding the subject permit.
The only change in this permit regards the name of the facility operator. All other terms and conditions in the
original permit remain unchanged and in full effect. This permit modification 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.
This permit does not affect the legal requirement 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 government permit that may be required.
If you have any questions concerning this permit, please contact Steve Coerper at telephone number
[phone], extension 361.
Sincerely.
1 4
A. Preston Howar , Jr., P.E.
cc: Central Files
Fayetteville Regional Office, Water Quality Section
Permits and Engineering Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Permit No. NC0005321
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 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,
Alpha Holding Corporation
is hereby authorized to discharge wastewater from a facility located at
Buckeye Lumberton, Inc.
1000 East Noir Street
city of Lumberton
Robeson County
to receiving waters designated as Lumber River in the Lumber River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, and III hereof.
This permit shall become effective January 19, 1998.
This permit and authorization to discharge shall expire at midnight on November 30, 1999.
Signed this 19th day of January, 1998.
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NC0005321
SUPPLEMENT TO PERMIT COVER SHEET
Alpha Holding Corporation
is hereby authorized to:
1. Continue to operate a 1.8 MGD wastewater treatment facility consisting of screening, grit
removal, primary clarification, equalization basin, aeration basin with nutrient addition, final
clarification, sludge holding tank, and sludge press located at Buckeye Lumberton, Inc., 1000
East Noir Street, Lumberton, Robeson County (See Part III of this Permit), and
2. After receiving an Authorization to Construct from the Division of Water Quality, increase flow
to 4.0 MGD, and
3. Discharge from said treatment works at the location specified on the attached map into the
Lumber River, which is classified Class C-Swamp waters in the Lumber River Basin.

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Chuck Oxendine, Technical Services Manager
Alpha Cellulose Corporation
P.O. Box 1305
Lumberton, North Carolina 28359
Dear Mr. Oxendine:
A LT.WMA
14 0 0 2J
A±91010�L�l 111111111111K
I DEHNF1
September 30,1996
Subject: NPDES Error Correction
NPDES Permit No. NC0005321
Alpha Cellulose WWTP
Robeson County
Based on your conversation with my staff and review of the September 18, 1996 modification letter and
attachments, an error was discovered with regard to the dioxin limit and the chronic toxicity effluent limit.
Please find enclosed the amended page for Part I.A (1) which should be inserted into your permit. The
appropriate quarterly effluent dioxin limit for the flow of 1.8 MGD is 4.3 pg/l. The appropriate quarterly
effluent toxicity limit is Chronic Toxicity Testing P/F at 2.3%. The old page (submitted with the September 18,
1996 letter) should be discarded. All other terms and conditions contained in the original permit remain
unchanged and in full effect. The permit modifications are issued pursuant to the requirements of North
Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U. S.
Environmental Protection Agency.
If any parts, measurement frequencies or sampling requirements contained in this permit modification
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.
If you have any questions concerning the permit error correction or return of the Authorization to
Construct permit request, please contact Susan Wilson at telephone number [phone], extension 555.
Si �cerel/y yours,
. Preston Howar , Jr., P.E.
cc. Fayetteville Regional Office
Central Files
Permits and Engineering Unit
Office of Attorney General, Kathy Cooper
Facility Assessment Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

A. (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning on the effective date of the permit and lasting until expansion above 1.8MGD or expiration, the Permittee is authorized to discharge
1'rom outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge
Limitations
Lbs/day
Units
(Specify)
Mon. Avg. Daily
Max.
Mon. Avg.
Daily Max.
Flow
2Z �,�
1.8 MGD
BOD5 (April 1 - October 31)
332.0
664.0
BOD5 (November 1 - March 31)
3� 450.0
900.0
TSS
850.0
NH3-N
166.0
Dissolved oxygen **
5:5"3.0
Total Nltrogen (NO2 + NO3 + TKN)
Total Phosphorus
Temperature ***
Chronic Toxicity ****
Total Residual Chlorine
28.0 µg/I
Conductivity
Dioxin t
4.3 pg/I
Settleable Solids
Monitoring
Requirements
Measurement
Sample
*Sample
Frequency
Type
Location
Continuous
Recording
I or E
Daily
Composite
E
Daily
Composite
E
Daily
Composite
E
Daily
Composite
E
Daily
Grab
E,U,D
Monthly
Composite
E
Monthly
Composite
E
Daily *
Grab
E,U,D
Quarterly
Composite
E
Daily
Grab
E
Daily
Grab
E,U,D
Quarterly
Composite
E
Weekly
Grab
E
Sample locations: E - Effluent, I - Influent, U - Upstream at NCSR 1620, D - Downstream (1) at NCSR 2123, (2) at NCSR 2121.
Instream samples shall be grab samples and shall be conducted 3 times per week during June. July, August, and September and once per week during the remainder of the year.
** The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/1.
k** The discharge shall not cause the temperature of the receiving stream to exceed 2.8°C above background temperature and in no case cause the receiving stream to exceed 32.0°C.
Y*** Chronic Toxicity Testing P/F at 2.3 %; February, May, August, and November; See Part III, Condition E.
See Part II1, Condition G, of this permit.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall he conducted daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

r11 _.t _ r n _ ..ti_ '-
JIUIC VI IVVI II I Varolina
IT
Department of Environment,
Health and Natural Resources 1 • •
Fayetteville Regional Office
James B. Hunt, Jr., Governor p E H N IR
Jonathan B. Howes, Secretary
DIVISION OF WATER QUALITY
July 24, 1997
Mr. Eric Bolin
Environmental Manager
Buckeye Cellulose Corporation
1000 East Noir Street, Box 1305
Lumberton, N.C. 28359
Subject: Acknowledgement Letter
Buckeye Cellulose Corp.
EMC SOC No. WQ 96-04
NPDES Permit No. NC0005321
Robeson County
Dear Mr. Bolin:
On May 30, 1997 and June 13, 1997 the Division of Water Quality'.rl ceived
the "Wastewater Treatment Plant Evaluation and the Treatability Studies and
Proposed Wastewater Treatment Facility Modifications" documents. Submittal of
both documents fullfills SOC target dates listed in items 2.(b) 1) and 2) of
subject SOC No. EMC WQ 96-04. Also, on June 13, 1997, a meeting was held
between persons with Buckeye Cellulose, Eckenfelder, Fayetteville -Regional
Office and Raleigh Central Office, to review the submitted documents.
The review of both submitted documents have been completed by this
Division and it is the recommendation of this Division that Buckeye Cellulose
procedure with drafting and submitting plans and specs for a request for an
Authorization to Construct (A/C) for the proposed modifications addressed in
their documents. To expedite matters with the A/C request, and as suggested by
Mr. Grady Dobson, please include information for the alternative treatment for
the use of methanol in the aeration basin, so that if that treatment scheme is
needed, an additional request for A/C will not be required.
Wachovia Building, Suite 714, Fayetteville Nq�� FAX [phone]
North Carolina 28301-5043 �� C An Equal Opportunity Affirmative Action Employer
Voice 910-486-1541 500% recycled/10% post -consumer paper

Mr. Bolin
July 24, 1997
Page 2
If you have any questions or require any further clarification, please do
not hesitate to contact me at [phone].
Sincerely,
!/ } y
Kitty A.K. Kramer,
Environmental Technician V
AKK/akk
cc: Bob Sledge/Mike Alexander
Mark McIntire

We look forward to our meeting on June 13`h when we expect to present the detailed scope and
findings of the study, along with the plans for modifications of the treatment system. If you have
any questions on this matter prior to our meeting, please do not hesitate to call me at (910) 737-
3201, or Eric Bolin at [phone].
Sincerely,
ALPHA CELLULOSE CORPORATION

WASTEWATER TREATMENT FACILITY EVALUATION,
TREATABILITY STUDIES AND PROPOSED WASTEWATER
TREATMENT FACILITY MODIFICATIONS
June 13, 1997
MEETING AGENDA
1. Introductions - Ray Andreu
2. Background - Al Bounds
3. Project Support - Dave Weeden
4. Wastewater Treatment Facility Evaluation - Kar Munirathinam, Ph.D.
5. Treatability Studies and Conclusions - KM
6. Plans for Modifications - KM
7. Predicted Results / Uncertainties - KM
8. Implementation and Evaluation Schedule - Eric Bolin
9. Questions / Discussion - All
10. Summary / Next Steps - Ray Andreu

99.8
11100
90
70
60
0
E
50
0
o 40
Activated Sludge Treatment System Performance - Chemical Pulp Mills
99 An (Best Removal Reported)
30
pvngp
R—
IMM
20
Sq xl,14�
Aw,�
10
z;A
0
Alpha
Alpha
Mill
#1
(Best)
\'Avg)
Mill j* Mill #3 Mill #4 Mill #5 Mill #6 Mill #7 Mill #8
Source: Proposed Technical Development Document for the Pulp: Pape, and Paperboard Category Eftluenl Limitations c-uidelini,,s, Prelfeatment
Standards, and New Source Performance Standards. Oct 29, 1993. USEPA.

w
ALPHA CELLULOSE CORPORATION
-- 1997 _ 1998 1999 2000 -- --
MAYJUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR -MAY JUN JUL AUG SEP OCT- NOV DEC JAN -FEB MAR APR MAY JUN-JUL-AUG SEP OCT NOV �DEC C-JAN'FEB MAR'APR MAY'JUN JUL AUG E
ENGINEERING
A BUCKEYE TO SUBMIT REPORT & PLANS TO STATE
BUCKEYE TO SUBMIT PLANS FOR MOD. TO STATE
STATE REVIEW OF REPORT & PLANS FOR MODIFICATIONS
♦ STATE APPROVAL
♦ --- --—-------- -- — — — — ------ --- --------------- —----------------------------------- —-------- -------
DESIGN.-. - .
♦ SUBMIT AUTHORIZATION TO CONSTRUCT
♦ RECEIVE AUTHORIZATION TO CONSTRUCT
,PROCUREMENT
—.._
T PUMPS
_— PIPING —
VALVES
BLOWERS
'i AERATION SYSTEM
CLARIFIER PARTS
7 CONSTRUCTION
A MOBILIZATION
AM SITEWORK
Amomm CONCRETE
Awft YARD PIPING
sw PROCESS PIPING —
Ap=L EQUIPMENT
Ammmft ELECTRICAL
A START-UP
AL DEMOBILIZATION
♦ COMPLETE CONSTRUCTION
EVALUATE MODIFICATIONS
♦ COMPLY WITH NPDES PERMITS
NPDES PERMIT EXPIRES
♦ OR
- --- - -- -- -- --------
moommmmL —
NETOTIATE FINAL NPDES PERMIT LIMITS -IF REQUIRED
♦ COMPLY WITH NPDES PERMIT LIMITS
Early start point
- Early finish point
I Early bar
Progress bar
Critical bar
Summary bar
Progress point
Critical point
Summary point
� Start milestone point
Finish milestone point
ALPHA CELLULOSE CORPORATION
IMPLEMENTATION AND EVALUATION SCHEDULE
FIGURE 5-1
Approved

BACKGROUND
Buckeye's Alpha plant in Lumberton, North Carolina, is a specialty cotton fiber pulp mill
that supplies fine paper producers around the world. The Lumberton plant was built and
started up in 1968 following the decision by Alpha Cellulose to relocate from
Bloomington, Illinois to North Carolina. The plant was equipped with a highly efficient
wastewater treatment plant from the beginning due to the characteristically high BOD and
TSS loadings from the process. The capacity of the WWTP has been continually
upgraded over the years as plant production has increased. Even with these upgrades
compliance has occasionally been an issue for Alpha. To maintain compliance, the plant
WWTP must constantly be at or above 98.5% efficiency for BOD removal and at or above
97.5% efficiency for TSS removal. These levels of efficiency are higher than the best
performing plants in our industry from a 1993 EPA study on pulp and paper mills. The
smallest upset from seasonal biological or climatic changes can put the plant into a non-
compliant condition before remedial action can have any effect.
These factors set the stage for the development of a Special Order by Consent agreement
between the North Carolina Environmental Management Commission and the Alpha plant.
This agreement is a cooperative platform to achieve the State's and Alpha's goal of
ongoing compliance. The SOC agreement itself sets forth reasonable interim limits and
timetables for studies, plans, approvals, construction and permit modification
consideration if needed. One of the important parts of the SOC was the period set aside
to evaluate the treatment system to search for reasonable and effective modifications, if
possible, to further increase the already industry -leading waste treatment plant efficiency.
To accomplish this goal, Eckenfelder, Inc. of Nashville, Tennessee, was employed to
conduct an evaluation of the Lumberton waste treatment operations. This evaluation led
to a treatability study of the plant effluent and the subsequent recommendations that it
generated.

May 29, 1997
Mr. Robert Sledge
NCDEHNR-Division of Water Quality
Facility Assessment Unit
P.O. Box 29535
Raleigh, N.C. 27626-0535
RECEIVED
MAY 3 U 1991
FACILITIES ASSESSMENT UNIT
RE: Alpha Cellulose Corporation (a Buckeye Cellulose company) - SOC #96-04
Dear Mr. Sledge:
Attached is a report on the evaluation of the Alpha Cellulose (Alpha) wastewater treatment plant
as required by SOC #96-04. This report was prepared by Kar Munirathinam, Ph.D. of
Eckenfelder, Inc. and covers the findings of a study conducted during the period 1 December
1996 through 31 March 1997.
It is Alpha's intention to submit a subsequent detailed report on bench -scale treatability studies,
our plans for modifications of the wastewater treatment system, and an implementation and
evaluation schedule during our meeting scheduled for June 13, 1997. The plans for
modifications are expected to focus on three possible improvements which address all of the
identified significant opportunities:
1. the addition of an aerobic selector to improve sludge quality and settleability, allowing
for increased biological concentrations in the aeration basin, improved treatment
efficiencies in cold weather conditions, and improved effluent BOD and TSS results;
2. a retrofit of three secondary clarifiers with skimmer mechanisms to reduce the effects of
periodic floating solids on effluent TSS; and
3. the ability to supplement the microbes in the aeration basin with a carbon (food) source
during extended plant shutdowns to maintain a viable biomass, allowing for improved
treatment efficiencies during start-up.
1000 East Nair Street, Box 1305 Lumberton, North Carolina 28359 USA ^m 910 738 4201 FAX [phone]
Z
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State of North Carolina
MICHAEL F. EASLEY Department of .justice
ATTORNEY GENERAL P. O. BOX 629
RALEIGH
27602-0629
June 27, 1996
Kurt Olsen
Attorney at Law
MAUPIN TAYLOR ELLIS & ADAMS, P.A.
Highwoods Tower One, Suite 500
3200 Beechleaf Court
Raleigh, N.C. 27604-1064
VIA FACSIMILE TRANSMISSION TO: [phone]
Dear Kurt,
REPLY TO: James P. Longest, Jr.
Environmental Division
Tel. [phone]
Faa.[phone]
iDRAFT
RE: SOC draft: Alpha Cellulose Corporation v. DEMNR-DEM 95
EHR 1056
The Settlement Agreement reached last month did not use the numbers listed in the
"Proposed 6-11-96" column of the Exhibit. Those parameters are in excess of anything
previously discussed by the parties and were not ones to which Mr. Howard agreed. My notes
reflect that the discussion and agreement by Preston was with respect to those parameters listed
in the Permit Modification request, the last column on the right side of the page. The parameters
requested in the column headed 6-11-96 are inconsistent with the basin wide plans for the
Lumber River. We seem to be engaged in a "Battle of the Forms" with respect to this agreement
at present. Let me disengage.
My client would like to settle this civil penalty. The SOC draft you sent back does not
require your client to build anything, merely report on its studies. SOC's are not
statutorily -authorized for data gathering. The General Statutes and the rules of the EMC provide
for SOC's to be entered with timetables for construction and with assurances that money can be
made available for construction. They are not to be used for a shield from regulatory action
while the permittee studies its options. An SOC is designed to give an industrial permittee who
is out of compliance an agreement which will allow it to construct needed improvements to get
back into compliance. Your clients are very close to being in compliance now.
Municipalities are specifically allowed to enter "Special Orders" with the EMC for
increased wasteload. This type of order is only available to municipalities. Without any
requirement to construct, the draft order you returned appears to be this type of Order. It is not
authorized by the general statutes for the EMC or the Director to enter into the Order you have
An Equal Opportunity / Affirmative Action Employer ��3

DRAFT
proposed, nor would they if they could. This Order does not protect the water quality of -the -
Lumber River basin, it merely protects your client's interests.
I am despairing as to whether this matter can be settled. I do not think that the Permit
Modification request is dead. What would be the reason to keep pursuing the SOC without a
plant modification? The SOC is designed to protect a continuing violator while the violator is
improving its treatment. The Order available to municipalities is designed to allow them to
arrange financing for improvements to their plants. Indeed, one could argue that your client can
either get an SOC or a Permit Modification, but not both at the same time.
Permits and Engineering of DEM is concerned about your client's apparent inability to
meet the current effluent limitations. I told them that I understood the permit violations were
minor, daily violations and not major or monthly violations related to-frlimentaeous bacteria.
The DMR's show that the problem is with a monthly average for TSS. They want to see more
data from your client including data on removal efficiencies and any pilot studies your client may
have conducted, before approving the modifications. If the May violations are the result of
equipment problems, perhaps they can be grounds for an SOC without an increase in the
hydraulic loading of the plant. Perhaps an SOC should be entered into to cover the May
violations and allow your client to get them under control, settle the CPA. After finishing the
SOC successfully, the permit modification might be allowed. In any event, please call me next
week. Until then, I remain,
Very Truly Yours,
Ryke Longest
Assistant Attorney General

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FAYETTE1fi
cr,
July 1, 1996
1
Ms. Kitty Kramer
North Carolina Department
of Environment, Health, and
Natural Resources
CA -_
Suite 714, Wachovia Building
—'
Fayetteville, N.C. 28301
Dear Ms. Kramer:
As a follow up to our earlier phone conversation, I am writing this letter to document the NPDES
noncompliances for the month of May 1996. The treatment process was above the daily maximum
limit for TSS discharges for 4 days. The monthly average was also exceeded. The actual values
are as follows:
Date
Actual Value (TSS 9/day)
May 6
933
May 16
1299
May 17
1491
May 18
896
The monthly average was 568 # TSS against a limit of 425#.
Based on microscopic examinations of the mixed liquors and the effluent samples, we determined
that the cause of the exceedances was the result of our attempt to reduce the filamentous bacteria
populations in the system via chlorination. The effluent samples were clear with no floc present
but the samples were abundant with filaments and filament sheaths. The fact that there was no floc
particles in the effluent and that the TSS was predominantly filaments was also indicated by the
low BOD values obtained during this time. The only course of action that we felt that we could
take was to continue to chlorinate until the filaments were significantly impacted. Microscopic
examinations by outside microbiologists gave us an identification on the type filaments we were
dealing with and the possible cause(s) of their proliferation. With this information we determined
that a low F/M had most likely caused the problem and we began to adjust the F/M gradually
upwards to help correct the problem.
1000 East Nair Street, Box 1305 Lumberton, North Carolina 28359 USA S 910 738 4201 FAX [phone]

We have come back into compliance with all parameters on the permit and have reduced the
chlorination rate as the filamentous populations have decreased.
If I can be of any further assistance, please give me a call.
Sincerely,
Chuck Oxendine
Technical Services Manager

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
"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."
C'1,1,42CEI fD a-,V,01 vim
Permittee (Please print or type)
000
Q�
Signature of Permit * Date
Svc T� ; S ��6�'"j� y -4?e i / /o/
Petmittee Address Phone Number Permit Exp. Date
00010 Temperature
00076. Turbidity
00080 Color (Pt -Co)
00082 Color (ADMI)
00095
Conductivity
00300
Dissolved Oxygen
00310
BOD5
00340
COD
00400
pH
00530 Total Suspended
Residue
00545
Settleable Matter
PARAMETER CODES
00556
Oil & Grease
00951
Total Fluoride
01067
Nickel
00600
Total Nitrogen
01002
Total Arsenic
01077
Silver
00610
Ammonia Nitrogen
01092
Zinc
00625
Total Kjeldhal
01027
Cadmium
01105
Aluminum
Nitrogen
00630
Nitrates/Nitrites
01032
Hexavalent Chromium
01147
Total Selenium
01034
Chromium
31616
Fecal Coliform
00665
Total Phosphorous
32730
Total Phenolics
00720
Cyanide
01037
Total Cobalt
34235
Benzene
00745
Total Sulfide
01042
Copper
34481
Toluene
00927
Total Magnesium
38260
M 3AS
00929
Total Sodium _
01045
Iron
39516
PCBs
00940
Total Chloride
01051
Lead
50050
Flow
50060 Total
Residual
Chlorine
71880 Formaldehyde
71900 Mercury
81551 Xylene
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at [phone], extension 581 or 534.
The monthly average for fecal colifotm is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B).
** If signed by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506 (b)
(2) (D)•

NPDES NO. /N C DISCHARGE NO. C f MONTH ✓r1 in YEAR
FACILITY NAME 144i) 14 _'LL L-cam- /_oii�^s ta7�c� COUNTY /��n%-✓��l
STREAM �, �����'£•� / %' ='� STREAM
LOCATION S-/( ZD LOCATIONa!;23
Upstream
00010
00400
00310
00300
31616
00095
Enter Parameter Code
y
L.Above
Name and
v3
y+
„
C
W
Units Below
G
E
EU
�N
�Oo
U
GO
umhw
HRS
' C
Units
mgA
m9/1
#/100m1
9 3n
2/
It I I I I I I I I I a
/0,SI --2o
DEM Forth MR-3 (12/93)
Downstream
Enter Parameter Code
Above Name and
Units Below

NPDE5 NO. N� CCr 'mil DISCHARGE NO. 00l MONTH /7ir' / YEAR % 1
•FACILITY NAME 1�41-�1I4 COUNTY /7,, i':- =' ^^)
STREAM L/rr,/h'%i' /���'"` STREAM
LOCATION �} �G Zo LOCATION Si" �p/;
Upstream
00010
00400
00310
00300
31616
00095
Enter Parameter Code
Above Name and
y C
Units Below
C
V--
v
vV
4O
DOE
8
u°
umhot
CD
HRS
• C
Units
mg/1
mg/I
#/100m1
1
9Zo
�1
7. E
S.3
go
mcMMm
m®
m
DEM Form MR-3 (12/93)
Downstream
00010
00400
00310
00300
31616
00095
Enter Parameter Code
=
e
_
Above Name and
Units Below
8
t`°. •�
..
C V
>04Q
O
u
O.
�u
F
U�
umhod
HRS
° C
Units
mg/1
mgfl
#/100nil
y
/Ga

NPDES NO. / 1 /' CCC , J,2 ! DISCHARGE NO. (-^G 1 MONTH /nrt r' YEAR %
FACILITY NAME 194Pi -) O LLILSSE C��v'•�n�Y�c� COUNTY /"Z;F
STREAM STREAM
LOCATION LOCATION vim' 21. /
Upstream Downstream
■M=
E=
= ,
== ==
Wff"0====
Above Name and
Units Below
®®®®moo®®
DEM Form MR-3 (12/93)
Above Num and
Units Below

Effluent Toxicity Report Form - Chronic Pass/Fail and Acute ICSn nato. nrii,lor,
Facility: ALPHA CELLULOSE NPDES#: NC0005321 Pipe#: 001 County: ROBESON
Labora-tgry Performiin st: HYDROLOGIC, INC. (017)
X ��kcit! Comments: * Color precludes
na ur tlo p a or In esponsi e arge determination.
Cigna ure o a ora y upervisor PASSED:-14.00% Reduction
Work Order: 2202 EnviroQm ntal Scienc s Branch
MAIL ORIGINAL TO: Div. of Environmental Management
N.C. Dept. of EHNR
4401 Reedy Creek Road
North Carolina Ceriodaphnia Raleigh, North Carolina 27607-6445
Chronic Pass/Fail Reproduction Toxicity Test Chronic Test Results
Calculated t =-2.2gg66
CONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 % Reduction = �14.
# Young Produced 1115124121130126124121126�29126I26I32
Adult (L)ive (D)ead 1IL IL IL IL IL JL IL 'L 'L IL �L IL
Effluent %: 2.3%
TREATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced 128 25 25 30 32 29 30 25 28 33 26 31
Adult (L) ive (D)ead �'L L L L L L L L L L L L
% Mortality
Avg.Reprod.
0.00
25.00
Control
Control
Treatment 2
Treattmenn 2
Control CV
18.211%
PASS FAIL
% control orggs
:il
producing 3rd
brood
Check One
91.67%
H 1st sample 1st sample 2nd sample Complete This For Either Test
p Test Start Date: 05/29/96
Control 7.90 8.00 7.96 8.37 8.45 7.90 Collection Start)) Date
Treatment 2 8.31 8.37 8.42 8.37 8.45 8.32 Sample T e /27/96 Sample 2: OS/30/96
p yp /Duration 2 d
s s s 1st %
t e t e t e Grab Comp. Duration D
r r d a r� Sample 1 X 24 hrs M M
t t d Sample 2 X 24 hrs T P P
D.O.
1st sample 1st sample 2nd sample Control 7.8 7.9 7.9 7.4 8.2 7.5 Hardness(mg/1) 47
Treatment 2 8.0 7.8 7.9 7.4 8.2 7.4 Spec. Cond.(Amhos) 122 8390 7540
Chlorine(mg/1)
LC50/Acute Toxicity Test Sample temp. at receipt(*C) 3.1 0.7
(Mortality expressed as %. comhininn ranlirAfacl
%
% %
% % %
LC50 = %
95% Con 1 ence imits
Note: Please
Concentration Compplete This
Mortality Section Also
start/end start/end
Method of Determination Control
Moving Avera e Probit
Spearman Karb�r - Other - High
Conc.
nH D 0
r
Organism Tested: Ceriodaphnia dubia Duration(hrs):
,upltu irum ur-ri form Ni-I (,1/8/) rev. 11/95 (DUBIA ver. 4.32)

o«.sweo,�3.
State of North Carolina
MICHAEL F. EASLEY Department of Justice
ATTORNEY GENERAL P. O. LOX 629
RAL.EIGH
27602-0629
July 18, 1996
Amos Dawson
Attorney at Law
MAUPIN TAYLOR ELLIS & ADAMS, P.A.
Highwoods Tower One, Suite 500
3200 Beechleaf Court
Raleigh, N.C. 27604-1064
VIA FACSIMILE TRANSMISSION TO: [phone]
Dear Amos,
REPLY TO: James P. Longest. Jr.
Environmental Dnision
Tel. (919)73}'_"2S
F".(919) 733-"1
RE: Settlement Agreement: Alpha Cellulose Corporation v. DEHNR-DEM 95
EHR 1056
I have consulted with my client regarding the settlement agreement drafts and the
attachments which Mr. Olsen had provided to me. First, let me compliment Mr. Olsen for his
persistence and patience. I appreciate that the delays involved in coming to terms have been
frustrating for your client. I hope that in future, we can maintain the high level of professional
relations between your office and mine that we have heretofore enjoyed.
The Division of Water Quality (DWQ) will agree to the following terms and parameters:
1) If your client still wishes to have their permit modified to include Summer and
Winter flexibility as to BOD5, DWQ does not object and would support the modification. This
Permit Modification would allow your client an increased loading of BOD5 of 450 lbs. per day
monthly average and 900 lbs. per day daily maximum during the winter months. DWQ cannot
support flow increase at this plant and accompanying increases in loadings based on flow
increases. Your client has been unable to achieve compliance at existing flow. Filamentous
growth has once again caused monthly parameter violations for TSS. DWQ cannot justify
supporting a flow increase under those circumstances.
2) If your client will pay $50,000 to DWQ and withdraw the contested case petition,
my client will settle the two outstanding penalties and will not issue any civil penalties for any
violations occurring at your client's plant prior to June 11, 1996.
An Equal opportunity / Affirmative Action Employer

3) DWQ will support an SOC application substantially in form as the one attached to
this letter. This SOC incorporates most changes proposed by your client through Mr. Olsen.
DWQ will not accept the flow parameter increase to 2.5 MGD suggested in your client's
responses. In fact, the 2.5 number was not in the column marked "Proposed (6-11-96)" on the
draft exhibit A provided to me and Mr. Howard at the meeting on June 11. It appeared in that
column only on the "New Exhibit 1 to Settlement Agreement" faxed to me on 6/24/96. I found
this odd since the memo otherwise appeared the same, including the date at the top of the page.
Flow increases are not authorized by the General Statutes for Special Orders issued to any
permittees except municipalities.
4) At some time after execution of the SOC, but prior to its termination, your client
is welcome to submit a request to be released from the SOC and a permit modification request.
Under the SOC, your client can study and adjust and once your client demonstrates that it can
meet underlying permit limits, my client would consider approving flow increases again with
concomitant increases in TSS loadings. Allowing increases in BOD5 is not consistent with the
Lumber River basin plan even at increased flow.
I hope that these terms are acceptable to your client and that we can put this matter
behind us. I look forward to hearing from you in the future. Until then, I remain,
Very Truly Yours,
6�0-- A
Ryke Longest
Assistant Attorney General
cc: Preston Howard
Dave Goodrich
Dianne Wilburn
Mike Wicker

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF ROBESON
IN THE MATTER OF
NORTH CAROLINA ) SPECIAL ORDER BY CONSENT
NPDES PERMIT ) EMC SOC 96-04
NUMBER NC0005321 )
HELD BY ALPHA CELLULOSEuKAF)T
Pursuant to provisions of North Carolina General Statute (G.S.) 143-215.2, this Special Order by
Consent is entered into by Alpha Cellulose Corporation, hereinafter referred to as a Company, and
the North Carolina Environmental Management Commission, an agency of the State of North
Carolina created by G.S. 143B-282, and hereinafter referred to as the Commission:
The Company and the Commission hereby stipulate the following:
(a) That the Company holds North Carolina NPDES Permit Number NC0005321 for
operation of an existing wastewater treatment works and for making an outlet therefrom for
treated wastewater to the Lumber River, Class "C-Swamp" waters of this State in the
Lumbar River Basin, but is unable to consistently comply with final effluent limitations for
BOD, TSS, and NH3-N, as set forth in NPDES Permit Number NC0005321.
Compliance will require a thorough evaluation of the treatment works and implementation
of those methods or changes determined necessary to achieve compliance.
(b) Noncompliance with final effluent limitations constitutes causing and contributing to
pollution of the waters of this State named above, and the Company is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143, Article 21.
(c) Since this Special Order is by Consent, neither party will file a petition for a contested
case or for judicial review concerning its terms.
2. The Company desiring to comply with the Permit identified in paragraph 1(a) above,
hereby agrees to do the following:
(a) Comply with all terms and conditions of the Permit except those effluent limitations
identified in paragraph 1(a) above. See Attachments A, B, and C for all current monitoring
requirements and effluent limitations. The Permittee may also be required to monitor for
other parameters as deemed necessary by the Director in future permits or administrative
letters.

(b) Undertake the following activities in accordance with the indicated time schedule:
1) Alpha Cellulose has through the winter of 1996 through March 31,
1997, to evaluate its production process and treatment system and to
perform such pilot studies as may be necessary to test/analyze any change or
modification needed to achieve compliance.
2) Alpha Cellulose will submit a report and/or plans for modifications or
additions by May 31, 1997.
3) DEM will complete the review of the materials submitted by August 31,
1997.
4) Alpha Cellulose will submit all necessary requests for an Authorization
to Construct by January 1, 1998.
5) Alpha Cellulose will complete all required construction by November
30, 1998.
6) Alpha Cellulose will comply with Final NPDES permit limits by May
31, 1999.
(c) During the time which this Special Order by Consent is effective, comply with the
interim effluent limitations contained in Attachment A which, for convenience, have been
set forth below:
Permit Limits Modified Limits (Attachment A)
Parameters
Unit
Monthly Avg
Daily Max.
Monthly Avg.
Daily Max.
BOD (summer)
lbs/day
332
664
415
830
BOD (winter)
lbs/day
332
664
563
1125
TSS (summer)
Ibs/day
425
850
738
1476
TSS (winter)
lbs/day
425
850
738
1476
(d) No later than fourteen (14) calendar days after any date identified for accomplishment
of any activity listed in 2(b) above, submit to the Director of the North Carolina Division of
Environmental Management (DEM) written notice of compliance or noncompliance
therewith. In the case of noncompliance, the notice shall include a statement of the
reason(s) for noncompliance, remedial action(s) taken, and a statement identifying the
extent to which subseauent dates or times for accomplishment of listed activities may be
affected.

H
5
The Company agrees that unless excused under paragraph four (4), the Company will pay
the Director of DEM, by check payable to the North Carolina Department of Environment,
Health and Natural Resources, according to the following schedule for failure to meet
the deadlines set out in paragraphs 2(b) and 2(d), or failure to attain compliance with
the effluent limitations/monitoring requirements contained in Attachments A, B, C, and D.
Failure to meet a schedule date
Failure to maintain compliance with
any modified limit contained in the SOC.
Failure to achieve compliance with
limitations at final compliance
deadline
Monitoring frequency violations
Monitoring frequency violations for Toxicity
Failure to submit progress reports
$100/day for the first
7 days; $500/day
thereafter
$1000/ monthly violation
$250/daily violation
$10,000
$100 per omitted value
per parameter
$1,000 per omitted value
$50/day for the first 7
days; $250/day thereafter
The Company and the Commission agree stipulated penalties are not due if the Company
satisfies the Division of Environmental Management noncompliance was caused solely by:
a. An act of God;
b. An act of war;
c. An intentional act or omission of a third party but this defense does not apply if the act or
omission is that of an employee, agent, or contractor of the Company ;
d. An extraordinary event beyond the Company's control. Contractor delays or failure to
obtain funding will not be considered as events beyond the Company's control; or
e. Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand to pay the penalties, or
challenge them by a contested case petition pursuant to G.S. 150B-23, will be grounds for
a collection action, which the Attorney General is hereby authorized to initiate. The only
issue in such an action will be whether the thirty (30) days has elapsed.
Noncompliance with the terms of this Special Order by Consent is subject to enforcement
action seeking injunctive relief pursuant to G.S. 143-215.6.(C).

6. This Special Order by Consent and any terms, conditions, and interim effluent limitations
contained herein, hereby supersede any and all previous Special Orders, Enforcement
Compliance Schedule Letters, terms, conditions, and limitations contained therein issued in
connection with NPDES Permit No. NC0005321. In the event of an NPDES Permit
modification or renewal, any effluent limitations or monitoring requirements contained
therein shall supersede those contained in Attachments A, B, and C of this Special Order
by Consent, except as modified and contained in paragraph 2(c) and 2(d) above.
7. The Company, upon signature of this Special Order by Consent, will be expected to
comply with all schedule dates, terms, and conditions of this document.
This Special Order by Consent shall expire August 31, 1999.
For Alpha Cellulose
Print Name and Title of Signing Official RAFT
Date
Signature of Signing Official
For the North Carolina Environmental Management Commission
Date
Chairman of the Commission

ATTACHMENT A Summer Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning upon execution of the Order and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as
specified below:
Effluent Characteristics
Discharge Limitations Monitoring Requirements
Lbs/day
Units (specifyl Measurement
Sample
*Sample
Mon. Ave.
Daily Max. Mon. Avg. Daily Avg. Frequency
Tvne
Location
Floes,
1.8 MGD Continuous
Recorder
E,I
BOD 5 Day, 20 °C 415
830 Daily
Composite
E
Total Suspended Residue 738
1476 Daily
Composite
E
NH3 as N 83.0
166.0 Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/1 Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
4.3 pg/I Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8* C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment B.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment C.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shell be no discha gc of floating solids or visible foam in tither than trace atnouttts.

ATTACHMENT A Winter Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning upon execution of the Order and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring
Requirements
Lbs/day Units (Specify)
Measurement
Sample
*Sample
Mon. Ave. Daily Max. Mon. Ave. Daily Ave.
Frequency
Tvne
Location
Flow
1.8 MGD
Continuous
Recorder
E,I
BOD, 5 Day, 20 °C
563 1125
Daily
Composite
E
Total Suspended Residue
738 1476
Daily
Composite
E
NH3 as N
83.0 166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/l
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
4.3 pg/1
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment B.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment C.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Attachment B
Dioxin Monitoring
For Permit compliance purposes, the point of compliance shall be defined as the final effluent
before discharge. Compliance with the daily maximum permit limit shall be demonstrated bN-
determining the TCDD concentration at the final discharge point.
Adequate sample volume shall be collected to perform the analysis. the total sample volume shall
be collected and preserved in accordance with the NPDES permit Part H, Section C Monitoring and
Records. The sample shall be analyzed in accordance with the appropriate method of analysis
specified in Analytical Procedure and Quality Assurance for Multimedia Analysis of
Polychlorinated Dibenzo-para-dioxins and Polychlorinated Dibenzofurans by High Resolution Gas
Chromatography / High Resolution Mass Spectrometry, EPA, 1987 (EPA Method 8290), or
another equivalent analytical protocol approved by DEM. A single sample may be analyzed to
determine compliance with the daily maximum effluent limitation. Alternatively, a sample volume
may be collected to enable the sample to be split (duplicate analysis). If the analysis of either split
sample is below the detection limit, the quantity, for the purposes of compliance evaluation. is
considered to be zero. If both the splits are positive, the results of the two analyses shall be
averaged to determine compliance with the daily maximum effluent limitation. If the measurement
if below detection limits the quantity for the purposes of compliance evaluation is considered to be
zero. The detection limit using these methods for the purpose of compliance evaluation is
considered to be 10 picograms per liter. The dioxin isomer to be monitored and limited by the
NPDES permit is 2,3, 7, 8 TCDD.
Fish Tissue analysis will be performed, as a minimum, at one station established upstream of the
discharge and at two stations downstream in accordance with the Division of Environmental
Management approved monitoring plan. The monitoring plan is an enforceable part of the NPDES
permit. All dioxin data collected as part of this monitoring requirement will be reported within three
months after collection. Fish tissue analysis will be performed once during the permit cycle.
specifically, during 1997. Should fish tissue levels indicate concentrations of concern, the Division
my require additional collections of data.
The permittee shall perform the following analyses for dioxin in addition to monitoring the effluent
as specified on the effluent pages of the NPDES permit:
Influent to wastewater treatment facility
Quarterly GRAB (2378 TCDD)
2. Sludge
Quarterly GRAB (2378 TCDD)
3. Fish Tissue Analysis
Once during the NPDES permit cycle
(During the year 1997)

Attachment C
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised * September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 2.3 % (defined as treatment two in North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the permit condition. Tests will be performed during the month of February, May, August,
and November. 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 TGP313. Additionally, DEM Form AT-1 (original) is toe sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurement
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 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 passes. 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 Environmental Management indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirement or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting (within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.

MAUPIN TAYLOR ELLIS & ADAMS. P.A.
MAILING ADDRESS
POST OFFICE DRAWER 19764
RALE IGH, NORTH CAROLINA 27619-9764
TELEFAX 19191 981-4300
DURHAM/RESEARCH TRIANGLE OFFICE
411 ANOPEWS ROAD. SUITE ISO
OUR HAM. NORTH CARD LINA 27705
TELEPHONE [phone]
AMOS C. DAWSON, III
ATTORNEYS AT LAW
HIGHWOODS TOWER ONE. SUITE 500
3200 BEECHLEAF COURT
RALEIGH, NORTH CAROLINA 27604-1064
TELEPHONE [phone]
0 IV
ROCK HILL OFFICE
448 LAKESHORE PARKWAY, SUITE 200
ROCK HILL, SOUTH CAROLINA 29730-4264
TELEFAX 18031324-2093
TELEPHONE [phone]
WRITER'S DIRECT DIAL NUMBER
July 22, 1996 � C ! E
981-4010
VIA HAND DELIVERY J U L 2 21996
James P. "Ryke" Longest, Jr., Esq. N.C. ATTORNEY GENERA!
Assistant Attorney General Environmental Division
Environmental Division
Post Office Box 629
Raleigh, North Carolina 27602
RE: Alpha Cellulose Corporation v DEHNR DEM 95, EHR 1056
Our File No. 6684.009
Dear Ryke:
This is in response to your July 18, 1996 letter in which you set forth the terms and
conditions of a settlement that the Division of Water Quality proposed to resolve the above
referenced contested case. After some consideration, Alpha Cellulose Corporation has requested
us to inform you that the terms and parameters presented in your letter as clarified herein
are acceptable. We believe the settlement should be formalized and have taken the liberty to
incorporate the terms of the settlement into a final agreement, two copies of which are enclosed
for your review. If the form of the Agreement is acceptable, these copies can be executed. If
not, please let us know any changes you propose.
We have also reviewed the draft SOC enclosed with your July 18, 1996 letter and subject
to the following, find it acceptable.
1. The reference to NH3-N in paragraph 1 on page 1 should be deleted. Alpha
Cellulose has not had difficulties in the past meeting this parameter.
2. Correct the "typo' in the first line of para. 2(b)(1) by deleting "through" after the
%vord "has."

James P. "Ryke" Longest, Jr., Esq.
July 22, 1996
Page 2
3. The phrase "Modified Limits (Attachment A)" in para. 2(c) on the second page
should be changed to "SOC Limits" or "SOC Modified Limits" to avoid confusion with the
limits in Alpha Cellulose's permit modification request.
4. A footnote should be placed in para. 2(c) following the words "Permit Limits" to
explain that Alpha Cellulose has a permit modification request pending which, if approved,
would change the BOD (winter) limit to a monthly average of 4501bs./day with a 900 lbs/day
maximum.
5. The "Summer" and "Winter" Limits on Attachment A to the SOC should have a
notation indicating the months which constitute "Summer," e.g., April through October and
"Winter," e.g., November through March.
6. Should the references to the Division of Environmental Management and DEM in
the SOC be changed to DWQ?
Thank you for your cooperation in this matter. Alpha Cellulose would like to finalize the
Settlement Agreement as soon as possible. Please call to discuss how we may expedite this
matter.
Very truly
Dawson, III
Enclosures
cc: Mr. Wayland W. McAllister (w/encl.)
Mr. Charles P. Oxendine (w/encl.)
KAU594al

STATE OF NORTH CAROLINA
COUNTY OF ROBESON
ALPHA CELLULOSE CORPORATION, )
Petitioner,
V.
NC DEHNR, ENVIRONMENTAL
MANAGEMENT COMMISSION AND
DIVISION OF WATER QUALITY,
FORMERLY THE DIVISION OF
ENVIRONMENTAL MANAGEMENT,
Respondent. )
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
95 EHR 1056
SETTLEMENT AGREEMENT
The North Carolina Department of Environment, Health and Natural Resources
(DEHNR) and the North Carolina Environmental Management Commission (EMC), through the
Division of Water Quality (DWQ) (formerly the Division of Environmental Management
(DEM)), respectively and concurrently enter into this Settlement Agreement ("Agreement") with
Alpha Cellulose Corporation (Alpha Cellulose) to resolve all matters currently in controversy
between them.
WHEREAS, this matter arose out an Assessment of Civil Penalties (Assessment)
in the amount of $84,948.28 assessed by the DEM (now the DWQ) against Alpha Cellulose on
August 28, 1995 for alleged violations of North Carolina General Statutes Section 143-
215.1(a)(6) and Alpha Cellulose's NPDES Permit No. NC0005321 (the Permit), as more fully
described in the Assessment; and
KAL33MI

WHEREAS, on February 6, 1996, DEM (now the DWQ) assessed a second Civil
Penalty (2nd Assessment) against Alpha Cellulose in the amount of $15,420.55 for alleged
violations of the Permit and the EMC's laboratory certification rules, N.C. Admin. Code § 15A
2H.0800 et seq., as more fully described in the 2nd Assessment; and
WHEREAS, in letters to the DEM (now the DWQ) dated February 14, 1996 and
February 22, 1996 Alpha Cellulose requested certain modifications to the Permit including the
addition of winter limits governing the concentration of BODS discharges during the months of
November through March; and
WHEREAS, DWQ has agreed to support and proceed to public notice on Alpha
Cellulose's request to have the Permit modified to include summer and winter limits for BOD5 as
follows: Summer - monthly average 332 lbs./day; daily maximum 664 lbs./day.; Winter -
monthly average 450/lbs./day; daily maximum 900 lbs./day; and
WHEREAS, Alpha Cellulose has submitted an application for a Special Order by
Consent (SOC) to the DWQ; and
WHEREAS, the DWQ has reviewed and approved a draft SOC in the form
attached hereto as Exhibit 1; and
WHEREAS, it is the intent of the parties hereto (the Parties) that both
assessments and all matters in controversy therein, be resolved for all times, in accordance with
the terms and conditions of this Agreement; and
RAL337MI 2

WHEREAS, without any trial of fact or law and without admission of liability or
fault, the Parties have reached the following settlement;
NOW, THEREFORE, in consideration of these premises and the mutual
asreements hereinafter set forth, the Parties agree as follows:
The proposed SOC and the permit modifications requested by Alpha
Cellulose shall be sent to public notice and, as necessary, submitted to the EMC as soon as
possible.
2. Upon approval by the Director or the EMC of an SOC and permit
modifications substantially in the form contemplated hereunder, Alpha Cellulose will pay a
penalty of $50,000 and withdraw its Petition for a Contested Case Hearing in this matter with
prejudice. The Parties agree that payment of the penalty and withdrawal of the Petition shall
resolve, fully and for all times, all matters for which a penalty was assessed in the Assessment
and 2nd Assessment and any violations of current permit effluent limitations, for which a penalty
could have been assessed prior to June 11, 1996.
3. DWQ agrees to use its best efforts to assure that the SOC and permit
modifications contemplated by this Agreement are approved by the Director or the EMC as
expeditiously as possible and further agrees to exercise its enforcement discretion so as to refrain
from initiating any enforcement action against Alpha Cellulose during the time period needed to
obtain approval of the SOC provided that during such time Alpha Cellulose complies with the
SOC modified effluent limitations for BOD and TSS set forth in the draft SOC in Exhibit 1
hereto and all other applicable terms and conditions of the Permit. Nothing in the preceding
sentence shall be construed as limiting DWQ's enforcement discretion to take or refrain from
RAL337MI 3

taking any action it otherwise would initiate for a failure to meet effluent limitations in the event
that Alpha Cellulose fails to meet the effluent limitations made applicable by this Paragraph.
FOR THE DIVISION OF
WATER QUALITY:
Name (Print):
Title. -
Date:
R.iL337VI 4
FOR ALPHA CELLULOSE
CORPORATION:
Name (Print):
Title:
Date:

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF ROBESON
1N THE MATTER OF
NORTH CAROLINA ) SPECIAL ORDER BY CONSENT
NPDES PERMIT ) EMC SOC 96-04
NUMBER NC0005321 )
HELD BY ALPHA CELLULOSE ) E) F 7
Pursuant to provisions of North Carolina General Statute (G.S.) 143-215.2, this Special Order by
Consent is entered into by Alpha Cellulose Corporation, hereinafter referred to as a Company, and
the North Carolina Environmental Management Commission, an agency of the State of North
Carolina created by G.S. 143B-282, and hereinafter referred to as the Commission:
1. The Company and the Commission hereby stipulate the following:
(a) That the Company holds North Carolina NPDES Permit Number NC0005321 for
operation of an existing wastewater treatment works and for making an outlet therefrom for
treated wastewater to the Lumber River, Class "C-Swamp" waters of this State in the
Lumbar River Basin, but is unable to consistently comply with final effluent limitations for
BOD, TSS, and NH3-N, as set forth in NPDES Permit Number NC0005321.
Compliance will require a thorough evaluation of the treatment works and implementation
of those methods or changes determined necessary to achieve compliance.
(b) Noncompliance with final effluent limitations constitutes causing and contributing to
pollution of the waters of this State named above, and the Company is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143, Article 21.
(c) Since this Special Order is by Consent, neither party will file a petition for a contested
case or for judicial review concerning its terms.
2. The Company desiring to comply with the Permit identified in paragraph 1(a) above,
hereby agrees to do the following:
(a) Comply with all terms and conditions of the Permit except those effluent limitations
identified in paragraph 1(a) above. See Attachments A, B, and C for all current monitoring
requirements and effluent limitations. The Permittee may also be required to monitor for
other parameters as deemed necessary by the Director in future permits or administrative
letters.

(b) Undertake the following activities in accordance with the indicated time schedule:
1) Alpha Cellulose has through the winter of 1996 through March 31,
1997, to evaluate its production process and treatment system and to
perform such pilot studies as may be necessary to test/analyze any change or
modification needed to achieve compliance.
2) Alpha Cellulose will submit a report and/or plans for modifications or
additions by May 31, 1997.
3) DEM will complete the review of the materials submitted by August 31,
1997.
4) Alpha Cellulose will submit all necessary requests for an Authorization
to Construct by January 1, 1998.
5) Alpha Cellulose will complete all required construction by November
30, 1998.
6) Alpha Cellulose will comply with Final NPDES permit limits by May
31, 1999.
(c) During the time which this Special Order by Consent is effective, comply with the
interim effluent limitations contained in Attachment A which, for convenience, have been
set forth below:
Permit Limits Modified Limits (Attachment A)
Parameters
Unit
Monthly Avg.
Daily Max.
Monthly Avg,
Daily Max.
BOD (summer)
lbs/day
332
664
415
830
BOD (winter)
lbs/day
332
664
563
1125
TSS (summer)
lbs/day
425
850
738
1476
TSS (winter)
lbs/day
425
850
738
1476
(d) No later than fourteen (14) calendar days after any date identified for accomplishment
of any activity listed in 2(b) above, submit to the Director of the North Carolina Division of
Environmental Management (DEM) written notice of compliance or noncompliance
therewith. In the case of noncompliance, the notice shall include a statement of the
reason(s) for noncompliance remedial action(s) taken, and a statement identifvin the_
extent to which subsequent dates or times for accomplishment of listed activities may be
affected.

4
The Company agrees that unless excused under paragraph four (4), the Company will pay
the Director of DEM, by check payable to the North Carolina Department of Environment,
Health and Natural Resources, according to the following schedule for failure to meet
the deadlines set out in paragraphs 2(b) and 2(d), or failure to attain compliance with
the effluent limitations/monitoring requirements contained in Attachments A, B, C, and D.
Failure to meet a schedule date
Failure to maintain compliance with
any modified limit contained in the SOC
Failure to achieve compliance with
limitations at final compliance
deadline
Monitoring frequency violations
Monitoring frequency violations for Toxicity
Failure to submit progress reports
$100/day for the first
7 days; $500/day
thereafter
$1000/ monthly violation
$250/daily violation
$10,000
$100 per omitted value
per parameter
$1,000 per omitted value
$50/day for the first 7
days; $250/day thereafter
The Company and the Commission agree stipulated penalties are not due if the Company
satisfies the Division of Environmental Management noncompliance was caused solely by:
a. An act of God;
b. An act of war;
c. An intentional act or omission of a third party but this defense does not apply if the act or
omission is that of an employee, agent, or contractor of the Company ;
d. An extraordinary event beyond the Company's control. Contractor delays or failure to
obtain funding will not be considered as events beyond the Company's control; or
e. Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand to pay the penalties, or
challenge them by a contested case petition pursuant to G.S. 150B-23, will be grounds for
a collection action, which the Attorney General is hereby authorized to initiate. The only
issue in such an action will be whether the thirty (30) days has elapsed.
Noncompliance with the terms of this Special Order by Consent is subject to enforcement
action seeking injunctive relief pursuant to G.S. 143-215.6.(C).

6. This Special Order by Consent and any terms, conditions, and interim effluent limitations
contained herein, hereby supersede any and all previous Special Orders, Enforcement
Compliance Schedule Letters, terms, conditions, and limitations contained therein issued in
connection with NPDES Permit No. NC0005321. In the event of an NPDES Permit
modification or renewal, any effluent limitations or monitoring requirements contained
therein shall supersede those contained in Attachments A, B, and C of this Special Order
by Consent, except as modified and contained in paragraph 2(c) and 2(d) above.
7. The Company, upon signature of this Special Order by Consent, will be expected to
comply with all schedule dates, terms, and conditions of this document.
This Special Order by Consent shall expire August 31, 1999.
For Alpha Cellulose
ri
Print Name and Title of Signing Official a.., RI AFT
Date
Signature of Signing Official
For the North Carolina Environmental Management Commission
Date
Chairman of the Commission

ATTACHMENT A Summer Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning upon execution of the Order and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Discharge
Limitations
Monitoring Requirements
Lbs/day
Units (specifvl
Measurement
Sample
*Sample
Mon. Ave.
Daily Max.
Mon. Ave. Daily Avg.
Frequency
Tvue
Location
Flow
1.8 MGD
Continuous
Recorder
E,I
BOD, 5 Day, 20 °C
415
830
Daily
Composite
E
Total Suspended Residue
738
1476
Daily
Composite
E
NH3 as N
83.0
166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/1
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
4.3 pg/l
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment B.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment C.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT A Winter Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning upon execution of the Order and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shell be limited and numitored by the I'crmiltee as specified below:
Effluent Chafacteristics
Discharge Limitations
Monitoring
Requirements
Lbs/day
Units (specifvl
Measurement
Sample
*Sample
Mon. Ave. Daily Max.
Mon, Avg_ Daily Avg.
Frequency
Tye
Location
Flow
1.8 MGD
Continuous
Recorder
E,I
BOD 5 Day, 20 °C
563 1125
Daily
Composite
E
Total Suspended Residue
738 1476
Daily
Composite
E
NH3 as N
83.0 166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/l
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
4.3 pg/1
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment B.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment C.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Attachment B
Dioxin Monitoring
For Permit compliance purposes, the point of compliance shall be defined as the final effluent
before discharge. Compliance with the daily maximum permit limit shall be demonstrated by
determining the TCDD concentration at the final discharge point.
Adequate sample volume shall be collected to perform the analysis. the total sample volume shall
be collected and preserved in accordance with the NPDES permit Part H, Section C Monitoring and
Records. The sample shall be analyzed in accordance with the appropriate method of analysis
specified in Analytical Procedure and Quality Assurance for Multimedia Analysis of
Polychlorinated Dibenzo-para-dioxins and Polychlorinated Dibenzofurans by High Resolution Gas
Chromatography / High Resolution Mass Spectrometry, EPA, 1987 (EPA Method 8290), or
another equivalent analytical protocol approved by DEM. A single sample may be analyzed to
determine compliance with the daily maximum effluent limitation. Alternatively, a sample volume
may be collected to enable the sample to be split (duplicate analysis). If the analysis of either split
sample is below the detection limit, the quantity, for the purposes of compliance evaluation, is
considered to be zero. If both the splits are positive, the results of the two analyses shall be
averaged to determine compliance with the daily maximum effluent limitation. If the measurement
if below detection limits the quantity for the purposes of compliance evaluation is considered to be
zero. The detection limit using these methods for the purpose of compliance evaluation is
considered to be 10 picograms per liter. The dioxin isomer to be monitored and limited by the
NPDES permit is 2,3, 7, 8 TCDD.
Fish Tissue analysis will be performed, as a minimum. at one station established upstream of the
discharge and at two stations downstream in accordance with the Division of Environmental
Management approved monitoring plan. The monitoring plan is an enforceable part of the NPDES
permit. All dioxin data collected as part of this monitoring requirement will be reported within three
months after collection. Fish tissue analysis will be performed once during the permit cycle,
specifically, during 1997. Should fish tissue levels indicate concentrations of concern, the Division
my require additional collections of data.
The permittee shall perform the following analyses for dioxin in addition to monitoring the effluent
as specified on the effluent pages of the NPDES permit:
Influent to wastewater treatment facility
Quarterly GRAB (2378 TCDD)
2. Sludge
Quarterly GRAB (2378 TCDD)
3. Fish Tissue Analysis
Once during the NPDES permit cycle
(During the year 1997)

Attachment C
CHRONIC TOXICITY PASS/FAII. PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised * September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 2.3 % (defined as treatment two in North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the permit condition. Tests will be performed during the month of February, May, August,
and November. 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, DEM Form AT-1 (original) is toe sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurement
performed in association with the toxicity tests, as well as all dosetresponse 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 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 passes. 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 Environmental Management indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirement or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting (within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.

MICHAEL F. EASLEY
ATTORNEY GENEiL\L
State of North Carolina
Department of Justice
P. O. SOX 629
RALEIGH
2 7602-0629
REPLY TO: James P. Longest, Jr.
Environmental Division
Tel. [phone]
Faz.[phone]
July 15, 1996
Amos Dawson
Attornev at Law
MAUPIN TAYLOR ELLIS & ADAMS, P.A.
Highwoods Tower One, Suite 500
r..
3200 Beechleaf Court
Raleigh, N.C. 27604-1064
VIA FACSIMILE TRANSMISSION TO: [phone]
RE: Settlement Agreement: Alpha Cellulose Corporation v. DEHNR-DEM95
EHR 1056
Dear Amos,
I have consulted with my client regarding the settlement agreement drafts and the
attachments which Kurt had provided to me. The Division of Water Quality (DWQ) will agree
to the following terms and parameters:
1) If your client still wishes to have their permit modified to include Summer and
Winter ' as -to BOD5, DWQ does not object and would support the modification. This
Permit Modification would allow your client an increased loading of BOD50450 lbs. per day
monthly average and 900 lbs. per day daily maximum. CDWQ cannot support flow increase at
this plant and accompanying increases in loadings*�'our client has been
unable to achieve compliance at existing flow, DWQ cannot justify supporting such an increase
-` Gl f 4wvs -k- ehu
"I) If your client will pay $50,000 to DWQ and withdraw the contested case petition,
my client will settle the two outstanding penalties and will not issue any civil penalties for any
violations occurring at your client's plant prior to June 11, 1996.
3) DWQ will support an SOC application substantially in form as the one attached to
this letter. This SOC incorporates most changes proposed by your client through Kurt. DWQ
will not accept the flow parameter increase to 2.5 MGD suggested in the responses. e
-�Tu`m-Ger was not in the co umn mar e - - provi e
to ar at the meeting on-Juw-11JtLapRe
Exhibit 1 to n axe 56TIie1SOC incorporates the
An Equal Opportunity / Affirmative Action Employer
Flow

increased TSS limitstoequested by your client in the column marked "Proposed (6-11-96)" on the
draft exhibit A provided to me and Mr. Howard at the meeting on June 11.
4) At some time after execution of the SOC, but prior to its termination, my client
Ov,
will be willing to re-evaluate increases to eithe 2.5 MGEtef 4.Q-MrQgen4-ft����s
04�'P
Plea�e that crease to 15, 3A411 requife-a- d �yIfflmtstrativn b yetir ehenHhat it
d prior ItLVO ti-M., increase to 4.6 vyvaid teqnire-a-pkiaL
eKpaneiaitat-ealled
I hope that these terms are acceptable to your client and that we can put this matter
behind us. I look forward to hearing from you in the future. Until then, I remain,
Very Truly Yours,
Ryke Longest
Assistant Attorney General
175
C7 V)
V) , -&L
I u-P
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MMI6;:M
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514
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WNI

MICHAEL F. EASLEY
ATTORNEY GENERAL
State of North Carolina
Department of Justice
P. O. BOX 629
RALEIGH
2 7602-0629
July 15, 1996
r
�v Amos Dawson
Attorney at Law
MAUPIN TAYLOR ELLIS & ADAMS, P.A.
\ Highwoods Tower One, Suite 500
N
3200 Beechleaf Court
Raleigh, N.C. 27604-1064
VIA FACSIMILE TRANSMISSION TO: [phone]
Dear Amos,
REPLY TO: James P. Longest, Jr.
Environmental Division
Tel. [phone]
Faa.[phone]
RE: Settlement Agreement: Alpha Cellulose Corporation v. DEHNR-DEM95
EHR 1056
I have consulted with my client regarding the settlement agreement drafts and the
attachments which Kurt had provided to me. The Division of Water Quality (DWQ) will agree
to the following terms and parameterst� ,,,htt✓
1) If your ient still wis es to have their permit modifi to include Summer and
Winter BOD5, DWQ does not object and would s port the modification. This
Permit Modification would allow your client an incre d loading of BOD54501bs��er_day
monthly average and 900 lbs. per day daily maximunkr_ WQ cannot support flow increasesat
this plant and accompanying increases in loadings'- Your client has been
/ s
unable to achieve compliance at existing flow. DWQ cannot justify supporting such an increase
under those circumstances.
2) If your client will pay $50,000 to DWQ and withdraw the contested case petition,
my client will settle the two outstanding penalties and will not issue any civil penalties for any
violations occurring at your client's plant prior to June 11, 1996.
3) DWQ will support an SOC application substantially in form as the one a he
this letter. This SOC incorporates most changes proposed by your client through Q
will not accept the flow parameter increase to 2.5 MGD suggested in the response . n fact, the �� Cc f 'L7 7
2.5 number as not in the column marked "Proposed (6-11-96)" on the draft exhibi provided��L
to m�. Howard at the meeting on June 11. It appeared in that column only on the "New �v
Exhibit I to Settlement Agreement" faxed to me by Kurt on 6/24/96. TheySOC i4ccorporates the
6
WINES
..
An Equal opportunity / Affirmative Action Employer

•
+ '` A
72
ep
k ' b
increased TS limits requested by your client in the column marked "Proposed (6- I 1-96)" on t e
draft exhibit A provided to me and Mr. oward at the meeting on June 11.
C-O) o-,
4)t some time after execution of the SOC, but oY to its termin tion m client
will be willi to re-evaluatenincrease; to cider 2.5 MGD,
4m=bmdiag*. t
I hope that these terms are acceptable to your client and that we can put this matter
behind us. I look forward to hearing from you in the future. Until then, I remain,
Very Truly Yours,
Ryke Longest
Assistant Attorney General
IAO �t� &�f

MICHAEL F. EASLEY
ATTORNEY GENERAL
State of North Carolina
Department of Justice
P. O. BOX 629
RALEIGH
27602-0629
REPLY TO: James P. Longest, Jr.
Environmental Division
Tel. [phone]
Fax.[phone]
June 27, 1996
Kurt Olsen
Attorney at Law
MAUPIN TAYLOR ELLIS & ADAMS, P.A.
Highwoods Tower One, Suite 500
3200 Beechleaf Court` -
Raleigh, N.C. 27604-1064 v `y
VIA FACSIMILE TRANSMISSION TO: [phone] N' =+
RE: SOC draft: Alpha Cellulose Corporation v. DEHNR-DEM95
EHR 1056
Dear Kurt,
I have faxed to you after this sheet a draft SOC for review by you and your client. Please
review them and give me any changes or comments at your earliest possible convenience. I am
attempting to set up a meeting between representatives of enforcement, permits and the Regional
Office next week to finalize the draft SOC and the draft Permit Modifications. If you could
return comments on the draft to me by next week, I can discuss the changes when I meet with the
client to finalize the draft.
The SOC does not contain the language regarding the civil penalty settlement since that is
handled by the Settlement Agreement. It does contain language requiring Alpha to submit plans
for a new treatment facility and to construct same. The SOC requires your client to conduct pilot
studies, plan and construct a new facility for waste treatment as before and provides permit limit
flexibility to allow them to so do. If your client fails to meet the deadlines imposed or violates
the permit in the mean time, this SOC provides for stipulated penalties.
I have spoken extensively with the Permits and Engineering group regarding the permit
modification request for an increase in the ammonia effluent limit based upon hydraulic uprating.
My client is not likely to approve the ammonia request. Basically, my client's review of Alpha's
DMR's show that TSS and BOD are the effluent parameters which have given your client
trouble. In contrast, ammonia has historically been discharged by this facility at minimal levels.
This is consistent with the reasons my client was unwilling to relax ammonia in the SOC
application. Compliance data do not justify the requested increase. Accordingly, my client
maintains that this increase is unneeded by your client and does not wish to grant the request. If
An Equal Opportunity / Affirmative Action Employer 1�3

your client has additional information to explain the need for the increase, my client will be glad
to review it. Without such information, I expect that when I meet with them next week, they will
decide not to recommend accepting the ammonia modification request.
My client also wants to see the data from the May DMR's before submitting the Permit
Modification request to public hearing. If you could obtain a copy of the May, 1996 DMR and
fax it directly to the attention of Susan Wilson at [phone], this will expedite the matter.
will call you after I get the input back next week on both drafts. Until then, I remain,
Very Truly Yours,
Ryke Longest
Assistant Attorney General
encl: 1 set

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF ROBESON
IN THE MATTER OF
NORTH CAROLINA
NPDES PERMIT
NUMBER NCO005321
HELD BY ALPHA CELLULOSE
SPECIAL ORDER BY CONSENT
EMC SOC 96-04
Pursuant to provisions of North Carolina General Statute (G.S.) 143-215.2, this Special Order by
Consent is entered into by Alpha Cellulose Corporation, hereinafter referred to as a Company, and
the North Carolina Environmental Management Commission, an agency of the State of North
Carolina created by G.S. 143B-282, and hereinafter referred to as the Commission:
The Company and the Commission hereby stipulate the following:
(a) That the Company holds North Carolina NPDES Permit Number NC0005321 for
operation of an existing wastewater treatment works and for making an outlet therefrom for
treated wastewater to the Lumber River, Class "C-Swamp" waters of this State in the
Lumbar River Basin, but is unable to consistently comply with final effluent limitations for
BOD, TSS, and NH3-N, as set forth in NPDES Permit Number NC0005321.
Compliance will require preparation of plans and specifications for construction and
operation of additional treatment works.
(b) Noncompliance with final effluent limitations constitutes causing and contributing to
pollution of the waters of this State named above, and the Company is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143, Article 21.
(c) Since this Special Order is by Consent, neither party will file a petition for a contested
case or for judicial review concerning its terms.
2. The Company desiring to comply with the Permit identified in paragraph 1(a) above,
hereby agrees to do the following:
(a) Comply with all terms and conditions of the Permit exceot those effluent limitations
identified in paragraph 1(a) above. See Attachments A 24for all current monitoring
requirements and effluent limitations. The Permittee may also be required to monitor for
other parameters as deemed necessary by the Director in future permits or administrative
letters.
D "T

(b) Undertake the following activities in accordance with the indicated time schedule:
1) Alpha Cellulose has through the winter of 1996-1997 to do pilot studies
for a new or supplemental treatment system.
2) Alpha Cellulose will submit a plan for a new system by May 31, 1997.
3) DEM will complete the review of the plan by August 31, 1997.
4) Alpha Cellulose will submit a request for an Authorization to Construct
by January 1, 1998.
5) Alpha Cellulose will complete construction by November 30, 1998.
6) Alpha Cellulose will comply with Final NPDES permit limits by May
31, 1999.
(c) During the time which this Special Order by Consent is effective, comply with the
interim effluent limitations contained in Attachment A aa4-4. The following reflects only
the limitations that have been modified from NPDES requirements by this Order:
Permit Limits Modified Limits (Attachment A)
Parameters
Unit
Monthly Avg.
Daily Max.
Monthly Avg_
Daily Max.
BOD (summer)
lbs/day
332
664
415
830
BOD (winter)
lbs/day
332
664
563
1125
TSS (summer)
lbs/day
425
850
531
1062
TSS (winter)
lbs/day
425
850
531
1062
;01
Environmental Management (DEM) written notice of compliance or noncomRliance
therewith. In the case of noncompliance, the notice shall include a statement of the
reason(s) for noncompliance, remedial action(s) taken, and a statement identifying the
extent to which subseauent dates or times for accomplishment of listed activities may be
affected.
3. The Company agrees that unless excused under paragraph four (4), the Company will pay
the Director of DEM, by check payable to the North Carolina Department of Environment,
Health and Natural Resources, according to the following schedule for failure to meet
the deadlines set out in paragraphs 2(b) and 2(d), or failure to attain compliance with
the effluent limitations/monitoring requirements contained in Attachments A, B, C, and D.
Failure to meet a schedule date $100/day for the first
7 days; $500/day
thereafter
Failure to maintain compliance with
any modified limit contained in the SOC. $1000/violation
L
a �,'

Failure to achieve compliance with
limitations at final compliance
deadline
Monitoring frequency violations
Monitoring frequency violations for Toxicity
Failure to submit progress reports
$10,000
$100 per omitted value
per parameter
$1,000 per omitted value
$50/day for the first 7
days; $250/day thereafter
4. The Company and the Commission agree stipulated penalties are not due if the Company
satisfies the Division of Environmental Management noncompliance was caused solely by:
a. An act of God,
b. An act of war;
c. An intentional act or omission of a third party but this defense does not apply if the act or
omission is that of an employee, agent, or contractor of the Company ;
d. An extraordinary event beyond the Company's control. Contractor delays or failure to
obtain funding will not be considered as events beyond the Company's control; or
e. Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand to pay the penalties, or
challenge them by a contested case petition pursuant to G.S. 150B-23, will be grounds for
a collection action, which the Attorney General is hereby authorized to initiate. The only
issue in such an action will be whether the thirty (30) days has elapsed.
5. Noncompliance with the terms of this Special Order by Consent is subject to enforcement
action in addition to the above stipulations, including injunctive relief pursuant to G.S.
143-215.6.(C).
6. This Special Order by Consent and any terms, conditions, and interim effluent limitations
contained herein, hereby supersede any and all previous Special Orders, Enforcement
Compliance Schedule Letters, terms, conditions, and limitations contained therein issued in
connection with NPDES Permit No. NC0005321. In the event of an NPDES Permit
modification or renewal, any effluent limitations or monitoring requirements contained
therein shall supersede those contained in Attachments A, B, C and D of this Special Order
by Consent, except as modified and contained in paragraph 2(c) and 2(d) above.
7. The Company, upon signature of this Special Order by Consent, will be expected to
comply with all schedule dates, terms, and conditions of this document.
®RAFT

S. This Special Order by Consent shall expire August 31, 1999.
For Alpha Cellulose
Print Name and Title of Signing Official
Date
Signature of Signing Official
For the North Carolina Environmental Management Commission
Date
Chairman of the Commission

ATTACHMENT A Winter Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning upon execution of the Order and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring
Requirements
Lbs/day
Units (. ecirv)
Measurement
Sample
*Sample
Mon. Ave. Daily
Mon, Avg_ Daily Avg,
Frequency
Tvoe
Location
Flow
1.8 MGD
Continuous
Recorder
E,1
BOD, 5 Day, 20 "C
563 1125
Daily
Composite
E
Total Suspended Residue
531 1062
Daily
Composite
E
NH3 as N
83.0 166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
*., ^ ;
(J
28.0 µg/1
Daily
Grab
E
Conductivity
!'�
Dail Y
Grab
E,U,D
Dioxin (2378-TCDD)***
.r
4.3 pg/1
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/I.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT A Summer Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning upon execution of the Order and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process
wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Discharge Limitations Monitoring
Requirements
Lbs/day
Units (specifvl Measurement
Sample *Sample
Mon. Ave.
Daily Max. Mon, Ave. Dail,�Ava, Frequency
Location
Flow
1.8 MGD Continuous
Recorder
E,I
BOD 5 Day. 20 °C 415
830 Daily
Composite
E
Total Suspended Residue 531
1062 Daily
Composite
E
NH3 as N 83.0
166.0 Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
` �`1 Monthly
, . , � �� � ,y Y
Composite
P
E
E
Total Residual Chlorine'
�t't, h 28.0 µg/1 Daily
Grab
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
4.3 pg/l Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visibic foam in otlicr tl1;u1 trace amounts.

ATTACHMENT A Summer Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning upon expansion above 1.8 MGD and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Discharge Limitations
Lbs/day
Mon. Avg_ Daily Max.
Units (specify]
Mon. Avg_ Daily Avg,
Monitoring Requirements
Measurement Sample *Sample
Freguency Tyne Location
Flow 4.0 MGD
Continuous
Recorder E,l
BOD, 5 Day, 20 °C 415 830
Daily
CompositeF
Total Susn ndetltesiduc 531 1062__—_._--_-.__--E
NH3 as N 83.0 166.0
Daily
Composite E
Dissolved Oxygen (+)
Daily
Grab E,U,D
Temperature **
Daily
Grab E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite E
Total Phosphorus
Monthly
Composite E
Total Residual Chlorine �.� �-� r^ 28.0 µg/l
Conductivity r�
Daily
Daily
Grab E
Grab E,U,D
t d
Dioxin (2378-TCDD)*** 1.9 /1
pg
Quarterly
Composite E
Chronic Toxicit Y ****
Quarterly
Grab E
Settleable Solids
Weekly
Grab E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8* C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) P/F at 5.0%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT A Winter Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning upon expansion above 1.8 MGD and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring
Requirements
Lbs/day
Units (specifv-1
Measurement
Sample
*Sample
Mon. Ave. Daily Max.
Mon. Ave. Daily Avg.
Frequency
Tyne
Location
Flow
4.0 MGD
Continuous
Recorder
E,1
BOD. 5 Day, 20 "C
563 1125
Daily
Composite
E
Total Suspended Residue
531 1062
Daily
Composite
E
NH3 as N
83.0 166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/l
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***_,_''
...'i
1.9 pg/I
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/I.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Attachmentu, 6
Dioxin Monitoring
For Permit compliance purposes, the point of compliance shall be defined as the final effluent
before discharge. Compliance with the daily maximum permit limit shall be demonstrated by
determining the TCDD concentration at the final discharge point.
Adequate sample volume shall be collected to perform the analysis. the total sample volume shall
be collected and preserved in accordance with the NPDES, permit Part H, Section C Monitoring and
Records. The sample shall be analyzed in accordance with the appropriate method of analysis
specified in Analytical Procedure and Quality Assurance for Multimedia Analysis of
Polychlorinated Dibenzo-para-dioxins and Polychlorinated Dibenzofurans by High Resolution Gas
Chromatography / High Resolution Mass Spectrometry, EPA, 1987 (EPA Method 8290), or
another equivalent analytical protocol approved by DEM. A single sample may be analyzed to
determine compliance with the daily maximum effluent limitation. Alternatively, a sample volume
may be collected to enable the sample to be split (duplicate analysis). If the analysis of either split
sample is below the detection limit, the quantity, for the purposes of compliance evaluation, is
considered to be zero. If both the splits are positive, the results of the two analyses shall be
averaged to determine compliance with the daily maximum effluent limitation. If the measurement
if below detection limits the quantity for the purposes of compliance evaluation is considered to be
zero. The detection limit using these methods for the purpose of compliance evaluation is
considered to be 10 picograms per liter. The dioxin isomer to be monitored and limited by the
NPDES permit is 2,3, 7, 8 TCDD.
Fish Tissue analysis will be performed, as a minimum, at one station established upstream of the
discharge and at two stations downstream in accordance with the Division of Environmental
Management approved monitoring plan. The monitoring plan is an enforceable part of the NPDES
permit. All dioxin data collected as part of this monitoring requirement will be reported within three
months after collection. Fish tissue analysis will be performed once during the permit cycle,
specifically, during 1997. Should fish tissue levels indicate concentrations of concern, the Division
my require additional collections of data.
The permittee shall perform the following analyses for dioxin in addition to monitoring the effluent
as specified on the effluent pages of the NPDES permit:
1. Influent to wastewater treatment facility
Quarterly GRAB (2378 TCDD)
2. Sludge
Quarterly GRAB (2378 TCDD)
3. Fish Tissue Analysis
Once during the NPDES permit cycle
(During the year 1997)
M.

Attachment 0 c-
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised * September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 2.3 % (defined as treatment two in North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the permit condition. Tests will be performed during the month of February, May, August,
and November. 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, DEM Form AT-1 (original) is toe sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurement
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 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 passes. 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 Environmental Management indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirement or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting (within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
Dm'p%
CHRONIC TOXICITY PASS/FAIL PERMIT LMI T (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised * September 1989) or subsequent versions.

The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 5.0 % (defined as treatment two in North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the permit condition. Tests will be performed during the month of February, May, August,
and November. 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, DEM Form AT-1 (original) is toe sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurement
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 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 passes. 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 Environmental Management indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirement or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting (within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
.°"
.IA�
i- 7

06/14/96 FRI 11:50 FAX [phone] MAUPIN TAYLOR > Q 001
MAUPIN TAYLOR ELLIS & ADAMS, P.A.
ATTORNEYS AT LAW
MAILING ADDRESS 3200 BEECHLEAF COURT ROCK HILL OFFICE
POST OFFICE DRAWER 19764 RALEIGH, NORTH CAROLINA 27604.1064 448 LAKESHORE PARKWAY, SUITE 200
RALEIGH, NORTH CAROLINA 27619.9764 ROCK HILL, SOUTH CAROLINA 29730-4264
TELEFAX [phone] TELEPHONE [phone] TELEFAX (8C3) 324-2093
TELEPHONE [phone]
DURHAM OFFICE
411 ANDREWS ROAD, SUITE 150
DURHAM, NORTH CAROLINA 27705
TELEFAX [phone]
TELEPHONE [phone]
FACSIMILE TRANSMISSION
CONMENTIAL IX] RUSH [XI
TO: RYKE LONGEST FROM: KURT OLSON
DEHNR - ENVrX DIV
CITY: RALEIGH
FACSIMILE ##: 733-0791
MAUPIN TAYLOR ELLIS & ADAMS, P.A.
POST OFFICE DRAWER 19764
RALEIGH, NORTH CARCUNA 27619.9764
DIRECT DIAL #: 981-4084
DATE: 6-14-96
OUR FILE NUMBER: 6684.009
TOTAL NUMBER OF PAGES, INCLUDING COVER SHEET: 6
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reader of this communication is not the intended recipient or the employee or agent responsible for delivering this
communication to the intended recipient, you are hereby notified that any dissemination, distribution or copying
of this communication is strictly prohibited. If you have received this communication in error, please notify us
immediately by telephone and return the original message to us at the above address via the U.S. Postal Service.
Thank you.
MESSAGE. PLEASE CALL RYTH ANY COMMENTS
Original to follow by mail? X Yes _ No
We are transmitting from Group III equipment,
Facsimile #: 91919814300 Help #: 919/9814063

06/14/96 FRI 11:50 FAX [phone] MAUPIN TAYLOR > 11002
STATE OF NORTH CAROLINA
COUNTY OF ROBESON
ALPHA CELLULOSE CORPORATION, )
Petitioner,
►W
NC DEHNR, ENVIRONMENTAL MGT
COMM. & DIV. OF ENVIRON. MGT.,
Respondent.
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
95 EHR 1056
SETTLEMENT AGREEMENT
The North Carolina Department of Environment, Health and Natural Resources
(DEHNR) and the North Carolina Environmental Management Commissi.oa (EMC), through the
Division of Environmental Management (DEM), respectively and concurrently enter into this
Settlement Agreement ("Agreement") with Alpha Cellulose Corporation (Alpha. Cellulose) to
amicably resolve all matters currently in controversy between them.
WHEREAS, this matter arose out an Assessment of Civil Penalties (Assessment)
in the amount of $84,948.28 assessed by the DEM against Alpha Cellulose on August 28, 1996
for alleged violations of North Carolina General Statutes Section 143-215,1(a)(6) and Alpha
Cellulose's NPDES Permit No. NC0005321 (the Permit), as more fully described in the
Assessment; and
WHEREAS, on February 6, 1996, DEM assessed a second Civil Penalty (2nd
Assessment) against Alpha Cellulose in the amount of $15,420.55 for alleged violations of the
Permit and the E.MC's laboratory certification rules, N.C. Admin, Code § 15A 2H.0800 et seq.,
as more fully described in the 2nd Assessment; and
RAU3377911

0$/14/96 FRI 11:51 FAX [phone] MAUPIN TAYLOR > 2003
WHEREAS, in letters to the DEM dated February 14, 1996 and February 22,
1996 Alpha Cellulose requested certain modifications to the Permit including winter discharge
limits governing discharges during the months of November to March;' and
WHEREAS, DEM has agreed to proceed to public notice on Alpha Cellulose's
requested modifications to the Permit and, with the possible exception of the requested NB, as N
limit, has agreed to support the modifications; and
WHEREAS, Alpha Cellulose has submitted an application for a Special Order by
Consent (SOC) to the DEM which is attached hereto as Exhibit 2 and has been reviewed and
approved by the DEM; and
WHEREAS, the SOC contemplates a transition period during which Alpha
Cellulose will conduct an extensive study and then modify its process and/or wastewater
treatment system to allow it to meet the limits in the Permit as modified; and
WHEREAS, it is the intent of the parties hereto (the Parties) that both
assessments and all matters in controversy therein, be resolved for all times, in accordance with
the terms and conditions of this Agreement, and
WHEREAS, without any trial of fact or law and without admission of liability or
fault, the Parties have reached the following settlement;
NOW, THEREFORE, in consideration of these premises and the mutual
agreements hereinafter set forth, the Parties agree as follows;
1. The SOC application and the permit modifications requested by Alpha
' The modifications Alpha Cellulose has requested are referenced in the column entitled
"MODs Requested 2/14 & 22!96 Pending Approval" in a June 10, 1996 memorandum from
Chuck Oxendine to Mack Mc.4,llister attached hereto as Exhibit 1.
xetnaru1 2

06/14/96 FRI 11:51 FAX [phone] MAUPIN TAYLOR > Q 004
Cellulose shall be sent to public notice and submitted to the EMC as soon as possible.
2. Upon the FMC's approval of an SOC and permit modifications
substantially in the form contemplated hereunder, Alpha Cellulose will pay a penalty of $50,000
and withdraw its Petition for a Contested Case Hearing in this matter currently pending at the
Office of Administrative Hearings with prejudice. The Parties agree that payment of the penalty
and R7thdrawal of the petition shall resolve, fully and for all times, all matters for which a
penalty was assessed in the Assessment and 2nd Assessment and all other matters involving a
discharge under the Permit, known or unknown, for which a penalty could have been assessed
prior to the date of this Agreement.
I D6M agrees to use its best efforts to assure that the SOC contemplated by
this Agreement is approved by the EMC as expeditiously as possible and further agrees to
exercise its enforcement discretion so as to refrain from initiating any enforcement action against
Alpha Cellulose during the time period needed to obtain FMC's approval of the SOC provided
that during such time Alpha Cellulose complies with interim effluent limitations for BOD and
TSS set forth in the application for an SOC in Exhibit 2 hereto and all other applicable terms and
conditions of the Permit. Nothing in the preceding sentence shall be construed as limiting
DEM's enforcement discretion to take or refrain from taking any action it otherwise would
initiate for a failure to meet effluent limitations in the event that Alpha Cellulose fails to meet the
effluent limitations made applicable by this paragraph .
RALA37MI

06/14/96 FRI 11:52 FAX [phone] MAUPIN TAYLOR > IZO05
FOR THE DIVISION OF
ENVIRONMENTAL MANAGEMENT:
Name (Print):
Title:
Date:
m
FOR ALPHA CELLULOSE
CORPORATION:

08/14/96 FRI 11:52 FAX [phone] MAUPIN TAYLOR > 006
12*1r6: M
DATE: 7u=10, 1996
TO: Mack McAllister
1•'ROM: Chuek Oxmidine
SOC Application NPDES Limits
MOD's Requemed
Settlement AgMMe It (1-&96) l
pAremIte. so eniieatign (2.23-96) Fronoeed 6-lr I.961 yt �t P ndi
ROD (mg/L) 415/830 (S) 415/830 (S) 332/664 3321664 (S)
$6311125 (W) 563/1125 (W) 4501900 (W)
TSS (per L) 531/1062 (S) 738A476 (S) 425/950
590/1180 (S)
531/1062 (W) 738/1476
590/1180 (W)
120l240 91/166
1201240
NE3 ai N (mg/L) •----- --
1.9
2.5
]FLOW (MGD)
(S) - Summrr limits
(W) ;2 Winter limits
its in the
Provided that we are granted the modifications that 1476 # daytt daily a itnutnwould be ` tThis would �tcorrelate to 1the TSS 1225% of the
50C
would be changed to 738 Wday monthly a etage 6 # ay - limits.
NPDES limit which was the basis for establishing the atilt

Page 1
Note for Susan Wilson
From: Dave Goodrich
Date: Thu, Feb 15, 1996 7:52 AM
Subject: RE: fyi - alpha c
To: Susan Wilson
Yeah, I agree. The question is: are the modelers holding everyone's limits at 15 and 4 or existing
loading? My impression was they were holding facilities to the concentration limits only.
From: Susan Wilson on Wed, Feb 14, 1996 4:19 PM
Subject: fyi - alpha c
To: Dave Goodrich
i got a call today from chuck oxendine of alpha cellulose, asking questions on their pending
modification. i don't know what the final outcome of that meeting was, but he will be requesting
more lenient limits for winter. he also requested more lenient pound levels at the 2.5 MGD phase.
i couched it very well, but i told him that the permit currently reflects the same load even at the 4
mgd, so i didn't see that that would change for summer limits. i also told him i wasn't privy to the
meeting on thursday and asked if that issue was discussed. he said michael was amenable to that
as long as they held their concentration. i told him he could make that request and we would
review it.
i don't understand why michael would make any statements like that regarding their summer
limits. this may develop into a big mess.

`��`J�O S E C �,o
Q
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2 9
Q , ` O
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` PulP
February 14, 1996
Water Quality Section
Permits and Engineering
P.O. Box 29535
Raleigh N.C. 27626-0535
ATTN: Mr. Dave Goodrich
Dear Mr. Goodrich:
As a result of a meeting held on 2-8-96 in Raleigh, N.C. with Michael Wicker, Diane
Williburn and Ryke Longest, Alpha Cellulose Corporation is requesting that the
NCDEHNR modify NPDES permit no. NC0005321 to include increased winter limits for
Biochemical Oxygen Demand and Ammonia Nitrogen discharges. Alpha currently
operates under the same limitations year round. The current BOD limits are 332 pounds -
monthly average and 664 pounds - daily max. The Ammonia Nitrogen limit is 83 pounds
per day - monthly average. Alpha is requesting a BOD increase to 450 pounds per day -
monthly average and 900 pounds per day - daily max. and an Ammonia Nitrogen limit
increase to 120 pounds per day - monthly average.
Alpha Cellulose Corporation treats approximately 1.6 - 1.8 MGD of wastewater. The
wastewater is 100% industrial process water while all sanitary waste from Alpha is treated
by the Lumberton municipal WWTP. Alpha's influent is a strong one ranging from 1200 -
2000 mg/L and typically averaging approx. 1600 mg/L. The COD value of the influent is
usually 6000 - 7000 mg/L. In order for Alpha to maintain compliance with the current
NPDES permit limits, the WWTP must consistently achieve approx. 99% efficiency for
BOD removal. This becomes very difficult during the winter months when colder weather
adversely effects biological activity in the secondary treatment process. With the extremely
high influent BOD it is necessary for Alpha to maintain a fairly long residence time in the
aeration basin to accommodate thorough biological treatment. This residence time
approximates that of an extended aeration mode. This is accomplished by using a large
volume (-5MG) aeration basin. Alpha also uses surface mechanical aerators to introduce
dissolved oxygen into the basin. The use of this type of aeration equipment results in a
cooling effect of the MLSS. While this cooling effect is beneficial in the hot summer
1000 East Nair Street, Box 1305 Lumberton, North Carolina 28359 USA V 910 738 4201 FAX [phone]

months it becomes undesirable in the cold of winter. The long residence time of the MLSS
and the cooling effect inherent in the use of surface mechanical aerators leads to heat loss
in the basin. The variation of the MLSS temperature from season to season directly effects
the rate at which biodegradation takes place, thus the BOD removal efficiencies may be
impacted so that excursions above permit limits occur during the winter months.
Enclosed is a check for $400.00 to cover the application and processing fees as requested
by Mr. Alan Jones from your office. If you have any questions or comments, please give
me a call.
Sincerely,
Chuck Oxendine
Technical Services Manager
cc: Michael Wicker
Susan Wilson
Wayland McAllister
File

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NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF ROBESON
IN THE MATTER OF
NORTH CAROLINA
NPDES PERMIT
NUMBER NC0005321
HELD BY ALPHA CELLULOSE
SPECIAL ORDER BY CONSENT
EMC SOC 96-04
Pursuant to provisions of North Carolina General Statute (G.S.) 143-215.2, this Special Order by
Consent is entered into by Alpha Cellulose Corporation, hereinafter referred to as a Company, and
the North Carolina Environmental Management Commission, an agency of the State of North
Carolina created by G.S. 143B-282, and hereinafter referred to as the Commission:
1.
2.
The Company and the Commission hereby stipulate the following:
(a) That the Company holds North Carolina NPDES Permit Number NC0005321 for
operation of an existing wastewater treatment works and for making an outlet therefrom for
treated wastewater to the Lumber River, Class "C-Swamp" waters of this State in the
Lumbar River Basin, but is unable to consistently comply with final effluent limitations for
BOD, TSS, and NH3-N, as set forth in NPDES Permit Number NC0005321.
Compliance will require preparation of plans and specifications for construction and
operation of additional treatment works.
(b) Noncompliance with final effluent limitations constitutes causing and contributing to
pollution of the waters of this State named above, and the Company is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143, Article 21.
(c) Since this Special Order is by Consent, neither party will file a petition for a contested
case or for judicial review concerning its terms.
(d) Civil Penalty Cases LV 95-12 and WQ 94-14 will be held in abeyance during the term
of this Special Order by Consent. The Company and the Commission have settled these
civil penalties as follows: LV 95-12 for $67,958 and WQ 94-14 for $12,336.
The Company desiring to comply with the Permit identified in paragraph 1(a) above,
hereby agrees to do the following:
(a) Comply with all terms and conditions of the Permit except those effluent limitations
identified in paragraph 1(a) above. See Attachments A, B, C and D for all current
monitoring requirements and effluent limitations. The Permittee may also be required to
monitor for other parameters as deemed necessary by the Director in future permits or
administrative letters.

(b) Undertake the following activities in accordance with the indicated time schedule:
1) Alpha Cellulose has through the winter of 1996-1997 to do pilot studies
for a new or supplemental treatment system.
2) Alpha Cellulose will submit a plan for a new system by May 31, 1997.
3) DEM will complete the review of the plan by August 31, 1997.
4) Alpha Cellulose will submit a request for an Authorization to Construct
by January 1, 1998.
5) Alpha Cellulose will complete construction by November 30, 1998.
(c) Until May 31, 1999, comply with the interim effluent limitations contained in
Attachment A. The following reflects only the limitations that have been modified from
NPDES requirements by this Order:
Permit Limits Modified Limits (Attachment A)
Parameters
Unit
Monthly Avg.
Daily Max.
Monthly Avg:
Daily Max.
BOD (summer)
lbs/day
332 �' I
664 G
415 v
830 K✓
OD (winter)
lbs/day
332 4 50
664 1 o 0
563
1125 ✓
TSS (summer)
lbs/day
425 i q o
850 v S °
531,(
1062 x
TSS (winter)
lbs/day
425 5q/,)
850 i I U -u
531 -1
1062 t
(d) The fines listed in 1(d) will be waived by the Commission if the Company complies
with the interim effluent limits contained in Attachment B during the period June 1, 1999
through May 30, 2000. The following reflects only the limitations that have been modified
from NPDES requirements by this Order:
Permit Limits
Modified Limits
(Attachment B)
Parameters
Unit
Monthly Avg. Daily Max.
Monthly Avg,
Daily Max
BOD (summer)
lbs/day
332
664
250
664
BOD (winter)
lbs/day
332
664
405
664
TSS (summer)
lbs/day
425
850
320
850
TSS (winter)
lbs/day
425
850
383
850
NH3N (summer)
lbs/day
83
166
60
166
NH3N (winter)
lbs/day
83
166
120
166
(e) No later than fourteen (,14) calendar days after any date identified for accomplishment
of any activity listed in 2(2) above, submit to the Director of the North Carolina Division of
Environmental Management (DEM) written notice of compliance or noncompliance
therewith. In the case of noncompliance, the notice shall include a statement of the
reason(s) for noncompliance, remedial action(s) taken, and a statement identifying the
extent to which subseauent dates or times for accomplishment of listed activities may be
affected.

3 . The Company agrees that unless excused under paragraph four (4), the Company will pay
the Director of DEM, by check payable to the North Carolina Department of Environment,
Health and Natural Resources, according to the following schedule for failure to meet
the deadlines set out in paragraphs 2(b) and 2(d), or failure to attain compliance with
the effluent limitations/monitoring requirements contained in Attachments A, B, C, and D.
Failure to meet a schedule date
Failure to maintain compliance with
any modified limit contained in the SOC.
Failure to achieve compliance with
limitations at final compliance
deadline
$100/day for the first
7 days; $500/day
thereafter
$1000/violation
$10,000
Monitoring frequency violations $100 per omitted value
per parameter
Monitoring frequency violations for Toxicity $1,000 per omitted value
Failure to submit progress reports $50/day for the first 7
days; $250/day thereafter
4. The Company and the Commission agree stipulated penalties are not due if the Company
satisfies the Division of Environmental Management noncompliance was caused solely by:
a. An act of God;
b. An act of war;
c. An intentional act or omission of a third party but this defense does not apply if the act or
omission is that of an employee, agent, or contractor of the Company ;
d. An extraordinary event beyond the Company's control. Contractor delays or failure to
obtain funding will not be considered as events beyond the Company's control; or
e. Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand to pay the penalties, or
challenge them by a contested case petition pursuant to G.S. 150B-23, will be grounds for
a collection action, which the Attorney General is hereby authorized to initiate. The only
issue in such an action will be whether the thirty (30) days has elapsed.
5. Noncompliance with the terms of this Special Order by Consent is subject to enforcement
action in addition to the above stipulations, including injunctive relief pursuant to G.S.
143-215.6.(C).

6. This Special Order by Consent and any terms, conditions, and interim effluent limitations
contained herein, hereby supersede any and all previous Special Orders, Enforcement
Compliance Schedule Letters, terms, conditions, and limitations contained therein issued in
connection with NPDES Permit No. NC0005321. In the event of an NPDES Permit
modification or renewal, any effluent limitations or monitoring requirements contained
therein shall supersede those contained in Attachments A, B, C and D of this Special Order
by Consent, except as modified and contained in paragraph 2(c) and 2(d) above.
7. The Company, upon signature of this Special Order by Consent, will be expected to
comply with all schedule dates, terms, and conditions of this document.
8. This Special Order by Consent shall expire August 31, 2000.
For Alpha Cellulose
Print Name and Title of Signing Official
Date
Signature of Signing Official
For the North Carolina Environmental Management Commission
Date
Chairman of the Commission

ATTACHMENT A Summer Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning upon execution of the Order and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics Discharge Limitations
Monitoring
Requirements
Lbstday
Units (specify)
Measurement
Sample
*Sample
Mon. Avg.. Daily Max.
Mon, Avg. Daily Avg.
Frequency
Tvoe
Location
Flow
1.8 MGD
Continuous
Recorder
E,I
$OD. 5 Day. 20 °C 415 830
Daily
Composite
E
Total Susnended Residue 531 1062
Daily
Composite
E
NH3 as N 83.0 166.0
Daily
Composite
E
_Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/1
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
4.3 pg/1
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8* C above background temperatures and in no case cause
the receiving stream to exceed 32.0* C.
*** See Attachment C.
* * * * Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT A Winter Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321 `
During the period beginning upon execution of the Order and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics Discharge Limitations
Monitoring Requirements
Lbs/day Units (specify)
Measurement
Sample
*Sample
Mon. Avg. Daily Max. Mon, Avg. Daily Ave.
Frequency
I=
Location
Flow 1.8 MGD
Continuous
Recorder
E,I
BOD, 5 Day. 20 °C 563 1125
Daily
Composite
E
Total Suspended Residue 531 1062
Daily
Composite
E
NH3 as N 83.0 166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine 28.0 µg/l
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)*** 4.3 pg/1
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT A Summer Limit
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning upon expansion above 1.8 MGD and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring Requirements
Lbstday
Units (specify)
Measurement
Sam le
*Sample
Mon. Ave, Daily Max,
n Ave,Daily Avg,
Frequency
Tvne
Location
Flow
4.0 MGD
Continuous
Recorder
E,I
BOD, 5 Day, 20 °C
415 830
Daily
Composite
E
Total Suspended Residue
531 1062
Daily
Composite
E
NH3 as N
83.0 166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/1
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
1.9 pg/1
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8* C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) P/F at 5.0%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT A Winter Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321 +
During the period beginning upon expansion above 1.8 MGD and lasting until May 31, 1999, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring
Requirements
Lbs/day Units (s=ify)
Measurement
Sample
*Sample
Mon. Avg. Daily Max. Mon, Avg. Daily Avg.
Frequency
IYpg
Location
Flow
4.0 MGD
Continuous
Recorder
E,I
BOD, 5 Day. 20 °C
563_ 1125
Daily
Composite
E
Total Suspended Residue
531 1062
Daily
Composite
E
NH3 as N
83.0 166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 pg/1
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
1.9 pg/I
Quarterly
Composite
E
Chronic Toxicity""
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) P/F t 2.3%; ebruary, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT B Summer Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC000.5321
During the period June 1, 1999, through May 30, 2000, and prior to expansion to 4.0 MGD, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Lbs/day knitsnits (specify) Measurement Sample *Sample
Mon. Avg. Daily Max. Mon. Ave, Daily Avg. FreQuency I+ g Location
Flow
,"—`� _ 1.8 MGD Continuous Recorder E,I
Dissolved Oxygen (+) /'
Daily
Grab
E,U,D
Temperature ** f
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/l Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
4.3 pg/l Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT B Winter Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period June 1, 1999, through May 30, 2000, and prior to expansion to 4.0 MGD, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the permittee as specified below:
Efrluent Characteristics
Discharge Limitations
Monitoring Requirements
Lbs/day Units (specify,)
Measurement
Sample
*Sample
Mon. Ava. Daily Max. Mon. Ave. Daily Avg.
Frequency
Twe
Location
Flow
1.8 MGD
Continuous
Recorder
E,I
BOD, 5 Day. 20 °C
405 664.0
Daily
Composite
E
Total Suspended Residue
383 850.0
Daily
Composite
E
NH3 as N
120 166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/1
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
4.3 pg/1
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
*** See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) PIF at 2.3%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/l.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT B Summer Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period June 1, 1999, through May 30, 2000, and after expansion to 4.0 MGD, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring Requirements
Lbs/day Units (spe
Measurement
Sample
*Sample
Mon. Ave. Daily Max. Mon, Ave. Daily Ave.
FEr quency
Tvne
Location
Flow
4.0 MGD
Continuous
Recorder
E,I
BOD, 5 Day. 20 °C
250 664.0
Daily
Composite_
Total Suspended Residue
320 850.0
Daily
Composite
E
NH3 as N
60 166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/l
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
1.9 pgfl
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
_ * Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0* C.
*** See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) P/F at 5.0%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/1.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ATTACHMENT B Winter Limits
A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period June 1, 1999, through May 30, 2000, and after expansion to 4.0 MGD, the Permittee is authorized to discharge from
outfall(s) serial number 001, process wastewaters. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring
Requirements
Lbs/dav Units (specify)
Measurement
Sample
*Sample
Mon. Ave. Dail} Max. Mon. AVc. Daily Avg.
frequency
type
Location
Flow
4.0 MGD
Continuous
Recorder
E,I
BOD, 5 Day, 20 °C
405 664.0
Daily
Composite
E
Total Suspended Residue
383 850.0
Daily
Composite
E
NH3 as N
120 166.0
Daily
Composite
E
Dissolved Oxygen (+)
Daily
Grab
E,U,D
Temperature **
Daily
Grab
E,U,D
Total Nitrogen (NO2+NO3+TKN)
Monthly
Composite
E
Total Phosphorus
Monthly
Composite
E
Total Residual Chlorine
28.0 µg/l
Daily
Grab
E
Conductivity
Daily
Grab
E,U,D
Dioxin (2378-TCDD)***
1.9 pg/1
Quarterly
Composite
E
Chronic Toxicity****
Quarterly
Grab
E
Settleable Solids
Weekly
Grab
E
* Sample locations: E-Effluent, I -Influent, U-Upstream at NCSR 1620, D-Downstream at NCSR 2123 and NCSR 2121.
Stream samples shall be grab samples and shall be collected three times per week during June, July, August, and September and once per
week during the remaining months of the year.
** The discharge shall not make the temperature of the receiving stream to exceed 2.8° C above background temperatures and in no case cause
the receiving stream to exceed 32.0° C.
* * * See Attachment C.
**** Chronic Toxicity (Ceriodaphnia) P/F at 2.3%; February, May, August and November; See Attachment D.
(+) The daily average dissolved oxygen concentration shall not be less than 5.0 mg/1.
The pH shall not be less than 6.0 standard units'nor greater than 9.0 standard units and shall be monitored daily by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Attachment C
Dioxin Monitoring
For Permit compliance purposes, the point of compliance shall be defined as the final effluent
before discharge. Compliance with the daily maximum permit limit shall be demonstrated by
determining the TCDD concentration at the final discharge point.
Adequate sample volume shall be collected to perform the analysis. the total sample volume shall
be collected and preserved in accordance with the NPDES permit Part II, Section C Monitoring and
Records. The sample shall be analyzed in accordance with the appropriate method of analysis
specified in Analytical Procedure and Quality Assurance for Multimedia Analysis of
Polychlorinated Dibenzo-pars-dioxins and Polychlorinated Dibenzofurans by High Resolution Gas
Chromatography / High Resolution Mass Spectrometry, EPA, 1987 (EPA Method 8290), or
another equivalent analytical protocol approved by DEM. A single sample may be analyzed to
determine compliance with the daily maximum effluent limitation. Alternatively, a sample volume
may be collected to enable the sample to be split (duplicate analysis). If the analysis of either split
sample is below the detection limit, the quantity, for the purposes of compliance evaluation, is
considered to be zero. If both the splits are positive, the results of the two analyses shall be
averaged to determine compliance with the daily maximum effluent limitation. If the measurement
if below detection limits the quantity for the purposes of compliance evaluation is considered to be
zero. The detection limit using these methods for the purpose of compliance evaluation is
considered to be 10 picograms per liter. The dioxin isomer to be monitored and limited by the
NPDES, permit is 2,3, 7, 8 TCDD.
Fish Tissue analysis will be performed, as a minimum, at one station established upstream of the
discharge and at two stations downstream in accordance with the Division of Environmental
Management approved monitoring plan. The monitoring plan is an enforceable part of the NPDES
permit. All dioxin data collected as part of this monitoring requirement will be reported within three
months after collection. Fish tissue analysis will be performed once during the permit cycle,
specifically, during 1997. Should fish tissue levels indicate concentrations of concern, the Division
my require additional collections of data.
The permittee shall perform the following analyses for dioxin in addition to monitoring the effluent
as specified on the effluent pages of the NPDES permit:
1. Influent to wastewater treatment facility
Quarterly GRAB (2378 TCDD)
2. Sludge
Quarterly GRAB (2378 TCDD)
3. Fish Tissue Analysis
Once during the NPDES permit cycle
(During the year 1997)

Attachment D
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised * September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 2.3 % (defined as treatment two in North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the permit condition. Tests will be performed during the month of February, May, August,
and November. 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, DEM Form AT-1 (original) is toe sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurement
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 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 passes. 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 Environmental Management indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirement or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting (within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised * September 1989) or subsequent versions.

The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 5.0 % (defined as treatment two in North Carolina procedure document).
The permit holder shall perform quarterly monitoring using this procedure to establish compliance
with the permit condition. Tests will be performed during the month of February, May, August,
and November. 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, DEM Form AT-1 (original) is toe sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete- and accurate and include all supporting chemical/physical measurement
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 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 passes. 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 Environmental Management indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirement or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting (within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.

TREATABILITY STUDIES AND PROPOSED
-' n
WASTEWATER TREATMENT FACILITY
MODIFICATIONS
Prepared for:
ALPHA CELLULOSE CORPORATION
(A Buckeye Cellulose Company)
Lumberton, North Carolina
Prepared by:
ECKENFELDER INC.®
227 French Landing Drive
Nashville, Tennessee 37228
[phone]
June 1997
0014
@:\ooia\T,9 .LET

TABLE OF CONTENTS
Page No.
Table of Contents
i
List of Tables
ii
List of Figures
ii
1.0 INTRODUCTION
1-1
2.0 BENCH -SCALE TREATABILITY STUDIES
2-1
2.1 Objectives
2-1
2.2 Experimental Methods
2-1
2.2.1 Jar Tests on the Raw Wastewater
2-1
2.2.2 Bench -Scale Continuous Flow Treatability Study
2-1
2.3 Results and Discussion
2-3
2.3.1 Jar Tests on Raw Wastewater
2-3
2.3.2 Biological Treatability Study
2-4
2.3.2.1 Influent Wastewater Characteristics
2-5
2.3.2.2 Reactor Operating Conditions
2-5
2.3.2.3 Performance Characteristics and Kinetic
Coefficients
2-6
2.3.2.4 Sludge Settling Characteristics
2-9
2.3.2.5 Observations During Treatability Study
2-10
2.3.2.6 Primary Solids Digestion
2-10
2.4 Conclusions
2-10
3.0 PROPOSED PLANS FOR WWTF MODIFICATIONS
3-1
4.0 PREDICTED EFFLUENT QUALITY RESULTS AND UNCERTAINTIES
4-1
4.1 Winter Operation
4-1
4.2 Summer Operation
4-3
4.3 Operation of WWTF During Production Plant Shut -down
4-3
4.4 Uncertainties in WWTF Performance
4-4
5.0 IMPLEMENTATION AND EVALUATION SCHEDULE
5-1
APPENDICES
Appendix A - Special Order by Consent (January 24, 1997)
Appendix B - Results of the Bench -Scale Treatability Study
Q\0014\TS\lstoc 1

LIST OF TABLES
Follows
Table No.
Title
Paae No.
2-1
Jar Test Results for the Raw Wastewater
2-3
2-2
Floc Load Test Results
2-4
2-3
Influent Characteristics During the Bench -Scale Treatability
Study
2-5
2-4
Reactor Operating Conditions
2-5
2-5
Reactor 1 Effluent Characteristics
2-6
2-6
Reactor 2 Effluent Characteristics
2-6
2-7
Reactor 3 Effluent Characteristics
2-6
2-8
Average Process Coefficients
2-6
LIST OF FIGURES
Follows
Figure No. Title Paae No.
1-1 Industry BOD Reduction Efficiency Comparison 1-1
2-1 Experimental Configurations for Reactors 1, 2, and 3 2-1
2-2 Results of Aerobic Solids Digestion Test 2-10
3-1 Preliminary Process Flow Diagram of the WWTF with
Proposed ModificationslUpgrade 5-1
q:\0014\TS\TSI.OTF ii

1.0 INTRODUCTION
Alpha Cellulose Corporation (Alpha) operates a 140-ton per day cotton fiber pulp
manufacturing facility in Lumberton, North Carolina. The wastewaters generated
from the production plant are currently being treated in the existing wastewater
treatment facility (W)AITF). The mill currently operates under a National Pollutant
Discharge Elimination System (NPDES) permit issued by the North Carolina
Department of Environment, Health and Natural Resources (DEHNR), Division of
Water Quality. This facility is already delivering effluent quality results (i.e.,
treatment system efficiencies) that are among the best, if not the best, in the pulp
and paper industry. This is shown in Figure 1-1, a comparison of activated sludge
treatment system performance obtained from the United States Environmental
Protection Agency (USEPA).
Due to some historical compliance issues with biochemical oxygen demand (BOD)
and total suspended solids (TSS), Alpha has entered into a Special Order by
Consent (SOC) with the state agency, according to the letter dated January 24, 1997
from DEHNR. A copy of the SOC is attached in Appendix A.
As required by the SOC, an evaluation of the WWTF was performed and the results
and conclusions were presented in the previous report entitled, "Wastewater
Treatment Plant Evaluation," dated May 29, 1997. Based on the results of the
WWTF evaluation, bench -scale treatability studies were undertaken to identify
potential WWTF operational changes and upgrades. This report presents the
results and conclusions of the treatability studies, the proposed plans for WWTF
modifications to address the opportunities identified by the WWTF evaluation, and
the implementation and evaluation schedule.
Also, in accordance with the SOC, a process study was completed evaluating the
impact of mill processes on the effluent quality. It was completed in September 1993
by BE&K Engineering of North Carolina, Inc. and the results were presented in the
report entitled, "Wastewater Discharge Reduction Study" dated September 17, 1993.
Another process evaluation study was also conducted by JAAKKO POYRY, Inc. and
Q:\00I A\TS\Lss01 1-1

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the results were presented in the report entitled, "Wastewater Treatment System
Evaluation," dated January 4, 1991. The recommended options from these two
studies generally included installation of an additional washing equipment to
recover spent cooking liquor, installation of an evaporation system for recovered
black liquor and blowdown liquor, export of concentrated liquor to a kraft pulp mill
as a source of sodium makeup, and consideration of an incineration system for
concentrated black liquor. However, both capital and operating and maintenance
costs for the recommended options were high.
Q:` 0014-.TS\Lss01 1-2

2.0 BENCH -SCALE TREATABILITY STUDIES
2.1 OBJECTIVES
The objectives of the treatability studies were as follows:
• Evaluate the potential to improve the influent solids removal in the
primary clarifier wi' . the addition of coagulant/flocculant chemicals.
• Evaluate biological selectors to improve the biological sludge settling
characteristics by reducing the filamentous bacteria and promoting the
growth of the floc -forming bacteria in the aeration basin.
• Develop BOD removal rate constants at winter and summer temperatures
and utilize the data to evaluate potential WWTF operational changes for
winter and summer conditions.
2.2 EXPERIMENTAL METHODS
2.2.1 Jar Tests on the Raw Wastewater
Jar tests were conducted on the raw wastewater using different coagulant/flocculant
chemicals. Tests were conducted with coagulant chemicals (ferric chloride and
alum) and polymers individually and in combination in order to enhance the solids
removal from the raw wastewater. The purpose of these tests was to identify
suitable chemical(s) and their required dosages.
2.2.2 Bench -Scale Continuous Flow Treatability Study
Biological treatability studies were performed with three bench -scale continuous
flow activated sludge systems. Schematic diagrams of these systems are presented
in Figure 2-1. The three reactor systems were designated as follows:
Reactor 1 - Simulate the existing full-scale plant operation at the winter
temperature of -11°C.
Q:\oo 14\Ts\Tsso2 2-1

Feed Clarified Effluent
Aeration
Reactor Internal Clarifier
Air
REACTOR1
Feed P- P, 10 Clarified Effluent
Clarifier
Aeration
Air Reactor
Selector
Air
Return Sludge
REACTOR 2 / REACTOR 3
FIGURE 2-1
EXPERIMENTAL CONFIGURATIONS FOR
REACTORS 1, 2, AND 3
ECKENFELDER Nashville, Tennessee
Mahwah, New Jersey
INC. Greenville, South Carolina
q:\0014\ts\tsfO2Ol.ppt

Reactor 2 - Simulate the existing full-scale plant operation, with the addition of an
aerobic selector, at the winter temperature of -I I'C.
Reactor 3 - Simulate the existing full-scale plant operation, with the addition of an
anaerobic selector, at the summer temperature of —31°C.
Reactor 1 consisted of a 10-liter aeration reactor with an internal clarifier for solids -
liquid separation.
Reactor 2 consisted of an aerobic selector with a volume of approximately 100 mL,
followed by a 10-liter aeration reactor and a 2-liter external clarifier. The volume of
the aerobic selector was initially selected as 350 mL based on floc -load tests.
However, the volume was reduced to 100 mL since the absorption of COD was
almost 100 percent for the 350 mL volume.
Reactor 3 consisted of an anaerobic selector with an approximate volume of 500 mL,
followed by a 10-liter aeration reactor and a 2-liter external clarifier. The anaerobic
selector was changed to an aerobic selector with a volume of 350 mL within 4 weeks
of the start-up date since the sludge settling characteristics were very poor. The
aerobic selector was operated based on a food -to -microorganism (F/M) ratio of
approximately 10 day-1. The purpose of Reactor 3 was primarily to develop BOD
removal rate constant at the temperature of 310C and not to evaluate the sludge
settling characteristics once the anaerobic selector failed.
Mixing and oxygen for biological treatment were provided by a combination of
mechanical mixers and diffused air.
The primary clarifier effluent was used as feed to all three reactors. The primary
clarifier effluent was shipped by overnight courier, three times per week, by Alpha
personnel to ECKENFELDER INC.'s wastewater laboratory in Nashville,
Tennessee. Nitrogen as ammonium chloride and phosphorus as phosphoric acid
were added to the feed to achieve a BOD:N:P ratio of approximately 100:5:1 to
ensure adequate nutrients for biological growth. Urea and phosphoric acid were
added in the full-scale WWTF to supplement nitrogen and phosphorus. The feed
was then pumped to each reactor at a flow rate of approximately 3.4 L/day to
Q:\001 n \9'S\TSS02 2-2

provide a hydraulic retention time (HRT) of approximately 3.0 days (equivalent to
the full-scale system).
The activated sludge reactors were started on February 3, 1997 with acclimated
biomass from the Alpha WWTF and unacclimated biomass from a Nashville POTW.
Since the sludge from the Alpha WWTF contained abundant filaments, it was
chlorinated initially and then mixed with municipal sludge at a mass ratio of 50:50
to reduce the filaments. For Reactor 1, the feed was pumped directly to the aeration
reactor. For Reactors 2 and 3, the feed was pumped to the corresponding selector
where it was mixed with the return activated sludge from the external clarifier.
The aerobic selector was designed to enhance rapid biosorption of the organics so
that floc -forming bacteria were predominant in the activated sludge to provide
improved sludge settling characteristics.
The systems were monitored daily for influent flow rate, pH, and temperature. The
aeration reactor mixed liquor was monitored for mixed liquor suspended solids
(MLSS), mixed liquor volatile suspended solids (MLVSS), dissolved oxygen (DO),
and oxygen uptake rates (OUR). Microscopic examinations were performed
periodically on the mixed liquor samples. The influent (primary clarifier effluent)
and reactor effluent samples were analyzed for TSS, VSS, total carbonaceous
BOD (TCBOD), soluble carbonaceous BOD (SCBOD), total -COD (TCOD), soluble
COD (SCOD), ammonia -nitrogen (NH3-N), and ortho-phosphorus (PO4-P). Sludge
was wasted daily from the activated sludge system to maintain the desired sludge
retention time (SRT).
Batch settling tests were conducted in 1-liter graduated cylinders on the MLSS from
each reactor. During the test, the interface height in milliliters versus time was
recorded. From the settling test data, sludge volume index (SVI) and zone settling
velocity (ZSV) were determined to evaluate sludge settling characteristics.
2.3 RESULTS AND DISCUSSION
2.3.1 Jar Tests on Raw Wastewater
Various jar tests were conducted on the raw wastewater to improve solids removal
and the results are summarized in Table 2-1. The raw wastewater pH was 10.5 s.u.
Q.`.OU 1.1 :S` TSS02 2-3

TABLE 2-1
JAR TEST RESULTS FOR THE RAW WASTEWATER
Description pH
TSS
VSS
TCOD
SCOD
TBOD
SBOD
(s.u.)
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(mg/L)
Raw Wastewater
10.5
650
580
7,685
5,220
2,150 1,775
Test No. 1 - pH Adjustment with H2SO4 and
8.3
495
485
7,495
5,690
2,210 1,805
Settled (2 hr)
Test No. 2 - pH adjustment with H2SO4 + Polymer
8.3
90
83
--
--
-- --
Addition @ 1,000 mg/L and Settled (2 hr)
Test No. 3 - Ferric chloride @ 2,000 mg/L+
8.3 to 6.8
18
5
1,755
1,650
960 925
Polymer @ 5 mg/L and Settled (2 hr)
Test No. 4 - Alum @ 2,000 mg/L + Polymer @
7.7 to 5.1
115
85
2,840
2,610
1,330 --
6 mg/L and Settled (2 hr)
Test No. 5A - Ferric Chloride @ 500 mg/L +
6.6
715
475
--
--
--
Polymer @ 10 mg/L and Settled (2 hr)
Test No. 5B - Alum @ 500 mg/L + Polymer @
8.8
500
367
--
10 mg/L and Settled 92 hr)
Q:\0014\ts\tst020I
Page 1 of I

Initially, the wastewater pH was reduced from 10.5 to 8.3 using sulfuric
acid (H2SO4) and settled for 2 hours (the HRT of the primary clarifier) to evaluate
solids removal with pH adjustment only (Test No. 1). The solids removal by pH
adjustment was not significant based on the reduction from 650 mg/L to 495 mg/L.
At a polymer (Drew 2205-anionic) dosage of 1,000 mg/L, there was a significant TSS
removal from 650 mg/L to 90 mg/L (Test No. 2). However, the quantity of polymer
required would be approximately 15,000 lb/day at the design flow of 1.8 MGD,
making this treatment option cost -prohibitive. A ferric chloride (as FeC13) dosage of
2,000 mg/L followed by a polymer dosage of 5 mg/L produced very good results (Test
No. 3). The TSS was reduced from 650 mg/L to 18 mg/L and the COD and BOD
concentrations were also reduced significantly. However, the ferric chloride dosage
was too high to implement on a full-scale basis given that the quantity required
would be approximately 30,0001b/day. A similar dosage was required using alum
(as Al2(SO4)3) as a coagulant (Test No. 4); however, the TSS removal efficiency was
less. Lower, dosages of ferric chloride and alum were not effective for TSS removal.
The raw wastewater solids removal of the primary clarifier could not be improved
without adding excessive chemicals (ferric chloride) and, hence, chemical addition is
not a viable option.
2.3.2 Biological Treatability Study
The bench -scale activated sludge reactors were started on February 3, 1997. As
discussed in Section 3.0, Reactor 1 was operated as a Control to simulate the winter
operation of the existing WWTF. Reactor 2 was operated with an aerobic selector.
The volume of the aerobic selector was initially determined based on a floc load test.
Floc load is defined as the mass of available substrate per mass of biological solids
in the selector and has units of mg COD (or BOD) per g MLVSS. The results of the
floc load test are presented in Table 2-2. Based on influent degradable SCOD, a floc
load of approximately 80 mg COD/g MLVSS was initially selected at the COD
removal (by absorption) of approximately 60 percent. The volume of the aerobic
selector was calculated to be approximately 350 mL at a HRT of 15 minutes and floc
load of 80 mg COD/g MLVSS. However, this operating condition resulted in almost
100 percent COD absorption in the selector which exceeded the desired rate and,
hence, the floc load was increased to approximately 200 mg COD/g MLVSS around
February 24, 1997, and then finally to approximately 400 mg COD/g MLVSS on
Q.'.00 14\TS\7:Ss02 2-4

TABLE 2-2
FLOC LOAD TEST RESULTS
Floc Load Feed Volume T=0 SCODd T=15 SCODd SCODd Removed
(m gig) (L) (mg/L) (mg/L) N
0
0
48
0.045
338
81
76
78
0.075
563
219
61
115
0.113
848
468
45
153
0.15
1,125
601
47
225
0.225
1,688
1,137
33
Influent SCOD, mg/L 4,000
SCODr, mg/L 1,000
SCODd, mg/L 3,000
Sludge Volume, L 0.14
SCODr of biomass, mg/L 68
SCOD = Soluble COD
SCODr = Refractory COD
SCODd = Degradable Soluble COD
a:\0014\ts\tst0202.doc Page 1 of 1

March 5, 1997. At the final floc load of 400 mg COD/g MLVSS and a HRT of
15 minutes, the aerobic selector volume was selected as approximately 100 mL with
a return activated sludge (RAS) flow rate of 6.8 L/day (200 percent).
The anaerobic selector of Reactor 3 was designed, from experience, based on a HRT
of approximately 2 hours with a RAS flow rate of 3.4 L/iay (100 percent). However,
since the sludge settling characteristics started deteriorating, the anaerobic selector
with a volume of 500 mL was converted to an aerobic selector after 3 weeks of
operation, with the volume reduced to 350 mL on March 10, 1997. The Reactor 3
aerobic selector was operated based on a F/M (BOD) ratio of approximately
10.0 day-1. Reactor 3 was operated primarily to develop BOD removal rate constant
at summer temperature (31°C).
All three reactors were operated for a period of approximately 2 months from
February 3 to April 3, 1997. The reactors reached steady-state condition based on
three sludge retention times (_30 days) during the first 4 weeks of the study. The
data collected from March 3 to March 27, 1997 were utilized for the performance
evaluation. The complete results of the influent characteristics, operating
conditions, and effluent quality achieved are presented in Appendix B.
2.3.2.1 Influent Wastewater Characteristics. A summary of the influent
characteristics to Reactors 1, 2, and 3 during the treatability study is presented in
Table 2-3. The average influent TCBOD and TCOD concentrations were 1,278 mg/L
and 4,870 mg/L, respectively. The average TSS and VSS concentrations were
300 mg/L and 270 mg/L, respectively. Based on a limited number of data points (8),
the particulate BOD (PBOD) contributed by influent VSS was determined to be
approximately 1.24 mg BOD/mg VSS, assuming a negligible amount of soluble
organics absorption in the influent VSS. The average influent TDS concentration
was 6,830 mg/L.
2.3.2.2 Reactor Operating Conditions. The operating conditions for Reactors 1,
2, and 3 are summarized in Table 2-4. For the majority of time, the mixed liquor
DO concentration was maintained between 3.0 mg/L and 7.0 mg/L for all reactors.
The SRT of Reactors 1 and 2 was maintained at approximately 10 days and
Reactor 3 at approximately 5 days. The SRT for each reactor was calculated using
Equation (2-1).
r

TABLE 2-3
INFLUENT CHARACTERISTICS DURING THE
BENCH -SCALE TREATABILITY STUDY
Number of
Parameter Range Average Data Points
pH, s.u.
8.2 to 9.0
--
--
TCBOD, mg/L
750 to 1,974
1,278
12
TCOD, mg/L
3,300 to 7,350
4,870
12
TSS, mg/L
100 to 510
300
12
VSS, mg/L
96 to 460
270
12
PBOD/VSS, Ratio
-
1.24
8
TDS, mg/L
5,540 to 8,420
6,830
3
QA00I4ALv\Ls10203 Page I of 1

TABLE 2-4
REACTOR OPERATING CONDITIONS
F/M Ratio, (day-1)
Description pH Temp MLSS MLVSS HRT SRT OUR BOD COD
(S-u) (°C) (mg/L) (mg/L) (day) (day) (mg/L-hr) Basis Basis
Reactor 1
Average
-
11
2,485
2,350
2.94
10.7 29.6 0.19 0.70
Minimum
8.2
10
1,950
1,800
2.78
- 20.0 - -
Maximum
9.2
12
3,050
2,850
3.47
- 40.0 - -
Reactor 2
Average
-
11
2,860
2,710
2.94
10.5 24.6 0.16 0.61
Minimum
8.6
10
2,050
2,050
2.67
- 17.0 - -
Maximum
9.1
12
3,250
3,000
3.31
- 32.0 - -
Reactor 3
Average
-
31
1,400
1,360
2.94
5.0 21.8 0.32 1.22
Minimum
8.8
29
900
850
2.67
- 15.0 - -
Maximum
9.5
32
2,600
2,450
3.65
34.0
Q:\0014\ta\t9t0204
Page 1 of 1

SRT = Vr•X
Qw' X + Qe' Xe
where:
Vr = volume of the aeration reactor, L
X = mixed liquor suspended solids, mg/L
Qw = waste flow rate (from aeration reactor), L/day
Qe = effluent flow rate, L/day
Xe = effluent TSS, mg/L
(2-1)
2.3.2.3 Performance Characteristics and Kinetic Coefficients. The effluent
characteristics from Reactor 1, Reactor 2, and Reactor 3 are presented in Tables 2-5
through 2-7. The average process coefficients and settling characteristics for each
reactor are presented in Table 2-8.
The effluent SCOD was generally high due to a significant amount of non-
degradable organics. The SCBOD was generally less than 30 mg/L. Based on
limited data, the average effluent PBOD/VSS ratio for Reactor 1, Reactor 2, and
Reactor 3 was 0.5, 0.4, and 0.2, respectively.
The average BOD removal rate coefficients (KBOD) were determined using
Equation (2-2).
So (So - Se)
KBOD = Xv ' t ' Se
where:
KBOD = complete mix reaction rate coefficient, day-1
So = influent BOD concentration, mg/L
Se = effluent SBOD concentration, mg/L
Xv = mixed liquor volatile suspended solids concentration, mg/L
t = hydraulic retention time, day
Q \0014\TS\TSS02 2-6
(2-2)

TABLE 2-5
REACTOR 1 EFFLUENT CHARACTERISTICS
Number of
Parameter Range Average Data Points
pH, s.u.
8.9 to 9.3
--
--
SCBOD, mg/L
18 to 39
27
11
SCOD, mg/L
1,425 to 2,620
2,060
12
TSS, mg/L
12 to 74
28
12
VSS, mg/L
8 to 68
26
12
PBOD/VSS, ratio
--
0.5
6
TDS, mg/L
5,340 to 7,120
6,190
3
Q:\0014\t4\0=05 Page 1 of 1

TABLE 2-6
REACTOR 2 EFFLUENT CHARACTERISTICS
Number of
Parameter Range Average Data Points
pH, s.u.
8.9 to 9.2
--
--
SCBOD, mg/L
10 to 26
19
12
SCOD, mg/L
1,435 to 2,430
1,855
12
TSS, mg/L
10 to 68
29
12
VSS, mg/L
8 to 66
26
12
PBOD/VSS, ratio
0.4
8
TDS, mg/L
5,340 to 7,080
6,070
3
Q:\00141,0MA0206 Page I of 1

TABLE 2-7
REACTOR 3 EFFLUENT CHARACTERISTICS
Parameter
Range
Average
Number of
Data Points
pH, s.u.
8.2 to 9.5
--
--
SCBOD, mg/L
5 to 19
10
12
SCOD, mg/L
1,590 to 2,880
2,020
12
TSS, mg/L
24 to 1,880
285
12
VSS, mg/L
16 to 1,700
260
12
PBOD/VSS, ratio
--
0.2
6
TDS, mg/L
7,140 to 8,860
7,900
3
Q:\00I4\ts\L4t02O7 Page I of I

TABLE 2-8
AVERAGE PROCESS COEFFICIENTS
Parameter
Reactor 1
Reactor 2
Reactor 3
KBOD, day-1
8.7 @ 110C
10.6 @ 110C
40.4 @ 310C
fobs, mg TSS/mg BODR
0.54
0.64
0.65
a, mg VSS/mg BODR
0.79
0.92
0.96
a, mg VSS/mg CODR
0.35
0.38
0.43
a', mg 02/mg BODR
1.64
1.36
1.20
a', mg 02/mg BODR
1.29
0.94
0.75
a', mg 02/mg CODR
0.58
0.39
0.33
SVI, mL/g TSS
180
90
--
ZSV, Whr
2.4
4.3
--
Q:\00I4'\ts\L%tO2O8 rage I of I

The average KBOD values for Reactor 1 and Reactor 2 at approximately 11°C were
8.7 day-1 and 10.6 day-1, respectively. The average KBOD for Reactor 3 at
approximately 31°C was 40.4 day-1. These BOD removal rate coefficients correlated
well to the different operating temperatures (11°C and 31°C). KBOD can be
estimated as a function of temperature in the range of YC to 32°C using
Equation (2-3).
KT2 = Ki 0T2-Ti
where:
KTi = reaction rate coefficient at temperature T1(°C), day-1
KT2 = reaction rate coefficient at and temperature T2(°C), day-1
0 = temperature correction coefficient
(2-3)
The temperature correction coefficient, 0, was determined to be 1.071 using
Reactor 2 and Reactor 3 KBOD5 for this wastewater.
The observed average sludge production rate (Yobs) was calculated based on the
average daily MLSS mass wastage rate, the mass of effluent TSS, and the measured
average BOD removal. This coefficient represents the "net" sludge yield for the
system rather than the "gross" yield from which the endogenous decay must be
deducted based on the operating SRT and HRT conditions. The term Yobs is unique
to the selected operating conditions of the bench -scale study. The results of
calculation of Yobs for the reactors are presented in Table 2-8. The "gross" biomass
yield coefficient (a) was also calculated using Equation (2-4).
OXv=aSr- bXdXvt
where:
a = gross biomass yield coefficient, mg VSS/mg BOD (or COD)
Sr = BOD or COD removed, mg/L
OXv = volatile suspended solids produced and wasted per day, mg/L
b = endogenous decay coefficient, day-1
= 0.1 at 200C
(2-4)
(2 ',00 I4 \T.S\TSS02 2-7

Xd = biodegradable fraction of biomass
The degradable fraction of the volatile biomass (Xd) was calculated using
Equation (2-5).
0.8
Xd-1+0.2b0c
where:
0c = sludge retention time, day
(2-5)
The endogenous decay coefficient (b) was corrected for the operating temperatures
of each reactor using Equation (2-6).
bT = b20-C x 1.04(T-20) (2-6)
The results of calculation of "gross" biomass yield coefficients (a) for each reactor in
terms of both BOD and COD are presented in Table 2-8. Using this sludge yield
coefficient (a), the "net" sludge production for any operating condition, such as SRT
and HRT, can be calculated.
The oxygen utilization rate by the biomass is the sum of the oxygen required for
substrate (BOD/COD) removal (energy oxygen) plus that required for cell
maintenance. This can be combined under a single kinetic coefficient designated
herein as a'. Term a', like the Yobs term, is unique to the operating conditions of the
bench -scale reactor. The coefficient a' was determined using Equation (2-7).
OURx24xV
a'= QoxSr
where:
a' = overall oxygen utilization rate, mg 02/mg BODR,
OUR = oxygen uptake rate, mg/L • hr
Vr = volume of aeration reactor, L
Q',001a1: SASSoz 2-8
(2-7)

Qo = average influent flow rate, L/day
Sr = as defined for Equation (2-4)
The results of the calculation of a', based on average BOD and COD values, are
presented in Table 2-8. The combined oxygen demand is typically expressed by
separate coefficients (a' for energy oxygen and b' for endogenous oxygen). These a'
and b' coefficients were also calculated for each reactor using Equation (2-8).
02 = a'Sr + b' Xd Xv t (2-8)
where:
02 = oxygen requirement, mg/L
a' = oxygen utilization coefficient for BOD or COD removal,
mg 02/mg BODR, or CODR,
b' = 1.4 b
The a' values for each reactor are presented in Table 2-8. Using the a' value, the
oxygen requirement can be calculated for any organic loading and operating
conditions. For Reactors 1 and 2, the oxygen consumption rates were approximately
equal if the oxygen consumed in the aerobic selector is incorporated. The oxygen
uptake rate in the aerobic selector of Reactor 2 (volume 100 mL) was approximately
560 mg/L • hr. The oxygen uptake rate in the aerobic selector of Reactor 3 (volume
350 mL) was approximately 85 mg/L•hr.
-- 2.3.2.4 Sludge Settling Characteristics. The sludge settling characteristics
were very good for Reactor 2 with aerobic selector. The average SVI and ZSV for
Reactor 1 and Reactor 2 are presented in Table 2-8. The SVI for Reactor 2 was
consistent throughout the study period, generally in the range of 70 to
100 mL/g TSS with an average value of 90 mL/g TSS. The SVI for Reactor 1
generally varied from 140 to 285 mL/g • TSS with an average value of
180 mL/g • TSS. Reactor 1 had abundant filaments and settled as clumps. The
aerobic selector controlled the excessive growth of filaments effectively in Reactor 2.
As discussed previously, the sludge settling characteristics of Reactor 3 were poor
with anaerobic selector and the purpose was only to develop kinetic coefficients at
(I ooia 'i:S 'rssw 2-9

A
I
summer temperature. Hence, the SVI and ZSV values were not presented in
Table 2-8.
2.3.2.5 Observations During Treatability Study. Significant observations of
the reactors during the treatability study are presented below:
• The Reactor 1 (Control) mixed liquor solids were generally slimy in nature.
The Reactor 2 and Reactor 3 mixed liquor solids were normal.
• Based on the microscopic examination, Reactor 1 had an abundant filament
population compared to a common filament population in the other two
reactors.
• Reduced to negligible foaming occurred in Reactor 2 with aerobic selector
compared to the other two reactors. Intermittent addition of defoamer was
required for Reactor 1 and Reactor 3.
2.3.2.6 Primary Solids Digestion. The primary solids digestion test was
conducted in a one -liter reactor at room temperature (20°C) using a mixture of
primary solids (60 percent) and biomass (40 percent) under aerobic conditions. The
test was conducted for a period of 11 days (approximate SRT of the full-scale
WWTF). The reactor content was sampled daily and analyzed for TSS and VSS.
The initial TSS and VSS concentrations of the reactor content were 2,550 mg/L and
2,440 mg/L, respectively. The test liquid TSS and VSS concentrations at 11 days
were 780 mg/L and 700 mg/L, respectively. Figure 2-2 shows the TSS and VSS
concentrations with time. The overall volatile solids digestion was approximately
70 percent after 11 days at 20°C. This indicates that some portion of primary solids
could be digested in the aeration basin depending on the temperature and SRT.
2.4 CONCLUSIONS
Based on the bench -scale treatability study results, the following conclusions were
developed:
• The influent wastewater solids removal could not be improved in the
primary clarifier without using excessive amounts of coagulant chemical
Q ,00H •rs\TSS02
2-10

3000
2500
2000
a
1500
N
1000
500
N
0 1 2 3 4 5 6 7 8 9 10 11 12
Time, days
Figure 2-2. Results of Aerobic Solids Digestion Test
H:\0014\batch

such as ferric chloride. The quantity of ferric chloride required would be
too high to implement on a full-scale basis making this treatment option
cost -prohibitive.
• BOD removal rate coefficients correlated very well to temperature at the
two different operating temperatures (11°C and 31°C). The temperature
correction coefficient (0) was calculated to be 1.071 for this wastewater.
• The observed sludge yield coefficients were about the same for all three
reactors.
• The oxygen consumption rates were about the same for Reactors 1 and 2 if
the oxygen consumed in the aerobic selector is incorporated.
• The sludge settling characteristics were very good throughout the study
period for Reactor 2 with an aerobic selector. The aerobic selector
controlled the excessive growth of filaments effectively. The control reactor
without a selector had abundant filaments.
• Based on the aerobic digestion test results of primary solids, a portion of
primary clarifier effluent solids could be digested in the aeration basin
depending on the temperature and SRT.
Q:\0014\TS\TSS02 2-11

3.0 PROPOSED PLANS FOR WWTF MODIFICATIONS
Based on the conclusions of the WWTF evaluation and the results of the bench -scale
treatability studies, the following recommendations are made to upgrade the
existing WWTF and improve its performance.
Opportunity No. 1. Reduced Biological Activity During Winter Months
Proposed Modification: Construct an aerobic selector with a volume of
approximately 56,500 gallons prior to the aeration basin to control filamentous
bacteria and improve sludge settling in the clarifier. The volume of the
selector was calculated based on a HRT of 15 min, wastewater flow of
1.8 MGD, and a sludge recycle rate of 200 percent (3.6 MGD). The improved
sludge settling characteristics that are expected with the installation of an
aerobic selector will allow the solids level in the aeration basin and solids
loading rate on the secondary clarifiers to be increased. A higher solids level
in the aeration basin will be used to achieve better BOD removal performance
in winter months.
Opportunity No. 2. Periodic Floating Solids from the Secondary Clarifiers
Proposed Modification: Provide surface skimmers for the secondary
clarifiers to remove periodic floating solids and process these solids along with
the waste sludge. This will reduce the periodic excess solids carryover in the
clarifier effluent and reduce the potential for exceedances of daily maximum
discharge limits for TSS and BOD. This will also help prevent exceedances of
the monthly average limits.
Opportunity No. 3. Reduction in Aeration Basin Biomass During
Production Restarts Following Extended Shut -down Periods
Proposed Modification: In order to improve the BOD removal during
production restarts following the production plant shut -down, the MLSS needs
to be increased in the aeration basin prior to production plant shut -down
without overloading the secondary clarifier. If this approach proved to be
Q:\oo»'.u, L403 3-1

ineffective, an external carbon source such as methanol could be added to
provide food for the biomass during production plant shut -down.
A preliminary process flow diagram of the existing WWTF with proposed
modifications is shown in Figure 3-1.
L j:\OO 14 \L.4\Les03 3-2

Primary Primary Pn
Basin Clarifier A
S1
Wastewater
-► -�,
Secondary
Clarifiers
(New Skimmers Proposed)
Waste Sludge

4.0 PREDICTED EFFLUENT QUALITY
RESULTS AND UNCERTAINTIES
The process coefficients developed from the bench -scale treatability studies were
used to predict the final effluent quality at various operating conditions. The
required operating conditions for winter and summer months to theoretically
achieve the final effluent BOD and TSS concentrations to below the permit limit
values were also defined.
4.1 WINTER OPERATION
In winter months, the MLSS levels in the aeration basin should be increased due to
the lower BOD removal rate at lower temperature. The following example
illustrates the required MLSS concentration to achieve a target effluent BOD
concentration.
Primary clarifier effluent flow =
1.8 MGD
Primary clarifier effluent BOD =
1,500 mg/L
Aeration basin temperature =
11°C
Aeration basin hydraulic retention time (t) =
3.0 day
BOD removal rate constant (KBOD) =
10.6 day-1 at 110C
Target final effluent BOD =
30 mg/L
Final effluent TSS =
27 mg/L
Final effluent VSS =
24 mg/L
PBODIVSS ratio =
0.4
PBOD due to effluent VSS =
0.4 x 24
10 mg/L
Required effluent SBOD =
30 - 10
=
20 mg/L
Factor of Safety =
1.25
Target effluent SBOD =
1225 = 16 mg/L
Equation (2-2) can be used to determine the required theoretical mixed liquor
volatile suspended solids (MLVSS) concentration to achieve the effluent SBOD of
16 m g/L.
Q\oo 14 \ts\Gve04.doc 4-1

MLVSS (XV)
Xv
SO (So - Se)
KBOD-t-Se
1,500 (1,500 - 16)
10.6 x 3.0 x 16
4,375 mg/L
Mixed liquor suspended solids (MLSS) = 4,375
0.9
4,860 mg/L
Hence, if the aeration basin MLSS is maintained at approximately 4,860 mg/L, the
predicted effluent BOD concentration will potentially be less than the winter
monthly average permit limit value of 30 mg/L.
The solids loading on the clarifiers at
100 percent RAS
The total surface area of three
clarifiers
Solids loading rate on the clarifiers
4,860 mg/L x 8.34 x
(1.8 + 1.8) MGD
= 145,920lb/day
7,575 ft2
145,920 1h.day
7,575 ft2
19.3 lb/d • ft2
The solids loading rate of 19.3 lb/d • ft2 is acceptable for a good settling sludge. It is
anticipated that the effluent TSS concentration will potentially be less than the
monthly average permit limit value of 27 mg/L.
If the aeration basin mixed liquor temperature is 15°C, then the KBOD at this
temperature can be calculated using Equation (2-3) as follows:
Q; \0014`.Ly\tss04.dm 4-2

K150C = 10.6 x 1.07115-11
= 14.0 day-1
The required theoretical MLSS concentration in the aeration basin at 15°C would be
approximately 3,680 mg/L to achieve the effluent SBOD of 16 mg/L. The solids
loading rate on the clarifiers would be approximately 14.6 lb/day • ft2. In this
manner, the required MLSS can be calculated for any operating conditions using the
Equations (2-2) and (2-3).
4.2 SUMMER OPERATION
In summer months, the MLSS levels in the aeration basin can be reduced due to
higher BOD removal rates at the higher temperature. The required theoretical
MLSS concentration in the aeration basin at the mixed liquor temperature of 31°C
and KBOD of 40.4 day-1 would be approximately 2,280 mg/L to achieve a target
effluent SBOD of 9.0 mg/L. At the mixed liquor temperature of 25°C, the KBOD
would be 27.8 day-1 and the required theoretical MLSS would be approximately
3,300 mg/L to achieve the effluent SBOD of 9.0 mg/L. The predicted effluent BOD
concentration for the above operating conditions will potentially be less than the
summer monthly average permit limit value of 22 mg/L.
4.3 OPERATION OF WWTF DURING PRODUCTION PLANT SHUT -DOWNS
Prior to production plant shut -downs, the level of MLSS in the aeration basin
should be increased by reducing the wasting without overloading the secondary
clarifier. This will allow presence of sufficient biomass in the aeration basin when
the production starts again. However, significant solids digestion will occur in the
basin. This is critical, especially in winter months due to lower BOD removal rates
at lower temperatures. If this approach proved to be ineffective, an external carbon
source, such as methanol, can be added to the aeration basin to provide food for the
biomass during the production plant shutdown. This will reduce the solids
(biomass) digestion in the aeration basin and help to maintain adequate biomass
concentration to treat the wastewater when production restarts. The quantity of
methanol required would be approximately 13,000lb/day at the MLSS
concentration of 5,000 mg/L and a F/M ratio of 0.05 day-1 (BOD basis).
Q\oo 14\Lv,UsA4.auc 4-3

Predictions are that these operational changes will improve the performance of the
WWTF following production plant shut -downs and reduce the effluent BOD
concentrations to below the permit limit values. However, the above operating
scenarios need to be further evaluated, especially during winter months after the
WWTF modifications.
4.4 UNCERTAINTIES IN WWTF PERFORMANCE
The proposed WWTF operational changes and modifications were based on the
results of the WWTF evaluation and bench -scale treatability studies. These
changes are expected to improve the performance of the WWTF and provide final
effluent BOD and TSS concentrations that are consistently below the permit limit
values. However, although the performances objectives were achieved in the bench -
scale reactor system, the effectiveness of the aerobic selector in controlling
filamentous bacteria must be verified in full-scale WWTF after modifications have
been implemented. The concept of MLSS buildup in the aeration basin prior to
production plant shut -downs to improve the WWTF performance upon production
restarts also needs to be demonstrated.
There were limitations in using a bench -scale treatment system to simulate
modifications to the full-scale WWTF. First, the bench -scale treatability studies
were conducted under controlled winter and summer temperatures of 11°C and
31°C, respectively. However, the full-scale system experiences daily variations in
temperature depending on the ambient conditions. Second, the influent
characteristics to the bench -scale reactors were constant over a period of 24 to
48 hours, whereas, the WWTF influent characteristics can vary on an hourly basis..
These uncertainties may affect the predicted effluent quality.
Q\0014 \L%\ Lm04.do 4-4

5.0 IMPLEMENTATION AND EVALUATION SCHEDULE
The proposed project implementation schedule is shown in Figure 5-1. This
schedule is consistent with the SOC time schedule and allows approximately
10 months to evaluate the performance of the WWTF (after completion of the
proposed modifications) prior to the NPDES permit compliance date of May 31,
1999. This evaluation period should allow adequate time to assess the effectiveness
of the proposed modifications and the appropriateness of the existing NPDES permit
limits. After all, this WWTF is already delivering BOD reduction efficiencies that
are among the best, if not the best, in the pulp and paper industry (Figure 1-1).
Q\OO I A\L%\LvaOCLdoc 5-1

ALPHA CELLULOSE CORPORATION
--- -
1997 - 1998 199V —_-- - -- ��-----_-200d
MAY JUN JUL AUG SEP OCT NOV DEC JAN FEBMAR APR MAY JUN JUL AUG SEP OCT NOV DECJANFEBMAR APR MAY JUNJULAUG -SEP OCT NOVDEC"JAN FEBMAR APR MAY JUN JUL AUG E
ENGINEERING
BUCKEYE TO SUBMIT REPORT & PLANS TO STATE
p BUCKEYE TO SUBMIT PLANS FOR MOD. TO STATE
STATE REVIEW OF REPORT & PLANS FOR MODIFICATIONS
♦ STATE APPROVAL
-----
DESIGN
�► SUBMIT AUTHORIZATION TO CONSTRUCT
♦ RECEIVE AUTHORIZATION TO CONSTRUCT
,PROCUREMENT
PUMPS
-- ---
----------------- -
- - ---- --- --------------------
PIPING
VALVES
j BLOWERS
. AERATION SYSTEM
CLARIFIER PARTS
- - ----- - - -- - - —
CONSTRUCTION
jL MOBILIZATION
jft SITEWORK
jmmmft CONCRETE
jpM YARD PIPING
jft PROCESS PIPING
jmmft EQUIPMENT
jmmoft ELECTRICAL
j& START-UP
jL DEMOBILIZATION
♦ COMPLETE CONSTRUCTION
EVALUATE MODIFICATIONS
♦ COMPLY WITH NPDES PERMITS
* NPDES PERMIT EXPIRES
Early start point
A
Progress point
Early finish point
A
Critical point
Early bar
)
Summary point
Progress bar
<
Start milestone point
Critical bar
Finish milestone point
Summary bar
* OR
NEft NETOTIATE FINAL NPDES PERMIT LIMITS -IF REQUIRED
♦ COMPLY WITH NPDES PERMIT LIMITS
ALPHA CELLULOSE CORPORATION
IMPLEMENTATION AND EVALUATION SCHEDULE
FIGURE 5-1
Date Revision Checked Approved

APPENDIX A
SPECIAL ORDER BY CONSENT
(January 24, 1997)

State of North Carolina
Department of Environment,
Hey lth and Natural Resources 4K4
Division of Water Quality
1 James B. Hunt, Jr., Govemor
Jonathan B. Howes, Secretary � � ■ ■
A. Preston Howard, Jr., P.E., Director I 1
IJanuary 24, 1997
Wayland W. McAllister
Alpha Cellulose Corporation
P. O. Box 1305
Lumberton, North Carolina 28359
Subject: Special Order by Consent
EMC SOC WQ 96-04
Robeson County
NPDES Permit NC0005321
Dear Mr. McAllister:
Attached for your records is a copy of the signed Special Order by Consent approved by the
Environmental Management Commission.
The terms and conditions of the Order are in full effect, and you are reminded that all final
permit limits contained in the permits must be met except those modified by the conditions of the
Order.
If you have questions concerning this matter, please contact Bob Sledge at [phone] ext.
233.
Sinc rely,
A. Preston Howard, Jr., P. E.
Attachment
cc: Fayetteville Regional Office
Mike Hom, EPA
Jimmie Overton
Robert Farmer
SOC Files
Central Files
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

1j,
NORTH CAROLINA
ENVIRONti1ENTAL MANAGEMENT COti1MISSION
COUNTY OF ROBESON
Lv THE MATTER OF
NORTH CAROLINA
NPDES PERMIT
NUMBER NC0005321
HELD BY ALPHA CELLLZOSE
SPECLAL. ORDER BY CONSENT
EMC SOC 96-04
Pursuant to provisions of North Carolina General Statute (G.S.) 113-" 15.2. this Special Order by
Consent is entered into by Alpha Cellulose Corporation, hereinafter referred to as a Company, and
the North Carolina Environmental Management Commission, an agency of the State of North
Carolina created by G.S. 14-,B-282, and hereinafter referred to as the Commission:
1. The Company and the Commission hereby stipulate the following:
(a) That the Company holds North Carolina NPDES Permit Number NC0005321 for
operation of an existing wastewater treatment works and for makin- an outlet therefrom for
treated wastewater to the Lumber River, Class "C-Swamp" waters of this State in the
Lumbar River Basin, but is unable to consistently comply with final effluent limitations for
BOD and TSS as set forth in NPDES Permit Number NC0005321. Compliance will
require a thorough evaluation of the treatment works and implementation of those methods
mi
or changes deterned necessary to achieve compliance.
(b) Noncompliance with final effluent limitations constitutes causing and contributing to
pollution of the waters of this State named above, and the Companv is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143, Article 21.
(c) S ince this Special Order is by Consent, neither party will file a petition for a contested
case or for judicial review concerning its terms.
2 The Company desiring to comply with the Permit identified in paragraph 1(a) above,
hereby agrees to do the following:
(a) Comply with all terms and conditions of the Permit except those effluent limitations
identified in paragraph 1(a) above. See Attachments A, B, and C for all current monitoring
requirements and effluent limitations. The Permittee may also be required to monitor for
other parameters as deemed necessary by the Director in future permits or administrative
letters.

1 i J
I
(b) Undertake the following activities in accordance with the indicated time schedule:
l) Alpha Cellulose has the winter of 1996 through ivlarch 311, 1997, to
evaluate its production process and treatment system and to perform such
pilot studies as may be necessary to test/analyze any change or modification
needed to achieve compliance.
2) Alpha Cellulose will submit a report and/or plans for modifications or
additions by May 31, 1997.
3) DWQ will complete the review of the materials submitted by August 31,
1997. If the evaluation and studies required in item 2(b)(1) conclude the
defined permit limits are not technologically or economically achievable,
DWQ will consider a modification of the permit limits consistent with
existing water quality standards upon proper permit modification
application.
4) Alpha Cellulose will submit all necessary requests for an Authorization
to Construct by January 1, 1998.
5) Alpha Cellulose will complete all required construction by November
30, 1998.
6) Alpha Cellulose will comply with Final NPDES permit limits by May
31, 1999.
(c) During the time which this Special Order by Consent is effective, comply with the
interim effluent limitations contained in Attachment A which, for convenience, have been
set forth below:
Permit Limitsl SOC Modified Limits (Attachment A)
Parameters Unit Monthly Avg. Daily Max. Monthly Avo. Daily Max.
BOD (summer) lbs/day 332 664 415 830
BOD (winter) lbs/day 450 900 563 1125
TSS (summer) lbs/day 425 850 738 1476
TSS (winter) lbs/day 425 850 738 1476
(d) No later than fourteen (14) calendar days after any date identified for accomplishmei
of anv activity listed in 2(b) above submit to the Director of the North Carolina Divisior
%Varer Quality (DWO) wntten notice of compliance or noncompliance therewith In the
case of noncompliance the notice shall include a statement of the reason(s) for
noncompliance, remedial action(s) taken and a statement identifying the extent to which
subsequent dates or times for accomplishment of listed activities may be affected
IA permit modification request is pending.

3. The Company agrees that unless excused under paragraph four (4), the Company will pay
the Director of DWQ, by check payable to the North Carolina Department of Environment,
Health and Natural Resources, according to the following schedule for failure to meet
the deadlines set out in paragraphs 2(b) and 2(d), or failure to attain compliance with
the effluent limitations/monitoring requirements contained in Attachments A, B, C, and D.
Failure to meet a schedule date
Failure to maintain compliance with
any modified limit contained in the SOC.
Failure to achieve compliance with
limitations at final compliance
deadline
S 100/dav for the first
7 days: 5500/day
thereafter
S 1000/ monthly violation
5250/da0y violation
310,000
Monitoring frequency violations 5100 per omitted value
per parameter
Monitoring frequency violations for Toxicity 51,000 per omitted value
Failure to submit progress reports S50/day for the first 7
days; S250/day thereafter
4. The Comoanv and the Commission agree stipulated penalties are not due if the Company
satisfies the Division of Water Quality noncompliance was caused solely by:
a. An act of God;
b. An act of war;
C. An intentional act or omission of a third party but this defense does not apply if the act or
omission is that of an employee, agent, or contractor of the Company ;
d. An extraordinary event beyond the Company's control. Contractor delays or failure to
obtain funding will not be considered as events beyond the Company's control; or
e. Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand to pay the penalties, or
challenge them by a contested case petition pursuant to G.S. 150B-23, will be grounds for
a collection action, which the Attorney General is hereby authorized to initiate. The only
issue in such an action will be whether the thirty (30) days has elapsed.
5. Noncompliance with the terms of this Special Order by Consent is subject to enforcement
action seeking injunctive relief pursuant to G.S. 143-215.6.(C).

n
J
6. This Special Order by Consent and any terms, conditions, and interim effluent limitations
contained herein, hereby supersede any and all previous Special Orders, Enforcement
Compliance Schedule Letters, terms, conditions, and limitations contained therein issued in
connection with NPDES Permit No. NC0005321. In the event of an NPDES Permit
' modification or renewal, any effluent limitations or monitoringanrequirements contained
therein shall supersede those contained in Attachments A, B, d C of this Special Order
by Consent, except as modified and contained in paragraph 2(c) above.
7 • The Company, upon signature of this Special Order by Consent, will be expected to
comply with all schedule dates, terms, and conditions of this document.
g This Special Order b o bal o ire ugu -3I 1999.
For Alpha Cellulose
GrJ��,G4,vo /•.) wit ZI
Print Name and Title of Signing Official
ign re of Signing Official Dace
For the i o Caroli. a Environmental Management Commission
1,57
Date
ptlCha=* an of the Conunissio,

11
1
LI
APPENDIX B
IRESULTS OF THE BENCH -SCALE TREATABILITY STUDY
I
+.,00in•.ls uMvr

1
INFLUENT CHARACTERISTICS
Alpha/Buckeye Cellulose Corporation
Date
pH
TBOD
SBOD
TCOD
SCOD
TSS
VSS
TDS
sm.
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
2-Feb-97
3-Feb-97
4-Feb-97
5-Feb-97
6-Feb-97
7-Feb-97
8-Feb-97
9-Feb-97
10-Feb-97
4740
3510
11-Feb-97
8.1
12-Feb-97
8.3
13-Feb-97
8.3
1387
1017
4200
3560
255
245
6260
14-Feb-97
8.3
15-Feb-97
8.2
16-Feb-97
8.2
17-Feb-97
8.4
5170
4030
295
280
6840
18-Feb-97
8.3
19-Feb-97
8.4
1092
782
20-Feb-97
8.6
1 1358
1048
1 3580
3060
213
1 193
6440
21-Feb-97
8.5
22-Feb-97
8.5
23-Feb-97
8.5
24-Feb-97
8.7
1 1425
1080
3840
3560
160
140
25-Feb-97
8.7
26-Feb-97
8.9
4030
3150
256
244
27-Feb-97
9.1
1080
810
5600
28-Feb-97
8.7
1165
3510
200
188
1-Mar-97
8.6
2-Mar-97
8.7
3-Mar-97
8.4
1225
4530
230 1
215
4-Mar-97
8.2
5-Mar-97
8.9
980
715
4530
3795
360
325
6-Mar-97
9.0
7-Mar-97
9.0
790
4270
355
330
h: \ 0014 \ bench \ INFTWO.XLS

INFLUENT CHARACTERISTICS
Alpha/Buckeye Cellulose Corporation
Date
pH
TBOD
SBOD
TCOD
SCOD
TSS
VSS
TDS
s.u.
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
8-Mar-97
8.4
9-Mar-97
8.6
10-Mar-97
8.5
750
3560
270
235
11-Mar-97
8.3
12-Mar-97
8.3
1180
900
3580
3080
100
96
5540
13-Mar-97
8.4
14-Mar-97
8.7
935
3300
260
230
15-Mar-97
8.5
16-Mar-97
8.5
17-Mar-97
8.5
1214
4340
250
245
18-Mar-97
8.7
19-Mar-97
8.5
1260
1080
4295
3560
215
200
6520
20-Mar-97
8.9
21-Mar-97
8.5
1610
6355
350
300
22-Mar-97
8.7
23-Mar-97
8.9
24-Mar-97
8.9
1516
6640
510
460
25-Mar-97
8.7
26-Mar-97
8.3
1974
1554
7350
5810
425
380
8420
27-Mar-97
8.3
1905
1
5690
270
240
28-Mar-97
8.5
29-Mar-97
8.4
30-Mar-97
8.5
31-Mar-97
8.2
2070
7070
405
370
1-Apr-97
8.6
2-Apr-97
8.8
1630
1080
6880
4790
500
445
3-Apr-97
8.7
4-Apr-97
8.4
1218
4745
325
300
Average
8.6
1278
1062
4870
4061
300
271
6827
Min
8.2
750
715
3300
3080
100
96
5540
Max
9.0
1974
1554
7350
5810
510
460
8420
STD
0.2
403
360
1321
1203
107
95
1464
Count
25
12
4
12
4
12
12 1
3
h: \ 0014 \ bench \ INFTWO.XLS

Wd
REACTOR 1 (CONTROL) TREATABILITY DATA
Alpha/Buckeye Cellulose Corporation
Effluent
Date
Inf. Flow
pH
TBOD
SBOD SCOD
NH3-N
TSS
VSS
TDS
ml/min
sm.
mg/L
mg/L mg/L
mg/L
mg/L
mg/L
mg/L
2-Feb-97
2.4
8.8
3-Feb-97
2.4
8.9
4-Feb-97
2.4
8.9
5-Feb-97
2.4
8.8
6-Feb-97 1
2.5
8.8
1
28
1708 1
15
12
6820
7-Feb-97
2.4
8.8
8-Feb-97
2.2
8.7
9-Feb-97
9.2
10-Feb-97
2.4
9.2
26
20
11-Feb-97
2.4
8.9
12-Feb-97
2.4
8.9
13-Feb-97
2.5
8.8
32
24
1803
17
6
5
6180
14-Feb-97
2.5
9.0
15-Feb-97
2.4
8.9
16-Feb-97
9.0
17-Feb-97
9.1
1719
12
12
18-Feb-97
2.5
9.0
19-Feb-97
2.6
9.0
45
33
20-Feb-97
2.4
8.9
27
21
1743
14
32
29
6300
21-Feb-97
2.5
8.8
22-Feb-97
2.3
8.8
23-Feb-97
9.0
24-Feb-97
2.6
8.9
60
34
1803
28
22
25-Feb-97
8.9
26-Feb-97
8.9
2372
256
244
27-Feb-97
2.7
9.3
5780
28-Feb-9 7
2.6
9.3
47
1800
1.7
90
88
Basin
ED.O.
mg/L
pH
S.U.
Temp
°C
MLSS
mg/L
MLVSS
mg/L
ZSV
ft/hr
SVI
ml/g
OUR
mg/L-hr
SOUR
m 02
Wastage
Liter
gm VSS -hr
4.5
8.7
19
4.4
8.7
19
4.7
8.7
1.8
6.2
8.6
0.7
5.8
8.6
15
4700
3920
30
7.7
1.0
5.7
8.6
4250
0.8
176
1.0
6.9
8.6
1.0
6.3
8.8
14
1.0
7.5
9.0
11
4620
3960
1.1
140
32
8.1
1.0
7.5
8.9
11
1.0
7.2
8.8
1.0
6.5
8.8
11
4150
3950
1.1
169
27
6.8
1.0
7.1
9.0
11
1.0
7.9
9.0
1.0
8.2
8.9
1.0
7.3
9.1
11
3450
3100
1.8
125
36
11.6
1.0
6.8
9.0
1.0
6.7
9.0
1.0
6.2
8.8
11
2650
2400
3.3
106
1.0
6.7
8.6
11
1.0
7.8
8.6
10
1.0
7.5
8.9
10
1.0
7.2
8.9
11
2900
2580
5.4
69
48
18.6
1.0
6.1
8.8
12
1.0
5.4
8.8
12
3060
2740
5.4
82
40
14.6
1.0
6.0
9.1
11
1.0
�5.7
9.1
11
3350
3050
4.3
84
1 33
10.8
1.0
h: 001-1 bench C'IR2.\LS

REACTOR 1 (CONTROL) TREATABILITY DATA
Alpha/Buckeye Cellulose Corporation
Effluent
Date
Inf. Flow
pH
TBOD
SBOD SCOD
NH3-N
TSS
VSS
TDS
ml/min
s.u.
mg/L
mg/L mg/L
mg/L
mg/L
mg/L
mg/L
1-Mar-97
2.6
9.0
2-Mar-97
2.6
9.2
3-Mar-97
2.5
9.3
26
1970
2.4
24
24
4-Mar-97
2.4
9.2
5-Mar-97
2.5
9.0
40
18
1900
38
34
6-Mar-97
2.5
9.1
7-Mar-97
2.4
8.9
2275
155
150
8-Mar-97
2.0
9.0
9-Mar-97
9.0
10-Mar-97
2.5
9.0
20
1780
13
38
38
11-Mar-97
2.4
9.1
12-Mar-97
2.4
9.0
43
22 1
1475
74
68
5340
13-Mar-97
2.4
9.1
14-Mar-97
2.4
9.2
31
1425
7
24
24
15-Mar-97
2.2
9.0
16-Mar-97
2.1
9.1
17 -Mar-97
2.4
9.1
22
2030
3
16
16
18-Mar-97
2.3
9.1
19-Mar-97
2.4
9.1
43
30
2120
18
16
6100
20-Mar-97
2.4
9.2
21-Mar-97
2.4
8.9
24
2135
18
12
12
22-Mar-97
2.3
9.0
23-Mar-97
2.4
9.0
24-Mar-97
2.4
31
2370
6
24
18
25-Mar-97
2.4
9.0
26-Mar-97
2.4
9.0
29
2620
12
8
7120
27-Mar-97
2.4
9.0
39
2610
1
32
30
Basin
D.O.
mg/L
pH
sm.
Temp
°C
MLSS
mg/L
MLVSS
mg/L
ZSV
ft/hr
SVI
ml/g
OUR
mg/L-hr
SOUR
mg02
Wastage
Liter
gm VSS • hr
4.8
8.8
12
1.0
7.0
9.2
12
1.0
6.3
9.2
12
2880
2700
6.0
87
40
14.8
1.0
7.6
9.1
12
1.0
7.6
9.0
11
3050
2850
4.5
92
25
8.8
1.0
7.6
9.0
11
1.0
1.0
8.6
11
2500
2450
3.0
144
32
13.1
1.0
6.8
8.9
11
1.0
7.0
8.8
11
0.0
6.7
8.6
11
2300
2100
20
9.5
1.0
6.9
8.9
11
2050
2.4
160
1.0
6.9
1 8.9
11
2000 1
2000
20
10.0
0.0
3.7
8.9
11
1
1.0
2.1
8.8
10
2450
2300
2.2
224
26
11.3
1.0
5.3
8.7
10
1.0
2.7
8.7
11
1.0
6.5
8.8
11
2650
2600
40
15.4
1.0
2.5
8.8
10
2450
0.8
285
1.0
5.5
8.8
2700
2400
0.7
280
1.0
3.1
8.4
10
1.0
5.4
8.2
1950
1800
1.2
280
27
15.0
0.0
4.6
8.6
11
1.0
2.9
8.8
11
1.0
4.7
8.7
10
2700
2350
1.1
167
32
14.0
0.0
1.8
8.6
11
2.0
3.8
8.7
11
2300
2100
2.4
148
25
12.0
1.0
2.3
8.8
1 11
2800
2550
2.0
100
1 38
14.7
1.0
h:' 001-I' bench C'I'R2.XLS

j k <\
REACTOR 1 (CONTROL) TREATABILITY DATA
Alpha/Buckeye Cellulose Corporation
Effluent
Date
Inf. Flow
pH
TBOD
SBOD SCOD
NH3-N
TSS
VSS
TDS
ml/min
s.u.
mg/L
mg/L mg/L
mg/L
mg/L
mg/L
mg/L
28-Mar-97
8.9
29-Mar-97
9.0
30-Mar-97
2.4
9.0
31-Mar-97
2.4
9.1
37
2905
75
65
1-A r-97
2.4
9.1
1
2-A r-97
2.4
9.1
43
34
3080
28
24
8300
3-A r-97
2.3
9.1
4-A r-97
2.4
9.1
1
1 45
1 2980
1 0
1 12
8
Average
2.4
9.1
42.0
26.5
2059
7.1
38.9
36.5
6187
Minimum
2.0
8.9
40.0
18.0
1425
0.5
12.0
8.0
5340
Maximum
2.5
9.3
43.0
39.0
2620
18.0
155
150
7120
STD
0.1
0.1
1.7
6.1
384
6.3
40
39
893
Count
24
24
1 3
11
12
7
12
12
3
h: 001.1 bendr,CIMALS
Basin
D.O.
mg/L
pH
s.u.
Temp
°C
MISS
mg/L
MLVSS
mg/L
ZSV
ft/hr
SVI
ml/g
I
OUR
mg/L-hr
SOUR
mg 02
Wastage
Liter
gm VSS • hr
1.0
8.8
11
1.0
2.1
8.6
11
1.0
5.4
8.9
11
1.0
3.3
8.9
11
3300
3000
36
12.0
1.0
4.5
8.9
11
1.0
3.0
8.9
11
3200
3000
44
14.7
1.0
2.6
8.8
11
0.6
5.9
8.9
11
3500
3200
1.5
114
1 26
8.3
1.0
4.9
8.8
10.9
2484
2350
2.4
178.8
29.6
12.6
0.88
1.0
8.2
10.0
1950
1800
0.7
87.0
20.0
8.8
0.00
7.6
9.2
12.0
3050
2850
6.0
285.0
40.0
15.4
2.00
2.1
0.2
0.5
336.9
307
1.6
76.6
7.3
2.4
0.44
25
25
23
14
12
1 11
11
1 11
11
25

REACTOR 2 (AEROBIC SELECTOR REACTOR) TREATABILITY DATA
Alpha/Buckeye Cellulose Corporation
Effluent
Date
Inf. Flow
pH
TBOD
SBOD SCOD
Nl13-N
O-PO4
'MS
VSS
TDS
ml/min
sm.
mgL
mglL mgL
mg'L
mg,L
mg,'L
mg/L
mg/L
2-Feb-97
2.4
8.9
3-Feb-97
2.4
9.0
4-Feb-97
2.5
9.0
5-Feb-97
2.4
8.8
6-Feb-97
2.2
8.8
24
1708
43
37
6800
7-Feb-97
2.4
8.8
8-Feb-97
2.1
8.7
9-Feb-97
8.5
10-Feb-97
2.7
8.6
28
18
2020
21
18
11-Feb-97
2.4
8.8
12-Feb-97
2.4
8.8
13-Feb-97
2.6
8.9
25
17
961
50
21
14
6700
14-Feb-97
2.5
8.7
15-Feb-97
2.4
8.7
16-Feb-97
8.8
17-Feb-97
8.9
1779
12
12
18-Feb-97
2.6
8.8
19-Feb-97
2.5
8.8
41
26
20-Feb-97
2.3
8.7
22
18
1743
52
23
22
6820
21-Feb-97
2.3
8.7
22-Feb-97
2.3
8.7
23-Feb-97
8.9
24-Feb-97
2.4
8.9
1755
24
20
rb-97
8.9
26-Feb-97
8.9
52
35
1957
64
58
27-Feb-97
2.5
9.2
6280
28-Feb-97
1 2.6
9.2
40
1 1780
11
34
32
1-Nlar-97
2.4
9.0
2-Nar-97
9.1
3-Nlar-97
2.4
9.2
20
1955
14
68
66
4-Alar-97
2.4
9.2
5-Atar-97
2.6
9.0
32
1 17
1885
44
32
6-Mar-97
2.4
9.0
7 -Nta r-97
2.4
9.0
14
1 2015
1
38
36
h: 01114 bench SEL3.,XLS
Basin
Selertor
D.O.
mg/L
pH
s.u.
Temp
°C
MLSS
mg/L
h1LVSS
mg/L
ZSV
ft,hr
SVI
mUg
OUR
mg/L-hr
SOUR
mg02
Wastage
Liter
SCOD
mg1L
MISS
mg/L
MLVSS
mg/L
m VSS • hr
6.3
8.9
19
6.3
8.9
19
7.3
8.9
1.8
5.8
8.6
1.0
5.9
8.7
16
4160
3480
18
5.2
1.0
6.1
8.7
4750
0.6
187
1.0
7.0 1
8.6
1
1
1.0
6.3
8.5
14
1.0
7.1
8.6
12
4100
3480
0.7
204
21
6.0
1.0
1423
4980
4260
7.4
8.8
11
1.0
6.0
8.7
1.0
6.5
8.8
12
3650
335o
1.4
194
15
4.5
1.0
1660
6000
5250
6.3 1
8.8
1
1.0
6.3
8.7
1.0
6.7
8.8
1.0
6.4
8.8
11
3200
3000
3.6
84
21
7.0
1.0
1482
3760
3320
5.5
8.8
1.0
6.1
8.7
1.0
6.5
8.7
11
3700
3300
2.8
89
1.0
2609
1 4767
4333
6.1
8.7
12
1.0
8.4
8.8
10
1.0
8.4
9.0
10
1.0
8.4
8.9
11
2200
2000
6.0
91
12
6.0
1.0
1340
2450
2150
6.1
8.8
12
1.0
6.8
8.8
12
2560
2320
6.3
66
24
10.3
1.0
1554
2780
2600
6.7
9.1
12
1.0
7.1
9.1
12
2800
1 2550
5.4
71
28
10.8
1.0
1480
2200
1900
5.3
8.9
11
1.0
6.7
1 9.0
11
1.0
6.2
9.0
12
3000
2800
6.1
93
25
8.9
1.0
1580
2700
2550
6.9
9.1
12
1.0
6.9
9.0
12
2750
2550
4.9
73
26
10.2
1.0
1900
7.1
8.9
11
1.0
1.0
8.6
It
1 3100
2900
3.8
94
1 32
1 11.0
1 1.0
1555
5050
5000

4m
REACTOR 2 (AEROBIC SELECTOR REACTOR) TREATABILITY DATA
Alpha/Buckeye Cellulose Corporation
Effluent
Date
Inf. Flow
pH
TBOD
SBOD SCOD
NH3-N
O-PO4
TSS
VSS
TDS
ml%min
s.u.
mg%L
mg/L mg,/L
mg/L
mg/L
mg/L
mg/L
mg/L
8-Atar-97
2.2
9.0
9-Niar-97
9.0
10-Mar-97
2.5
8.9
15
1900
17
42
38
11-Mar-97
2.5
9.0
12-Mar-97
2.3
9.0
26
18
1520
22
22
5340
13-Nlar-97
2.4
9.1
14-Diar-97 1
2.4
9.1
1
20
1435 1
14
22
16
15-Mar-97
2.2
8.9
16-Mar-97
2.1
9.0
17-Mar-97
2.4
9.1
10
1540
4
16
16
18-Mar-97
2.3
9.1
19-Mar-97
2.5
9.1
27
20
1520
13
12
5800
20-Aiar-97
2.5
9.2
21-Nlar-97
2.4
8.9
20
1780
12
10
8
22-Mar-97
2.3
9.0
23-Mar-97
2.4
9.0
24-Mar-97
2.4
20
2040
3
24
20
25-Mar-97
2.4
8.9
26-piar-97
2.4
9.0
25
2430
18
16
7080
27-Niar-97
2.5
9.0
26
2250
4
32
30
28-A1ar-97
0.0
29-Niar-97
0.0
30-Mar-97
2.3
9.2
31-Mar-97
2.4
1-Apr-97
2.4
9.1
2- Apr-97
2.4
9.1
35
22
2360
20
18
7520
3-Apr-97
2.2
9.0
4-Apr-97
1 2.4
9.0
27
1 2510
5
28
1 22
,average
2.4
9.0
28.3
18.8
1856
9.6
29.1
26.0
6073
Minimum
2.1
8.9
26.0
10.0
1435
2.6
10.0
8.0
5340
Maxirnum
2.6
9.2
32.0
26.0
2430
17.0
68
66.0
7080
STD
0.1
0.1
3.2
4.4
311
5.9
17
16
902
Count
24
24
3
12
12
7
12
12
3
Basin
Selector
D.O.
mg/L
pH
s.u.
Temp
°C
MLSS
mg/L
MLVSS
mg/L
ZSV
ft/hr
SVI
mUg
OUR
mg/L-hr
SOUR
mg02
Wastage
Liter
SCOD
mg/L
MLSS
mg./L
MLVSS
mg/L
gm VSS • hr
4.1
8.7
11
1.0
6.0
8.8
11
1.0
6.0
8.8
11
3250
3000
24
8.0
1.0
1245
3350
2900
6.5
8.8
11
2850
5.3
84
1.0
6.2
8.8
11
2050
2050
17
8.3
0.0
1540
4.7
8.9
11
1.0
1665
3350
3150
5.3
8.9
10
2500
2350
4.6
80
18
7.7
1.0
6.6
8.7
10
1.0
6.5
8.8
11
1.0
4.5
8.9
11
2600
2500
19
7.6
1.0
2000
4000
3750
4.0
8.9
2450
4.6
94
1.0
3.8
8.8
2950
2800
4.0
92
25
9.0
1.0
2.1
8.9
10
1.0
2.7
8.6
3100
2900
4.1
80
30
10.3
0.0
2480
11200
10300
4.8
8.7
11
1.0
3.0
8.8
I1
1.0
4.1
8.7
11
3200
2950
3.0
94
28
9.5
0.0
1945
11100
9900
2.5
8.6
it
2.0
4.9
8.6
11
3050
2850
3.6
98
28
9.7
1.0
7.3
8.9
11
3200
2900
3.6
103
23
7.9
1.0
1780
4900
4400
7.0
9.2
11
0.0
6.4
8.9
11
1.0
9.5
9.2
11
0.0
8.4
9.2
11
0.0
6.0
8.9
11
1.0
5.5
8.9
11
3000
2850
29
10.1
1.0
5.1
8.9
11
0.7
5.8
8.9
11
2900
2600
2.3
130
1 20
1 7.5
1.0
1 1435
1 8700
1 7700
8.8
1 11.0
2861
2713
4.3
89.5
24.6
9.0
0.9
1769
5706
5244
8.6
10.0
2050
2050
3.0
73.0
17.0
7.6
0.0
1245
2700
2550
9.1
12.0
3250
3000
6.1
103.0
32.0
11.0
2.0
2480
1 t200
10300
0.1
0.5
350
289
0.9
9.0
4.7
1.1
0.4
338
3452
3103
25
22
14
12
it
11
12
12
25
10
8
8
h: OG14 bench SEL3.\"1 S

AM i
Effluent
REACTOR 3 TREATABILITY DATA
Alpha/Buckeye Cellulose Corporation
Date
Flow
pH
TBOD
SBOD
NH3-N
TSS
VSS
TDS
ml/min
sm.,
mg/L
�SCOD
mg/L mg/L
rng/L
mg/L
mg/L
mg/L
2-Feb-97
2.4
8.7
3-Feb-97
2.5
8.9
4-Feb-97
2.4
8.9
5-Feb-97
2.4
8.8
G-Feb-97
2.4
8.8
28
1660
18
16
6820
7-Feb-97
2.8
8.8
8-Feb-97
2.1
8.7
9-Feb-97
9.2
10-Feb-97
2.4
9.2
31
13
1731
48
44
11-Feb-97
2.4
8.8
12-Feb-9 7
2.4
8.9
13-Feb-97
2.4
9.0
51
11
830
40
188
168
6960
14-Feb-97
2.5
8.8
15-Feb-97
2.3
8.8
16-Feb-97
9.0
17-Feb-97
9.0
1790
32
30
18-Feb-97
2.5
9.0
19-Feb-97
2.6
8.9
183
26
20-Feb-97
2.3
8.7
19
8
1826
550
534
7880
21-Feb 9 7
2.4
8.9
22-Feb-97
2.3
9.0
23-Feb-97
9.2
24-Feb-97
2.5
9.2
1803
313
287
25-Feb-97
9.2
26-Feb-97
9.2
93
13
1791
28
24
27-Feb-97
2.5
9.7
7740
28-Feb-97
2.5
9.5
8
1770
6
580
550
1-Mar-97
2.5
9.4
2-Mar-97
9.6
h: 1014 ben,h'.A5EL4.XLS
Basin
Selector
D.O.
mg/L
pH
sm.
Temp
°C
MLSS
mg/L
MLVSS
mg/L
ZSV
ft/hr
SVI
ml/g
OUR
mg/L-hr
SOUR
mg 02
Wastage
Liter
SCOD
mg/L
MLSS
mg/L
MLVSS
mg/L
VSS -hr
3.3
8.5
20
3.2
8.6
20
2.3
8.7
1.8
2.9
8.5
1.0
2.8
8.5
28
3640
3040
24
8
1.0
1.7
8.3
3350
0.8
220
1.0
2.5
8.8
1.0
1.4
8.6
32
1.0
2.3
8.7
33
3340
2840
0.9
212
26
9
1.0
1968
39G0
3380
2.8
8.7
33
1.0
2.8
8.8
1.0
3.2
8.7
31
3300
3000
0.9
229
21
7
1.0
1779
3850
3400
2.4
8.5
1.0
0.6
8.5
30
1.0
6.6
9.0
1.0
5.0
8.8
30
3050
2800
1.0
229
34
12
1.0
1.0
8.6
1.0
4.1
8.7
1.0
5.9
8.8
32
3850
3550
0.8
192
1.0
2491
46M
4267
6.3
8.8
31
1.0
6.8
9.0
31
1.0
7.3
9.2
31
1.0
6.9
9.2
32
3000
2600
3.9
67
16
6
1.0
1910
1050
800
6.8
9.2
32
1.0
6.8
9.2
32
1260
1100
7.2
159
18
16
1.0
1779
800
720
6.3
9.5
32
1.0
6.2
9.4
32
2550
2100
1.9
196
29
14
1.0
1670
2450
2100
6.4
9.3
30
1.0
6.7
9.5
30
1.0

PrrACTOR 3 TREATABILITY DATA
Alpha/Buckeye Cellulose Corporation
Effluent
Date
Flow
pH
TBOD
SBOD
NH3-N
TSS
VSS
TDS
mL'min
sm.
mg/L
�SCOD
mg/L mg/L
mg/L
mg/L
mg/L
mg/L
3-Mar-97
2.4
8.4
5
1790
0.1
44
40
4-Mar-9 7
2.4
8.2
5-Mar-9 7
2.6
8.9
15
5
1900
44
42
6-Mar-9 7
2.4
9.0
7-Mar-97
2.3
8.9
5
1990
170
155
8-Mar-97
1.9
9.4
9-Mar-97
2.4
9.4
10-Mar-97
2.4
9.3
6
1790
0.6
24
24
11-Mar-97
2.5
9.4
12-Mar-97
2.5
9.3
21
9
1590
26
26
7 700
13-Mar-97
2.5
9.5
14-Mar-97
2.4
9.5
6
1660
<0.1
56
56
15-Mar-97
2.2
9.3
16-Mar-97
1.9
9.4
17-Mar-97
2.3
9.5
5
1730
2
200
195
18-Mar-9 7
2.5
9.5
19-Mar-9 7
2.6
9.4
144
14
1755
760
710
7140
20-D1ar-97
2.4
9.5
21-1%1ar-97
2.4
9.2
19
2000
2
1880
1700
22-Mar-9 7
2.4
8.9
23-Mar-97
2.4
9.4
24-Mar-9 7
2.3
17
2465
1
135
125
25-Mar-9 7
2.4
9.2
26-Mar-9 7
2.4
9.3
13
2880
50
40
8860
27-Mar-97
2.4
9.3
14
2730
0
28
16
28-Mar-9 7
9.5
29-Mar-97
9.4
30-Mar-97
2.4
9.4
31-Mar-97
2.5
9.4
20
2860
45
36
h: -11114 bench',ASEMALS
Basin
Selector
D.O.
mg/L
pH
sm.
Temp
°C
MISS
mg/L
MLVSS
mg/L
ZSV
ft/hr
SVI
ml/g
OUR
mg/L -hr
SOUR
mg 02
Wastage
Liter
SCOD
mg/L
MLSS
mg/L
MLVSS
mg/L
gm VSS • hr
6.5
9.5
30
2600
2450
2.4
115
28
11
1.0
1900
2650
2300
6.9
9.5
30
1.0
6.5
9.4
31
2300
2100
4.3
109
34
16
1.5
5.8
9.1
31
1.5
6.5
9.3
32
1200
1050
8.3
125
20
19
1.5
1330
1400
1400
6.2
9.3
29
1.5
6.4
9.3
30
1.5
5.7
9.2
1300
1250
16
13
1.5
1045
1850
1800
6.5
9.3
31
1200
10.0
150
1.5
6.2
9.2
31
1250
1250
15
12
1.0
1920
1200
1150
5.6
9.3
31
1.4
5.6
9.3
30
1500
1500
1.7
190
20
13
1.4
1660
1950
1850
6.4
9.2
30
1.4
5.8
9.3
31
1.4
5.5
9.4
31
1000
950
17
18
1.4
2265
850
800
5.5
9.4
30
1050
2.3
430
1.0
5.5
9.3
31
1550
1450
0.5
580
28
19
1.4
5.6
9.4
31
1.4
6.0
9.1
900
850
20
24
2480
1600
1500
5.8
8.8
31
1.4
6.4
9.3
30
1.4
5.9
9.3
30
1350
1250
24
19
0.0
2480
3600
3200
6.3
9.2
30
1.4
5.5
9.2
31
1050
1000
19
19
1.4
6.4
9.3
30
1400
1250
9.6
71
21
17
1.4
2630
2100
1850
9.5
30
1.4
r
9.4
30
1.4
9.4
31
1.4
9.4
30
320
280
22
77
1.4
2490
1740
1500

REACTOR 3 TREATABILITY DATA
Alpha/Buckeye Cellulose Corporation
Effluent
Date
Flow
pH
TBOD
SBOD SCOD
NH3-N
TSS
VSS
TDS
ml/min
s.u.
mg/L
mg/L mg/L
mg/L
mg/L
mg/L
mg/L
1-A r-97
2.5
9.2
5
2 A r-97
2.5
9.3
27
7
2965
20
16
9700
3-A r-97
2.4
9.3
4-A r-97
2.4
9.3
13
2845
0
16
12
Average
2.4
9.2
60.0
9.8
2023
0.9
285
261
7900
Minimum
1.9
8.2
15.0
5.0
1590
0.1
24
16
7140
Maximum
2.6
9.5
144.0
19.0
2880
2.3
1880
1700
8860
STD
0.2
0.3
73
5.3
430
0.8
543
492
877
Count
25
1 24
1 3
12
12
6
12
F 12
1 3
h: 0014bench`.ASEL4.XLS
Basin
Selector
D.O.
mg/L
pH
s.u.
Temp
°C
MLSS
mg/L
MLVSS
mg/L
ZSV
ft/hr
SVI
ml/g
OUR
mg/L hr
SOUR
rng 02
Wastage
Liter
SCOD
mg/L
MISS
mg/L
MLVSS
mg/L
gm VSS • hr
4.2
9.1
31
1.4
4.0
9.1
30
1550
1500
36
24
1.4
4.0
9.1
31
1.4
4.5
9.2
30
1650
1350
2.9
200
19
14
1.4
2490
2000
1800
9.3
1 30.5
1404
1 1363
4.9
1 221
21.8
16.7
1.3
1968
1911
1761
8.8
29.0
900
850
0.5
71
15.0
11.4
0.0
1045
850
800
9.5
32.0
2600
2450
10.0
580
34.0
23.5
1.5
2630
3600
3200
0.1
0.7
485
473
3.8
183
5.6
3.7
0.3
549
824
696
25
23
14
12
8
8
12
12
24
1 9
9
9

State of North Carolina 17
Department of Environment,
Health and Natural Resources • •
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary E3 E H N F1
A. Preston Howard, Jr., P.E., Director
September 18,1996
Mr. Chuck Oxendine, Technical Services Manager
Alpha Cellulose Corporation
P.O. Box 1305
Lumberton, North Carolina 28359
Subject: NPDES Permit Modification
NPDES Permit No. NC0005321
Alpha Cellulose WWTP
Robeson County
Dear Mr. Oxendine:
Based on the Settlement Agreement between Alpha Cellulose Corporation and the Division of Water
Quality, the current NPDES permit has been modified to reflect winter limits for BOD5 at 1.8 MGD and 4.0 MGD
effluent flow. This modification will allow Alpha Cellulose some flexibility during winter operation while
still complying with the intent of the Lumber River Basinwide Strategy.
Please find enclosed the amended pages for Part I.A (1) and (2) which should be inserted into your
permit. The old pages should be discarded. All other terms and conditions contained in the original permit
remain unchanged and in full effect. These permit modifications are issued pursuant to the requirements of North
Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U. S.
Environmental Protection Agency.
Also, as part of this modification the total suspended solids limit for 4.0 MGD has been modified to
reflect a mass loading for a concentration of 28.3 mg/1 (944 lbs/day, monthly average; 1888 lbs/day, daily
maximum). This concentration is based on the existing load and flow at 1.8 MGD.
If any parts, measurement frequencies or sampling requirements contained in this permit modification
are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days folio, ving 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

Alpha Cellulose Corporation
Permit Modification
NC0005321
Page 2
This letter also serves to return Alpha Cellulose Corporation's request to increase the wastewater flow
from 1.8 MGD to 2.5 MGD, which was received February 3, 1995. As you are aware, the Division has been
holding this request until such time that the facility was able to show consistent compliance. Although the
information submitted indicated that hydraulically the plant could accommodate additional flow, BOD5 and
TSS values were inconsistent and sometimes out of compliance with permitted limits. Due to the nature of the
wastestream, the Division has relied heavily on existing data in its determination to approve the increase in
flow. More specifically, the Division has concerns with the TSS values reported in May 1996 and the facility's
problem with filamentous growth. This seems to have been a recurring problem at the plant. The Special Order
by Consent should allow Alpha Cellulose the opportunity to further investigate and correct this problem. The
request for the hydraulic expansion may be reviewed again (upon Alpha Cellulose Corporation's written
request) when Alpha Cellulose can show consistent compliance.
Although not required as part of the permit, the Division recommends that Alpha Cellulose conduct
influent monitoring for BOD5 and TSS. This will help Alpha Cellulose and the Division better evaluate the
treatment capability of the plant.
If you have any questions concerning the permit modification or return of the Authorization to Construct
permit request, please contact Susan Wilson at telephone number [phone], extension 555.
Si cerely yours,
Preston Howard, Jr`, P.E.
cc. Fayetteville Regional Office
Central Files
Permits and Engineering Unit
Office of Attorney General, Kathy Cooper
Facility Assessment Unit

A. (1). EFFLUENT LIMITATIONS ANI) MONITORING REQUIREMENTS FINAL
Permit No. NC0005321
During the period beginning on the effective date of the permit and lasting until expansion above /.8MGD or expiration, the Permittee is authorized to discharge
from outfall(s) serial number 001. Such discharges shall be limited and monitored by the pennittee as specified below:
Effluent Characteristics Discharge Limitations
Lbs da Units (Specify)
Mon. Avg. Daily Max. Mon. Avg. Daily Max.
Flow
BOD5 (April 1 - October 31)
BOD5 (November 1 - March 31)
TSS
NH3-N
Dissolved oxygen
Total Nitrogen (NO2 + NO3 + TKN)
Total Phosphorus
Temperature "'
Chronic Toxicity
Total Residual Chlorine
Conductivity
Dioxin t
332.0
664.0
450.0
900.0
425.0
850.0
83.0
166.0
1 .8 MGD
Monitoring
Requirements
Measurement
Sample
'Sample
Frequency
Tyne
Location
Continuous
Recording
I or E
Daily
Composite
E
Daily
Composite
E
Daily
Composite
E
Daily
Composite
E
Daily
Grab
E,U,D
Monthly
Composite
E
Monthly
Composite
E
Daily '
Grab
E,U,D
Quarterly
Composite
E
Daily
Grab
E
Daily
Grab
E,U,D
Quarterly
Composite
E
e
E
Sample locats: E - Effluent, I - Influent, U - Upstream at NCSR 1620, D - Downstream (1) at NCSR 2123, (2) at NCSR 2 21.
i6n
Instream samples shall be grab samples and shall be conducted 3 times per week during June, July, August, and September and once per week during the remainder of the year.
** The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l.
*** The discharge shall not cause the temperature of the receiving stream to exceed 2.8°C above background temperature and in no case cause the receiving stream to exceed 32.0°C.
*** Chronic Toxicity Testing P/F a/thk3 February, May, August, and November; See Part III, Condition E.
f See Part III, Condition G, of this permit.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be conducted daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. (2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC000.5321
During the period beginning upon expansion above 1.8 MGD and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number
001, Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Discharge Limitations
Lbs/day Units (Specify)
Mon. Avg. Daily Max. Mon. Avg. Daily Max.
Flow
BOD5 (April 1 - October 31)
BODs (November 1 - March 31)
TSS
NH3-N
Dissolved oxygen
Total Nltrogen (NO2 + NO3 + TKN)
Total Phosphorus
Temperature "'
Chronic Toxicity
Total Residual Chlorine
Conductivity
Dioxin t
Settleable Solids
332.0
664.0
450.0
900.0
944.0
1888.0
83.0
166.0
4.0 MGD
28.0 pg/1
1.9 pg/I
Monitoring
Requirements
Measurement
Sample
'Sample
Frequency
Type
Location
Continuous
Recording
I or E
Daily
Composite
E
Daily
Composite
E
Daily
Composite
E
Daily
Composite
E
Daily '
Grab
E,U,D
Monthly
Composite
E
Monthly
Composite
E
Daily '
Grab
E,U,D
Quarterly
Composite
E
Daily
Grab
E
Daily
Grab
E,U,D
Quarterly
Composite
E
Weekly
Grab
E
* Sample locations: E - Effluent, 1 - Influent, U - Upstream at NCSR 1620, D - Downstream (1) at NCSR 2123, (2) at NCSR 2121.
Instream samples shall be grab samples and shall be conducted 3 times per week during June, July, August, and September and once per week during the remainder of the year.
** The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/I.
*** The discharge shall not cause the temperature of the receiving stream to exceed 2.8°C above background temperature and in no case cause the receiving stream to exceed 32.0°C.
**** Chronic Toxicity Testing P/F atFebruary, May, August, and November; See Part III, Condition F.
t See Part Ill, Condition G, of this permit.
The pl-I shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be conducted daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

2
TOXICS/METALS/CONVENTIONAL PARAMETERS
Type of Toxicity Test: Chronic P/F (Ceriodaphnia)
Existing Limit: 5%
Recommended Limit: 5% Chronic P/F (Ceriodaphnia)
Monitoring Schedule: Feb, May, Aug, Nov
Existine Limits
Mon. Ave
Dal. Max.
Wasteflow (mgd)
4.0
BOD5 (#/d)
332
664
TS S (#/d):
425
850
NH3N (#/d):
83
166
DO (mg/1):
5 (dal ave)
R. Chlorine (ug/1):
28
pH (Sin:
6-9
Dioxin (pg/1):
monitor quarterly
TN
monitor
TP
monitor
Conductivity
monitor
APAM
monitor annually
Temperature
monitor*
Long Term BOD
monitor
*The discharge shall not make the temperature of the receiving stream to exceed 2.8 degrees C above background
temperature and in no case cause the receiving stream to exceed 32 degrees C.
Recommended Limi
Mon. Ave
Dal. Max.
Wasteflow (mgd)
4.0
BOD5 (#/d)
332
664
TSS (#/d):
425
850
NH3N (#/d):
83
166
DO (mg/1):
5 (dal ave)
R. Chlorine (ug/1):
28
pH (Sin:
6-9
Dioxin (pg/1):
1.9
IN
monitor
TP
monitor
Conductivity
monitor
Settleable Solids (ml/1):
monitor
Temperature
monitor*
*The discharge shall not make the temperature of the receiving stream to exceed 2.8 degrees C above background
temperature and in no case cause the receiving stream to exceed 32 degrees C.
Limits Changes Due To:
New Dioxin Limit to comply with instream standard
APAM no longer required per new Directive
No more BOD long-term data required. Further study on Lumber River will continue in the future. Long -Term
BOD may or may not be required as part of the study.
Set. Sol. monitoring - to determine of possible problem with solids given high guideline limits. This may be
removed after a year of data if found negligible.
X Parameter(s) are water quality limited. For some parameters, the available load capacity of the immediate
receiving water will be consumed. This may affect future water quality based effluent limitations for additional
dischargers within this portion of the watershed.
OR
No parameters are water quality limited, but this discharge may affect future allocations.

INSTREAM MONITORING REQUIREMENTS
Upstream Location: @ NCSR 1620
Downstream Location: 1) @ NCSR 2123; 2) @ NCSR 2121
Parameters: DO, Temperature, Conductivity
Special instream monitoring locations or monitoring frequencies:
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Ad .auacy of Existing Treatment
Has the facility de nstrated the ability to meet the proposed new limits with existing treatment
facilities? Yes ✓ No
If no, which parameters cannot be met?
Would a "phasing in" of the new limits be appropriate? Yes No
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
If no, why not?
Special Instructions or Conditions
Wasteload sent to EPA? (Major) (Y or N)
(If yes, then attach schematic, toxics spreadsheet, copy of model, or, if not modeled, then old
assumptions that were made, and description of how it fits into basinwide plan)
Additional Information attached? (Y or N) If yes, explain with attachments.

Facility Name , f l'/��1G� (Q �dS Q Permit 4t Pipe
CHRONIC TOXICITY PASSTAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality
is _, - % (defined as treatment two in the North Carolina procedure document). The permit holder shall perform
guarter monitoring using this procedure to establish compliance with the permit condition. The first test will be
performed after thirty days from the effective date of this permit during the months of
. Effluent sampling for this testing shall be performed at the NPDES
permitted finale uent discharge below all treatment processes.
All toxicity testing results required as pan 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, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 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 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 any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management 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 and appropriate environmental controls, shall constitute an invalid test and will require immediate
retesting(,Azthin 30 days of initial monitoring event). Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
7Q10 190 cfs
Permitted Flow MGD
IWC 1— %
Basin & Sub -basin 30'7 S
Receiving Stream l L)WbPv Fi% yey
County _ &'l'1
QCL P/F Version 9191
Rec /mmended
/ CCP/�o
Date 1 ti y

Part V
A. Dioxin Monitoring
For permit compliance purposes, the point of compliance shall be defined as the final
effluent before discharge. Compliance with the daily maximum permit limit shall be
deomonstrated by determining the TCDD concentration at the final discharge point.
Adequate sample volume shall be collected to perform the analysis. The total sample
volume shall be collected and preserved sample shall be analyce with zed in accrt II, Section C
ordance with the
Monitoring and Records. The P Analytical procedures and Quality
appropriate method of analysis specified in
Assurance for Multimedia Analysisof
Polh Resolution Gas Chroma hlorinated ography/High d
Polychlorinated Dibenzofurans y g
Resolution Mass Spectrometry, EPoved by (EPA Method
Aesing a sample may be analyzed
equivalent analytical protocolpp
to determine compliance with veto enable the samplmaximum e to be split (dupluent limitation. icate analysis) a
sample volume may be collected
If the analysis of either split sample is below the detection limit, the quantity, for the
purposes of compliance evaluation, is considered to be zero. If both splits are
positive, the results of the two ananalyses
mitiation If the mbe easuremeto determine
t sibelo detection
ce
with the daily mayor the
effluenturpurposes of compliance evaluation is considered to be zero.
limits the quantity for the purp
The detection limit using these methods for the purpose of compliance evaluation is
considered to be 10 picograms per liter. The dioxin isomer to be monitored and
limited by this permit is 2,3,7, 8, TCDD.
Fish tissue analysis will be performed, as a minimum, at one station established
upstream of the discharge and at two stations downstream in accordance with the
Division of Environmental Management approved monitoring plan. The monitoring
plan is an eforceable° 1 besrpeportlt. Afl ed withinxin data threemonthsected as after collectiart of on.
monitoring requirement
The
The permittee shall perform the following analyses for dioxin in addition to
monitoring the effluent as specified on the effluent pages:
1. Influent to wastewater treatment facility Quarterly GRAB (2378 TCDD)
2. Sludge Quarterly GRAB (2378 TCDD)
3. Fish tissue analysis Annually (TCDD and TCDF)
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WHOLE EFFLUENT TOXICITY TESTING 0(SELF-MONITORING SUMMARY) Tue, Jun 14, 1994
rAru.iTY RFOUIRFMFNT YEAR JAN FEB MARA
PR MAY RN JUL
A.D. CARI'FR, INC. PERM CUR I.IMA.7%
00 FAIL
—
--
FAIL
FAIL
FAIL
FAIL
FAIL
—
FAIL
FAIL
FAIL
-
FAIL
-
FAIL
FAIL
FAIL
---
NCOO63835AX)I Begin:2/1/93 FnvpA-riry: Q 1W A JAN AI'R JUI. ("'
NonComp:SINGIJI
91 FAIL
--
FAIL
FAIL.PASS
FAIL
FAIL
FAIL
FAIL
FAIL
FAIL
FAIL
County:(iASTON Region: MRO Subbasin:C7D37
92 FAIL
93 FAIL
FAIL
FAIL
FAIL
PA
FAIL
PENDING(s)
PASS
PASS
FAIL
FAIL
rAn
PASS
Pr: 0.022 Special
7QIO:0.69 IWC(%):4.7 Order
94 FAIL.FAIL
FAIL
FAIL
FAIL
ADTco, INC. PERM AC LIM: 268%
V 90 NONE
—
—
>90
—
—
NR
NI
W
>90*
—
-
N000052661001 Begin: 11/30/92 Frequency: Q A JAN APR JUL OCT
NonComp:SINGLE
91 >90'
—
—
25.6'
>100*
—
NONE'
—
>100'County:
LATE
24.06'
76.85'
WILKES Region: WSRO Subbasin: YAD01
92 44.65'
72.36'
—
>100'
—
—
>100*-
—
Special
93 53.D8'
35.36'
21.02'
50.0'
21.02'
60.95'
>100'
—
>700'
PF:1.0
7QIO: 228.0 IWC(%):0.675 Order
94 42.04'
>100'
—
>100'(s)
ALBEMARLE WW"I'P PERM CIIR LIM:90%
90 FAIL
FAIL
FAIL
FAIL
—
PASS
FAIL
PASS
PASS
FAIL
PASS
PASS
FAIL
PASS
LATE
PASS
bt
FAIL
NC0024244/001 Begin:11/4/92 Frequency: Q P/I7 A MAR JUN SEP DEC
NonComp:SINGLE
91 PASS
PASS
PASS
FAIL
PASS
FAIL
FAIL
PASS
PASS
County: STANLY Region: MRO Subbasin: YAD13
92 PASS
PASS
Ni
—
—
PASS
FAIL
—
PASS
—
LATE
PASS
—
FAIL
PF: 16.00 Special
93 —
—
PASS
—
—
7QIO:1.60 IWC(%):93.92 Ord":
94 PASS
—
PASS
—
ALCOA-002 PERM CIIR LIM:16%
0o —
—
PASS
—
--
PASS
PASS(s)
—
—
—
PASS
PASS
—
—
-
bt
PASS
NC0004308/002 Begin: 10/9/92 Fancy: Q P/F A MAR JUN SEP DEC
NonComp:SINGLE
91 PASS
—
PASS(s)
—
--
PASS
—
-
FAIL
PASS.PASS
FAIL
County: STANLY Region: MRO Subbasin: YAD08
02 —
—
PASS
—
—
FAIL
PASS
-
PASS
-
FAIL
Special
93 PASS
—
PASS
—
—
PF: NA
7Q10: NA IWC(%):NA Order
94 PASS
—
PASS
—
ALCOA-005 PERM CIIR I.IM:90% (GRAB) (DURING PHASE It -POST DEL
90 —
—
—
—
NCODD4308/005 Begin:10/9192 Frequency: Q P/F A MAR JUN SEP DEC
NonComp:SINGLE
91 —
—
--
--
—
-
-
—
—
—
—
County: STANLY Region: MRO Subbasin: YADOR
92 —
—
—
—
47.2'
—
H
—
—
PASS
I'F: NA Special
1
93 —
—
—
'—
—
—
Oar.
94 —
—
PASS
—
ALCOA-012 PERM Cl LIM:16%
NC0004308/012 Begin: 1019/92 Frequency: Q Pfr A MAR JUN SEP DEC
-
NonComp:SINGLE
90 —
91 FAIL
—
PASS
PASS
FAIL(s)
—
FAIL
—
PASS
PASS
bt.F
—
PASS
—
PASS
PASS
PASS
-
-
bt
PASS
County: STANLY Region: MRO Subbasin: YAD08
'
92 —
—
PASS
—
—
PASS
—
FAIL
PASS
PASS,PASS -
PASS
PASS
Special
93 —
—
PASS
—
—
FAIL
PASS
—
PF: NA
7Q10: NA IWC(%):NA Order:
94 —
—
PASS
—
ALGXANUGR MILLS WW1 PERM CUR LIM:11'16
Y 90 PASS
—
--
PASS
—
—
PASS
Ni
—
PASS
—
—
PASS
—
—
PASS
—
NC0020320/001 Begin:3/I/94 Frequency: Q P/F A FEB MAY AUG NOV
NonComp:SINGLE
91 PASS
—
—
Ni
—
—
FAIL
PASS
PASS
—
County:RUTHERFORD Region: ARID Subbasin: DRD02
92 —
PASS
—
—
PASS
PASS
-
-
PASS
-
PASS
-
PF:0.20 Special
93 —
FAIL
PASS
—
-7QIO:2.5 IWC(%):11.0 Order
94 —
PASS
—
—
ALLIED CHEM. CORPJ002 PERM:2411R LC50 AC MONIT EPIS FTHD (GRAB)
90 —-
1,1170001899/002 Begin:3/l/94 Frequenry:5OWD/A
NonComp:
91 —
Cnunty:CHATIIAM Region: RRO Subbasin: CPF07
92 —
—
—
—
—
Pr: N/A Special
03 —
—
—
—
—
—
—
7Q10:0.0 IWC(%): 100.0 Order.
94 —
—
—
>10DISIG
AIJAI d) SIGNAL FIBERS PERMA81IR LC50 AC LIM 90% CERIO OR DAPH
90 —
—
—
—
^
NCOD01899/001 Begin:3/I/94 17—fuency: Q A JAN APR JUL OCT
NonComp:SINGLE
91 —
—
——
County:CIIATIIAM Region:RRO Subbmin:CPN7
D2 —
—
—
I'r:0.244 Special
Order.
93 —
94 —
—
—
—
—
—
>100'SIG
^
7Q10:40 IWC(%):0.94
ALPI IA CELLULOSE PERM CHR LIM:5.0%
V 90 PASS
—
—
PASS
—
—
PASS
—
LATE
—
PASS
LATE
PASS
PASS
-
N000053211001 Begin: l/I/93 Frequency: Q P/F A M-B MAY AUG NOV
NonComp:SINGLE
91 Ni
PASS
—
—
PASS
NR
—
—
—
PASS
PASS
-
PASS
—
County: ROBESON Region: FRO Subbasin: LUM51
92 —
93 —
PASS
FAIL
—
PASS
--
—
PASS
PA
FAIL
PASS
—
PASS
—
I'V: 4.0 Special
Order
94 —
PASS
—
—
7QIO:120 rWC(%):5.0
0 2 amsccutive failures = significant noncompliance Y I'm 1990 Dnta Available
LEGEND:
PERM = Permit Requirement LET = Administrative Letter - Target Frequency = Monitoring ftequeney: Q- Quarterly; M- Monthly; BM- Bimonthly; SA- Semiannually; A- Annually; OWD- Only when discharging; D- Discontinued monitoring requirement; IS- Conducting independent study
Begin = first month required 7Q10 = Receiving stream low now criterion (cfs) A = sated monitoring increases to monthly upon single failure Months that testing must occur -ex. JAN,APR,lUL,OCr NonComp = Current Compliance Requirement
III, = Permitted Bow (MGD) IWC% = Instream waste concentration P/F = raas/Fall chronic test AC = Acute CHR = Chronic
Data Notation: f - Fathead Minnow: a - Ceriodaphnis so.: my - Mvsid shrimp: ChV - Chronic value: P - Mortality of stated De centaae at hithest concentration: st - Perfomred by DEM Tox Eval Group: bt - Bad best
Reporting Notation: --- = Data not required; NR -Not reported;( ) -Beginning of Quarter Facility Activity Stares: I - Inactive, N - Newly Issued(To construct); H - Active but not discharging; l-More data available for month in question SIG = ORC signature needed

August 18, 1994
State of North Carolina
Department of Environment, Health and Natural Resources
512 North Salisbury Street
P.O. Box 27687
Raleigh, NC 27611 '
:J
Attention: Ms. Susan A. Wilson
Dear Ms. Wilson:
Reference: Alpha Cellulose Corporation - Lumberton, NC
NPDES Discharge Permit No. NC0005321
Request for Authorization to Construct
Attached are two design calculations on our diffusion system for
the aeration basin from Environmental Dynamics, Inc., the system
supplier. One calculation is for a flow of 2.5 MGD with all
parameters the same as the 1.8 MGD supplied to you except that
there is a little more air to each diffusion unit (which our
current blower system can handle) and the DO residual drops to
1.0 (still in acceptable range).
The second calculation is for 4.0 MGD. This one has an increased
Alpha factor since at this higher flow rate, the mill would be
using more dilution water in the process and the Alpha factor
would increase. We currently feel the Alpha factor used was
conservatively low and that it is closer to that used for the 4
MGD flow calculation.
Currently we feel the wastetreatment system can handle up to 2.5
MGD but to go up to 4 MGD we would probably have to modify our
primary and secondary clarifiers to handle the increased
hydraulic load.
If you have any further questions please feel free to give me a
call.
Since ly, /
l
R nald D. Hilbelink
Asst. VP Manufacturing
/cpt
1000 East Nair Street, Box 1305 Lumberton, North Carolina 28359 USA ^a 910 738 4201 FAX [phone]

f
Environmental Dynamics, Inc.
4509 I-70 Drive S.E.
Columbia, Missouri 65201
31a-474-9456
DB M662 Page 1
FLEXAIR DESIGN BRIEF
EDI "FLEXAIRTH" AERATION SYSTEM FOR AEROBIC TREATMENT
Project Location:
ALPHA CELLULOSE
1000 EAST NOIR ST
LUMBERTON, NC 28359
A-fTN : MR. RONALD D. H[LBELINK
Date: AUGUST 10, 1994
DESIGN CALCULATIONS
(1) Type Waste and Process COTTON PAPER -ACTIVATED SLUDGE
(2) Design Flow MAXIMUM DESIGN
-(3) BOD Raw Waste
(4) Preliminary Treatment (% BOD Removal)
(5) % ROD Remaining (10007o - Item 4)
(6) ALPHA = Ratio of oxygen transfer in waste to transfer in tap waver
BETA = Ratio of solubility of oxygen in wastewater to solubility in tap water
(7) Site Elevation '
(8) Operating ambient pressure, Winter
Operating ambient pressure, summer
(9) Dissolved oxygen level to be maintained in the aeration basic
(10) Temperature of waste in aeration basin:
Winter Temperature (Degrees'C)
Summer Temperature (Degrees C)
(11) Design BOD removal
(12) Carbonaceous BOD(5) to the aeration basin (Item 3) x (Item 5)
(13) Oxygen required per lb of carbonaceous BOD removed
(14) Carbonaceous oxygen requirements for the aeration at field conditions
(Item 11) x (Item 12) x (Item 13)
(15) Ammonia to aeration basin
(16) Oxygen requirements for ammonia (Item 15) x (4.6#02/#NH4-N)
2.5 MGD
1400 M94
29190 lbs/day
0 70
100 q0
0.4 Alpha
0.95 Beta
123 Feet
14.6344 Asia
14.6397 psia
1.5 mali
12
C
35
C
100
%
29190
lbstday
1
lb/lb
29190
lb 02/day
0 mg/1
0 lb/day
0 lb 02/day
Liza ' :)N I ' I 'Cl '3 Wbt72 : 60 b6. 01 !Dnu

DB M662 Page 2
'
AOR (Item 14 + Item 16) 124
1216.25 lb 021hour
(17) Total oxygen requirements,
13 scfai
(18) Air supply for each EDT FlexAirTM diffuser tube
366 in2
(19) Active surface area per diffuser tube
16.5 ft
(20) Air release depth of diffusers
24 %
(21) % Oxygen transfer, SOTS
3.23 lb 02/hr/unit
(22) Lbs oxygen per hour per unit, SOR
10.777 mg/i
(23) Winter surface saturation, Csmt
6.94932 mg/l
Summer surface saturation, Cstni
0.4
(24) Effective depth correction factor
saturation 1 the
( ) Standard 92� C*20
10.8599 mg/1
em19*Item
C23 /29
*20 9.09 (29 92+0 88 8O�
(26) AOR/SOR=ALPHA[BETA(C-?0)(Csmt/9.09)(Psite/Psc)-(Item 9)] 1.024^(Ttem 10-20)!(C4
30 53
Winter AOR/SOR
0.33408
Summer AOR/SOR
j27) Number of EDI F1exAirTM units required for oxygen demand
1158 units
(Item 17) / [(Item 22) x (Item 26)]
(28) Air requirements for oxygenation (Item 18) x (Item 27)
15054 scfm
(29) Number of units for mixing and/or properdistribution
1168 units
3.3 scfm
(30) Airflow per unit (mixing only)
3854.4 sCfm
(31) Air requirements for mixing (Item 29) x (Item 30)
(32) Design diffuser air Oxygenation or mixing requirements
3.24 <.;cfm per ft2
Defined as scfin per active surface area
(33) F-stimated system operating pressure:
16.5 It
(a) Static liquid head
(b) Pressure loss at blower building and header
1.2 ft
0.7 ft
(c) Pressure loss lateral piping
1.8 It
(d) Pressure loss through F1exA4Tm unit
20.2 ft
(f) Nonnal compressor operating pressure (a+b+c+d)
8.74 psig
(34) Normal operating pressure
1 psig
(35) Design over -pressure APPROXIMATE
9.74 psig
(36) Peak design pressure
NOTES:
Lib'd 'DWI 'I'Q.3 Wd172:60 b6, 0I mu

' Environmental Dynamics, Inc.
4S09 I.70 Drive S.E.
Columbia, Missouri 65201
314-474-9456
DB M661 Page 1
FLEXAIR DESIGN BRIEF
EDI "FLEXAIRTM" AERATION SYSTEM FOR AEROBIC TREATMENT
Project Location:
ALPHA CELLULOSE
1000 EAST NOIR ST
LUMBERTON, NC 28359
ATTN : MR. RONALD D. EMBELINK
Date: AUGUST 9, 1994
DESIGN CALCULATIONS
(1) Type Waste and Process COTTON PAPER -ACTIVATED SLUDGE
(2) Design Flow MAXIMUM DESIGN
4
MrD
(3) BOD Raw Waste
1400
46704
mg/1
lbs/day
(4) Preliminary Treatment (% BOD Removal)
0
%
(5) % BOD Remaining (100% - Item 4)
100
%
(6) ALPHA = Ratio of oxygen transfer in waste to transfer in tap water
0.5
Alpha
BETA = Ratio of solubility of oxygen in wastewater to solubility in tap water
0.95
Beta
(7) Site Elevation
123
Feet
(8) Operating ambient pressure, winter
14.6344
14.6397
Asia
Operating ambient pressure, summer
psia
(9) Dissolved oxygen level to be maintained in the aeration basin
1
mgll
(10) Temperature of waste in aeration basin:
Winter Temperature (Degrees C)
12
C
Summer Temperature (Degrees C)
35
C
(11) Design BOD removal
100
%a
(12) Carbonaceous BOD(5) to the aeration basin (Item 3) x (Item 5)
46704
lbs/day
(13) Oxygen required per lb of carbonaceous BOD removed
1
Ib/ib
(14) Carbonaceous oxygen requirements for the aeration at field conditions
46704
lb 02/day
(Item 11) x (Item 12) x (Item 13)
(15) Ammonia to aeration basin
0
0
Ing/l
Ib/day
(16) Oxygen requirements for ammonia (Item 15) x (4.6#02/#NH4-N)
0
11) 02/day
E/2'd 'DWI 'I'(1'3 Wdz7:80 b6. 60 9fld

'
DB M661 Page 2
(17) Total oxygen requirements, AOR (Item 14 + Item 16) 24
1946
lb 02/hour
(18) Air supply for each EDI F1exAirn" diffuser tube
16
scfm
(19) Active surface area per diffuser tube
366
in2
(20) Air release depth of diffusers
16.5
ft
(21) % Oxygen transfer, SOTS
24
cf.
(22) Lbs oxygen per hour per unit, SOR
3.98
lb 02Jhr/unit
(23) Winter surface saturation, Csmt
10.777
mg/1
Summer surface saturation, Csmt
6.94932
mg/1
(24) Effective depth correction factor
0.4
(25) Standard condition aerated 02 saturation in the tank, C*20
10.8599
ing/l
C*20=9.09*(29.92+0.8828*Item19*Item 23)/29.92
(26) AOR/SOR=ALPHA[BETA(C*20)(Csrnt/9.09)(Psite/Psc)-(Item 9)]1.024^(Item
10-20)/(C*20)
Winter AORJSOR
0.42567
Summer AOR/SOR
0.45045
(27) Number of EDI FlexAir''74 units required for oxygen remand
(Item 17) / [(Item 22) x (Item 26))
1149
units
(28) Air requirements for oxygenation (Item 18) x (Item 27)
18384
scfm
(29) Number of units for mixing and/or proper distribution
1168
units
(30) Airflow per unit (mixing only)
3.3
scfm
(31) Air requirements for mixing (Item 29) x (Item 30)
3854.4
scfm
(32) Design diffuser air fluxrate based on oxygenation or mixing requirements
3.24
scfm per ft2
Defined as scfm per active surface area
(33) Estimated system operating pressure:
16.5
ft
(a) Static liquid head
(b) Pressure loss at blower building, and header
1.2
ft
(c) Pressure loss lateral piping
0.7
ft
(d) Pressure loss through F1exAir7m unit
1.8
ft
(f) Normal compressor operating pressure (a+b+c+d)
20.2
ft
(34) Normal operating pressure
8.74
prig
(35) Design over -pressure APPROXIMATE
1
psig
(36) Peak design pressure
9.74
pig
NOTES:
Eic'd 'DNI 'I'Q'3 Wd2b:80 b6. 60 5nu

ALPHA CELLULOSE
ALPHA CELLULOSE
NC0005321
MODIFIED (Conventional) PERMIT LIMITS
Summer
Winter
PARAMETER
Mon. Avg
Daily Max
Mon. Avg
Daily Max
Flow (MGD)
1.8
1.8
BOD5 (#/day)
332
664
450
900
TSS (#/day)
425
850
425
850
NH3-N (#/day)
83
166
83
166
Summer
Winter
PARAMETER
Mon. Avg
Daily Max
Mon. Avg
Daily Max
Flow (MGD) t
2.5
2.5
BOD5 (#/day)
332
664
450
900
TSS (#/day)
590
1180
590
1180
NH3-N (#/day)
83
166
83
166
t If, and only if, the re -rating to 2.5 MGD meets Division approval.
PARAMETER
Mon. Avg
Daily Max
Mon. Avg
Daily Max
Flow (MGD) ^
4.0
4.0
BOD5 (#/day)
332
664
450
900
TSS (#/day)
944
1888
944
1888
NH3-N (#/day)
83
166
83
166
^ Only with a treatment plant expansion, as specified in the permit.
SOC (Conventional) LIMITS
Summer
Winter
PARAMETER
Mon. Avg
Daily Max
Mon. Avg
Daily Max
Flow (MGD)
1.8
1.8
BOD5 (#/day)
415
830
563
1 125
TSS (#/day)
738
1476
738
1476
NH3-N (#/day)
83
166
83
166�
7/12/96

rr1�Na -i�►
13C&K
= I
BE&K ENGINEERING OF NORTH CAROLINA, INC.
July 22, 1994
Ms. Susan A. Wilson
State of North Carolina - DEHNR
P. O. Box 29535
Raleigh, NC 27626-2535
Subject: Alpha Cellulose
Lumberton, North Carolina
Waste Water Treatment Plant
Robeson County
BE&K Contract No.: 50-94-139
Application No. ACDO05321
Authorization to Construct
Dear Ms. Wilson:
Attached is the information you have requested in your letter to Ron Hilbelink dated July
21, 1994 which is required to complete your review.
1. Product data sheets for the blowers, Lamson Model 1400, 7 Stage. The rated
capacity is 5810 SCFM @ 9.01 psig per blower.
2. The volume of the aeration basin is approximately 4.5 million gallons.
3. A copy of the EDI Aeration -Mixing Systems Operation and Maintenance manual
which contains a detailed description of the diffusers.
4. A copy of the calculations that demonstrate the new diffusers will provide the
aeration required.
If you should have any questions or require any additional information please call me at
[phone].
Sincerely,
OiaZmJ. ady
WJB/j mr: corres001.139
2700 Gateway Centre, Suite 150 *Morrisville, North Carolina 27560 *Tel. [phone] • Fax. [phone]

Ms. Susan A. Wilson
July 22, 1994
Page Two
cc: Alpha Cellulose
Mr. Ron Hilbelink
Mr. Jim Israelson
BE&K
Mr. Robert Tysinger
Project File

State of North Carolina
Department of Environment, - XAA
Health and Natural Resources •
Division of Environmental Management A4
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary C) E H N
A. Preston Howard, Jr., P.E., Director
DIVISION OF ENVIRONMENTAL MANAGMENT
WATER QUALITY SECTION
FAX: [phone]
FAX TO: BILL BRADY FAX NO.: 919/481-9516
BE&K
i A L-A)H 4 be L L u L
FROM: SUSAN WILSON
PHONE: [phone] EXT. 555
NO. OF PAGES INCLUDING THIS SHEET: 3
AM
Here is some of the information that we are looking for in order to
issue the Authorization to Construct. I tried to give a brief look at
your plans. I did not see any information of the diffusers
themselves. In the P&E Unit we are not so much concerned about
construction plans as we are with ensuring that the treatment unit
will meet the facility's NPDES limits. In this case, since the
previous plans have already been approved, we just want to be sure
that the new system will provide the same or better aeration than
the previous system.
AAk90fL
f A�FA( � n.�� -i{1� PC-,MhLTy FOR- cod%"c(70) �I i�ouT � A C is
�2VOOO You Mk( 01$0 To T� 1 s kH sP 4Ktalc, u�lT�i
�ntirvNc (� (nMPuA-NGE OIL Somt✓oNE A" Iigo F (q (eVIU-E
kditotJAL OPFtce)
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

,State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
July 21, 1994
Mr. Ronald D. Hilbelink
Assistant Vice President, Manufacturing
Alpha Cellulose Corporation
1000 East Noir Street, Box 1305
Lumberton, North Carolina 28359
AKT4
EDEHNR
Subject: Application No. ACDO05321
Acknowledgment of Receipt
Authorization to Construct
Alpha -Cellulose WWTP
Robeson County
FRIMM3I *fi["PifM
The Permits and Engineering Unit of the Division of Environmental Management
acknowledges receipt of your permit application and supporting materials on July 15, 1994. This
application has been assigned the number shown above. Please refer to this number when making
inquiries on this project.
Preliminary review of the plans indicates that the following information must be provided
before the Permits and Engineering Unit can complete its review:
• Although the horsepower of the blowers is provided in your letter, please have the
engineer submit a full description of the blowers and their capacity (i.e. the cubic feet per minute
capacity of the blowers).
• In order to expedite the Authorization to Construct permit, please verify the aeration
basin volume.
• Please provide a full description of the diffusers (the plans submitted do not provide a
detail of the diffusers).
• If possible, please provide calculations regarding the aeration requirements of the
previous set-up and provide information that the current diffuser scenario will provide equal or
better aeration.
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

Mr. Ronald Hilbelink
Alpha Cellulose Corporation
July 21, 1994
Page 2
Be aware that the Division's regional office, copied below, must provide recommendations
from the Regional Supervisor for this project prior to final action by the Division. I am, by copy of
this letter, requesting that our Regional Office Supervisor prepare a staff report and
recommendations regarding this discharge.
If you have any questions regarding this application, please contact me at [phone].
Sincerely,
Susan A. Wilson, Environmental Engineer
Permits and Engineering Unit
cc: Fayetteville Regional Office
Permit File ACD005321
Bill Brady, BE&K

Mr. Ronald Hilbelink
Alpha Cellulose Corporation
July 21, 1994
Page 2
Be aware that the Division's regional. office, copied below, must provide recommendations
from the Regional Supervisor for this project prior to final action by the Division. I am, by copy of
this letter, requesting that our Regional Office Supervisor prepare a staff report and
recommendations regarding this discharge.
If you have any questions regarding this application, please contact me at [phone].
Sincerely,
Susan A. Wilson, Environmental Engineer
Permits and Engineering Unit
cc: Fayetteville Regional Office
Permit File ACD005321
Bill Brady, BE&K

July 15, 1994
State of North Carolina
Department of Environment, Health and Natural Resources
512 North Salisbury Street
P.O. Box 27687
Raleigh, NC 27611
Attention: Ms. Coleen Sullins
Dear Ms. Sullins:
Reference: Alpha Cellulose Corporation - Lumberton, NC
NPDES Discharge Permit No. NC0005321
Request for Authorization to Construct
I have just had a phone conversation with Gregg Nizich of your
office concerning our request for Authorization to Construct. In
going over our application he stated that everything looked good
but he needed a statement concerning before and after oxygen and
horse power requirements of our system.
Alpha Cellulose Corporation currently has 18 aerators in its
aeration basin; 3-75hp, 14-40hp, and 1-35hp for a total of 82Ohp
(normal load use about 7O0hp). Our aeration basin is 17 feet
deep and the current aerators are theoretically only effective
down to 12-15 feet, leaving a possible 2-5 feet of dead area.
The new diffuser system will be set on the bottom of the basin,
thus ensuring oxygen throughout the basin. Because of better
oxygen transfer with diffusers compared to surface aerators, it
has been calculated that we need only 520hp for normal load. We
will be installing 3 - 350hp centrifugal blowers (2 for
operation, one for a spare), to be able to more than handle peak
loads.
1000 East Nair Street, Box 1305 Lumberton, North Carolina 28359 USA & 919 738 4201 FAX [phone]

v
Ms. Coleen Sullins
Authorization to Construct
July 15, 1994
In the near future, we plan on converting our pulp bleaching
system from chlorine to ozone. With ozone generation, there is
an amount of oxygen off -gases that we can divert to the diffusers
in the aeration basin, thus supplying 100% oxygen to a portion of
the basin and thereby reducing blower horse power demand.
If you need any further information please feel free to contact
me.
Sincerely,
)Wx4i
Ronald D. Hilbelink
Asst. VP Manufacturing
/cpt
CC: W. McAllister
Gregg Nizich

-:�;w
AT Z, rocWC-S 32-4
C�CC'L-ta('0s)Z0
4 2�4D
June 30, 1994
State of North Carolina
Department of Environment, Health and Natural Resources
512 North Salisbury Street
P.O. Box 27687
Raleigh, NC 27611
Attention: Mr. Donald Safrit, P.E.
Dear Mr. Safrit:
Reference: Alpha Cellulose Corporation - Lumberton, NC
NPDES Discharge Permit No. NC0005321
Request for Authorization to Construct
I am writing to request formal Authorization to Construct
approval for Alpha Cellulose Corporation for replacing its
current aerators in the aeration basin, with a fine bubble
diffusion system. The diffusion system offers better oxygen
transfer, better D.O. control and reduced horse power demand.
Enclosed find three complete sets of technical drawings and
specifications dealing with the proposed diffuser system. Also
enclosed is a check for $200. Upon review of the enclosed
materials if you have any questions or need any additional
information please feel free to contact me.
Sincerely,
Ronald D. Hilbelink
Asst. VP Manufacturing
/cpt
1000 East Nair Street, Box 1305 Lumberton, North Carolina 28359 USA ^c 919 738 4201 FAX [phone]

DIVISION OF ENVIRONMENTAL MANAGEMENT
July 25, 1994
M E M O R A N D U M
TO: Coleen Sullins, Unit Supervisor
Permitting and Engineering Unit 1
mu'
FROM: Michael Wicker, P.E., Water Quality Regional Supervisor
Fayetteville Regional Office
SUBJECT: Renewal of NPDES Permit No. NC005321
Alpha Cellulose Corporation
Robeson County
Please find enclosed the staff report and recommendations of the
Fayetteville Regional Office concerning the renewal of subject NPDES Permit.
If you have any questions or require any further information, please
advise.
MCW/PER/tf
Enclosure
cc: Technical Support Branch

SOC PRIORITY PROJECT:
If yes, SOC No.
To: Attention: Susan Wilson
Permits and Engineering Unit
Water Quality Section
July 25, 1994
NPDES STAFF REPORT AND RECOMMENDATIONS
County Robeson
Permit No. NC0005321
PART I. GENERAL INFORMATION
Yes No x
1. Facility and Address: Alpha Cellulose Corp.
1000 East Noir Street, Box 1305
Lumberton, NC 28359
2. Date of Investigation: January 5, 1994
3. Report Prepared By: Paul E. Rawls
4. Persons Contacted and Telephone Number:
5. Directions to Site: Facility is located 1000 Noir Street, Lumberton.
6. Discharge Point(s), List for all discharge points:
Latitude: 340 36' 20" Longitude: 780 59' 35"
USGS map extract attached.
USGS Quad No.: 123 SW USGS Quad Name: SW Lumberton, NC
7. Site size and expansion area consistent with application?
Yes No (If no, explain)
Application makes no reference of expansion area. Any expansion would be
within the flood plain of the river. The writer believes adequate land
is available if flood protection is employed.
8. Topography (relationship to flood plain included): Entire WWTP is within
Lumber River flood plain. Primary clarifier and aeration basin is
elevated. Secondary clarifiers are not.
9. Location of nearest dwelling: Greater than 500 feet.
10. Receiving stream: Lumber River
a. Classification: C-Swamp
b. River Basin and Subbasin No.: Lumber River Basin 03-07-51
C. Describe receiving stream features and pertinent downstream uses:
Fishing, boating, fish and wildlife propagation.

Staff Report and Recommendations
Page 2
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted: 4.0 MGD (Ultimate Design
Capacity)
b. What is the current permitted capacity of the Wastewater Treatment
facility? 4.0
C. Actual treatment capacity of the current facility (current design
capacity). 4.0
d. Date(s) and construction activities allowed by previous
Authorizations to Construct issued in the previous two (2) years.
February 15, 1994 - conversion of the DAF unit into a primary
clarifier and the addition of a 2-meter sludge press.
e. Please provide a description of existing or substantially
constructed wastewater treatment facilities.
The existing wastewater treatment facility consists of the
following:
Screening, manual grit removal, influent equalization, influent pH
adjustment, influent pumps, one primary clarifier, equalization
basin with nutrient addition, three (3) secondary clarifiers (two
(2) 55' diameter, one (1) 60' diameter], continuous recording
effluent flow meter, one (1) 1,500-gallon capacity sludge holding
tank, one (1) 2-meter sludge press and one (1) 1-meter sludge press.
f. Please provide a description of proposed wastewater treatment
facilities: Current application for Authorization to Construct is
for changing existing floating aerators to diffused air.
g. Possible toxic impacts to surface waters: Facility currently
monitors dioxin (2, 3, 7, and 8 TCDD); the writer has no knowledge
of dioxin being a concern.
h. Pretreatment Program (POTWs only): N/A
In development Approved
Should be requirre — Not neede3-
2. Residuals handling and utilization/disposal scheme:
a. Land Application Permit No.: WQ0002932
3,300-dry ton/yr land application program managed by facility.
b. Residuals stabilization: PSRP x PFRP Other
C. Landfill: N/A
d. Other disposal/utilization scheme (Specify): N/A
3. Treatment plant classification (Completed rating sheet attached):
Class IV

Staff Report and Recommendations
Page 3
4. SIC Code(s): 2621
Wastewater Code:
Primary 18 Secondary _
Main Treatment Unit Code: 04F0--F4
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grants Funds or are
any public monies involved (municipals only)? N/A
2. Special monitoring or limitations: In keeping with Basin Wide Strategy.
3. Important SOC, JOC, or Compliance Schedule dates: None.
Date
Submission of Plans and Specifications . . . . . . . .
Begin Construction . . . . . . . . . . . . . . . . . .
Complete Construction . . . . . . . . . . . . . . . .
4. Alternative Analysis Evaluation: Has the facility evaluated all of the
nondischarge options available. Please provide regional perspective for
each option evaluated.
Spray Irrigation: N/A
Connection to Regional Sewer System: N/A
Subsurface: N/A
Other disposal options: N/A
5. Other Special Items: N/A
PART IV - EVALUATION AND RECOMMENDATION
The applicant has requested that dioxin monitoring be changed from
annually to every other year. It is suggested that past dioxin tests values
be reviewed; and if appropriate, the permit be modified to dioxin monitoring
every other year but in no case less than once per permit cycle.
The applicant has also questioned the current limit for dioxin (2, 3, 7,
8 TCDD) limitation of 1.9 pg/1 in relation to the current test detection limit
of 10 pg/l. This office requests that the lowest detection level be continued
and reported accordingly.

Staff Report and Recommendations
Page 4
It is the recommendation of this office that the permit be reissued in
keeping with the Basin Wide Strategy.
Signature of Report Preparer
Water Quality Regional Supervisor
�t 1 �.s ig4
Date

RATING SCALE FOR CLASSIFICATION OF WATER POLLUTION CONTROL SYSTEMS
Name of Facility: Alpha Cellulose Corp.
Owner or Contact Person: Ronald Rodford
Mailing Address: P.O. Box 1305, Lumberton, NC 28359
County: Robeson Telephone: [phone]
Present Classification: Iv New Facility Existing Facility x
NPDES Per. No. NC00 05321 Nondisc. Per. No.WQ Health Dept.Per No.
Rated by: Paul Rawls Telephone: Date:
Reviewed by: Health Dept. Telephone:
tN Regional Office Telephone:
Central
ORC: Ronald Radford Grade:
Check Classification(s): Subsurface SF
Wastewater Classification: (Circle One) 1 II
Oitice Telephone:
IV Telephone: [phone]
,ray Irrigat' Land Application
III IV Total Points: -79
i : \I � : � �._ �► : ► � i 7 : lid 1� \ II: � ��. 1%.. �\I U. �.:�:�� \ u11. :: : it � i► � �'a����i'.'A 71=$1 � \�����trt.�� C
SUBSURFACE CLA_SS1FiCATION
(check all units that apply)
1—septic tanks
2. pump tanks
3 siphon or purr -dosing systems
4. sand filters
S. grease trapAniertaptor
6 oil/water separators
7 gravity subsurface treatment and disposal:
8. pressure subsurface treatment and disposal
SPRAY IRRIGATION a/5SiF)CAT10N
(check all units that apply)
1—preliminary
treatment (definition no. 32 )
2.
.lagoons
3-
septic tanks
4
pump tanks
5.
pumps
6.
sand filters
7—grease
trap/nterceptor
8.
oil/water separators
8_
disinfection
10.
chemical addition for nutrienUalgae control
11. spray irrigation of wastewater
In addition to the above classifications, pretreatment of wastewater in excess of these components shnli
be rated using the point rating system and will require on operator with an appropriate dual certification.
LAND APPLICAT10fVRESIDUALS CLASSIFICATION (Applies only to permit holder)
1. Land application of biosolids, residuals or contaminated soils on a designated site.
-------------------------------------------------------------
WASTEWATER TREATMENT FACJLJTY CLAS.SiFV_-ATi0N
The following systems shaA be assigned a Class i classification, unless the flow is of a significant quantity or the technology is unusually
complex, to require consideration by the Commission on a case -by -case basis: (Check B Appropriate)
1. OWwater Separalor Systems consisting only of physical separation, pumps and disposal;
2 SWic Tank/Sand Fifter Systems consisting only of septic tanks, dosing apparatus, pumps,sand titters, disinfection
and direct discharge;
3_ Lagoon Systems consisting only d preiminary treatment, lagoons, pumps, disinfection, necessary chemical treatment for
algae or nutrierd control, and duect discharge;
4. Gosed-loop Recycle Systems;
5. Groundwater Remediation Systems consisting only of oWwater separators, pumps, air -stripping, carbon adsorption, disinfection
and disposal;
6_ Aquacuiture operations with discharge to surface waters;
7- Water Plant sludge handling and back -wash water treatment;
a. Seafood processing consisting of screening and disposal.
9 _Single-family discharging systems, with the exception of Aerobic Treatment Units, will be classified if permitted after July 1,
1993 or I upon inspection by the Division, k is found that the system is not being adequately operated or maintained. Such
systems will be notified of the classification or reclassification by the Commission, in writing.

The following scale is used for rating wastewater treatment facilities: (circle appropriate points)
ITEM POINTS
(1 )
htdustrfal Pretresirnort thths or hdustrtal Pretreatment Program (we defintiion No. 33)...................................................4
(2)
DESIGN
FLAW OF PLANT 1N gpd (rot applicable to non -contaminated cooing waters. sludge handing facithws for
water purification plants, btalfy ciosed cycie sysiams(wa definition No. 11) and facilities consisting only of Item
(4)(d) or hams (4)(d) and (11)(d))
O- 20.000..... »..........»......_.._......_»..................................... ......... ._.---.............................................. 1
........................... »_................................... _.......... »»-'-........................... 2
60,001 - 100,000......»».................. ...................................... ...................... ...... _..-............ ............ 3
100,D01 - 250.000...-..-..».»............ ...................... .......... _... .--.............. .--..»»» ......................... 4
250.001 - 600,D00... ._................. ................... ............................ _.....»»..--....... ...................
600.001 - 1,000,D00...... ...... »... ..... .......................... .........._.........» ..»..».......--_.......................
1.000,D01 - 2.000,000......... ............................................................. ...»»............................................ i10
2,000,001 (and up) rats 1 point additional for each 200.D00 gpd capacity up to a maximum of ..-.»._...... + 10 =
Design Flow (gpd) g, coon neo_
(3)
PREUMNARY
uNrTSrPRDCESSES (ase defr*w No32)
(a)
Bar Screens ...... .... .... .»........ .......................... .......».......... ................. »......... ........ ......................... 1
(b)
of
fMechan"I Screens, Static Screens or Comminuting Devices --------------- ....-.»-»....-....»---_ ._...._....._...
(c)
trl Remora' ........ .... ...... ».................................................................................................................... .1
(d)
or
ihw:fnrticaJ or Aerated Get Removal ...... .............. »......................................................................................2
(e)
Flow MeaaniV Device ....-.».... »... ._..»... _................. »........................................................._.....................1
(1)
or
frtstrumented Flow Measurement ... ........ ....... .......................................................................................
(9)
(h)
PreaeralIon........... »........... »...»..._... .................................................................................................
krfluent Flow Equalization.........................................................................................................................
(1)
2
Grease or Oil Separators -Gravity......_..._....»..._..._...._..._...._»._..._........._......._...»........._..._..............2
Mechanical ...... ....»................ ................................................. _................................................................ 3
DissolvedAY Flotation ... ........................ _...................................................................................................
t))
PrechiorNutbn......... ..._........... ......... .... »............. ».............................. .-................................................
(4)
PFRAkRY TREATMENT L141TSPFOCESSES
(a)
Septic Tank (see defiNtion No. 43)..... _.... .............. .......... ................................................................... 2
(b)
Imhoff Tank ..... ......... ... ........................ ..-............................ ..-.............................................................
(c)
Primary Clarifiers........................................................................................................................................5
�
(d)
Seniing Ponds or Sealing Tanks for Yiorganic Non -toxic Materials (sludge handling facilities for water
purtlicalion plants, sand, gravel, stone, and other mining operations except recreational activities such as gem
orgold mining) ............................. ........... »............................................................................................. 2
(5)
SEOCNakFiYTREATMENT
WTSrPFCCE•SSES
(a)
Carbonaceous Stage
(1) Aeration -Mph Purity Oxygen System .......... .... ......................................................... 2�endin
DmucadAir System......................................................................................................`�fo� current
Mechanical Air System (fixed, floating or rotor)....._..._..._..._..._..._..._..._...»..._..._..._.IJB
SeparateSludge Reaeraiion............................................................................................
(11) Trickling Filer
HighRate ........ _........ _................ »... »... ».-.-..-................. .............. ............................... 7
StandardRate ............ __......................... »».............................................................
PackedTower................................................................................................................5
(11() Biological Aerated Mar or Aerated Biological Filer -»._.._......_.. ... _.__.___._.. ..._... .1 0
{iv) Aerated lagoons .......................................... »... .......................................................... 10
(v) Rotating Biological Contactors .................................... ..... ......................... ................. 10
Of) Sand Fitters -intermittent biological ..... »........ ....... »............................ _........................... 2
Recirculatingbioioglcal........................................ ............................................................3
(v11) Stabtltzalbn Lagoons ........... ...»................................................................................. ...
(vfli)clwfw....................................... _... ........... ............................................................. ..f.S
(Ix) Si stage system for combined carbonaceous removal of BOO and nhmgenous removal
nitrification (see definftion No. 12)(Points for this Item have to be in addition to ksms
(5)(a)(1) through (5)(a)(viil),
No.3a)ci)
Wllzing the mended aeration process (see definition ...... ..................................
uttlizing other than the extended aeration process. ..... ............................................. 8
(x) Nutrient addniors to enfwwo BOO removal ............... ............ ......... .._....................... 5
(xi) Blologkal Culture ('Super Bugs')addhion...... .................. _.........................................
(b)
Nlvogenous Stage
{I) Aeration - High Purity Oxygen System.0
DiffusedAl+ Systam........ ........................................................ .........»._...............1 0
Mechanical Air System plied. floating of ..8
Separate Sludge Reaeration....................... _.»............_.....»»........................................3
(fi) Trickling FYter•High Rate ........ ..-».-»....... ................................................ ....................7
StandardRate.........»».»..».. .».._»....».........».»..»....»...........»...............................5
PackedTower ...... »....»».^_»............................ _. .. »..-..-»».............. _...........
(Ip) Sio$4"f Asraled Filer or Aerated Biological .10
(lv) Rotating Biological Confatlors........ .............. _..... »..... »...... _._..... ........................... ..10
(v) Sand Fihw - infermfaert 2
Reclrrulating biologlul...._ .»_ �.»»» r................... ..»--».».----.............. ............ .........
(VI) C]arfr..»»...»__......... _»..».............. ..»...»...... »» ».» . »_. ...»»....».5
(6)
TERTIARY OR ADYANMITEATMENT
(a)
AcWa*d Carbon Bens -
5
withoutcarbon reganeralfom....». _....»....._ ......».».....»»»»»_._»..................»...........
erhhcarbon regeneration .............. »_.».» ...». » »._. » . »..___. » »_.» ....16
(b)
Powdered or Granular Activated ated Carbon Feed
1Mfthout carbon regene5
with carbon 15
(o)
AY atrlppinp. ».»�w... ._._ _._....» ».........»_. _».»...._...»._..»�....» »............». .5
(d)
Denhrffkatbn Proosaa_.� _._...._ ...._ ».»...._...._...... » »...... _ �» ».�... �...»».»...10
(a)
Elect rodialysk..._
(1)
(9)
Foam Separation
ion Exchange...» ........ ............. »..................... .... ..................... ................. »».»..-........... _.
(h)
Land Application of Treated Effluent (see definition No. 22b) (rot applicable for sand. pravef, atone
and other similar mink-g operations) by high rate
(I)
ll1
Mkroscreena.......».»..»....»...........».......»»».......»».......... »..............
Phosphorous Flertoval by Biological Processes (See definilon No. 26)..._» »... ».». » .......».. ....20
(k)
Polishing Ponds without oration » »» »_..» »..»_..» » _ » .».. » ... . »..»»..»•••••••2
B
with

(I)
Post Aeration - cascade .......................... ....................................................................................................0
.diffused or mechanical........................................................................................................2
(m)
Reverse Osmosis........................................................................................................................................5
(n)
Sand or Mixed -Media Filters - bow rate ..... ...... _................................................................._...._....................2
highrate......................................................................5
(o)
Treatment processes for removal of metal or cyanide...................................................................................1 5
(p)
treatment processes for removal of toxic materials other than metal or cyanide...__......__.__._».» ..._.„„._.15
(7)
SLUCGE TREATfvtt W
(a)
Sludge Digestion Tank - Heated (anaerobic) ............... ................................. ........._......._.......„..............t o
Aerobic.............................................................................................................................................5
Unheated(anaerobic)...............................................................................................................................3
b
Sludge Stabilization chemical or thermal) .....................................................................................5
(c)
Sludge Drying Beds - Gravity......................................................................................._.............................2
VacuumAssisted......................................................................................................................................5
(d)
Sludge Eutriation... „................................................................................................................................5
(e)
Sludge Condhloner (ch6mrtcal or thermal) ............................... ....................................................................5
(f)
Sludge Thickener (gravity)......_............................................................................................I..................�.
(g)
Dissolved Air Flotation Unit [not aM4cab4s to a unit rated as(3)(i))..........................................................�'
(h)
Sludge Gas Utilization (including gas storage) ....... _......... ........... _.................... »........ _......... .................... 2
(1)
Sludge Holding Tank - Aerated .......................................... »........................................................................
Non- as rat ad ................................. -........................................................................................................... 2
(l)
Sludge Incinerator (not including activated carbon regeneration)ISL
(k)
Vacuum Fitter, Centrifuge, or Filter Prase or other similar dewaiering .100
(8)
RESIDUALS
LTTILIZATIOWDISPOSAL (nduding incinerated ash)
(a)
Lagoons..................................................................................................................................................2
(b)
Land Application (surface and subsurface) (see definition 22a)
by contracting to a Land application operator or landfill operator who folds the land application permit
2
orLandfill pent'th.......................................................................................................................................
(c)
Dedicated Landtill(buriai) by the permInse of the wastewater treatment facility..._ .................... „.................. .
(9)
DLSIFECTCN
(a)
Chlorination.........„........„........................................................................................................................5
(b)
Dechlorination..........................................................................................................................................5
(c)
Ozone .......... »..........................................................................................................................................5
(d)
Radiation.................................................................................................................................................5
(10)
CHEMICAL ADDITION SYSTEM(S) ( see definition No. 9) (rot applicable to chemical additions rated as ham (3)0),
(5)(a)(xi),
(6)(a), (6)(b), (7)(b). (7)(e). (9a), (9)(b) or (9)(c) 5 points each:
List.Twr4C
Lreni- {+ od3....................................................................................... ............................................®
................................................................................................................................... 5
................................................................................................................................... 5
....................................................................................................................... 5
(11)
MLSCE
UANEC1JS UNITSrPROCESSES
(a)
Molding Ponds, Folding Tanks or Settling Ponds for Organic or Toxic Materials Including wastes from mining
operations containing nitrogen or phosphorus compounds in amounts significantly greater than is common
fordomestic wastewater............................................................................................................................4
(b)
Effluent Flow Equalization (not applicable to storage basins which are inherent In land application systems).....2
(c)
Stage Discharge (not applicable to storage basins inherent in land application systems).. _._....._.__......».....�5,
(d)
Pumps................................................................................................................................................... kA,
(e)
Stand -By Power Supply.......................................................................................................................... J
(f)
Thermal Pollution Control Device............................................................................................................_ N
TOTALPOINTS........................................................................•zi_
CASSIFICATICN *This ratip is bas d on diffused
aeration l er No. �)
Cta$ I...........................................................................................................5-25 Points
Class11.........................................................................................................26.50 Points
ClassII........................................................................................................ 51.Ar, P ints
ClassN..................................................................................................... 66-Up Point?
----------------------------------------------------
Facilihies having a rating of one through four points, Indus", do not require a certffied operator.
Facilities having an activated sludge process wig be assigned a minimum classification of Class IL
Facilh;ss having treatmem processes for the removal of metal or cyanide will be assigned a minimum classification of Class II.
Facilities having tntatment processes for the biological removal of phosphorus will be assigned a minimum claWriicaton of Class III.
A004 DEFINITIONS
The following definhions shall apply throughout this Subchapter.
(1) Activated Carbon Bads. A physical/chemical method for reducing soluble organic material from wastewater effluent; The column -type beds used in this
method will have a flow rate varying from two to eight gallons per minute per square foot and may be either upflow or downflow carbon beds. Carbon may or
may not be regenerated on the wastewater treatment plant she;
(2) Aerated Lagoons. A basin In which all solids are maintained In suspension and by which biological oxidation or organic matter is reduced through artificially
accelerated transfer of oxygen on a flow -through basis;
(3) Aerator A process of bringing about imamate contact between ale or high purity oxygen In a liquid by spraying, agitation or dffusiong3a) Extended
Aeration. An activated sludge process utiNzing a minimum hydraulic detention flue of 18 hours.
(4) Agriculturally managed she. Any site on which a crop is produced. managed. and harvested (Crop includes grasses, grains, tress, etc.);
(5) Air Stripping. A process by which the ammonium Ion Is first convened to dissolved ammonia (pH adjustment) with the ammonia then released to the
atmosphere by physical means; or other similar processes which remove petroleum products such as benzene, toluene, and xylents;
(6) Carbon Regeneration The regeneration of exhausted carbon by tie use of a furnace to provide extremely high temperatures which volatilize and oxidize the
absorbed lrripuritles-,
(7) Carbonaceous Stage. A stags of wastewater treatment designed to achieve `secvndary' etffuant gilts;
(8) Centrifuge. A mechanical oevics In winch centrifugal force Is used to ssparate solids from liquids or to separate liquids of different denst.as;
(9) Chemical Addition Systems- The addhion of chemical(s) to wastewater at an applkaflon point for purposes of Inprvving solids removal, pH adjustment,
aJkalinhy control, etc.; the capability to experiment with dtterem chemicals and different application points to achieve a specific result will be considered one
system; the capability to add chemical(s) to dual units will be rated as one system; capability to add a chemical at a differam application ponta for different
purposes will resuh In the systems being rated as sepanU systems;
(10) Chemical Sludge Conditioning. The addition of a chemical compound such as Ilene, ferric chloride, or a polymer to wet sludge to coalesce the mass prior to
Its application to a dewatering device;
(11) Closed Cycis Systems. Use of holding ponds or holding tanks for containment of wastewater containing inorganic, non -toxic materials from sand. gravel,
crushed store or other similar operations. Such systems shall carry a maximum of two points regardleas of pumping facilities or any other appurtenances;
(12) Combined Removal of Carbonaceous BOO and Nitrogenous Ramaval by Nltrlficatbn- A single slags system required to achieve permit effluent limits on BOO
and ammonia nitrogen whin the same biological reactor,
(13) Dechioriraton. The partial or complete reduction of residual chlorine In a Squid by arty chemical or physical process;
(14) Dsnhrhicaton Process_ The conversion of nitrate -nitrogen to nitrogen gas;

(15) EMctrodaysk. Process for removing ionized Saks from water through the use of ion -selective ion-sathanps membranes;
(16) Filter Pro". A prooess operated mechanically for partially dowatering sludge;
(17) Foam Separation. The plarved frothing of wastewater or wastewater effluent as a means of removing excessive amounts of datergent materials through
the Introduction of air In the form of fine bubbles; also Called loam fractionation;
(18) Grit Removal. The process of removing grt and other heavy mineral matter from wastewater;
(19) Mtoff Tank- A deep two story wastewater tank consisting of an upper isodimnentation chamber and a lower sludge digestion chamber.
(2O) kefrumerned Flow Measurement. A device which Indicates and records rate of flow;
(21) ion Exchange. A chemical process in which Ions from two different molecules are exchanged;
(22) Land application:
(s) Sludge Disposal. A Mal sludge disposal method by which wet sludge may be "had to land either by spraying on the surface or by subsunaee Injection
p.a.. ct"al ploy); (nw applicable for types of sludge described in (11) of this Rule);
fjb) Troatod Ef sera. The process of spraying freed wastewater onto a land area or ofyner methods of application of wastewater onto a lard area as a
tlnearts of final deposal or treatment;
( 3) Micrvac oon A bow speed. continuously back -washed, rotating drum finer operating under gravity Conditions as a polishing method for removing
suspended solids tram istitusn;
(24) Nitrification Process. The b'iocheimical conversion of tmoxidtzed nitrogen (ammonia and organic nluogen) to oxidized nitrogen (usually nitrate);
PS) W.rogenous Stage. A separate stage of wastewater troafm+ent designed for the specific purpose of converting ammonia nitrogen to nitrate nitrogen;
R6) Phosphate Removal, Bblopial. The removal of phosphorus from wastewater by an oxiwanoxic process designed to enhance luxury uptake of phosphorus
by the microorganisms;
(27) Polishing Pond. A holding pond following secondary treatment with sufflclont detention time to allow settling of finely suspended solids;
(2E) Post Aeration Aeration following conventions! secondary trestmerd urffs to Increase amkent D.O. or for any other purpose;
(29) Pod AeratiorL (Cascade) A polshing method by which dissolved oxygen is added to the effluent by a nonmschanical, gravity meant of flowing down a
series of slept or weirs; The flow occurting across the slops or weirs moves in a fairly thin layer and the operation of the cascade requires no operator
adjustment; thus, zero points are assigned own though Ihie is an essential step to meeting the emits of the discharge pornit;
(30) Powdered to Granular AcNatod Carbon Feed. A biophysical carbon process the utillzes biological activity and organic absorption by using powdered or
granular activated carbon; Virgin or regenerated carbon is feed controlled into the system;
(31) Preaerellon A tank constructed to provide aeration prior to primary treatment;
(32) Proliminary Units. UnA operations In the troatmont process, such as screening and comminution, that prepare the liquor for subsequent major operations;
(33) Industrial Pretreatment.
(a) Pro -treatment Lk*, lidustrial. The conditioning of a waste at Its source before discharge, to romow or to neutralize substances Injurious to sawers and
trsaimnant processes or to *flea a partial reduction in bad on the treatment process which is operated by the same governing body as the wastewater
treatment plant being rated;
b) Pro-trsatment Program, Industrial - mutt be a State or EPA roqulrod program to recelve points on the rating sheet;
(34) Primary Ciarttiers. This first settling tanks through which wastewater is passed in a troument works for the purpose of removing settleable and suspended
solids and BOO which is associated with the solids;
(35) Pumps. All influent, effluort and in -plans pumps;
(36) Radiation. Disinfection or sterilization process utilizing devices omtning ultraviolet or gamma rays;
(37) Ravers& Osmosis. A troatmtont process In which a heavy contaminated liquid Is prossunzod through a merntbrane forming nearly pure liquid free from
au"rided solids;
(38) Rotaling Biological Contractors. A fixed biological growth process in which wastewater flows through tanks in which a series of parttaly subnerped cinwiar
surfaces are rotat*d;
(39) Sand Rtars:
(a) Inlornhtent Biological. Filtration of ofifuent following soptic tanks, lagoons, or some other treatment process in which further bio lecompositlon is
expected to produce desired effluemis; Hydraulic loading rates on these tillers are computed in gpdrac and have a resulting low gpmvsf (less than one);
b) Recirculating biological • the same typo of sand filter ao defined in Subparagraph (39) (a) of this Rule with the added capability to rerycie effluent back
through the sand finer,
(40) Sand or Mixed-Modia Flners. A polishing procsss by which effluent limits are achieved through a further reduction of suspended solids;
(a) low rate — gravity, fydrautkally loaded filter with loading rates in the one to three gpmvd tangs;
(b) high rate — a pressure, hydraulically leaded filter with loading rates In the i" gpmvd range; At any rate, the boding rate will exceed three gpmif;
(41) Secondary Ctartliers. A tank which follows the biological unit of treatment plant and which has the purpose of removing sludges associated with the
biological treairnent unlis;
(42) Separate Sludge Reaeratlon A pan of the contact stabilization process where the activated sludge is transferred to a tank and aerated before retuming it
to the contact basin;
(43) Septic Tank A single -story sattling tank in which settled sludge Is In contact with the wastewater flowing through the tank; shall not be applicable for
septic tarts systems serving simple family residences having capacity of 2.000 galiors or less which discharge to a nitrification field;
(44) Sludge Digestion The process by which organic or volatile manor and sludges gasified, Jquslied, minerarized or convened into more stable organic matter
though tho activity of living organisms, which Includes aerated holding tanks;
(45) Sludge Drying Beds. M area comprising natural or artificial layers of porous materials upon which digested &swap* sludge Is died by drainage and
evaporation;
(46) Sludge Elutriation. A process of sludge conditioning In which certain eortwituents are removod by successive washings with fresh water or plant effluent;
(47) Sludge Gas Utilization The process of using sewage gas for the purpose of healing bulidings, drtving anginas, etc.;
(48) Sludge Holding Tank (Aerated and Non serated). A tank utilized for small wastewater treatment plants no( containing a digester in which sludge may be
kept fres)), and supernatant withdrawn prior to a drying method (i.e. sludge drying beds); This may be done by adding a amafl amours of air simply to keep the
sludge fresh, but not necessarily an amour that would be required to achieve stabilization of organic matter. A nonaerwed tank would simply be used to
decant sludge prior to dewatering and would not allow long periods (several days or detention) without resuming odor problems;
(49) Sludge Incinerators- A furnace designed to bum sludge and to remove all molsturs and comb=11:4 materials and reduce the sludge to a sterile ash;
(50) Sludge Stabilization (Chemical or Thermal} A process to make treated sludge less odorous and putrescaie, and to reduce the pathogenic organism
content; This may be done by pH ad)ustmont, chlorine dosing, or by host treatment;
(51) Sludge Thickaner. A type of sodimantation tank In which the sludge is psrmittod to tattle and thkkan through agitation and gravity;
(52) Slabilaalion Lagoon A type of oxidation lagoon In which biok>gical oxkiation of organic matter Is effectod by natural trandor of oxygen fo the water from
air (not a polishing pond);
(53) Stand -By Power Supply. On she or portable oleariat generating equipmant;
(54) Static Scv*ere. A stationary scroon designed to remove solids, lnciuding non-biodogredable particulate (flowable solids, suspended solids and BOD
reduction) from municipal and industrial wastewater irsatment sysems;
(55) Tertiary Treatment. A stage of treatment following secondary which is primarily for to purpose of offluard polishing; A tetfting lagoon or sand or Coat inner
Wright be employed for this purpose.
(M) Thermal Pollution Control Device. A dovke providing for the transfer of hold from a fluid fleeing in tubes to another fluid outside the tubes, or vim versa;
or other mears of regulating liquid temperatures;
(57) Thermal Sludge Conditioner. A conditioning process by which heat Is added for a protracted period of ante to kriprove the dewaterabifty of sludge by the
sokubillzdng and hydrauitzing of the smaller and more highly hydrated sludge panicies;
(M) Toxic Matorais. Those wastes or combinations of waves. Including disease -causing agents which attar discharge and upon exposure, ingestion, tnhalatbn
or asalmnation into any organiser, either directly from the orwironmont or kdirect)y by Lipeslion through food desire, will cause death, drseaoe, behavioral
abnormalities, cancer, genetic mutations, physiological malfunctions (Including malfunctions In roproducllon) or physical doiformsflors, in such organisms or their
sfisprtng; Toxic materials Include, by way of illustration and rot Nmhallon: load, cadmium, chromium, mercury, vanadium, arsenic, zinc, ortho-rhtrti-chlorobonzone
(ONCE), pohychiorinated biph" (PCBs; and dkhlorodiphonyl trichioro*thans (DDT); and any other maenals that have or may hereafter be detomtired to have
toxic proponles;
(52) Trickling Fliter. A bbbglcal treatment unit oon&Wing of a material such as broken [tone or rode over which wastewater is drarbuted; A high rats trickling
Mar is one which operated al between 10 and 30 rngd per acre. A low rue trickling fiher Is one which is designed to operate at ore to four mpd per acre;
(50) Trickling Finer (Packed Towor). A plug flow type of operation In which wastewa:er flows down through succosshve layers of media or filtrate maisrial; Organic
matwW Is removed continually by th* active blok>pical fixed growth in each sutxesdvo layer. This method may produce 'secandaty quality smuGht or may be
adaptod to produce a Nullied effluent;
(61) Vacuum Finor, ContrMugm or Finer Presses. Devices which are doso,*d to remove excess water from tither digested or undigatdod sludge prior to disposal
or futher frsatment

CP&L Weather,
_ CP&L Weath
NPDES discharger
County Boundary
f Lumber River Basin Hydrography
Hi hwa
9 Ys
Municipal boundary
N
A
F-
41
Alamac Knit Fabric, Inc.
Buckeye Lumberton
Outf al 1001
.- � i
City of Lumbert
Buckeye Lumberton, Incorporated
NC0005321
Robeson County
0.5 0 0.5 1 Miles
211
on.
Facility Information
State Grid: 123 SW
USGS Quad: SE Lumbeton
Subbasin: 03-07-51

of North Carolina IT
artment of E ivironment, _ffl:WYTA
Ith and Natural Resources 4 •
Sion of Environmental Management
0'WWft%% �"_
i B. Hunt, Jr., Governor p E H N R
aththan B. Howes, Secretary
Preston Howard, Jr., P.E., Director
February 15, 1994
fr. Waylon McAllister
alpha Cellulose Corporation
;000 East Noir St., Box 1305
.Lumberton, NC 28359
Subject: Permit No. ACCO05321
Authorization to Construct
Alpha Cellulose Corp. WWTP
Robeson County
Dear Mr. McAllister:
A letter of request for an Authorization to Construct was received September 22, 1993 by the
Division and final plans and specifications for the subject project have been reviewed and found to be
satisfactory. Authorization is hereby granted for the conversion of the Dissolved Air Flotation unit into a
primary clarifier and the addition of a new Andritz-Ruthner belt filter press or equivalent and all the
necessary piping, valves and appurtenances needed for proper operation and compliance with the state
regulations with discharge of treated wastewater from the wastewater treatment facility into the Lumber
River.
This Authorization to Construct is issued in accordance with Part III, Paragraph A of NPDES
Permit No. NC0005321 issued December 9, 1992, and shall be subject to revocation unless the
wastewater treatment facilities are constructed in accordance with the conditions and limitations specified in
Permit No. NC0005321.
The sludge generated from these treatment facilities must be disposed of in accordance with G.S.
143-215.1 and in a manner approved by the North Carolina Division of Environmental Management.
In the event that the facilities fail to perform satisfactorily, including the creation of nuisance
conditions, the Permittee shall take immediate corrective action, including those as may be required by this
Division, such as the construction of additional or replacement wastewater treatment or disposal facilities.
The Fayetteville Regional Office, telephone number 919-486-1541, shall be notified at least forty-
eight (48) hours in advance of operation of the installed facilities so that an in -place inspection can be
made. Such notification to the regional supervisor shall be made during the normal office hours from 8:00
a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays.
Upon completion of construction and prior to operation of this permitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been installed in
accordance with the NPDES Permit, this Authorization to Construct and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box 29535, Raleigh, NC
27626-0535.
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

Permit No. NCOOACC05321
Authorization to Construct
Alpha Cellulose Corp.
February 15, 1994
Page 2
Upon classification of the facility by the Certification Commission, 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 and grade to comply with
the conditions of Title 15A, Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class H, I1I, 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 must
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.
A copy of the approved plans and specifications shall be maintained on file by the Permittee for the
life of the facility.
Failure to abide by the requirements contained in this Authorization to Construct may subject the
Permittee to an enforcement action by the Division of Environmental Management 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.
One (1) set of approved plans and specifications is being forwarded to you. If you have any
questions or need additional information, please contact Mr. Randy L. Kepler, telephone number
919/733-5083.
Sincerely,
S
�—P,reston oward, 7r., P.E.
cc: Robeson County Health Department
Fayetteville Regional Office, Water Quality
Training and Certification Unit
Permits and Engineering

State of North Carolina701
Department of Environment,
Health and Natural Resources , 1�
Division of Environmental Management / ► A
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary [D E H N F1
A. Preston Howard, Jr., P.E., Director
April 30, 1993
Mr. Michael G. Hardie
Director of Technical Services
Alpha Cellulose Corporation
P.O. Box 1305
Lumberton, North Carolina 28359
Subject: Alpha Cellulose Corporation
NPDES Permit No. NC0005321
Long -Terre BOD Monitoring Agreement
Robeson County
Dear Mr. Hardie:
I am writing to inform you that the long-term BOD monitoring requirements for Alpha
Cellulose Corporation need not be continued through the summer of 1993. The Division of
Environmental Management (DEM) has received all of the data for the summers of 1989
through 1992 from each of the three facilities involved (Lumberton WWTP and West Point
Pepperell included). The instream and effluent data were used to calibrate an intensive
model for the Lumber River, and in this case, specifically, the segment of stream below
Lumberton proper.
Long-term BOD data were used to estimate BOD ultimate concentrations using the model
BODCURVE (Barnwell). These data were used to estimate CBOD, NBOD, and a
CBOD/BOD5 to ratio for each facility The CBOD to BOD5 ratios were used with facility
self monitoring BOD5 data to estimate CBOD loading from the facilities and instream
concentrations of CBOD for the model calibration.
The long-term BOD data submitted by Alpha Cellulose were evaluated for the years 1990,
1991, and 1992. The 1989 data were not used since the analyses were being performed by
different laboratories and criteria for analyses were not consistent. The effluent data for
1992 were used for model calibration since that was the year that DEM's Water Quality
Intensive Survey Unit visited and performed a reconnaissance on the River. The instream
data collected by all three facilities over three years were used for instream concentrations to
calibrate the model.
Since model calibration has been completed for the Lumber River and we are now into the
allocation stage, further intensive sampling for long-term BOD data is not warranted at
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

this time. The data submitted were a great help for Water Quality's Technical Support
Branch to calibrate the sensitive area where your discharge is located. The Lumber River is
impacted by an increased amount of discharges directly below the City of Lumberton. At
permit renewal for this facility the long-term BOD monitoring may be a requirement for the
effluent only.
Please notify Carla Sanderson at [phone] if you have any further questions or
comments concerning this matter.
Sincerely,
Steve W. Tedder, Chief
Water Quality Section
cc: Mick Noland
Coleen Sullins
Carla Sanderson
Central Files

NPDES WASTE LOAD ALLOCATION
w
PERMIT NO.: NC0005321
PERMITTEE NAME: Alpha Cellulose Corporation
FACILITY NAME: Alpha Cellulose Corporation
Facility Status: Existing
Permit Status: Modification
Major -V
Pipe No.: 001
Minor
Design Capacity: 4.0 MGD
Domestic (% of Flow):
Industrial (% of Flow): 100 %
Comments:
The facility wants to increase flow from 1.8 MGD to 4.0 MGD. They
have offered to have other limits remain the same. Bleached Pulp
manufactured from cotton linters
No effluent guidelines - BPJ
RECEIVING STREAM: Lumber River
Class: C-Swamp
Sub -Basin: 03-07-51
Reference USGS Quad: 123 SW (please attach)
County: Robeson
Regional Office: Fayetteville Regional OfficeRegional Office
Previous Exp. Date: 6/6/93
Treatment Plant Class: Class IV
Classification changes within three miles:
none
Requested by: Rosanne Barona Date: 2/26/92
Prepared by: Date: 5 1 (.p qo2
Reviewed by: y i Date:
Modeler Date Rec. #
Z
Drainage Area (mil) 'J [�_ Avg. Streamflow (cfs): g53
7Q10 (cfs))) Winter 7Q10 (cfs) 30Q2 (cfs)
Toxicity Limits: IWC % Acute hronic
Instream Monitoring: "� ll o.4�eje 13ee \�
Parameters �(�, l�YY1P2`CUhO� l'DI�C� �(� �4 , �-t, �Gi!�
Ile-
I�l
Upstream S Location JPLO
Downstream es Location 1 �}k%e, g- 3
a -A1 SR ai,;21
Effluent
Characteristics,
BOD5 (
D.O. (, .g/1)
5
TSS (�. ' i
y a 5
g5�0J,
pH (SU)
Lon - km-bc D
ob v
ICU u-� (�
� s • V11�C�u.,�.-�V
V�
� e a�v� :
i� ��
i ►�+ �o�e. '
orwry
�,g°C oar°
Comments: GLh d ' P- V�-e M St O aL6E i � +0 lAaLd Sa ° L
-)Vao added ak-k FaL5kc
0 K' Tem" 64u� A em
.a kvq.
CAL k� r,�14
�

t
FOR APPROPRIATE DISCHARGERS. LIST COMPLETE GUIDELINE LIMITATIONS BELOW ,
Effluent Characteristics
Monthly
DailyAverage Maximum
Comments
cu, ;per-eas /. M GD
-Ft,
Bp
lis
det
� 5
6q. o
-r 5s
a5, 0
50. 6
* b`5:nn;'�l lr151Q 3
Tons /Yr
Type of Product Produced
-L-bsMay Produced
Effluent Guideline Reference
Gy►` C6 ffaq ,'17
q Y, 0 0 o 1 N c r r-*j:
n e— t3 P S
Pc;al wl r
5 of 00 0

R► CEIVED
DEHHR-DEM-WO
PERtiI T S & E"7aiH. U
'7;-) Ape�� ?O 4- 32
I7I�T
FACT SHEET FOR WASTELOA.LOCAT1�d�
Request # 6791
Facility Name: Alpha Cellulose
NPDES No.: NC0005321
Type of Waste: Industrial - 100%
Facility Status: Existing
Permit Status: Modification APR 14 1992
Receiving Stream: Luumber River
Stream Classification: C-swamp ENV. MANAGEMENT
Subbasin: 030751 PAYETTEVILLE REG. OFFICE
County: Robeson Stream Characteristic:
Regional Office: FRO USGS # 2.1341.7900
Requestor: Rosanne Barona Date: 1990
Date of Request: 2/26/92 Drainage Area (mi2): 712
Topo Quad: I23SW Summer 7Q10 (cfs): 120
Winter 7Q10 (cfs): 191
Average Flow (cfs): 853
30Q2 (cfs):
IWC M: 5.0
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
Facility requests for increase in design flow with no increased loading. Interim limits are provided
(same as existing load) with the condition that these limits may change when the basinwide
modeling analysis has been completed for the Lumber River. Low dissolved oxygen levels are
observed from mstream self -monitoring data below this discharge several miles downstream on the
Lumber River. Wasteflow from this type of industy is considered very resilient and may have a
. nificant affect on the upcomin modelig analysis for the LumbeRiver. ,
priori jilv+& ahu� sly -faoAd 7 ib ty re oima IK
Special Schedule Requirements and additional comments frof Reviewers:
Recommended by:
Date: Lj/ Lq'D-
Reviewed byri
�n
Assessment:
Date:
Instream
Regional Supervisor:
Date: j /
r—�
Fn
4'� rn
rn
Permits & Engineering:
Date:
C"
ZFE
RETURN TO TECHNICAL SERVICES BY:
MAY 0 3 1992

2
Type of Toxicity Test:
Existing Limit:
Recommended Limit:
Monitoring Schedule:
Existing_Limits
Wasteflow (MGD):
BODS (#/d):
TSS (#/d)
NH3N (#/d)
DO (mg/1):
pH (SU)
chlorine (ug/1)
Dioxin (pg/1):
Pollutant Analysis:
Long -Term BOD:
TOXICS/METALS/CONVENTIONAL PARAMETERS
Chronic Pass/Fail
2.1 %
5.0%
FEB,MAY,AUG,NOV
Daily Ave
Daily Max
1.8
332
664
425
850
83
166
5
6-9
6-9
Monitor
Monitor Annually
Monitor
4.4
The facility discharge shall not cause the temp. of the receiving waters to ecxceed 2.8 degrees C above background
and in no case cause it to exceed 32 degrees C
Recommended Limi
Daily Ave
Daily Max
Wasteflow (MGD):
4.0
BODS (#/d):
332
664
TSS (#/d)
425
850
N113N (#/d)
83
166
DO (mg/1):
5
pH (SU)
6-9
6-9
chlorine (ug/1)
Monitor
Dioxin (pg/1):
1.9
Pollutant Analysis:
Monitor Annually
Long -Term BOD
Monitor
The facility discharge shall not cause the temp of the receiving waters to exceed 2.8 degrees C above background
and in no case cause it to exceed 32 degrees C
Limits Changes Due To:
No limits changed wxcept wasteflow
BPJs given for limits
Paramgjg�ss) Affected
Parameter(s) are water quality limited. For some parameters, the available load capacity of the immediate
receiving water will be consumed. This may affect future water quality based effluent limitations for additional
dischargers within this portion of the watershed.
OR
No parameters are water quality limited, but this discharge may affect future allocations.

INSTREAM MONITORING REQUIREMENTS
Upstream Location: At SR 1620 (existing location)
Downstream Location: 1) At SR 2123 and 2) At SR 2121 (existing locations)
Parameters: DO, Temperature, Conductivity, pH, and Long-term BOD (see attached)
Special instream monitoring locations or monitoring frequencies:
See attached special requirements for instream monitoring
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
AAd .quacv of Existing Treatment
Has the facility delrlonstrated the ability to meet the proposed new limits with existing treatment
facilities? Yes et// No
If no, which parameters cannot be met?
Would a "phasing in" of the new limits be appropriate? Yes No t.--
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
If no, why not?
Special Instructions or Conditions
Wasteload sent to EPA? (Major) (Y or N)
(If yes, then attach schematic, toxics spreadsheet, copy of model, or, if not modeled, then old
assumptions that were made, and description of how it fits into basinwide plan)
Additional Information attached? _Y_ (Y or N) If yes, explain with attachments.
Special monitoring conditions for instream parameters and especially long-term BOD.
Special Dioxin monitoring conditions.

Facility Name 46- &_J 1U IoY_ i ,Dr f b llA&o Permit # 0063 a) Pipe # 60 t_
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay
Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality
is 5 0 % (defined as treatment two in the North Carolina procedure document). The permit holder shall perform
quarterquarterjy monitoring using this procedure to establish compliance with the permit condition. The first test will be
performed after thirty days from the effective date of this permit during the months of
e Lo . Effluent sampling for this testing shall be performed at the NPDES
permitted fin efflue t 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, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 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 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 any test data from this monitoring requirement or tests performed by the North Carolina Division of
Environmental Management 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 and appropriate environmental controls, shall constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event). Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
7Q10 dad. D cfs
Permitted Flow q. 6 MGD
IWC S %
Basin & Sub -basin 6,30 /
Receiving S tream n'1 Wf?; Vef
County �%bP5on
Recommend7y:
z.
Azk�
Date
QCL PIF Version 9191

H
a�
In addition to monitoring for parameters on the effluent page of the permit,
Alpha Cellulose will implement a sampling program according to the following
details.
1. The self -monitoring sites are now defined as follows:
,Ff41uent
Upstream NCSR 1620
1st Downstream: NCSR 2123
2nd Downstream: NCSR 2121
2. The parameters to be sampled are: temperature, conductivity, dissolved
oxygen, and pH.
3. During the months of April through October, the sampling frequency will be
twice per week with these days being Tuesday and Friday. During the months
of November through March, the sampling frequency will be once per week with
this day being Wednesday (program will start 6-1-89).
4. Sampling will be performed between the hours of 0900 and 1100.
5. A sampling protocol will be developed with DEM's Fayetteville Regional Office
(FRO). This protocol will reflect procedures detailed in "Standard Methods"
and the Division's standard operating procedure for water quality modeling.
Alpha Cellulose technicians will maintain sampling instruments in a manner
that will produce accurate, reproducible results (calibrating instruments
before each sampling run, checking calibration af.to.r each run, changing DO
probe membranes when necessary, etc.).
6. Alpha Cellulose will collect a long-term BOD in its effluent and at each of
the designated instream sampling sites during the months of July, August, and
September. Effluent collection will be composed of 24 hr. composite samples
while instream collection will be grab samples. Each month's sampling day
for this parameter shall be coordinated beforehand with the FRO. It is very
important that Alpha Cellulose and the other dischargers involved in this
joint study retain a common laboratory for analyzing the long-term BOD
samples. The FRO can assist your company by providing a list of laboratories
that are set up to do this test. The laboratory that is selected should be
made aware that DEM has certain guidelines that need to be followed when a
long=term test is performed, these are:
a. No nitrogen inhibitors shall be used.
b. In addition to ultimate BOD, intermediate nitrogen series measurements
should be made (upon set-up and at days 5, 15, and 25).
c. Tests will be run as long as necessary to predict an ultimate BOD, but at
least 30 days.
7. Long-term test data and a copy of the monthly DMR sheets should be sent
within 30 days of completion to:
Ms. Carla Sanderson
Technical Support Unit
Water Quality Section
NRCD/DEM
PO Box 27687
Raleigh, NC 27611-7687
COPY

PART V
Dioxin Monitoring Requirements
A. Dioxin N2nitoring
All analysis must be performed using the appropriate method of analysis specified
in Analytical Procedures and Quality Assurance for Multimedia Analysis of
Polychlorinated Dibenzo-para-dioxins and Polychlorinated Dibenzofurans by High
Resolution Gas Chromatography/High Resolution Mass Spectrometry, EPA, 1987, (EPA
Method 8290), or another equivalent analytical protocol approved by DEM. Detection
limits using this method for the purposes of compliance evaluations are considered to
be 10 picograms per liter. If the measurement is below detection limits the quantity,
for the -purposes of compliance evaluation, is considered to be zero unless
quantification below 10 picograms per liter is achieved. The dioxin isomer to be
monitored and limited by this permit is 2,3,7,8,•TCDD.
Fish tissue analysis will be performed, as a minimum, at one station established
upstream of the discharge and at two stations downstream. The sampling design for
fish tissue monitoring is to be submitted to the Division of Environmental Management
no later that 90 days after the effective date of the permit. Upon approval, the
monitoring plan becomes an enforceable part of the permit. All dioxin data collected
as part of this monitoring requirement will be reported within three months after
collection.
The permittee shall perform the following analyses for dioxin in addition to
monitoring the effluent as specified on the effluent pages:
1. Influent to wastewater treatment facility Quarterly GRAB (2378 TCDD)
2. Sludge Quarterly GRAB (2378 TCDD)
3. Landfills leachate (if appropriate Quarterly GRAB (2378 TCDD)
4. Fish tissue analysis Annually (TCDD and TCDF)
B. Dioxin Control Plan
Within 120 days of the effective date of this permit, the permittee shall submit
to the DEM a dioxin control plan (DCP). The DCP shall present any proposed process
modifications intended to reduce the discharge of dioxins, along with projected
implementation schedules and predicted effects. Additionally, the DCP must also
present the provisions expected to address suspended solids and chlorine minimization
programs. Upon approval by the permitting authority, the DCP implementation schedule
shall become an enforceable part of the permit.
':?crp
..] ►C'e
OCT 12 1990
CENTRAL FILE COPY

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WIIOLE C311.UENTZ fTY WSTING 0(SELF-MONITORING SUMMARY) Mon, Mar 16, 1992
A.B. CARTrR. INC. PERM CI[R LIM: 22%
NI'DESN: NCO063835 SubBasint CTB37 Begin: IV00 Frequency: Q P/Ir A
County: GASTON Ragion:MRO Non -Camp: Months: JAN APR JUL OCT
PF:0.022 SOC/JOC Req:
7010: 0.12 I W C(%): 29.97
'89 NR — — NR FAIL — FAR. — — FAIL — —
90 FAR. — — FAIL FAIL — FAIL — — FAIL — —
'91 FAIL — FAIL FAIL FAIL FAIL FAIL FAIL FAIL FAIL FAIL FAIL
'92 FAIL FAIL
88 — — (58) — — (NONE) — — (NONE) — — (NONE)
8mJ — — (P30) — — NONE — — — NONE — —
90 NONE — — >90 — — NR NR NR >90' — —
91 >90' — — 25.6' >I00' — NONE- — — >100• — —
ABrrim-PRICE
ABrrim-PRICE
PERM AC LIM: 268%
Y
NI'DIiSM: NC0005266
Sub0asin: YA D01
Begin; 7/1/89
r-qucncy: Q A
County: WILKES
Region: WSRO
Non -Camp:
Months: JAN APR JUL OCT
PF:1.0
SOCJJOC Req:
7QI0: 228.0
IWC(%):0.675
'92
ALAMANCE OIL CO.
PERM CHR LIM: 99% (GRAB)
'88
NPDESN: NC0077313
SubBasi. CPF02
Begin: M/90
frequency.Q PIP A
89
County: ALAMANCH
Region:WSRO
Non -Camp:
Months: MAR JUN SEP DEC
90
PF:0.009
SOC/JOC Req:
91
7Q10-. 0.0
IWC(%):100.0
'9
ALBEMARLE W WTP
PERM CHR MONIT:94%
'88
NPDESM: NCOO24244
SubBasin YA D 13
Begin: 7/1/89
rwAoc tcy. Q P/P A
89
County: STANLY
Rcgion:MRO
Nan -Camp:
Months: MAR JUN SEP DEC
90
PF:16.00
SOC/JOC Req:
91
7Q10: 1.60
IWC(%):93.92
'9
44.65'
N
2
— PASS NR —
2 FAIL FAIL
NONE — — —
FAIL PASS? NR bt
FAIL FAIL PAIL FAIL
PASS PASS PASS FAIL
PASS PASS
PASS — — FAIL
FAIL FAIL FAIL FAIL PASS
FAIL7 NR bt FAIL FAIL FAIL FAIL FAIL
PASS FAIL PASS PASS PAIL LATE bt
PASS FAIL PASS FAIL PASS PASS PASS FAIL
— — — — — — — — PASS — — bt
— — PASS — — PASS — — PASS — — bt
PASS — PASS,P — — PASS,P — — PASS — — PASS
2
— — — — — — — — PASS — — bt
— — PASS — — PASS — — PASS — — bt
FAIL PASS FAIL,F FAIL PASS bt,P PASS PASS PASS — — PASS
2—
NONE' 5.06 163 NONE 1732 NONE! NONE 593 NONE 77A NR NONB
FAIL — — NR PASS — PASS — — PASS — —
PASS — — PASS — — PASS — — PASS — —
PASS — — NR — — NR PASS — — PASS —
2 — PASS
PASS — (—) — NR (—) PASS — (—) NR PASS —
LATE — — PASS — — NR PASS — PASS — —
PASS — — PASS — — PASS — — LATE PASS —
NR PASS — — PASS — — LATE PASS — NR NR
92 NR
— — — — — — — — >100 — — >100
— >100 — — NONE — — >100 — — —
92 —
0 — — — — — — — — NONE >100 — —
NONE — — >100 — — >100 >100 — — >90f —
0 2 consecutive failures. significant noncompliance Y Prc1988dataay.iI.bIc
LEGEND:
PF=Permitted flow (MGD), 7Q10=11eceiving stream low flow, criterion (efs), rWC%=lnsucam waste concentration, Begin=Fist month required. Frequency=(Monitaing 6equency): (Q-Quarterly; M-Monthly; BM -Bimonthly; SA-Serniannually; A -Annually;
OW D-Only when discharging; D-Discontinued monitoring requirement; IS -Conducting independent study). P/F=Pass/Fail chronic bioassay, AcAcute, Chr=Chronic, A=quamerly monitoring increases to monthly upon single fail=.
(Data Notation): If=Fathead Mir=w,'--Ceriodaphnis sp., my=Mysid shrimp. ChV=Chronic value, P=Mortality of stated percentage at highest concentration, at=Performed by DEM Aq Tox Group, bt=Bad test],
(Reporting Notation): ( ... =Data not required. NR=Nor reported, ( )--Beginning of Quarter], (Facility Activity Status): ]I=lnactive, N=Newly issued(To construct), I [=Active but not discharging]
I
PASS — — FAIL
FAIL FAIL FAIL FAIL PASS
FAIL7 NR bt FAIL FAIL FAIL FAIL FAIL
PASS FAIL PASS PASS PAIL LATE bt
PASS FAIL PASS FAIL PASS PASS PASS FAIL
— — — — — — — — PASS — — bt
— — PASS — — PASS — — PASS — — bt
PASS — PASS,P — — PASS,P — — PASS — — PASS
2
— — — — — — — — PASS — — bt
— — PASS — — PASS — — PASS — — bt
FAIL PASS FAIL,F FAIL PASS bt,P PASS PASS PASS — — PASS
2—
NONE' 5.06 163 NONE 1732 NONE! NONE 593 NONE 77A NR NONB
FAIL — — NR PASS — PASS — — PASS — —
PASS — — PASS — — PASS — — PASS — —
PASS — — NR — — NR PASS — — PASS —
2 — PASS
PASS — (—) — NR (—) PASS — (—) NR PASS —
LATE — — PASS — — NR PASS — PASS — —
PASS — — PASS — — PASS — — LATE PASS —
NR PASS — — PASS — — LATE PASS — NR NR
92 NR
— — — — — — — — >100 — — >100
— >100 — — NONE — — >100 — — —
92 —
0 — — — — — — — — NONE >100 — —
NONE — — >100 — — >100 >100 — — >90f —
0 2 consecutive failures. significant noncompliance Y Prc1988dataay.iI.bIc
LEGEND:
PF=Permitted flow (MGD), 7Q10=11eceiving stream low flow, criterion (efs), rWC%=lnsucam waste concentration, Begin=Fist month required. Frequency=(Monitaing 6equency): (Q-Quarterly; M-Monthly; BM -Bimonthly; SA-Serniannually; A -Annually;
OW D-Only when discharging; D-Discontinued monitoring requirement; IS -Conducting independent study). P/F=Pass/Fail chronic bioassay, AcAcute, Chr=Chronic, A=quamerly monitoring increases to monthly upon single fail=.
(Data Notation): If=Fathead Mir=w,'--Ceriodaphnis sp., my=Mysid shrimp. ChV=Chronic value, P=Mortality of stated percentage at highest concentration, at=Performed by DEM Aq Tox Group, bt=Bad test],
(Reporting Notation): ( ... =Data not required. NR=Nor reported, ( )--Beginning of Quarter], (Facility Activity Status): ]I=lnactive, N=Newly issued(To construct), I [=Active but not discharging]
I
0 2 consecutive failures. significant noncompliance Y Prc1988dataay.iI.bIc
LEGEND:
PF=Permitted flow (MGD), 7Q10=11eceiving stream low flow, criterion (efs), rWC%=lnsucam waste concentration, Begin=Fist month required. Frequency=(Monitaing 6equency): (Q-Quarterly; M-Monthly; BM -Bimonthly; SA-Serniannually; A -Annually;
OW D-Only when discharging; D-Discontinued monitoring requirement; IS -Conducting independent study). P/F=Pass/Fail chronic bioassay, AcAcute, Chr=Chronic, A=quamerly monitoring increases to monthly upon single fail=.
(Data Notation): If=Fathead Mir=w,'--Ceriodaphnis sp., my=Mysid shrimp. ChV=Chronic value, P=Mortality of stated percentage at highest concentration, at=Performed by DEM Aq Tox Group, bt=Bad test],
(Reporting Notation): ( ... =Data not required. NR=Nor reported, ( )--Beginning of Quarter], (Facility Activity Status): ]I=lnactive, N=Newly issued(To construct), I [=Active but not discharging]
I

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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary April 21, 1992 Director
Mr. Michael G. Hardie, P.E.
Director of Technical Services
Alpha Cellulose Corporation
P.O. Box 1305
Lumberton, NC 28359
Subject: Alpha Cellulose Longterm BOD
NPDES No. NC0005321 - Robeson County
Dear Mr. Hardie:
I am writing to provide further information about the longterm BOD monitoring requirements for
your NPDES discharge and that of West Point Pepperell and the City of Lumberton. As stated in
earlier correspondence, the Division of Environmental Management (DEM) has not yet completed its
water quality studies to develop a calibrated QUAL2E model of the Lumber River. Therefore, it is
important that each of the facilities continue to collect the longterm BOD information during this
summer for use in the model development.
DEM understands your concerns about who is responsible for paying laboratory costs. Therefore,
each facility will be responsible for collecting its own information according to a schedule which will
be coordinated by the Fayetteville Regional Office. Each facility will also be allowed to use the lab
of their choice. However, if labs are changed, and the data are not useful, DEM may require another
year of longterm BOD monitoring from each of the facilities. In addition, if any facility uses a lab
other than Microbac Environmental Laboratory, it must provide a split sample from one of its
effluent samples to DEM. This split sample should be coordinated with Howard Bryant of our
Environmental Sciences Branch. Howard can be reached at [phone].
I hope that this letter adequately addresses your concerns. If you have any questions or comments,
please contact Ruth Swanek of our Instream Assessment Unit at [phone].
cc: Tommy Stevens
Jay Sauber
Central Files
4teSincerely, e
ve W. Tedder, Chief
Water Quality Section
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

DIVISION OF ENVIRONMENTAL MANAGEMENT
April 9, 1992
M E M O R A N D U M
TO: Don Safrit
Permits & Engineering Unit
FROM: M. J. Noland, Regional Supervisor IC,�
Fayetteville Regional Office / 1\
SUBJECT: NPDES Permit Modification
NPDES Permit No. NC0005321
Alpha Cellulose Corporation WWTP
Robeson County
m r``
O
C`� L ?
�.J
It has recently been brought to the attention of the Fayetteville
Regional Office that NPDES Permit No. NC0005321 issued to Alpha Cellulose
Corporation on October 10, 1990, and effective on December 1, 1990, has been
written with the wrong sample type for the Toxicity parameter. The permit
states that Toxicity should be done by grab sampling, however, this would not
be a representative sample of the discharge from Alpha Cellulose. Therefore,
it is the request of the Fayetteville Regional Office that NPDES Permit
NC0005321 be modified to require that Toxicity monitoring be conducted by
composite sampling.
If you have any questions, please do not hesitate to contact Kitty
Kramer.
MJN/akk
Attachment
cc: Larry Ausley

RECEIVE®
APR ? 0 1992
TECHNICAL SUPPORT BRANCH
April 6, 1992 "'" 14
p.
State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 Salisbury Street
P.O. Box 29535
Raleigh, NC 27626-0535
Attention: Mr. Trevor Clements
Dear Mr. Clements:
Reference: Alpha Cellulose Corporation Longterm BOD
NPDES No. NC0005321
Robeson County
Thank you for your response to our inquiry of February 13th
regarding Alpha Cellulose's payment of the City of Lumberton's
laboratory costs for the longterm BOD study being conducted by
the State on the Lumber River. Alpha Cellulose appreciates the
State's effort to complete the calibration of the Qual2E model of
the Lumber River which will play an important part in any future
allocations along the river. We fully understand that the
results obtained will only be as good as the data provided.
Therefore, since only one (1) additional sampling period, this
coming summer, remains to complete collection of the necessary
data, Alpha Cellulose Corporation agrees to pay 1/3 of the cost
of the City's laboratory costs for the last year's samples for
the longterm BUD analysis as covered in the previous two (2)
years. It is my understanding that the City and West Point
Pepperell will each pick up a third of the remaining 2/3 of the
cost involved.
This will assure that all the samples over the three (3) year
period are analyzed by the same laboratory, thus minimizing the
potential for inconsistencies to occur if different laboratories
were involved. Unfortunately, there is no way to standardize the
sampling procedures used so as to assure consistency from this
point of view.
1000 East Nair Street, Box 1305 Lumberton, North Carolina28359 USA ^e 919 738 4201 TWX 510 939 3505 FAX [phone]

Mr. Trevor Clements
April 6, 1992
Page 2
I will write the City of Lumberton and inform them of our
decision. I will also request again copies of their longterm BOD
data which has been requested on several occasions but has never
been received and was part of the original agreement. Again,
thank you for your response and Alpha Cellulose looks forward to
the completion of the Qual2E calibration this coming summer.
Sincerely,
;�.sV. � %
Michael G. Hardie, P.E.
Director of Technical Services
/cpt

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street - Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
February 28, 1992
Mr. Michael G. Hardie, P.E.
Director of Environmental and Technical Services
Alpha Cellulose Corporation
1000 East Noir Street
Lumberton, North Carolina 28359
Dear Mr. Hardie:
George T. Everett, Ph.D
Director
Subject: Permit No. NC0005321
Authorization to Construct
Alpha Cellulose Corporation
Wastewater Treatment Facility
Robeson County
Pursuant to your letter of February 5, 1992, the Division is hereby amending the authorization to
construct to clarify the language concerning the notification of the Fayetteville Regional Office prior to
operation of the completed facilities. In addition, the language concerning the connection to a publicly
owned treatment works has been deleted.
A letter of request for an Authorization to Construct was received September 16, 1991 by the
Division and final plans and specifications for the subject project have been reviewed and found to be
satisfactory. Approval is hereby given for the new aeration basin aerator configuration consisting of three
(3) new 75 hp aerators, ten (10) existing 40 hp aerators, two(2) existing 30 hp aerators, and the deletion of
six (6) existing 30 hp aerator/mixers. Authorization is hereby granted for the construction of a new 30 hp
primary pump (Gorman -Rupp Model T8A3-B with a 14.75 inch impeller operating at 1,150 rpm), a new
dissolved air flotation (DAF) unit with a diameter of 55 feet with a flocculation tank with a 5 hp mixer and
chemical feed, convert the existing primary clarifier to a secondary clarifier, a new RAS/WAS pump
station consisting of three (3) 435 gpm progressive cavity pumps to serve the DAF unit and the new
secondary clarifier, a new aeration effluent flocculation tank with a 5 hp mixer and chemical feed, two (2)
new RAS/WAS pumping station each consisting of three (3) 400 gpm submersible pumps to serve the
existing secondary clarifiers, a new filtrate sludge pump station consisting of two (230) gpm submersible
pumps to serve the existing sludge press, a new waste sludge flow meter, a new 1 hp (Gorman -Rupp
Model 02D3-E1 operating at 3450 rpm) effluent reuse pump, and all the associated piping, valves and
appurtenances with discharge of treated wastewater into Lumber River classified as C-Swamp waters. .
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

This Authorization to Construct is issued in accordance with Part III paragraph B of NPDES
Permit No. NC0005321, issued October 10, 1990, and shall be subject to revocation unless the
wastewater treatment facilities are constructed in accordance with the conditions and limitations specified in
Permit No. NC0005321
The sludge generated from these treatment facilities must be disposed of in accordance with G.S.
143-215.1 and in a manner approved by the North Carolina Division of Environmental Management.
In the event that the facilities fail to perform satisfactorily, including the creation of nuisance
conditions, the Permittee shall take immediate corrective action, including those as may be required by this
Division, such as the construction of additional or replacement wastewater treatment or disposal facilities.
The Fayetteville Regional Office, phone no. [phone], shall be notified at least forty-eight
(48) hours in advance of operation of the completed facilities so that an in -place inspection can be made.
Such notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m.
until 5:00 p.m. on Monday through Friday, excluding State Holidays.
Upon completion of construction and prior to operation of this permitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been installed in
accordance with the NPDES Permit, this Authorization to Construct and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box 29535, Raleigh, NC
27626-0535.
Upon classification of the facility by the Certification Commission, the Permittee shall employ a
certified wastewater treatment plant operator to be in responsible charge of the wastewater treatment
facilities. The operator must hold a certificate of the type and grade at least equivalent to the classification
assigned to the wastewater treatment facilities by the Certification Commission.
A copy of the approved plans and specifications shall be maintained on file by the Perrriittee for the
life of the facility.
Failure to abide by the requirements contained in this Authorization to Construct may subject the
Permittee to an enforcement action by the Division of Environmental Management 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.
One (1) set of approved plans and specifications is being forwarded to you. If you have any
questions or need additional information, please contact Mark Hawes telephone number 919/733-5083.
Sin r4Eve
Georg
cc: Robeson County Health Department -b
Fayetteville Regional Office
Training and Certification Unit
Michael Walker, Camp Dresser & McKee

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph.D
William W. Cobey, Jr., Secretary Director
January 24, 1992
Mr. Michael G. Hardie, P.E.
Director of Environmental and Technical Services
Alpha Cellulose Corporation
1000 East Noir Street
Lumberton, North Carolina 28359
Subject: Permit No. NC0005321
Authorization to Construct
Alpha Cellulose Corporation
Wastewater Treatment Facility
Robeson County
Dear Mr. Hardie:
A letter of request for an Authorization to Construct was received September 16, 1991 by the
Division and final plans and specifications for the subject project have been reviewed and found to be
satisfactory. Approval is hereby given for the new aeration basin aerator configuration consisting of three
(3) new 75 hp aerators, ten (10) existing 40 hp aerators, two(2) existing 30 hp aerators, and the deletion of
six (6) existing 30 hp aerator/mixers. Authorization is hereby granted for the construction of a new 30 hp
primary pump (Gorman -Rupp Model T8A3-B with a 14.75 inch impeller operating at 1,150 rpm), a new
dissolved air flotation (DAF) unit with a diameter of 55 feet with a flocculation tank with a 5 hp mixer and
chemical feed, convert the existing primary clarifier to a secondary clarifier, a new RAS/WAS pump
station consisting of three (3) 435 gpm progressive cavity pumps to serve the DAF unit and the new
secondary clarifier, a new aeration effluent flocculation tank with a 5 hp mixer and chemical feed, two (2)
new RASJWAS pumping station each consisting of three (3) 400 gpm submersible pumps to serve the
existing secondary clarifiers, a new filtrate sludge pump station consisting of two (230) gpm submersible
pumps to serve the existing sludge press, a new waste sludge flow meter, a new 1 hp (Gorman -Rupp
Model 02D3-El operating at 3450 rpm) effluent reuse pump, and all the associated piping, valves and
appurtenances with discharge of treated wastewater into Lumber River classified as C-Swamp waters.
This Authorization to Construct is issued in. accordance with Part III paragraph B of NPDES
Permit No. NC0005321, issued October 10, 1990, and shall be subject to revocation unless the
wastewater treatment facilities are constructed in accordance with the conditions and limitations specified in
Permit No. NC0005321
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. Hardie
January 24, 1992
Page Two
The sludge generated from these treatment facilities must be disposed of in accordance with G.S.
143-215.1 and in a manner approved by the North Carolina Division of Environmental Management.
In the event that the facilities fail to perform satisfactorily, including the creation of nuisance
conditions, the Pemittee shall take immediate corrective action, including those as may be required by this
Division, such as the construction of additional or replacement wastewater treatment or disposal facilities.
The Fayetteville Regional Office, phone no. [phone], shall be notified at least forty-eight
(48) hours in advance of operation of the installed facilities so that an in -place inspection can be made.
Such notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m.
until 5:00 p.m. on Monday through Friday, excluding State Holidays.
Upon completion of construction and prior to operation of this permitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been installed in
accordance with the NPDES Permit, this Authorization to Construct and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box 29535, Raleigh, NC
27626-0535.
The subject wastewater treatment and disposal facilities shall be connected to an operational
publicly owned wastewater collection system within 180 days of its availability to the subject facilities, if
the subject wastewater treatment or disposal facilities are in noncompliance with the terms and conditions
of the NPDES permit, the Authorization to Construct, or the governing statutes or regulations. Prior to the
initiation of these connection activities, appropriate approval must be received from this Division.
Upon classification of the facility by the Certification Commission, the Permittee shall employ a
certified wastewater treatment plant operator to be in responsible charge of the wastewater treatment
facilities. The operator must hold a certificate of the type and grade at least equivalent to the classification
assigned to the wastewater treatment facilities by the Certification Commission.
A copy of the approved plans and specifications shall be maintained on file by the Pennittee for the
life of the facility.
Failure to abide by the requirements contained in this Authorization to Construct may subject the
Permittee to an enforcement action by the Division of Environmental Management 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.
One (1) set of approved plans and specifications is being forwarded to you. If you have any
questions or need additional information, please contact Mark Hawes telephone number 919/733-5083.
cc: Robeson County P Health Department
Fayetteville Regional Office
Training and Certification Unit
Michael Walker, Camp Dresser & McKee

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. N►artin, Govemor George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary June 12, 1990 Director
Mr. Ronald W. Sanders
Laboratory Director
Microbac Environmental Laboratory
817 Castle Hayne Street
Fayetteville, NC 28303
Subject: Long Term BOD Procedures
Dear Mr. Sanders:
I would like to take this opportunity to thank you for meeting
with Howard Bryant and myself on May 30. The results of the long
term BOD analyses will be a critical part of our Lumber River model
development. Therefore, it is important that both the Division of
Environmental Management (DEM) and Microbac understand the test
protocol used on the Lumber River samples. This letter is intended
to summarize the results of the meeting.
Microbac is running the tests using proper lab procedure.
However, the seed control, the blank, and seeded blank samples were
reaerated to supersaturated DO concentrations. The blank and
seeded blank bottles should not need to be reaerated since the oxy-
gen demand should be relatively low. If you believe that any
sample needs to be reaerated, it should not be reaerated to high
concentrations. A concentration of approximately 8 mg/1 should be
sufficient. Aerate samples above the saturation level only when
necessary to keep the concentration above 3 mg/1 during the five
day interval.
The greatest misunderstanding occurred on how the diluted
samples should be corrected. There are a number of ways to perform
this calculation, and H and I discussed various methods after our
meeting. We came up with the following method:
(1) Subtract highest (i.e. of the replicate seed control
bottles) seed control BOD concentration from accumulated
DO used in sample bottles.
(2) Subtract the appropriate proportion of the lowest of the
blank bottles from result obtained in step 1 - i.e. if
the dilution is 80% (80% sample and 20% dilution water)
and the lowest blank demand is 4 mg/l, subtract
Pollution Preventkm Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Frn ul (lnnnrh init., AR'irmativa Artinn FmnlnvPr

(0.2)*4 = 0.8 mg/l
(3) Divide result of step 2 by the dilution - in above
example, divide by 0.8
I have attached an example to further explain the above method. If
you have any questions about the method or your individual test
results, call H at [phone]. If your blank replicates give
very different results, you may want to call him to discuss alter-
native methods of correcting the data.
I told you that I would investigate at what dilution we would
like the nitrogen series performed. If you are running the test on
a diluted sample, you should perform the initial nitrogen tests and
all subsequent ones on the diluted sample. However, it would also
be beneficial to us to have initial nitrogen measurements made on
the 100% sample. You stated that the nitrogen series measurements
were expensive, and you did not want to run more tests than you
already were running. Therefore, you may omit the nitrogen measu-
rements from one of the diluted samples (preferably the dilution
with the lowest concentration of sample). In summary,
(1) Run initial nitrogen series on 100% sample
(2) Run initial and periodic nitrogen series on two of the
samples (two with highest effluent concentrations).
Since the stream samples are 100% effluent, continue performing
this test as you have been.
Finally, DEM needs the 5 day BOD so it is important that
uptake is measured on this day. You may use your judgment on which
other days the samples should be read.
You also inquired whether the City of Lumberton would be using
your laboratory for their long term BOD tests. The City will be
performing its own tesi due to budget constraints. However, DEM
plans on performing long term BOD tests on split samples with you
and the City of Lumberton to see if there are comparable test
results.
If you have any questions or comments, please call me at
[phone].
Sincerely,
Ruth C. Swanek
cc: Howard Bryant
Tommy Stevens
West Point Pepperell WLA File
Alpha Cellulose WLA File

Example Long Term BOD Correction for Diluted Samples
Seed
Control
Blank
20% Sample
Cum. BODu
Cum. BODu
Cum. BODu
Cum. BODu
Uncorrect Corrected
Bottle A
Bottle B
Bottle A
Bottle B
Cum. BODu Cum.
BODu
Day
(mg/1)
(mg/1)
(mg/1)
(mg/1)
(mg/1)
(mg/1)
5
0.50
0.65
0.50
0.30
5.24
21.75
10
0.76
0.80
1.26
1.01
8.73
35.61
15
0.91
0.96
1.79
1.54
9.84
38.24
20
1.10
1.20
2.14
2.01
10.55
38.71
Sample Calculations
-------------------
-------------------
Day 5
Step 1: Subtract highest seed control
5.24 - 0.65 = 4.59
Step 2: Subtract appropriate proportion of
4.59 - (0.8) (0.3) = 4.35
Step 3: Divide by dilution
4.35/0.2 = 21.75
Day 10
(8.73 - 0.8 - (0.8)*(1.01))/0.2 = 35.61
Day 15
(9.84 - 0.96 - (0.8)*(1.54))/0.2 = 38.24
Day 20
(10.55 - 1.20 - (0.8) * (2.01)) /0.2 = 38.71
lowest blank

DIVISION OF ENVIRONMENTAL MANAGEMENT
June 7, 1990
To: Tommy Stevens
From: Carla Sanderson ei
Through: Trevor Clements e
Subject: Alpha Cellulose Monitoring Requirements
Lumber River
Scotland & Robeson Counties
As we have discussed, the SOC for Alpha Cellulose should contain requirements to
perform a comprehensive summer monitoring study of the Lumber River from above
the JP Stevens WWTP outfall above Maxton to the NC/SC State line (approximately
95 miles). Technical Support would like weekly sampling along the River 1000
meters apart (see locations on the attached maps). The parameters to be sampled
are D.O., temperature, pH, and conductivity. It may be difficult to locate the
exact points indicated on the maps, therefore, we suggest the following steps to
ensure the correct number of points are monitored and each location is repeated
for every sample run:
1. Alpha Cellulose should buy the necessary topographical maps needed for
this study and mark the locations. The topographical maps needed are:
Map Name Ouadrangle
Wakulla, NC
H21SE
Maxton, NC
I21NE
Pembroke,
NC
122NW
McDonald,
NC
122SW
Southwest
Lumberton, NC
122SE
Northwest
Lumberton, NC
I22NE
Southeast
Lumberton, NC
123SW
Evergreen,
NC
J23NW
Fairmont,
NC
J22NE
Fairbluff,
NC
J22SE
2. The first trip down the River will involve setting up the station loca-
tion landmarks (recommend flagging) and marking them on the maps. Efforts
should be made to keep the locations close to 1000 meters apart as on the
attached maps.
3. Each sampling point should be marked with a number (to distinguish from
all other points) along the bank of the River.
4. The total number of sampling locations in the River equals 155.
To ensure that the correct number of samples are being taken, below is a break-
down of the number of sampling points between certain locations such as road
or railroad crossings. This may serve as a checklist when sampling.

_1
From
To No. of
sampling points
Above JP Stevens
SR 1310
4
SR 1310
HWY 71
8
HWY 71
Seaboard Coastline
2
Coastline
SR 1303
2
SR 1303
SR 1153
5
SR 1153
Coastline
2
Coastline
SR 1354
8
SR 1354
SR 1373
4
SR 1373
Coastline
6
Coastline
SR 1003
6
SR 1003
SR 1550
9
SR 1550
McNeils Bridge
14
McNeils Bridge
Coastline
2
Coastline
I-95
3
I-95
SR 1620
3
SR 1620
SR 2289
1
SR 2289
HWY 72
4
HWY 72
Popes Landing
7
Popes Landing
SR 2123
8
SR 2123
SR 2121
6
SR 2121
Piney Island Landing
7
Piney Island Landing
SR 1511
6
SR 1511
Griffin Whirl
13
Griffin Whirl
HWY 904 @ Fair Bluff
18
HWY 904
State line
7
Please let me know if you have any questions.

NPDES WASTE LbAD ALLOCA ► 1UN
PERMIT NO.: NCOC 0 S3Z/
ii �a GZ.��� I O S-� CD ✓.�od'c�w
FACILITY NAME:
Facility Status:Q EKN7PII!(3) PROPOSM
(circle one)
Permit Status: �tl ENEW L X00WCATION UNPERMMED NEW
(circle oas) -
Major Minor,
Pipe No: - 001 '
Design Capacity (MGD):
Domestic (X of Flow): -,,;,q
Industrial
Commants: G`�'����—
L LAv-% 6e,v t ✓er
RECEIVING STREAK.
Ci u>0,
Class:
Sub -Basin:
D 0
Reference USGS
Quad: Z plsaae attach)
20be
County:
Regional Office:
As Fa Mo . Ra Wa WI WS
(circle *so)
Requested By:-----,—)
Prepared By:
�c(�`� Date:
Reviewed By:
r
Modeler Date R c�`
2
Drainage Area (mi ) � Avg. Streamflow (cfs):
7Q10 (cfs) l7_61 Winter 7Q10 (cf-) �� 30Q2 (cfs)
Toxicity Limits: IW X (Circe one cute / hronic
Instream Monitoring: ,, r
0AL,_,La �r
Parameters
Upstream y Location
Downstream Location
��SC�ZIz 3 Z) S2 Ziz.
Effluent
Characteristics
mo,�� Avq
BODE (�6 M"}
3 3 Z
NH,N
D.O. (mg/1)
TSS C�bsl �
F. Col. (/100ml)
Ll2 5
S o
pH (SU)
Vtoi- -Piet fewtt. of 4c-
ftcelviin I wafe's -tv excud
move ba*_gMub%d pLn�
t'N Mo case case Lt �rcecd -
3 %0 C ,
Comment,*:
�ronn 4,--U (SSIXaAMI caa c
S dt,�Soiv
Ccuc �.stiv► L pvv Caws as

Facility Name Apk a (11 C%��� �-(JY Q. Permit # j"063a'
CHRONIC TOXICITY TESTING REQUIREMENT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity in any two consecutive toxicity tests,
using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *February 1987) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is % (defined as treatment two in the North Carolina procedure
document). The permit holder shall perform quarterly monitoring using this procedure to establish
compliance with the permit condition. The first test will be performed -after thirty days from
issuance of this permit during the months of MOO 30j JM 1. : . 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 pemut condition will be entered on th,- Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using th,- parameter
code TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
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. Totem residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then-ronthly
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 Environmental Management indicate potential impacts•to the receiving stres:n, this
pen -nit may be re -opened and modified to include alternate monitoring requirements or :imits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as rrnimum
control organism survival and appropriate environmental controls, shall constitute an i-.-valid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
7Q10ja __—cf�
A1
Permited Flow GD Recommended by:
1WC% �.
Basin & Sub -basin 5
Receiving Stream L!� � ►/�!' __
County _�hPsnvt ate
""Chronic Toxicity (Ceriodaphnia) P/F atCq_L%,�Vt 10,. r1�C, See Part , Condition V .

Facility Name (oS C, V)(2 '
Permit # M L© O© S3 a I
CHRONIC TOXICITY MONITORING REQUIREMENT (QRTRLY)
The oermittee shall conduct chronic toxicity tests using test procedures outlined in:
1.) The North Carolina C'erioda_phnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *February 1987) or subsequent versions.
The effluent concentration defined as treatment two in the North Carolina procedure document is
�_�•- %. The permit holder shall perform auarterl monitoring using this procedure to establish
compliance with the permit condition. The first test will be performed aftg thirty days from
issuance of this permit during the months of eb In Na ✓ Effluent
sampling for this testing 'shall be performed at the N DES rmit anal effluent discharge below
!J all treatment processes.
All toxicity testing results required as part of this pernut 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, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
.Raleigh, N.C. 27611
Tes data shall be complete and accurate and include all supporting chemical/physical measurements
periorrned 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 any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management 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 and. appropriate environmental controls, shall constitute an invalid test
and will require immediate ret�sting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute, a failure of permit condition.
7Q10 127 cfs b.
Permited Flow MGD Recommended by:
'3a:;in & �.rn-basin_�7=5 i
Receiving Str,i ✓M
Countyt Co e -so n Dat S-S'

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NCOO O S3Z/
FACILITY NAME: Ma �a"Ilu foe a C�rpo 0
Facility Status: EX1lrM PROPOSED
(circle one)
Permit Status: RENEWAL DKXWIC,A TM LQOERMrrrM NEW
(circle one)
MaJor 4 Alaor.__
Pipe No: 001
Design Capacity (MGD):
Domestic (% of Flow): G a°
Industrial (X of Flow): 0 '
Comments:
RECEIVING STREAM: L Uvi 6e r F—` ✓er
Class:
Sub -Basin:
Reference USGS Quad: 1 2Z' r:5(6�c pisase attach)
County: 20 _-"o`n
Regional Office: As Fa Me Ra Wa W1 WS
(circle one)
Requested By: Date: /
Prepared By:: DaAayQO�� Date: S/s 07.
Reviewed By:
Date:
l-
Drainage Area (mid) Avg. Str
7Q10 (cfs) tLl Winter 7Q10 (cfs) �� 30
Toxicity Limits: IWC X (circle one) Acut. "71
Instream Monitoring: l
Parameters s� Q�c,`LOl 4 r ✓elan j 6rw,� i_
Upstream y Location ZIP, I
Z b
Downstream Location 0SS7-1Z 3 Z) S(2 Z Iz t
Effluent
Characteristics
11••..
ON'"i Avg,
Boob (ll05/d�y�
3 3 z
(a4
N H' N
83
110
D.O. (mg/0
5
TSS C%5/,6L4>
F. Col. (/ 100ml)
`l2 5
53 So
pH (SU)(�—
T4.c
vto% cAuSe PRt �ewtP. of -(fit.
R ce rn�� wa+evs exceed
2.8 °e a-ove backt autid and
t" It cast CWASC cUCeai
3 Z" c .
Comments:
ronn �L (6511
S
ve 1� U ear
r
ail < i 0 1

TE DISCHARGERS, LIST COMPLETE GUIDELINE LIMITATIONS BELOW
r
o�
eog u►�,.,/ 3
Monthly
Average
Daily
Maximum
Comments
332.0
OPT
�Q
va
Type of Product Produced
I WD*y Produced
Effluent Guideline Reference
Aj P
u

Request No. :4961
---------------------- WASTELOAD ALLOCATION APPROVAL FORM ------ --yp.
Permit Number : NC0005321
Facility Name : ALPHA CELLULOSE MAY �7
Type of Waste : 99.86% INDUSTRIAL, 0.14% DOMESTIC
Status : EXISTING ENV. MANAGEMENT
Receiving Stream : LUMBER RIVER FAYETTEVILLE REG. OFFICE
Stream Class : C-SWAMP
Subbasin : 030751
County : ROBESON Drainage Area (sq mi) : 714.
Regional Office : FAYETTEVILLE Average Flow (cfs) : 867
Requestor : J. SHANKLIN Summer 7Q10 (cfs) : 129.
Date of Request : 11-8-88 Winter 7Q10 (cfs) : 191.
Quad : I 23 30Q2 (cfs) :
------------------------- RECOMMENDED EFFLUENT LIMITS -------------------------
ProPc+ae�
Mon Avg Dal Max; Mon Avg Da"49 Max
Wasteflow (mgd): 1.6 1.6
5-Day BOD (tb-#/a�� : 332 664 332 664
Ammonia Nitrogen (ibs/dam : 83 166 83 166
*Dissolved Oxygen (mg/1): 5
TSS (IDs/jq) : 425 850 355 710
pH (Su): 6-9 6-9
**Temperature ( C): 1
Y 8 1989
--------------------------------- MONITORING ---------------------------------
Upstream (YIN): Y Location: SR 1620
Downstream (YIN): Y Location: 1) SR 2123, 2) SR 2121
----------------------------------- COMMENTS ----------------------------------
* PERMIT CONDITION: THE FACILITY SHALL HAVE ONE YEAR FROM THE ISSUANCE DATE OF
THIS PERMIT BEFORE BEING REQUIRED TO MEET THE 5 MG/L DISSOLVED OXYGEN LIMIT.
** THE DISCHARGE SHALL NOT CAUSE THE TEMPERATURE OF THE RECEIVING WATERS TO
EXCEED 2.80C ABOVE BACKGROUND AND IN NO CASE CAUSE IT TO EXCEED 32'C.
FACILITYREQUIRED TO ENGAGE IN SAMPLING PROGRAM AS AGREED WITH DEM.
`_`---------��--��---------------------------------------------------------------
Recommended by
Reviewed by:
Tech. Support Supervisor
Regional Supervisor
Permits & Engineering
RETURN TO TECHNICAL SERVICES BY
Date S S —0
Date — O
Date
Date f
JUN 10 198)

Facility Name Al'ah o� f 110105e C�1�L I�I�Tl -A Permit # � d�3a 1
CHRONIC TOXICITY TESTING REQUIREMENT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity in any two consecutive toxicity tests,
using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised `February 1987) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is,--?. I % (defined as treatment two in the North Carolina procedure
document). The pen -nit holder shall perform quarterly monitoring using this procedure to establish
compliance with the permit condition. The first test will be performed after thirty da)'s from
issuance of this permit during the months of MOV, 70% -,y p (i?(s 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, DEM Form AT-1 (original) is to be sent to the following _3dress:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
Test data shall be complete and accurate and include all supporting chenucal/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Totz residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then -lonthly
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 Environmental Management indicate potential impacts to the receiving stre--m, this
pen -nit may be. re -opened and modified to include alternate monitoring requirements or ' mits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an i,r%,alid test
and will require immediate retesting(within 30 days of initial monitoring event). Failu to submit
suitable test results will constitute noncompliance with monitoring requirements.
7Q10 Jo? cf
Pertnited Flow_ MGD Recommended by:
IWC% .
Basin & Sub -basin 43 0 5 (V"
ReceivingStream eri'Vel'
County -_bed-___ a to 1,011-- - ------
"`Chronic Toxicity (Ceriodaphnia) P/F ato21%,�Y farm p ��C, See Part �-5 , Condition V

A.
Dioxin Monitoring Conditions
In addition to the effluent limitations specified in Part I of this per-
mit, the permittee is required to monitor for all chloro-dibenzo dioxins
and furans listed in the below table, at the following locations and
frequency:
Frequency
I. Influent to wastewater treatment facility Monthly
2. Sludge Quarterly
3. Landfills leachate (if appropriate) Quarterly
4. Final effluent Monthly
5. Fish tissue analysis Annually
All analyses must be performed using an Environmental Protection Agency
approved laboratory. For each sampling period, the limit of detection
shall be reported for each sample analyzed.
Fish tissue analysis will be performed, as a minimum, at one station
established upstream of the discharge and at two stations downstream.
The sampling design for fish tissue monitoring is to be submitted to the
Division of Environmental Management no later than 90 days after the
effective date of the permit. Upon approval, the monitoring plan becomes
an enforceable part of the permit. All dioxin data collected as part of
this monitoring requirement will be reported within three months after
collection.
All samples shall be analyzed and reported for all isomers of chlorodi-
benzo dioxins and furans and also reported as toxicity equivalents (TEQ)
based on the relative toxic equivalence factors listed below:
DIOXIN
Isomer
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,6,7,8-HxCDD
CSS/CDF ISOMERS OF MOST TOXIC CONCERNa
DIBENZOFURAN
TEFb Isomer TEFb
1
2,3,7,8-TCDF
0.1
0.5
1,2,3,7,8-PeCDF
0.1
2,3,4,7,8-PeCDF
0.1
0.04
1,2,3,4,7,8-HxCDF
0.01
0.04
1,2,3,7,8,9-HxCDF
0.01
1,2,3,6,7,8-HxCDF
0.01
0.04
2,3,4,6,7,8-HxCDF
0.01
1,2,3,4,6,7,8-HpCDD 0.001 1,2,3,4,6,7,8-HpCDF 0.001
1,2,3,4,7,8,9-HpCDF 0.001
a/ In each homologous group the relative toxicity factor for the isomers
not listed is 1/100 of the value listed above.
b/ TEF = toxic equivalence factor = relative toxicity assigned.

B. Dioxin Control Plan
Within 120 days of the effective date of this permit, the permittee shall
submit to DEM a dioxin control plan (DCP). The DCP shall present any
proposed process modifications intended to reduce the discharge of diox-
ins, along with projected implementation schedules and predicted effects.
Additionally, the DCP must also present the provisions expected to
address suspended solids and chlorine minimization programs. Upon
approval by the permitting authority, the DCP implementation schedule
shall become an enforceable part of the permit.

State of North Carolina
Department of Natural Resources and Community Development
Division or Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
William W. Cobey, Jr., Secretary May 9, 1989 Director
Clayton R. Walters
Alpha Cellulose Corporation
Box 1305
Lumberton, NC 28359
Subject: Instream Sampling Program
NPDES NC0005321
Alpha Cellulose Corp.
Robeson Co.
Dear Mr. Walters:
In reference to the letter sent to you on 4-26-89 regarding the joint
instream sampling program, the Division of Environmental Management is amending
item 6 of this program (see attached) to include an effluent long-term sample
to be taken on the same day that the instream long-term samples are taken.
Thank you for your cooperation and feel free to contact the Division if
you have any questions regarding thus matter.
Sincerely,
Steve W. Tedder, Chief
Water Quality Section
cc: David -Vogt, Technical `Support
Dale Overcash, Permits and Engineering
Trevor Clements, Technical Support
Tommy Stevens, Fayetteville Regional Office
Central Files
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

REVISION
• :•
6) Alpha Cellulose will collect a long-term BOD in its effluent and at
each of the designated instream sampling sites during the months of July,
August, and September. Effluent collection will be composed of 24 hr
composite samples while instream collection will be grab samples. Each
month's sampling day for this parameter shall be coordinated beforehand
with the FRO. It is very important that Alpha Cellulose and the other
dischargers involved in this joint study retain a common laboratory for
analyzing the long-term BOD samples. The FRO can assist your company by
providing a list of laboratories that are set up to do this test. The
laboratory that is selected should be made aware that DEM has certain
guidelines that need to be followed when a long-term test is performed,
these are:
a) No nitrogen inhibitors shall be used.
b) In addition to ultimate BOD, intermediate nitrogen series
measurements should be made (upon set-up and at days 5, 15,
and 25).
c) Tests will be run as long as necessary to predict an ultimate
BOD, but at least 30 days.

A oa STATE
ti
7
I
State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street 0 Raleigh, North Carolina 27011
James G. Martin, Governor R. Paul Wilms
William W. Cobey, Jr., Secretary April 26, 1989 Director
Clayton R. Walters
Alpha Cellulose Corporation
Box 1305
Lumberton, NC 28359
Subject: Instream Sampling Program
NPDES NC0005321
Alpha Cellulose Corp.
Robeson Co.
Dear Mr. Walters:
Pursuant to the verbal agreement between Alpha Cellulose and the Division
of Environmental Management (DEM) put forth during our 4-11-89 meeting, I am
sending you specifics of the sampling program we discussed. This program will
be part of your company's upcoming permit renewal, but as agreed, will be done
on a voluntary basis until that time.
1) Alpha Cellulose's '-^ct—.�r�� self -monitoring locations are revised as
follows (map copies attached):
upstream SR 1620
1st downstream: SR 2123
2nd downstream: SR 2121
2) Parameters to be sampled: temperature, conductivity, dissolved oxygen,
and pH.
3) During the months of April through October, the sampling frequency will
be twice per week with these days being Tuesday and Friday. During the
months of November through March, the sampling frequency will be once per
week with this day being Wednesday (program will start 6-1-89).
4) Sampling will be performed between the hours of 0900 and 1100.
5) A sampling protocol will be developed with DEM's Fayetteville Regional
Office (FRO). This protocol will reflect procedures detailed in "Standard
Methods" and the Division's standard operating procedure for water quality
modeling. Alpha Cellulose technicians will maintain sampling instruments
in a manner that will produce accurate, reproducible results (calibrating
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

instruments before each sampling run, checking calibration after each run,
changing DO probe membranes when necessary, etc.)
6) Alpha Cellulose will collect a long-term BOD at each of its designated
sampling sites during the months of July, August, and September. Each
month's sampling day for this parameter shall be coordinated beforehand
with the FRO. It is very important that Alpha Cellulose and the other
dischargers involved in this joint study retain a common laboratory for
analyzing the long-term BOD samples. The FRO can assist your company by
providing a list of laboratories that are set up to do this test. The
laboratory that is selected should be made aware that DEM has certain
guidelines that need to be followed when a long-term test is performed,
these are:
a) No nitrogen inhibitors shall be used.
b) In addition to ultimate BOD, intermediate nitrogen series
measurements should be made (upon set-up and at days 5, 15,
and 25).
c) Tests will be run as long as necessary to predict an ultimate
BOD, but at least 30 days.
7) Long-term test data and a copy of the monthly DMR sheets should be sent
within 30 days of completion to:
Ms. Carla Sanderson
Technical Support Unit
Water Quality Section
NRCD/DEM
P.O. Box 27687
Raleigh, NC 27611-7687
Please contact either Trevor Clements or David Vogt at [phone] if
you desire further clarification of this matter.
Sincerely,
Steve W. Tedder, Chief
Water Quality Section
cc: David Vogt, Technical Support
Dale Overcash, Permits and Engineering
Trevor Clements, Technical Support
Tommy Stevens, Fayetteville Regional Office
Central Files

7
CD
__o-\
7?
Jj�
01, 1
CD
CD
Cl)
T T
TZ
tit .
L
t
4 Jit' i
7-1
000
n
x
IF
CS

I taw/
March 16, 1989
Mr. Jule Shanklin
NCDNRED
Division of Environmental Management
P.O. Box 27687
Raleigh, NC 27611-7687
hjjff.
1
r
kp
Dear Jule:
Attached is the priority pollutant analysis required for Alpha Cellulose
Corporation's new permit.
In reference to color, measured on a spectrophotometer, our effluent averages
6.80% transmittance and 1.25% absorbance.
If you need any further information, please call.
Sincerely yours,
Clayton R. Walters
Technical Superintendent
Enclosure
CRW/sl
1000 East Nair Street Box 1305 Lumberton, North Carolina 28359 telephone [phone] TWX 510 939 3505

2 ♦y,
f
RF.sJ'
LIYi;!
ALPHA CELLULOSE
MR. CLAYTON VaLTERS ALPHA CELLULOSE
P.O. BOX 1305
LUMBERTON, NC 28358 DATE: 12/07/88
CERTIFIED BY:
PARAMETERS EFFLUENT
FECAL COLIFORM (MF), /100 mis
TOTAL KJELDAHL NITROGEN, mg/l
TOTAL PHOSPHATE, mg/l
OIL AND GREASE, mg/l
PHENOL, ug/l
TOTAL ORGANIC CARBON, mg/l
TOTAL CYANIDE, mg/l
ANTIMONY, ug/l
ARSENIC, ug/l
BERYLLIUM, ug/1
CADMIUM, ug/l
COPPER, ug/l
TOTAL CHROMIUM, ug/l
IRON, ug/l
LEAD, ug/l
MAGNESIUM, ug/1
MANGANESE, ug/l
MERCURY, ug/1
NICKEL, ug/1
SELENIUM, ug/l
SILVER, ug/l
THALLIUM, ug/l
ZINC, ug/l
TOTAL TOXIC ORGANICS,
<10
456.0
2.80
7.0
88
7.40
Q.01
24
25
<10
<1
37
10.0
930
11
20700
60
Q.8
23
<1
4.7
100
127

Comment
BQL - BELOW QUANTITATION LIMIT
Alpha Cellulose 12/07/88
GC/MS Acid Extractables
EPA Method 625 Compounds
1 EA Sample No_ 213091 1
Sample Identification AC
Date Extracted December 13, 1988
Date Analyzed December 20, 1988
By O'Toole
Results
W.iter
Number
Compound
Quantitation Limit
Concentration
ua/L
M/L
1
4-CHLORO-3- MET HYLPHENOL
10
BQL
2
2-CHLOROPHENOL
10
BOL
2,4-DICHLOROPHENOL
10
BQL
4
2,4-DIMETHYLPHENOL
10
BQL
S
2,4-DINITROPHENOL
50
BQL
6
2- METHYL- 4,6-DINITROPHENOL
50
BQL
7
2-NITROPHENOL
10
BQL
8
4-NITROPHENOL
S0
BQL
Q
PENTACHLOROPHENOL
50
BQL
10
PHENOL
10
BQL
11
2,4,6-TRICHLOROPHENOL
10
BQL

Commenta
SOL - 8ELOW QUANTITATION LIMIT
Alpha Cellulose 12/07/88
IEA Sample No.
213091 1 Sample Identification AC
Date Extracted
December 13, 1983 Date Analyzed December 20,
1988 By
O'Toole
GC/MS Base/Neutral Extractables
EPA Method 625 Compounds
Water
Quantltatlon Limit
Concentration
Number
Compound
LLL
u ] f L
1
ACENAPHTHENE
10
SQL
2
ACEN APHTHYLENE
10
BQL
3
ANTHRACENE
10
SQL
4
BENZO (a) ANTHRACENE
10
BQL
5
BENZO (a)PYRENE
10
BQL
6
BENZO (b) FLUORANTHENE
10
BQL
7
BENZO (ghi) PER.YLENE
10
BQL
8
BENZO (k) FLUORANTHENE
10
BQL
9
BIB (.2-CHLOROETHOXY) METHANE
10
BQL
10
BIB (2-CHLOROETHYL) ETHER
10
BQL
11
BIS(2-CHLOROISOPROPYL)ETHER
10
BQL
12
BIS (2-ETHYLHEXYL) PHTHALATE
10
BQL
13
4-BROMOPHENYL PHENYL ETHER
10
BQL
14
BENZYLBUTYL PHTHALATE
10
BQL
15
2-CHLORONAPHTHALENE
10
BQL
16
4-CHLQROPHENYL PHENYL ETHER
10
BQL
17
CHRYSENE
10
BQL
13
DIBENZO (a,h) ANTHRACENE
10
BQL
19
1,2-DiCHLOROBENZENE
10
BQL
20
1 ?-DIC1-!LOROBENZENE
10
BQL
21
1,4-DICHLOROBENZENE
10
BQL
22
3 3'-CICHLOkOBENZlDINE
10
BQL
23
DIETHYL PHTH AL ATE
10
BQL
24
DIP^ETHYL PHTHALATE
10
BQL
25
DI-N-BUTYL PHTHALATE
10
BQL
26
2,4-DINITROTOLUENE
10
BQL
27
2,6-DtNITROTOLUENE
10
BQL
23
DI-N-OCTYLPHTHALATE
10
BQL
29
FLUORANTHENE
10
BQL
30
FLUORENE
10
BQL
31
HEX ACHLOROBENZENE
10
BQL
32
HEX ACHLOROBUT AD IENE
10
BQL
33
HEX ACHLOROCYCLOPENT AD IENE
10
BQL
34
HEXACHLOROETHANE
10
BQL
35
INDENO 0 ,2,3-ed) PYRENE
10
BQL
36
ISOPHORONE
10
BQL
37
NAPHTHALENE
10
BQL
38
NITROBENZENE
10
BQL
39
N-PI ITROSO-D I-N-PP,OPYL AM INE
10
BQL
40
N-NITROSODPHENYL AMINE
10
BQL
41
PHEPIANTHRENE
10
BQL
42
PYRENE
10
BQL
43
1 2,4-TRICHLOROBENZENE
10
BQL
44
BENZIDINE
543
BQL
45
1 ,2- D IPHENYLHYDR AZ INE
50
BOL
46
N-N ITROSOD IMETHYL AM INE
10
BQL

Comments
BQL - BELOW QUANTITATION LIMIT
Alpha Cellulose 12/07/88
Pesticides/PCBs
SW-846 Method 8080
lEA Sample No_ 213091 1
Sample Identification AC
Date Analyzed December 29, 1988 By K_ Hinshaw
Wi,ter
Number
Compound
Quantitation Limit
Concentration
GC:'MS Confirmation:
AVIL
uq/L
Yes/No
1
alpha - BHC
0.05
BQL
No
2
beta - BHC
0.05
BQL
No
3
delta - BHC
0.05
BQL
No
4
gamma - BHC (Lindanel
0.05
BQL
No
5
Heptachlor
0 05
BQL
No
6
Oki n
0.05
BQL
No
7
Heptachlor epoxide
0.05
BQL
No
8
Endosulfan 1
0.05
BQL
No
9
Dieldri n
0.10
BQL
No
10
4,4'-DDE
0.10
BQL
No
11
Endri n
0.10
BQL
No
12
Endosulfan II
0.10
BQL
No
13
4,4'-DDD
0.10
SQL
No
14
Endosulfan sulfate
0.10
BQL
No
15
4,4'-DDT
0.10
BQL
No
16
End rin Ketone
0.10
BQL
No
17
MethoxWhlor
0.5
BQL
No
18
al pha-Chlordane
0.5
BQL
No
19
gamma -Chlordane
0.5
BQL
No
20
Toxaphene
1.0
BQL
No
21
PCB 1016
0.5
BQL
No
LL
PCB 1221
0.5
BQL
No
23
PCB 12132
0.5
BQL
No
24
Pf-81242
0.5
BQL
No
25
PCB 1248
0.5
BQL
No
26
PCB 1254
1.0
BQL
No
27
PCB 1260
1.0
BOL
No

Comment:;
rill DWL - lDLIL;iIIlSY I�iJUAl INTI T!H. TIUIYVI L11A1i1T
Alpha Cellulose
12/07/88
GC/MS Purgeobl es
EPA Method 624 Compounds
EA Sample No. 21.309 i 1
Sample Identification AC
Date Anal yzed December 16. 1933 By Cornwell
Number
1
3
4
5
6
7
8
9
10
11
13
1 Y
15
16
17
18
19
20
21
22
23
24
25
26
27
�A
29
30
31
Compound
BENZENE
BROMODICHLOPOMETHANE
BROMOFORr1
BROMOMETHANE
CARBON TETRACHLORIDE
CHLOROBENZENE
CHLOROETHANE
2-CHLOROETHYLYINYL ETHER
CHLOROFORM
CHLf P,OMETHANE
DI BROMOCHLOROMETHANE
1 �-DICHLOROBEN7ENE
1,3- DICHLOROBENZENE
=� -
vii iiL..U.L /
1 1-DICHLOROETHANE
1 ,2-DICHLOROETHANE
1 1-DICHLOROETHENE
tr3n3-1,2-DICHLOROETHENE
1 2-DICHLOROPROPANE
cis-1,3- DICHLOROPROPENE
trans-1,3- DICHLOROPROPENE
ETHYL BENZENE
METHYLENE CHLORIDE
1,1,2,2-TETRAC HLOR.OETHANE
TETRACHLOROETHENE
TOLUENE
1 ,1 ,1-TRICHLOROETHANE
1 1 2-TRIrHL OROETHANE
TRICHLOROETHENE
TRICHLOROFLUOROMETHANE
VI NYL CHLORIDE
Water
Quantitation Limit
ug;' L
5
5
5
10
5
5
10
5
5
10
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
10
Results
Concentration
ALL
BQL
BQL
BQL
BOL
BQL
BOL
BQL
BQL
77F i �.1
BQL r
BQL,s�- -
GCS�1M
BQL �\J\
BQL
BiJL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL
13
BQL
BQL
BQL
BQL
BQL
BQL
BQL
BQL

March 14, 1989
Mr. Jule Shanklin
NCDNRED
Division of Environmental Management
P.O. Box 27687
Raleigh, NC 27611-7687
Dear Mr. Shanklin:
2
z
�•.._ _.. 'ley G� i..
1989
f
Attached is the information you requested to help you evaluate Alpha Cellulose
Corporation's request for an increase in permit limitations. I have also
supplied graphs of the information based on yearly averages.
The following information illustrates the dramatic increase in mill production,
TSS, BOD and to a lesser degree flow:
COMPARISON ( 1979-1980)vs.(1987-1988
AVG. MILL
AVG. BOD
AVG. TSS
AVG. FLOW
PRODUCTION TONS/DAY
LBS./DAY
LBS./DAY
MMGD
LIMIT
332
335
1.600
1979-1980
94
179
151
0.938
1987-1988
146
293
274
1.173
INCREASE
55%
64%
81%
25%
The average flow has further increased in January and February, 1989 to 1.358 MGD,
an increase of 45% over 1979-1980.
The planned production for 1989 is 200 tons/day which would be 113% increase in
production over 1979-1980.
The information I have supplied you should help you to make a decision as to
whether to grant Alpha Cellulose Corporation an increase in limitations.
Thank you.
Sincerely yours,
Clayton R. Walters
Technical Superintendent
1000 East Nair Strsst Box 1305 Lumberton, North Carolina 28359
telephone [phone] TWX 510 939 3505

YEARLY AVERAGES
AVG. PRODUCTION
AVG. FLOW
AVG. BOD
AVG. TSS
YEAR
TONS/DAY
MMGD
LBS./DAY
LBS./DAY
1979
96
.857
174
140
1980
92
1.019
184
159
1981
106
1.039
214
116
1982
124
1.185
248
240
1983
133
1.143
314
314
1984
135
1.083
194
229
1985
133
.914
230
205
1986
136
.835
201
216
1987
147
1.069
279
260
1988
145
1.276
306
288
1989 *
200
* PROJECTED

u.
O
-A
l
0
i

B-f li °lX 51 41 9$ z8
08 yLb/
� 8s bi - b c �►) ss1 ��#���d ��a�n

Af td
9� S� 7V / 8 09 6G bl
CIotl 9 °IM 3n t{ -\ -&tsgA

VE:An,L.y g\/aftA6eir I= ow C19-7`t- i 4 S$i
/.Soo;
,'. 2 00
/. ioo
u
r-
�
.9001
�00
/979 d o 73 'PIP
1��A2

MONTHLY
AVERAGES
BOD
MAX
TONS
TONS
DAILY
AGV.
DAILY
AVG.
DAILY
AVG. PROD.
DAILY MAX
FLOW AVG.
MAX.
BOD
MAX
TSS
TSS
DEC
88
136
185
1.209
1.531
399
580
429
479
NOV
88
145
181
1.241
1.516
655
988
412
495
OCT
88
148
181
1.296
1.547
249
307
260
311
SEPT
88
148
184
1.311
1.551
234
281
222
296
AUG
88
150
202
1.120
1.510
222
253
250
277
JULY
88
151
192
1.150
1.471
172
245
185
259
JUNE
88
151
192
1.318
1.500
293
320
259
285
MAY
88
153
199
1.339
1.560
305
310
295
312
APRIL
88
149
194
1.303
1.483
328
220
268
295
MARCH
88
130
179
1.400
1.555
263
281
261
266
FEB
88
139
180
1.375
1.544
280
313
304
321
JAN
88
138
194
1.252
1.558
273
329
310
329
DEC
87
145
174
1.257
1.497
289
289
296
304
NOV
87
146
182
1.271
1.593
279
311
270
285
OCT
87
146
181
1.335
1.555
274
285
224
231
SEPT
87
147
189
1.308
1.598
308
311
300
333
AUG
87
149
186
0.824
1.400
280
304
222
259
JULY
87
160
183
0.975
1.425
309
329
231
329
JUNE
87
153
183
1.069
1.324
254
293
253
324
MAY
87
151
172
0.977
1.354
258
294
236
294
APRIL
87
152
188
1.065
1.265
282
321
280
307
MARCH
87
138
171
.961
1.288
295
303
294
304
FEB
87
139
166
0.909
1.201
326
326
307
307
JAN
87
141
167
0.876
1.266
190
317
205
338

MONTHLY
AVERAGES
BOD
MAX
TONS
TONS
DAILY
AGV.
DAILY
AVG.
DAILY
AVG. PROD.
DAILY MAX
FLOW AVG.
MAX.
BOD
MAX
TSS
TSS
DEC
86
148
176
.804
1.296
207
345
201
345
NOV
86
147
177
OCT
86
145
173
.925
1.364
200
386
216
364
SEPT
86
124
144
.793
1.281
205
303
185
299
AUG
86
120
152
.601
1.374
105
297
125
367
JULY
86
139
169
1.018
1.526
267
407
267
331
JUNE
86
139
161
1.043
1.296
256
367
278
305
MAY
86
134
177
1.018
1.493
259
423
267
319
APRIL
86
140
179
.768
1.216
179
385
210
333
MARCH
86
128
167
.661
1.152
121
269
182
346
FEB
86
141
162
.768
1.152
195
345
224
346
JAN
86
131
169
.791
1.299
219
309
320
330
DEC
85
135
168
.726
1.339
194
258
233
323
NOV
85
138
180
.737
1.267
215
2k5
N/A
-
OCT
85
150
188
.733
1.267
257
257
N/A
-
SEPT
85
148
180
.802
1.272
224
224
298
298
AUG
85
126
190
.796
1.378
245
245
N/A
JULY
85
129
167
.685
1.296
224
224
N/A
JUNE
85
131
171
1.123
1.411
302
302
180
180
MAY
85
133
162
1.077
1.301
223
223
N/A
-
APRIL
85
137
191
.976
1.359
206
206
294
294
MARCH
85
129
154
1.113
1.415
252
252
196
196
FEB
85
123
154
1.112
1.403
177
177
197
197
JAN
85
120
156
1.082
1.303
239
239
34
34

MONTHLY AVERAGES
BOD
MAX
TONS
TONS
DAILY
AGV.
DAILY
AVG.
DAILY
AVG. PROD.
DAILY MAX
FLOW AVG.
MAX.
BOD
MAX
TSS
TSS
DEC
84
133
161
1.122
1.411
169
234
121
121
NOV
84
137
160
OCT
84
124
176
1.076
1.349
307
307
N/A
N/A
SEPT
84
136
179
1.056
1.340
232
232
227
227
AUG
84
133
167
1.054
1.301
91
91
N/A
N/A
JULY
84
136
175
1.113
1.375
246
246
N/A
-
JUNE
84
143
178
1.025
1.411
186
186
279
279
MAY
84
141
175
1.036
1.469
95
95
N/A
N/A
APRIL
84
137
161
1.062
1.399
165
165
N/A
N/A
MARCH
84
141
163
1.175
1.411
209
209
290
290
FEB
84
130
150
1.082
1.382
207
207
N/A
N/A
JAN
84
134
159
1.114
1.378
230
230
N/A
N/A
DEC
83
143
169
1.150
1.511
242
242
165
165
NOV
83
138
170
1.069
1.418
226
266
N/A
N/A
OCT
83
133
162
1.154
1.420
184
184
N/A
N/A
SEPT
83
136
180
1.132
1.425
N/A
N/A
587
587
AUG
83
137
171
1.212
1.574
270
270
N/A
N/A
JULY
83
125
175
1.190
1.423
513
513
N/A
N/A
JUNE
83
120
155
1.063
1.428
420
420
302
302
MAY
83
128
169
1.153
1.354
258
258
N/A
N/A
APRIL
83
135
175
1.313
1.450
433
433
N/A
N/A
MARCH
83
137
166
1.130
1.460
383
383
201
201
FEB
83
133
166
1.170
1.320
N/A
N/A
N/A
N/A
JAN
83
127
156
.980
1.440
212
212
N/A
N/A

MONTHLY
AVERAGES
BOD
MAX
TONS
TONS
DAILY
ACV.
DAILY
AVG.
DAILY
AVG. PROD.
DAILY MAX
FLOW AVG.
MAX.
BOD
MAX
TSS
TSS
DEC
82
132
160
1.140
1.470
225
225
510
510
NOV
82
136
164
1.260
1.510
253
253
N/A
-
OCT
82
132
169
1.075
1.550
392
392
N/A
-
SEPT
82
128
172
1.320
1.450
219
219
171
171
AUG
82
126
164
1.230
1.390
253
253
N/A
-
JULY
82
116
148
1.320
1.450
285
285
N/A
-
JUNE
82
120
149
1.270
1.410
163
163
74
74
MAY
82
128
158
1.260
1.390
257
257
N/A
-
APRIL
82
125
159
1.250
1.440
236
236
N/A
-
MARCH
82
119
151
1.080
1.410
234
234
205
205
FEB
82
113
153
.980
1.170
273
273
N/A
-
JAN
82
107
144
1.030
1.170
188
188
N/A
-
DEC
81
115
156
.980
1.090
184
184
48
48
NOV
81
91
152
.950
1.160
223
223
N/A
-
OCT
81
116
159
.980
1.240
147
147
N/A
-
SEPT
81
103
152
.980
1.350
210
210
90
90
AUG
81
103
140
1.110
1.320
228
228
N/A
-
JULY
81
94
136
1.150
1.360
242
242
N/A
-
JUNE
81
115
149
1.200
1.300
250
250
210
210
MAY
81
111
148
1.140
1.270
236
236
N/A
-
APRIL
81
108
154
1.050
1.330
210
210
N/A
-
MARCH
81
114
151
1.040
1.200
198
198
116
116
FEB
81
106
157
.950
1.120
241
241
N/A
-
JAN
81
98
143
.940
1.100
204
204
N/A
-

MONTHLY
AVERAGES
BOD
MAX
TONS
TONS
DAILY
AGV.
DAILY
AVG.
DAILY
AVG. PROD.
DAILY MAX
FLOW AVG.
MAX.
BOD
MAX
TSS
TSS
DEC
80
88
153
1.000
1.170
254
254
205
205
NOV
80
107
143
1.070
1.280
206
206
N/A
-
OCT
80
93
126
1.060
1.240
202
202
N/A
-
SEPT
80
97
128
1.100
1.210
225
225
117
117
AUG
80
101
131
1.100
1.230
217
217
N/A
-
JULY
80
85
116
1.070
1.290
290
290
N/A
-
JUNE
80
100
132
1.090
1.250
246
246
174
174
MAY
80
94
129
1.020
1.280
206
206
N/A
-
APRIL
80
101
135
.980
1.100
215
215
N/A
-
MARCH
80
87
116
.930
1.090
196
196
138
138
FEB
80
74
111
.900
.980
163
163
N/A
-
JAN
80
81
110
.910
.980
184
184
N/A
-
DEC
79
93
122
.900
.970
184
184
149
149
NOV
79
100
123
.880
.960
187
187
N/A
-
OCT
79
94
127
.870
.980
168
168
N/A
-
SEPT
79
N/A
N/A
.850
.950
148
148
149
149
AUG
79
N/A
N/A
.850
.930
178
178
N/A
-
JULY
79
N/A
N/A
.840
.950
164
164
N/A
-
JUNE
79
N/A
N/A
.850
.930
178
178
109
109
MAY
79
N/A
N/A
.850
.910
182
182
N/A
-
APRIL
79
N/A
N/A
.850
.920
185
185
N/A
-
MARCH
79
N/A
N/A
.850
.910
145
145
152
152
FEB
79
N/A
N/A
.850
.920
176
176
N/A
-
JAN
79
N/A
N/A
.857
.938
187
187
N/A
-

re .
State of North Carolina rye/4 s£ 11'8,g
Department of Natural Resources and Community Developm' SB19q
Division of Environ rental iv nagement NChr
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
February 13, 1989
Clayton R. Walters, Technical Superintendent
Alpha Cellulose Corporation
P.O. Box 1305
Lumberton, N.C. 28359
Subject:
Dear Mr. Walters:
R. Paul Wilms
Director
Modification Request
NPDES Permit NC0005321
Alpha Cellulose Corporation
Robeson County
We have received your January 25, 1989 request for increase in permit
limitations due to production increase at Alpha Cellulose. In order to make a
detailed evaluation of your request, please provide the following for the previous
10-year period cited in your letter:
Parameter Monthly Average Daily Max. for that month
Production Data (1) (1)
Wastewater flow (1) (1)
BODS (1) (1)
TSS (1) (1)
Planned Production (2) (2)
(1) 12 monthly values x 10 years= 120 values
(2) Cited parameter(s) as well as effective date(s)
your application is currently being reviewed using your present limits. The Division
of Environmental Management must perform another review of any proposed changes by
Alpha Cellulose. Therefore, your expansion request cannot be complete until the above
requested data is received. The above requested information must be received before
March 3, 1989, to be reviewed as part of your renewal request.
If you have any questions, please call me at 919/733-5083.
cc: Mick Noland
David Vogt
Sincerely,
)ule Shanklin
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
S. Thomas Rhodes, Secretary December 20, 1988 Director
Mr. Clayton Walters
Alpha Cellulose Corporation
1000 East Noir Street
Lumberton, N.C. 28359
Dear Mr. Walters:
SUBJECT: Permit No. NC0005321
Authorization to Construct
Alpha Cellulose Corporation
Wastewater Treatment Facility
Robeson County
A letter of request for an Authori-zation to Construct was received November
21, 1988, by the Division and final plans and specifications for the subject project
have been reviewed and found to be satisfactory. Authorization is hereby granted
for the construction of additional facilities consistin` of a 220,000 gallon
circular clarifier (60 feet diameter) to provide primar_, clarification to serve
Alpha Cellulose Corporation.
This Authorization to Construct is issued in accor-:.ance with Part III paragraph
B of the NPDES Permit No. NC0005321 issued August 25, 1986, and shall be subject_
to revocation unless the wastewater treatment facilitie!- are constructed in
accordance with the conditions and limitations specified in Permit No. NC0005321.
The sludge generated from these treatment facilities must be disposed of in
accordance with G.S. 143-215.1 and in a manner approvable by the North Carolina
Division of Environmental Management.
In event the facilities fail to perform satisfactorily in meeting its NPDES
permit effluent limits, the permittee shall take such immediate corrective action as
may be required by this Division, including the construction of additional
wastewater treatment and disposal facilities.
Upon completion of construction and prior to operation of this permitted
facility, a certification must be received from a professional engineer certifying
that the permitted facility has been installed in accordance with the approved plans
and specifications. Mail the Certification to the Perm.ts and Engineering Unit,
P.O. Box 27687, Raleigh, N.C. 27611-7687.
A set of approved plans and specifications for the subject project must be
retained by the applicant for the life of the project-.
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

One (1) set of approved plans and specifications is being forwarded to you. If
you have any questions or need additional information, please contact Mr. Jack
Floyd, telephone number 919/733-5083.
Sincerely,
R. Paul Wilms
cc Robeson County Heralth Department
Fayetteville Regional Supervisor
Mr. Dennis R. Ramsey
ENGINEER'S CERTIFICATION
I, , as a duly registered Professional
Engineer in the State of North Carolina, having been authorized to observe
(periodically/weekly/full time) the construction of the project,
(Project)
(Name or Location)
for the
hereby state that, to the best of my
(Project Owner)
abilities, due care and diligence was used in the observation of the project
construction such that the construction was observed to be built within substantial
compliance and intent of the approved plans and specifications.
Signature
Date
Registration No.

!Vd kP
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sf�o , Pe- W re( I
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/ Sin(-L Tc Ca E Gc1
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MEMO.
TO: + (e-
DATE: 3- i 6— J 7
er
SUBJECT: L
A' C.ejt. I s e 4 Lv"I t Jc� (, , ; �er,,f
r
�P-%j A -, Sys 0(t).tC- cvx.- 3-13-97 rdeol1
j;0 1) n _f% C- Cr
,t 1 +1 vvj�� J� r �e)Nf ra - 't I It
*'TLC e,-�o /I c. n ew 11,
w .` b O = Sy
� J
C �) s
14 Y u ( A, 9 1 - C 114 5-- 3
V /
North Carolina Department of Natural
f : Resources
&Comaunit Development
Ql-
.� Y p

C, J-u�e�riokA
hu�Of
loPr veIV f ('
West P,4�
P`PPPr�`�
a . �;- rn (r v
Pee, I I
6.2. /3,0- 7700 �6
-D�4 = 711 ,, Ie z
S74 10 = /.� $ c f.s
w7,+lo = / I / c fs
qo = 1?1.Scfs/
kum Lerjuti Luuj fO
02.13`f1. 79Sp &(.
Q w Z l o. o mtrD
D4 = his/ ticle- I
S 70 o = /A f c fs
(A,7*lo = III C{S
A = fG7c�S
41pO cz Ce(�u%ose
02.13511.797,E %L
Q w = 1 co � C L
DA = 7/y le Z
S7gZS rIS
uj7cj jo = 19/c. fS
Carte cip�4cC.i��
qN
d.)
r,
coo//,?
I alcF
1` ec. G� L4
oa. 134 Z It so U.
DA = 14z wide'' --�
S`7Qto= 1'0 cis
k-7� iu = 144 c�
1"? e 0 ,.
/
0134 2-- 1347-0
S7131 c(S
L417Ct?(0
1U6 �f Cjour
�--- s►� a t z�
off, t 3 � z. 3aao �6
/4 = 746. m,(e L
S7QIv= I,ZUC�S
l�7(� fo = 1Y5 c�

MEMO.
TO: :� l (Q
DATE: 3 - ' k - ,C- 7
w i-Z-4-tf
SUBJECT: _ w L, A
;8 ,-tC I p� Cej IV l d s
were. f,- n Sec Sce i t `�
rw y e (LA) , j c.r-)
.t.o (3C) -+ 4. zu) = I
` (44,, Ct4(I(aS a
3 • o (30) f 4..s--
U %01 CJ I &%o%� j J 6 C L
.lti�eS c4jcr� Ccss� bL Se
CL
,V
North Carolina Department of Natural
Resources &Community Development

dJ
00
ci
cY
I
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2
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_
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its
i

F
STATION NO.
STATION
NAME
DRAINAGE AREA
QA.
7g10
W7Q10
0213361900
Lumber
R.
at
SR 1404 nr Wagram, NC
340
474
104
145
0213361780
Lumber
R.
nr
Wagram, NC
349
486
106
146
0213361985
Lumber
R.
ab
SR 1433 nr Wagram, NC
350
488
107
146
0213362100
Lumber
R.
at
SR 1433 nr Laurinburg, NC
354
493
108
146
0213362400
Lumber
R.
at
NC 71 nr Maxton, NC
365
508
111
148
-0213362405
Lumber
R.
ab
AURR nr Maxton, NC
367
511
111
148
0213362600
Lumber
R.
nr
Maxton, NC
372
517
112
148 0
0213362700
Lumber
R.
nr
Daystrom, NC
374
319
112
149
0213365100
Lumber
R.
at
NC 710 nr Pembroke, NC
420
583
114
154
0213367100
Lumber
R.
at
Pembroke. NC
427
590
114
155
0213369100
Lumber
R.
nr
Moss Neck, NC
432
595
114
156
0213369150
Lumber
R.
ab
Back Swp nr Lumberton, NC
438
601
118
157
0213375150
Lumber
R.
bl
Back Swp nr Lumberton, NC
471
634
115
161
0213379610
Lumber
R.
at
NC 72 at Lumberton, NC706
505
670
116
165
w.sfi P.a-r 0213415150
Lumber
R.
at
I 95 nr Lumberton, NC
706
860
128
r11--pfemi(-s0213417700
Lumber
R.
nr
Lumberton
711
867
128
190
-�0213417950
Lumber
R.
bl
SR 2289 nr Lumberton, NC
714
867
129
191
WwTIO 4-70213417975
(•se 0213421950
Lumber
R.
ab
US 74 nr Lumberton, NC
714
867
129
191
191
u((
Lumber
R.
bl
US 74 at Popes Landing, NC
742
890
130
194
0213423000
Lumber
R.
at
SR 2123 nr Popes Landing, NC
746
894
130
195
0213423450
Lumber
R.
at
SR 2121 nr Orrum, NC
770
916
131
198
0213423475
Lumber
R.
nr
Boardman, NC
786
931
131
208
*Note:
The accuracy of these estimates is estimated to range from 15 to 30 percent. The significant figures shown imply
greater accuracy, however this refinement is for computational purposes only and no greater degree of accuracy
should be assumed.
REC'1
JW4

SUMMER
---------- MODEL RESULTS ----------
Discharger : LUMBERTON WWTP
Receiving Stream : LUMBER RIVER
______________________________________________________________________
The End D.O. is 5.10 mg/l.
The End CBOD is 7.01 mg/l.
The End NBOD is 0.00 mg/l.
______________________________________________________________________
`
WLA
WLA
WLA
DO Min CBOD
NBOD
DO
Waste Flow
(mg/l) Milepoint Reach # (mg/l)
_______ ____
(mg/l)
____
(mg/l)
__
(mgd)
-----------
Segment
1
______ _________
5.08 9.96 6
Reach
1
[ue*f��u ��3 ^]| 46
-y '� 79
0.00
0.00
0.00
5.00
2.50000
10.00000
Reach
2
�_��� of A
Reach
3
�(�� ��K / s 79
0.00
5.00
1.60000
Reach
Reach
4
5
�? 2�'' 8— ]&35
*u``-C"^r«� /Loo�ar��
�� 0
0 00
^
0.00
^
0 00
0.00
^
0 00900
0.00000
Reach
6
0
0.00
0.00
0.00000

*** I' DE EL. 'SUl''1P'1AFZ`r 1)Fi T A *-x- :•
W W T' P S t_t b b a .; i. ri : 0 3 f) ""151.
Rercei.vinq Streafn L_U1,11'AER RIVER citr-earn C,'-Sw
i!_tnal r It 1.0 1.29„ Wrote r. '1*,'(..)].(..) 1.91 .
E)esi(a'r'r 6.
;LENGTH; SLOPE: VELOCITY ; DEPTH: K1 1 Ki 1 K2 1 K2 1 KN 1 K:N 1 K:NR ; KNR 1
mile ; Wail fps ; ft ;design; 3201 ;design; 3201 ;design; Ml ;design; 320' 1
Segment 1 ; 0.661 1.15: 0.472 ; 4.32 1 0.48 ; 0.36 ; 0.54 1 0.481 0.00 1 0.00 ; 0.00 ; 0.00
Reach 1 ; ; 1 ; ; ; ; 1 ;
-----------------------------------------------------------------------------------------------------
1 1 1 i i 1 1 i 1 1 1 1 i
Segment 1 1 0.301 1.15: 0.514 ; 4.39 1 0.48 ; 0.36 1 0.59 ; 0.521 0.00 ; 0.00 ; 0.00 ; 0.00
Reach 2 ; ; 1 1
-----------------------------------------------------------------------------------------------------
,
Segment 1 ; 0.941 1.151 0.521 1 4.39 1 0.48 ; 0.36 1 0.60 ; 0.53; 0.00 ; 0.00 1 0.00 1 0.00
Reach 3
-----------------------------------------------------------------------------------------------------
i
Segment 1 1 3.82: 1.851 0.597 1 4.11 ; 0.48 1 0.36 1 1.11 1 0.97; 0.00 0.00 1 0.00 ; 0.00 1
Reach 4; 1 ; 1 1 1 1 ;
-----------------------------------------------------------------------------------------------------
1
1 , , I
i 1 { , 1 1
Segment 1 1 3.03: 1.851 0.597 ; 4.12 ; 0.48 1 0.36 1 1.11 1 0.97; 0.00 ; 0.00 1 0.00 1 0.00 1
Reach 5 1 1 ; ; 1 1 ; 1
-----------------------------------------------------------------------------------------------------
Segment 1 1 2.741 1.85: 0.600 1 4.14 1 0.48 ; 0.36 1 1.11 1 0.98; 0.00 1 0.00 ; 0.00 ; 0.00
Reach 6 1 ; ; ; ; ; ; ; 1 1 1 1 1
-----------------------------------------------------------------------------------------------------
1 F l.ow
; (MOD ;
NNOF)
1 D. O. 1
cfs
; Mg/1
rng1 1
; Mg,/1 1
Segneint 1
Reach 1
6Jat.-1: e
1 3.875
1 46 .0 0i) 1
4). ('?()(-
1
lieaciwate?r s:1.L2'8 0C)0
1 2.(?C)i.) 1
o.Oo0
; 7,4iii")
I-r.. 1. b U t c�lI- y
; f_) {)(_)(_)
1 (_) . ( 0C) ;
0. 000
; C) . 0 )0
' R1_(r-10f
; 1.520
; 2 . i.)()f.) ;
0 .;, 0()
; 7 . 4()( )
f_segaierrit 1
Rei---ict-1 S
w lste
1 15.500
; "/ . f)()(,)
L-.)utal-y
1 0»iifyO
; i:).00C) 1
c_i.(10C)
1 C).0o(.)
Rt_trlr_I-ff
1 i i » C)i )C:)
; f") . fjC)i:) 1
0. ()()C)
; {:) . (::)C)(>
Segner'1t 1
RL?act 1 3
wolf>te
1 2.48)
1 79.(')(:){.:1 1
{).C>(::)(")
1 ;`,.'i.
I i b t..t •1: fa r' y
C) . ) C) (=)
; C) » C) 0 0 1
C) . i) (`) C.)i:;
. C) 0 i )
Rt_(1'"Ic-,'f'f'
; 0.000
; (> . C){:)(..)
i:) . C)C)(.1

auqWwrt x
mean" "
, Waste
| 0.014
|135.000
|
0.000
0.000
.
^ ^ Tributary
1 0.000
|
0.000 1
0.000 |
0.000
* Runoff
| 0.200
1
2.000 1
0.000 |
7.400
Segment 1
Reach 5
Waste
i 0.000
|
0.000 |
0.000 |
0.000
Tributary
| 0.000
|
0.000 |
0.000 1
0.000
* Runoff
| 0.330
|
2.000 1
0.000 |
7.400
Segment 1
Reach 6
Waste
| 0.000
(
0.000 1
0.000 1
0.000
Tributary
| 0.000
|
0.000 |
0.000 |
0.000
* Runoff
( 1.090
|
2.000 |
0.000 |
7.400
* Runoff flow is in cfs/mile

WINTER
---------- MODEL RESULTS ----------
Discharger : LUMBERTON WWTP
Receiving Stream : LUMBER RIVER
______________________________________________________________________
The End D.O. is 7.22 mg/l.
The End CBOD is 11.73 mg/l.
The End NBOD is 0.00 mg/l.
______________________________________________________________________
WLA
WLA
WLA
DO Min CBOD
NBOD
DO
Waste Flow
(mg/l) Milepoint Reach # (mg/1)
______ _________ _______ ____
(mg/l)
____
(mg/l)
__
(mgd)
-----------
Segment
1
7.22 11.36 6
Reach
1
46
0.00
0.00
2.50000
Reach
2
150
0.00
5.00
10.00000
Reach
3
180
0.00
5.00
1.60000
Reach
4
135
0.00
0.00
0.00900
Reach
5
0
0.00
0.00
0.00000
Reach
6
O
0.00
0.00
0.00000

Disc:harclei : L._L.11`'1L=+1=F;TON WWTII --' :3c..rtaf::rasin : 030751
Receiving OtreamLUMBER. RIVER Stream lL n s,: _. -. ' Irl
Summer 7010 . 129. Winter 7010 . 191.
Design Temperature: 16.
:LENGTH; SLOPE; VELOCITY : DEPTH; KI : KI : K2 ; K2 ; KN : KN : KNR ; KNR
mile : ftfmi: fps : ft :design: 82O' ;design: K0' :design: 320' :design: Z201 :
Segment 1 ; 0.66; 1.15; 0.631 ; 404 : 010 ; 0.36 : 009 ; 0.64: 0.00 : 0.00 000 : 0.00
Reach 1 : ; ; : ; : :
-----------------------------------------------------------------------------------------------------
Segment 1 ; 0.30; 1.15: 0.668 ; 4 18 1 0 A : 0.36 : 0.62 ; 0.68: 0.00 ; 0.00 ; 0.00 ; 0.00 ;
,
, , , , I
Reach 2 , ,
-----------------------------------------------------------------------------------------------------
Segment 1 ; 0.901 1.151 0.674 : 409 : 130 : 0 A ; 0.63 ; 0.681 0.00 : 0.00 ; 0.00 : 0.00 :
Reach 3 ; ; ; ; ; ; ; ; ; ; ; ; :
-----------------------------------------------------------------------------------------------------
Segment 1 ; 3.821 1.951 0.774 ; 419 ; 0.31 : O X ; 1.16 ; 1.26: 0.00 ; 0.00 0.00 : 0.00
Reach 4
-----------------------------------------------------------------------------------------------------
Segment 1 ; 3.03: 1.85: 0.775 : 4.31 : V 31 : 017 ; 1.5 ; 110 0.00 ; 0.00 ; 0.00 ; 0.00
Reach 5 ; ; ;
-----------------------------------------------------------------------------------------------------
Segment 1 : 2.741 1.85: 0.777 ; 4.32 : 0.31 : 0.37 ; 1.16 : 1.26: 0.00 : 0.00 ; 0.00 : 0.00
Reach 6 : ; ; ; : I ; ; ; : :
-----------------------------------------------------------------------------------------------------
: Flow
; CD01)
: :` BOD
:
D.O. :
cfs
a-Igi ].
; (rrgi 1
:
mgi 1 :
Segment 1
Reach 1
Waste
: 3.675
: 46.000
: 0.000
;
0.000
Headwater s: 1 9 1 . 0`• 0
: 2.000
: 0.000
;
4 . i.r00
`I'ribc_rtai-y
,
* Runoff
; 0.000
; 0.000
1 0.000
:
0.000
Oegment '1
Reach c""-_.
Waste
; 15.500
1150.000
: 0.000
;
5.C}0f.)
Tributary
: 0..00u0
1 0.000
; 0.000
:
0.000
Segment 1
Reach 3
Waste
; 2.480
1180.000
1 0.000
:
5.i.j0C.)
Tributary
: 0.000
; 0.000
; 0..00 r
:
0.000
* Runoff
: 0.000
: 0.000
; 0.000
;
0.000
U ■

, Waste
| 0.014 1135.000
|
0.000 |
0.000
^ . ^ Tributary
| 0.000 |
0.000 1
0.000 |
0.000
* Runoff
< 0.600 |
2.00() 1
0.000 |
9.000
`
Segment 1
Reach 5
Waste
i 0.000 i
0.000 |
0.000
0.000
Tributary
1 0.000 |
0.000 |
0.000 |
0.000
* Runoff
| 0.330 (
2.000
0.000 |
9.000
Segment 1
Reach 6
Waste
| 0.000 (
0.000 (
0.000 1
0.000
Tributary
| 0.000 1
0.000 |
0.000 1
0.000
* Runoff
| 1.090 (
2.000 1
0.000 (
9.000
* Runoff flow is in cfs/mile

0"_STA114
State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
S. Thomas Rhodes, Secretary Director
September 4, 1986
Mr. Jeff Truax,
Alpha Cellulose
P.O. Box 1305
Lumberton, N.C.
Dear Mr. Truax:
Technical Director
Corporation
28359
SUBJECT: Permit No. NC0005321
Authorization to Construct
Alpha Cellulose Corporation
Sludge Belt Dewatering Press
Robeson County
A letter of request for Authorization to Construct was received April
293. 1986, by the Division and final plans and specifications for the subject project
have been reviewed and found to be satisfactory. Authorization is hereby granted for
the construction of sludge dewatering facilities consisting of a 40-inch belt filter
press, filtrate return and all associated valves, piping and appurtenances to serve
the Alpha Cellulose Corporation.
This Authorization to Construct is issued in accordance with Part III
paragraph C of the NPDES Permit NO. NC0005321 issued August 25, 1986, and shall be
subject to revocation unless the wastewater treatment facilities are constructed in
accordance with the conditions and limitations specified in Permit No. NC0005321.
The Permittee must employ a certified wastewater operator in
accordance with Part III paragraph D of the referenced permit.
The sludge generated from these treatment facilities must be disposed
of in accordance with G.S. 143.215.1 and in a manner approvable by the North Carolina
Division of Environmental Management.
The Fayetteville Regional Office, telephone number 919/4861541 shall
be notified at least twenty-four (24) hours in advance of operation of the installed
system so that an in -place inspection can be made. Such notification to the Regional
Supervisor shall be made during normal office hours from 8:00 a.m. until 5:00 p.m. on
Monday through Friday, excluding State Holidays.
In event the facilities fail to perform satisfactorily in meeting its
NPDES permit effluent limits, the permittee shall take such immediate corrective
Pollution Prevention Pays
P.O. Box 27697, Raleigh, North Carolina 27611-7697 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

action as may be required by this Division, including the construction of additional
wastewater treatment and disposal facilities.
If you have any questions or need additional information, plelse
contact Mr. Donald Safrit, telephone number 919/733-5083, ext. 170.
;Sincere y yours,
4�ou 4 -�
Paul Wilms
cc: Robeson County Health Department
Mr. Dennis R. Ramsey
Fayetteville Regional Supervisor

Engineer Dat R c.
NPDES WASTE LOAD ALLOCATION s-� i8 8 3oS9
Facility Name: ` �(� GELLlt�aSE= CcK'r�o�,¢?!di✓ Date t? 8G
�fpRoobovo ro IA1ct.u.AE A1�/LaKi,M.�T�Gy LZsa Grp eF DerlEtTtc wkStt •
Existing
Proposed O Permit No.. AICOW-5--321 Pipe No.. 60( County: Q00650M
DesignCapacity (MGD) : 1-gyp Industrial (% of Flow): ?��e pa y Q'9 d Domestic (% of Flow) : Q, f ¢ 1d
Receiving Stream: L LAAIL 'Q. R1V M Class: sub -Basin: O —Q 7 - S
Reference USGS Quad: �3 (Please_ attach) Requestor: Regional Office
gt,Ar'DE1� 6aeo _
Guideline limitations, if applicable, are to be listed on the back of this form.)
a
Design Temp.: �� C.-T�9G Drainage Area (mil) = ,jy ye�� Avg. Streamflow (cfs) : %�y0
7Q10 (cfs) { y0 Winter 7Q10 (cfs )
Location of D.O. minimum (miles below outfall):
Velocity (fps): Q •Q3y
30Q2 (cfs )
Slope (fpm )
Kl (base e, per day): 10•6� K2 (base e. Der day): 2.06
Effluent
Characteristics
Monthly
Average
bu •�etm x
-rJ
�3d
tb( ►txs��
l�s
71oelk
- sv
Orig 1 Al c tion O
Revised. location
L-By
Effluent I
Characteristics
:':) ntnly
Lverage
Comments
lGR,24v
Comments: A MOM vt r
40 0YOW -ro r Cana 6; Ua6eb v�
„ctQ S*01e j .
k-U irmation O
Prepared By:
4 .-�,,, Reviewed By: Date: 5
Ii

a
For Appropriate Dischargers, list Complete Guideline Limitations Below
Effluent
Characteristics
Average
Maximum Daily
Cbmments
aoe S zo •C-
�3
&
T
ss
3ss' d�
?t C> «
gP 3-
M� -- N
8 3 �f
�fda
BP1
Itype of Product Produced I Lbs/Day Produced I Effluent Cuideline Reference I

' Request No. : 3059
--------------------- WASTELOAD ALLOCATION APPROVAL FORM - ----
�50a
Facility Name ALPHA CELLULOSE CORP. MAY 19 1986
Type of Waste :
Status :
Receiving Stream :
Stream Class :
Subbasin :
County �
Regional Office :
Requestor :
Date of Request :
Quad :
99.86% INDUSTRIAL, 0.14% DOMESTIC
EXISTING
LUMBER RIVER
C-SW
030751
ROBESON Drainage Area
FAYETTEVILLE 7010 (cfs)
SAM BRIDGES Winter 7010 Acfs>
4/18/86 3002 (cfs)
I-23 Average Flow (cfs)
pERhAfTS &ENG|NEER\MG
I
(sq mi>
------------------------- RECOMMENDED EFFLUENT LIMITS -------------------------
` : Mn Avg Dy Max
Wasteflow (mgd) : 1.6
5-Day DOD (LBS/DAY) : 332 664
Ammonia Nitrogen (LBS/D): 83 166 -
TSS (LBS/DAY) : 355 710 ���� 15 �86
pH (SU) : 6-9 ---- — —
________________________________________________________ ___
---------------------------------- COMMENTS
TOXICITY REQUIREMENTS: SEE ATTACHED PAGE
A REOPENER CLAUSE SHOULD BE PLACED IN THIS PERMIT TO ALLOW FOR CHANGES TO
BE MADE IN LIMITS BASED UPON FUTURE WATER QUALITY STUDIES. A STUDY OF THE
LUMBER RIVER IS SCHEDULED FOR 1986.
Recommended by ___
Reviewed by: - /
Tech. Support Supervisor
Regional Supervisor 0
Permits & Engineerin4
/an
Date__ _
Date_ -��/Y�- /M�
Date -

F • ( � A` e.¢.��� (ose (;gy p, W C 006 537-1
(s w ,• I. % M lrD
-7& Lo
1.) The permittee shall conduct chronic toxicity tests on a quarterly
basis using protocols defined in E.P.A. Document 600/4-85/014
entitled "Short -Term Methods for Estimating the Chronic Toxicity
of Effluents and Receiving Waters to Freshwater Organisms". The
testing shall be performed as a Ceriodaphnia Survival and Repro-
duction Test. Effluent collection will be performed twice during
each test as 24 hour composite samples. Toxicity test exposure
using the first composite sample will include the first three full
days of testing. Exposure to the second composite sample will in-
clude the last four full days of testing. Efflue samples will
be taken immediately prior to disinfection, but 4= all other
treatment processes. The Chronic Value (ChV) must be greater than
0 %. There will be minimally five effluent concentrations and a
control exposure treatment. One effluent concentration shall equal
(.'7 %, which represents the instream waste concentration (I.W.C.)
during 7Q10 low flow conditions and daily permitted discharge volume.
The remaining concentrations shall be Q,S� 3..5 �Lk�
There may not be more than 20% mortality in at least 9/ effluent
after 48 hours of exposure.
Note: Failure to achieve test conditions as specified ini:the cited
document, such as minimum control organism survival and appropriate
environmental controls, shall constitute an invalid test and will re-
quire immediate retesting. Failure to submit suitable test results
will constitute a permit violation.

Request No. : 3059
--------------------- WASTELOAD ALLOCATION APPROVAL FORM ----------------------
Facility Name : Alpha Cellulose Corp.
Type of Waste . 99.86 % Industrial, 0.14 % Domestic
Status : Existing
Receiving Stream : Lumber River
Stream Class : C-SW
Subbasin : 030751
County : Robeson Drainage Area (sq mi) . 714
Regional Office : Fayetteville 7Q10 (cfs) . 140
Requestor : Sam Bridges Winter 7Q10 (cfs)
Date of Request : 4/18/86 30Q2 (cfs)
Quad : Bladenboro Average Flow (cfs) 760
c
------------------------- RECOMMENDED EFFLUENT LIMITS -------------------------
: Mn Avg Dy Max �+
Wasteflow (mgd) : 1.6
5-Day BOD (lbs/day) : 332 664 JT 1�g
APR 2'4
Ammonia Nitrogen (lbs/day)
: 83 166
T S S ( lb s /day ) : 355 710 MANAGMEFFICEENV
VA._ (SU)69vLLE G
- ---------------------------------------------._ �-O---- ------
COMMENTS
Also, a reopener clause
should be placed in this permit to allow for changes to be made in limits
based upon future water quality studies. A study of the Lumber River is one
of the top priorities on the 1986 field study agenda.
Recommended by _ Date I
Reviewed by:
Tech. Support Supervisor
Regional Supervisor
Permits & Engineering
Date_ ?-3M
Date •� �6_
Date_LS__

DIVISION OF ENVIRONMENTAL MANAGEMENT
April 23, 1986
M E M O R A N D U M
TO: Mick Noland
Dennis Ramsey ,III
THRU: �,t1George T. Everett#-
/
1
FROM: Steve W. Tedder
SUBJECT: Intensive Toxics Evaluation / Alpha Cellulose Corporation
NPDES No. NC0005321, Robeson County
Staff of the Technical Services Branch conducted an intensive
toxics evaluation at the Alpha Cellulose Corporation facility during
the week of July 15 - 20, 1985. The attached report details the
findings and conclusions of this comprehensive evaluation which
included multiple toxics tests, chemical characterization of the
wastewater and receiving streams, and biological evaluation of the
receiving waters.
We regret the delay of report preparation and release which
was a result of awaiting analytical results. If there are any
questions, please contact myself or Ken Eagleson at 919/733-5083
or Larry Ausley at 919/733-2136.
SWT:mlt
Attachment
cc: L.P. Benton
Ken Eagleson
Larry Ausley
Meg Kerr
Jay Sauber
Jimmy Overton
Alan Klimek

ALPHA CELLULOSE
TOXICITY EXAMINATION
NPDES #NC0005321
IIIIIIII rillllllll
IIIIIIiI C 111111111
North Carolina Department of Natural
Resources & Community Development.
40
MOB/LE
Bioassay and Biomonitoring
LABORATORY o
NORTH CAROLINA DEPARTMENT OF NATURAL
RESOURCES AND COII, JNITY
DEVELOPMENT
WATER QUALITY SECTION
APRIL 1986

ALPHA CELLULOSE
TOXICITY EXAMINATION
NPDES *NC0005321
April 1986
DEPARTMENT OF NATURAL RESOURCES
AND COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
TECHNICAL SERVICES BRANCH

TABLE OF CONTENTS
Page
List of Figures............................................................ ii
List of Tables .............................. . .._...... ... . .. ii
Introduction............................................................... 1
Toxicity Examination....................................................... 3
Chemical Sampling.......................................................... 8
Benthic Macroinvertebrate Analyses ......................................... 13
Summary and Conclusions.................................................... 19
Recommendations............................................................ 22
Appendix.................................. ................................ 24
Daphnia pulex Test Procedure .......................................... 25
96 Hour Flow -Through Test Procedure ................................... 26
Ceriodaphnia Reproduction Bioasay Procedure ........................... 28
Benthic Macroinvertebrate Procedure ................................... 29
List of Definitions................................................... 31
-1-

LIST OF FIGURES
Page
Figure 1. Schematic Diagram of Alpha Cellulose Wastewater
Treatment Facility ...... ........................................ 2
Figure 2. Ceriodaphnia 168 Hour Mean Cumulative Reproduction ............... 6
Figure 3. Ceriodaphnia 168 Hour LC6o....................................... 7
Figure 4. Alpha Cellulose Study Area and Sampling Locations ................ 10
LIST OF TABLES
Page
Table 1. Flow -Through Test - Fathead Minnow Mortality ..................... 5
Table 2. Sampling Site Descriptions ....................................... 9
Table 3. Chemical Results ................................................. 11
Table 4. Benthic Macroinvertebrate Taxa Richness .......................... 15
Table 5. Benthic Macroinvertebrates Collected ............................. 16

INTRODUCTION
A flow -through toxicological investigation was performed at the Alpha
Cellulose Corporation (#NC0005321) from July 15-20, 1985. This facility is
located in the City of Lumberton in Robeson County, N.C. Alpha Cellulose is
engaged in the processing of cotton linters into pulp for use in high quality
paper products.
This document details findings of chemical and biological sampling performed
at this facility, including the following:
1) 48 hour static bioassays using Daphnia pulex on cooking liquor, boiler
blowdown, and effluent samples to determine acute toxicity.
2) 96 hour flow -through bioassay using Pimephales promelas (fathead
minnows) performed on effluent collected prior to chlorination (bioassay
sampling point).
3) 7-day Ceriodaphnia reproduction test used to assess sublethal toxicity.
4) Chemical samples of influent, effluent, and receiving stream.
5) Collection and analysis of macroinvertebrate samples to determine impact
on receiving stream populations.
Alpha Cellulose discharges into the Lumber River (Class "C") located in the
Yadkin River Basin. The permitted flow of the subject facility is 1.6 MGD. The
7-day, 10 year low flow (7010) for the Lumber River at this location is 140 cis.
At permitted facility flow and 7010 stream flow, this discharge comprises
approximately 1.74% of the Lumber River flow. Figure 1 presents a schematic
diagram of facility wastewater treatment processes.
Wastewater is generated by the digestion, bleaching, and washing processes
carried out on the raw cotton linter. These processes include high temperature
sodium hydroxide digestion, chlorine and chlorine dioxide bleaching, maceration,
and a series of water removal sieves. These steps are interspersed with a series
of copious freshwater rinses. Rinse water is supplied from the city water

Figure 1. Alpha Cellulose Waste Water Treatment Facility Schematic
02 Hashers
Haste Cooker Liquor Slowdown
City water Filter Backwash 41 Hashers
Influent Sampling Point Phosphoric Acid
Addition
2A Equalization Chamber
r
Hydrasieve I
Nitrogen Addition
Aeration
Basin
(4.3 Killion Gal.)
55, � — ---l55' Clarifier Clarifier
Final { 1 1 Station2
Parshall Bioassay Sampling
Flune ) ( Point
Discharge To Lumber River
—2—

system. Additional wastewater is contributed by cooling systems for vacuum pumps
and bearings and boiler blowdowns.
Wastewater treatment processes include grit removal and hydrasieving of
rinse waters, flow equalization, pH adjustment with phosphoric acid, nutrient
addition, aeration, and clarification. Domestic wastes are discharged to the
city wastewater treatment facility.
TOXICITY EXAMINATION
The on -site toxicological examination was performed at the Alpha Cellulose
Corporation at the request of the NRCD Fayetteville Regional Office. This
request was made in light of a Daphnia up lex screening bioassay performed by DEM
which resulted in an LC6o of 28% effluent and three (3) self -monitoring static
bioassays completed by Alpha Cellulose during February, March, and April 1985.
These tests resulted in LC60 values of 42.4%, 42.8%, and 31.76% respectively. On
June 27, 1985 the Aquatic Toxicology Group performed two static tests
concurrently, using Daphnia pulex and Pimephales promelas (fathead minnows) as
the test species. The D. up lex bioassay resulted in an LC60 of 28% and the
fathead minnow test yielded a partial mortality of 20% in the 100% effluent
concentration. Alpha Cellulose has continued to conduct monthly self -monitoring
bioassays and have reported the following LC60 values: May 1985 - 35.2%; June -
42.73%; August - 33.9%; September - 31.79%; October - 35.86%; November - 45.16%;
December - 41.19%; January '86 - 29.1%; February - 37.55%; and March - 33.7%.
These results compare closely with the LC60 values found by DEM screening tests.
Bioassays performed during the on -site investigation included Daphnia pulex
static tests, Ceriodaphnio reproduction tests, and a flow -through bioassay using
fathead minnows as test organisms.
The flow -through bioassay was performed on effluent collected from a trough
which received effluent from two final clarifiers. Dilution water for on -site
testing was obtained from Mill Swamp Creek at SR-2220 in Roberson County, N.C.
-3-

The flow -through test was initiated at 10:34 A.M. on July 16, 1985- The test
organisms, fathead minnows, were 34-38 days old and were obtained from cultures
at the Aquatic Toxicology Laboratory in Cary, N.C. These fish were acclimated to
Mill Swamp Creek water on July 13 from a sample collected June 26, 1985- The
minnows were transferred to the test chambers with dilution water approximately
16 hours prior to test initiation. Ten fish were placed in each chamber with
replicates of six concentrations and a control (dilution water). The toxicant
delivery system cycled 408 times during the course of the test. Due to test
chamber overflows caused by solids clogging drain screens, several of the higher
test concentrations lost test fish during the flow -through test. Thus,
definitive 96 hour mortality results cannot be strictly calculated. From
tracking fish loss and subsequent fish additions to several test chambers through
the course of the test, it is apparent that mortality in the 75% and 100% test
concentrations exceeds control mortality. This mortality is summarized in Table
1.
A series of 48 hour Daphnia pulex static bioassays were performed on
effluent, boiler blowdown, and cooking liquor samples. An LC6o value of 28% was
determined for a 22 hour composite sample of effluent collected at the
flow -through sampling point. The boiler blowdown and cooking liquor samples were
both taken as grabs and resulted in LC6o values of 50% and 0.32%, respectively.
In order to assess sublethal toxicity, a seven-day Ceriodaphnia static
replacement test was performed on eight effluent concentrations and a control
(dilution water). Dilution water for this test, as well as all other bioassays,
was obtained from Mill Swamp Creek and was pH adjusted with sodium bicarbonate in
light of the low pH of the dilution source. Mortalities of 100% occurred in all
concentrations of 25% and greater. It was noted that the 100% mortalities of the
fifty percent and higher concentrations were reached within 24 hours of test
commencement. A significant reduction in reproductive success, an average of
-4-

13.6 young per adult, was observed at the 10% effluent concentration.
Reproduction similar to and exceeding that of the control, 23.5 young per adult,
was exhibited in the .01%, 1.0% concentrations. Mean cumulative reproduction is
shown in Figure 2. A 168 hour LCOO value of 16% effluent was calculated for this
bioassay. A graphical representation of the mortality data is shown in Figure 3.
Table 1. Flow -Through Test - Fathead Minnow Mortality
Test Concentration
% Mortality
Control
20
Control
0
5%
10
5%
0
10%
10
10%
10
25%
11.1
25%
0
50%
12.5
50%
?22.2 (72
hrs.)
75%
37.5
75%
111.1 (72
hrs.)
100%
144.4 (48
hrs.)
100%
220 (72
hrs.)
—5—

Figure 2.Mean Cumulative Reproduction
Ceriodaphnia Chronic Bioassay
Mean Young Produced
25
21
10
5
0
Significant Impact at
10% Effluent
0 2 4
Day of Test
Alpha Cellulose
-6-
0
Control
0
0. 01 %
25. 0%
4

Figure 3.
LOG -CONCENTRATION VS. % MORTALITY
FACILITY AInha CP11111nGP
TEST DATE 850715 - 840722
0 10 20 30 40 50 60 70 60 90 100
% MORTALITY
Ceriodaphnia 168 hr LC50 = 16%
-7-

CHEMICAL SAMPLING
A series of chemical samples was collected while on -site at Alpha Cellulose,
Inc. These samples were sent to the Division of Environmental Management's
chemistry laboratory for analysis. Samples were collected on two dates at the
sampling stations described in Table 2. All samples were obtained as
instantaneous grabs with the exception of Station 02 (bioassay sampling point)
which were collected as 24 hour composite samples_ An additional metals analysis
was conducted on the City of Lumberton's water as it entered the Alpha Cellulose
facility for use as process and cooling water. Results and summaries of these
chemical analyses are found in Table 3. A schematic of the study area, including
chemical sampling stations, is depicted in Figure 4.
Metals analyses of effluent samples reported zinc concentrations of 130 ug/I
and 100 ug/I on July 18 and July 20, 1985 respectively. Zinc concentrations of
140 ug/I and 20 ug/I were reported for influent samples collected on the same
dates. Samples collected at the upstream station (01) yielded results of 30 ug/I
and <20 ug/I on July 18 and July 20, 1985 respectively. Concentrations of zinc
analyzed from downstream (Station 3) samples are nearly identical to upstream
samples for their respective dates. The North Carolina Water Quality Action
Level for zinc is 50 ug/l. Effluent copper levels decreased from 100 ug/I on
July 18, 1985 to <20 ug/I on July 20, 1985. Influent copper concentrations on
the same dates were 60 ug/I and 30 ug/I. Copper was not detected above lower
detectable limits (20 ug/1) in any of the receiving stream or dilution water
samples. The North Carolina Water Quality Action Level for copper is 15 ug/l.
The July 19 sample of Lumberton city water contained <20 ug/I of copper and 60
ug/I of zinc.
Effluent BODE for the two sampling dates remained nearly constant with
values of 29 and 30 ug/I. Effluent total solids remained at 6,000 mq/1 and 5,500

Table 2. Sampling Site Descriptions
Station Number Description
01 Lumber River at SR-2202, approximately 500 m
upstream of the Alpha Cellulose, Inc. discharge.
At this point, the Lumber River is approximately 30
m wide and 3 m deep. The substrate is coarse sand.
02 Alpha Cellulose treatment plant effluent collected
from an effluent trough receiving effluent from two
final clarifiers. This is the bioassay sampling
point for the 96-hour flow -through bioassay,
Ceriodaphnia reproduction bioassay and Daphnia
ulex effluent static bioassays.
02A Alpha Cellulose influent collected at the weir
prior to entering the aeration basin.
02B City of Lumberton water entering Alpha Cellulose.
03 Lumber River at NC Hwy 72 (SR-1620), approximately
3 mi. downstream of the Alpha Cellulose discharge.
At this location, the Lumber River is 4 m deep and
50 m wide with a sand substrate.
04 Mill Creek Swamp at SR-2220. Here, Mill Creek
Swamp is 2 m deep and 4 m wide with a substrate of
mud and leaf litter. This is the dilution water
site for all on -site bioassays.

Figure 4. Alpha Cellulose Study Area and Sampling Sites
PAN
MG211
;Neap Greek
5 miles
0

Table 3. Chemical Results
PERNITIEO FLOU (NGD)
1.6
IMAGE DISCNAM (N®)
1.02
AVEM MON fLOU (CFS)
710
7918 Cf S
140
Chemical/Physical
Units
Utter Quality
STATION 11
STATION 02
STATION 02A
STATION 13
STATION 04
LONIERTON CITY
Anil ses
Standards
1IJUL15
11JUL85
11JOL15
1IJ®LIS
IM65
DATER 19JUL65
PPM
.8
19
720
1.7
1
C00
PPN
42
1600
2900
36
78
Residue TOTAL
PPN
120
HOD
5/01
191
140
Volatile
PPM
45
1500
15"
74
71
fixed
PPM
78
4510
4300
120
59
Residue SUSPENDED
PPN
4
zu
760
6
26
Volatile
PPM
3
Z30
540
6
23
fixed
PPM
1
31
129
<1
3
pH (standard snits)
6.0-9.0
6.7
!
12.2
7
5.5
AlkAliflity to PN 8.3
PPN
171
140
filkilisitv to PH 4.5
PPN
19
1 2411
5o
47
8
kiditY to PN 1.3
►IN
7
5
18
Chloride
PPM
!
710
1200
19
9
Nardness
PPM
11
3"
ISO
zo
20
HAS
PPM
500
1.1
Sulfates
PPN
17
654
4/
Z2
7
ecific Comductwe
VMS
140 1
5zt0
5700
260
79
M3
PPM
.63
1.1
13
.36
.5
TNN
PPN
.4
Z6
39
.1
1.4
102,103
PPM
.57
.01
1.5
.55
.91
P. total
PPI
.23
2.5
5.1
.35 1
.32
41winrn
PPI
390
710
12"
S00
600
Z10
Calcium
PPM
1.6
14
17
2.3
z.9
11
CadAiuA
"1
2
<21
<11
<10
<10
QO
<20
Ciromitm
PPI
50
<50
<50
<50
<50
<50
<50
Co r
PP8
15 AL
<ZO
1M
60
<ZD
<2o
<20
Iroa
"I
IM
710
1Z10
16"
900
4169
Mercury
PPI
1
<.1
<.z
<.1
<.2
<.1
<0.1
NAIMAim
PPM
.l
.7
11
.99
1.5
1
untaftele
PR
<50
18
ISO
<58
90
<50
Sodium
PPM
26
1560
1700
54
5.Z
12
Nickel
PPI
SO
<190
(in
<100
<100
<100
<100
Lead
PPB
Z5
<100
<IN
<100
<100
<101
<100
zinc
PPB
56(AL)
30
130
140
30
20 1
50
Trisut
ltia NWride
PPI
.001
<.02
<.02
<.02
<.02
<.02
Midentified Or wic Peaks
!
NO
0
a zz
• 1
l 5
11imethylethyl
Netkyl PMeell
PPI
NO
0
5
N0
NO
(AL) = Values represent action levels as specified in .0211(b)(4) Fresh Water
Classification Standards
ND = Not Detected
-11-

Table 3. Chemical Results (Cont.)
PERNITTEO FLOU (1G0)
1.6
NE"a 1ISCNNRGE (INS)
1.12
W21GE STREAM FLOU (CFS)
750
7911 (CFS)
140
cheNial/Ph sial
Units
STATION O1
STATION 02
STATION ON
STATION 03
STATION 04
Predicted stream~
aural ses
20JULI5
20JUL15
I/3UL15
20JUL85
20JUL15
cone. at 7910
BOO
PPM
1.7
31
ISO
2.6
6.1
C00
PPM
12
1300
570
35
54
Residue TOTAL
PPN
120
MOO
1500
200
120
1N.05
volatile
/PII
a
750
579
75
73
fixed
PPN
74
4100
KO
120
51
Rtsidw SISPEIM
PPM
3
11
1 340
5
15
2.42
volatile
PPR
<1
15
310
5
1z
fixed
/PN
3
3
1e
<1
3
PN (starAud Nits)
1.9
1.0
11.9
7.4
5.5
Alkalisity to pi 1.3
PPM
170
410
Alkaliaity L pi 4.5
PPM
1
1 2611
91
46
4
scidity U P1 6.3
PPM
9
I
36
Chloride
PPM
11
790
11
21
I
13.14
Nedeess
PPN
15
ISO
100
15
10
NAS
PPN
Sulfates
►pI
_Specific
Comuctama
id dies
140
57M
zwl
150
13
IN3
PPN
.93
.24
1.1
.19
.71
.91
IKN
PPN
.3
12
4.2
.7
1.4
.33
10I.103
PPM
.51
<.01
1
.57
.11
<.111
P. total
PPM
.26
.36
1.3
X
.13
.02
A1NNiaw
PPI
400
400
IN
400
1/0
9.57
Calcium
PPM
1.5
11
12
1.9
3.1
.12
Cadmium
PPI
<10
<20
<21
<20
<20
1.04
arNin
"I
<54
<50
de
<50
<50
rAper
PPI
<20
<20
31
<20
<zO
Iran
Pro
710
N1
11N
700
2180
17.4
NercN
PP1
<.2
<.z
<.1
<.1
<.1
eesium
PPN
.72
14
3.1
.12
1.6
kglwje
PP/
<50
<5/
<50
<56
71
Sodium
IPA
32
1700
364
41
5.1
Nickel
PPB
<100
<190
<100
<100
<100
Lead
PP1
<110
<100
<100
<100
<100
zinc
PP1
<20
100
50
20
<20
2
TriNut
ltin Nydride
PP1
<.02
<.12
<.12
<.11
<.11
laideatified
Or is "as
s
s 2
s 4
NI
Sirifides
PPN
<_11
<.It
�a = Values represent predicted instream concentrations using average effluent
concentrations and assuming upstream concentrations of 0.
-12-

mg/I with total suspended solids of 260 mg/1 decreasing to 18 mg/I as flow
decreased and settling became more efficient.
Organics analyses reported 22 unidentified organics peaks in July 18
influent samples ranging from 10 to 730 ug/I and 5 ug/I dimethylethyl
methylphenol. No organics were detected in the July 18 effluent sample. July 20
samples were reported with two unidentified organic peaks in the effluent with
concentrations of 18 ug/I and 16 ug/I and 4 unidentified organics peaks in the
influent sample with concentrations from 34 to 130 ug/I.
Influent and effluent concentrations of total fixed residue, chloride and
sodium, as well as pH and specific conductance reflect the major waste sources
entering the waste treatment system, ie. the NaOH cooking liquor waste and
subsequent rinses and chlorine and chlorine dioxide bleaches.
On -site measurements of total residual chlorine of upstream, downstream,
influent, and effluent samples on July 16 and 17 revealed no measurable levels
(<0.01 mg/I)_
BENTHIC MACROINVERTEBRATE ANALYSES
Benthic macroinvertebrates were collected on July 16 and October 23, 1985
from the Lumber River in order to determine what impact the Alpha Cellulose
discharge may be having on the resident populations. Samples were collected at
Station 01 and 03 on July 16 and additionally at a station approximately 150
meters below the Alpha Cellulose discharge, yet above the Lumberton WWTP
discharge.
Benthic macroinvertebrates were sampled using a standardized qualitative
collection technique (DEM 1983). The primary output from this collection tech-
nique is a tabulation of taxa richness, i.e., the number of different kinds of
animals present. Unstressed streams and rivers always have high taxa richness.
Various types of pollution will reduce or eliminate the more intolerant species,
—13—

producing lower taxa richness values. In-house criteria have been developed to
relate taxa richness to five water quality ratings or bioclassifications:
Excellent, Good, Good -Fair, Fair and Poor. Taxa richness values are calculated
both for all species (ST) and for the more intolerant groups (Ephemeroptera,
Plecoptera, Trichoptera: SEPT). The distribution and abundance of various
pollution "indicator" species also can be utilized to deduce changes in water
quality. Taxa richness values are summarized in Table 4. All taxa collected in
the survey are listed in Table 5.
Based on the available macroinvertebrate data, organisms of the intolerant
mayfly, stonefly, caddisfly groups (EPT) do not appear affected by the Alpha
Cellulose discharge, nor is any major shift of species noted in taxa of other
groups. Any impact which the Alpha Cellulose discharge may have on the Lumber
River at this point is being masked by impacts occurring further upstream, as
noted by more extensive macroinvertebrate surveys conducted in the area at the
same time as this survey_
—14—

Table 4. Taxa Richness, by Group, Lumber River Sites, July and October 1986.
Month:
Station:
Group
*Ephemeroptera
*Plecoptera
*Trichoptera
Coleoptera
Odonata
Megaloptera
Diptera: Misc.
Diptera: Chiron
Oligochaeta
Crustacea
Mollusca
Other
*Subtotal (EPT)
Total
Change vs. July
• Unique Species'
Rating
July 16, 1985 October 23, 1985
5 7 6
4
4
3
2
2
6
9
9
10
8
11
8
9
1
8
9
1
-
1
1
1
16
12
15
3
6
7
2
2
2
4
3
4
3
7
9
15 15 19
62 65 75
0 9 3
Good/Fair Good/Fair
' Found in only 1 out of 9 collections
—15—

Table 5. Macroinvertebrates Collected from the Lumber River, July and October
1985. (A = Abundant, C = Common, R = Rare)
Station: 01 WWTP 03
EPHEMEROPTERA
Baetis propinquus gr.
A
-
C
B. pygmaeus
R
A
C
Cloeon sp.
R
-
R
Eurylophella bicolor
-
C
-
Stenonema modestum
-
C
-
PLECOPTERA
Acroneuria abnormis
R
C
-
Neoperla clymene
-
A
R
Pteronarcys dorsata
R
-
P,
Taeniopteryx sp.
-
R
-
TRICHOPTERA
Cheumatopsyche sp.
R
C
C
Chimarra sp.
A
A
A
Hydropsyche rossi
-
-
C
H. venularis
-
C
C
Lype diversa
R
-
-
Macronema carolina
A
C
A
Nectopsyche exquisita
R
R
-
Neureclipsis sp.
C
C
C
Oecetis sp. t
-
R
C
Polycentropus sp.
A
R
-
-16-

Table 5. (Cont.) Station:
01
WWTP
03
COLEOPTERA
Ancyronyx variegata
A
A
C
Dineutes/Gyrinus
C
C
A
Hydroporus spp.
C
C
C
Macronychus glabratus
C
C
R
Peltodytes spp_
C
C
A
Stenelmis spp.
A
A
C
ODONATA
Argia spp.
R
R
R
Boyeria vinosa
R
-
-
Enallagma spp.
AS
C
C
Gomphus spp.
AS
R
C
Macromia sp.
C
R
R
Tetragoneuria cynosura
A
R
C
DIPTERA: CHIRON.
Ablabesmyia ornata
-
C
-
A. parajanta
A
C
A
A. tarella
A
Cryptochironomus fulvus
-
C
-
Nanocladius sp.
-
C
A
Polypedilum convictum
R
-
R
Rheocricotopus robacki
R
R
-
OLIGOCHAETA
Dero sp.
-
C
A
Limnodrilus hoffineisteri
C
A
A
Lumbriculidae
A
A
A
Stylaria locustris
R
VA
VA
-17-

Table 5. (Cont-) Station
CRUSTACEA
Asellus/Lirceus
Hyalella azteca
MOLLUSCA
Somatogyrus/Amnicola
Physella sp_
Corbicula manilensis
Sphaerium spp.
OTHER
Dugesia tigrina
Helobdella clongata
H. triserialis
Mooreobdella tetragon
01 VWVTP 03
A A
A A VA
R A
R C
R A
A A
C VA
— A
R
R A
A
A
A
A
C
A
A
9:�

SUMMARY AND CONCLUSIONS
Results of toxicity tests conducted on the effluent of Alpha Cellulose
indicate Daphnia pulex 48 hr. LC6o of 28%, a Ceriodaphnia 168 hr. LC6o of 16%,
and a 96 hr. fathead minnow LC60 somewhere between 75% and 100%. Ceriodaphnia
seven-day reproduction was moderately, yet significantly, depressed at 10%
effluent, yet showed no adverse effects at 1% effluent. Analysis of two separate
influent streams using the 48 hr. Daphnia up lex bioassay resulted in LC6o's of
50% for boiler blowdown and 0.32% for cooking liquor waste. Monthly
self -monitoring bioassays conducted by Alpha Cellulose from February 1985 to
March 1986 have shown consistent toxicity results varying from LC6o's of 28% to
45% for 48 hour Daphnia Pulex tests.
Results of chemical analyses revealed elevated effluent levels of total
dissolved solids, total suspended solids, chloride, sulfate, copper and zinc with
the two sampling dates varying widely in concentrations. Major physical influent
and effluent characteristics were elevated pH and conductance, resulting from
NaOH cooling liquor and bleaching processes. The following parameters displayed
increases in levels downstream of the discharge (03) as compared to the upstream
station (01): BOD6, total residue, suspended residue, alkalinity, chloride,
hardness, specific conductance, ammonia, TKN, total phosphorus, aluminum,
calcium, iron and sodium. These increases may or may not reflect a direct
contribution by Alpha Cellulose since the Lumberton WWTP discharges between the
Alpha Cellulose facility and the downstream (03) sampling site.
Analysis of benthic macroinvertebrate populations in the Lumber River
upstream and downstream of the Alpha Cellulose effluent indicate a degradation of
benthic communities upstream of the discharge before the Lumber River passes this
site. No further degradation of community structure is realized at the
downstream station, thus any slight effects which the Alpha Cellulose discharge
may have on the Lumber River are masked by upstream influences.
—19—

Acute toxicity observed in this series of on -site tests appears to have been
caused by the additive effects of several effluent constituents and/or
characteristics. Among these are copper, zinc, pH, and the interrelated effects
of sodium, chloride, sulfates, and specific conductance. The latter would be
expected to cause osmotic imbalances in the test organisms, resulting in loss of
resistance to the effects of other toxicants. The Daphnia ua lex 48 hr LC6o for
chloride in reconstituted water has been reported as 1.47 g/1_' Thus, with
effluent chloride measured at 720 and 790 mg/I on two sampling dates, the effect
of chloride alone would be projected to cause some mortality at higher test
concentrations. The 21 day No Observed Effect concentration to Daphnia pulex for
chloride has been reported as 0.314 g/l.' Thus, it is possible that a portion of
the inhibition of Ceriodaphnia reproduction can be attributed to ionic problems
caused by the effluent, though measured concentrations of any single compound
were not great enough to have created a No Observed Effect level of 1% effluent.
Effluent organics analyses revealed only two unidentified peaks at a maximum
concentration of 18 ug/l, thus it is not felt that these compounds contributed
significantly to observed acute toxicity_
Much variation is noted between these two sampling dates in effluent
chemistry parameters. This connotes an effluent of highly variable nature
through the course of the test week Since effluent samples were collected as
composite samples, the results reported can be assumed an average of effluent
concentrations during the period with actual exposure levels of the organisms in
excess of those reported by chemical analysis.
' Kentucky Natural Resources and Env. Protection Cabinet. 1985. Recommendations
on numerical values for regulating iron and chloride concentrations for the
purpose of protecting warm water species of aquatic life in the Commonwealth
of Kentucky.
—20—

Another variation in effluent quality was noted during the on -site testing
activities as an increase in suspended solids concentrations during the nights
on -site. This was assumed due to nightly clogging of flow -through test chamber
screens by an accumulation of solids not occurring during daylight hours_
Based on the toxicity data generated by this on -site investigation, only
very subtle chronically toxic conditions could be expected in the Lumber River
caused by the Alpha Cellulose discharge. With the Ceriodaphnia No Observed
Effect Concentration of 1%, the lowest Observed Effect concentration of 10%, and
the facility's instream waste concentration (IWC) of 1.74% at 7010 receiving
stream flow, the actual no effect level may lie quite close to the IWC. Based on
the lowest measured Daphnia up lex LC6o of 28% for the effluent, no acute toxicity
is predicted instream.
-21-

RECOMMENDATIONS
1. The Alpha Cellulose facility should continue the performance of
self -monitoring 48 hour Daphnia pulex bioassays using protocols defined in
EPA Document 600/4-85/013 entitled "Methods for Measuring the Acute Toxicity
of Effluents to Freshwater and Marine Organisms". These tests should be
performed on 24 hour composite samples of the effluent collected from the
combined discharge channel from the final clarifiers at the effluent
parshall flume. These tests should continue on a once per month basis until
the LC60 acute toxicity target level of >90% has been achieved for three
consecutive months.
At such time, the facility should begin the performance of chronic
toxicity tests on a quarterly basis using protocols defined in the EPA
Document 600/4-85/014 entitled "Short Term Methods for Estimating the
Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms".
This testing should be performed as a seven day Ceriodaphnia survival and
reproduction test. The effluent should be collected twice during the test
period as 24 hour composite samples at the location described under acute
testing. This test should consist of a minimum of five effluent
concentrations plus a control series. One of the effluent concentrations
should equal 1.7%, which represents the Instream Waste Concentration (IWC)
during 7010 low flow of the receiving stream and daily permitted average
discharge volume of the facility. The remaining concentrations should equal
0.8%, 3.4%, 6.8% and 90%. There may be no greater mortality than 20% in 90%
effluent after 48 hours of exposure. The resulting Chronic Value (ChV) of
the seven day test should be greater than 1.7% defined as the geometric mean
of the lowest Observed Effect Concentration (LOEC) and the No Observed
Effect Concentration. The test will be considered passed if the Chronic
Value is greater than 1.7% and acute mortality at 90% effluent is less than
-22-

20%. The failure of either parameters will be considered as failure of the
test.
2. In light of effluent suspended solids and BODs levels encountered by on —site
sampling and the fact that no sludge disposal method is employed by the
Alpha Cellulose facility, solids loading and fate should be further studied
to determine whether existing treatment is appropriate for permit
restrictions now in force.
—23—

APPENDIX
-24-

48 Hour Daphnia pulex Screening Bioassay
Aquatic Toxicology Group
N. C. Division of Environmental Management
The Aquatic Toxicology Group performs 48 hour static bioassays using the cladoceran
Daphnia pulex to estimate the toxicity of waste discharge to aquatic life in receiving
streams. All test and sampling glassware and equipment are washed with soap and
hot water, then rinsed in nitric acid, acetone, and distilled/deionized water, to
remove all toxins and contaminants. Effluent samples are collected by DEM Regional
Office or Aquatic Toxicology personnel. All samples are collected chilled and above
chlorination unless otherwise specified. Each sample is collected as a grab or 24 hour
composite using an automatic sampler and is sent chilled to the Aquatic Toxicology
Laboratory by state courier or bus. The sample must be received within 24 hours
after collection.
The samples are prepared for testing by being thouroughly mixed. adjusted to
standard test temperature, and aerated if dissolved oxygen is below 40% saturation.
Chlorine is removed with Sodium Thiosulfate if applicable. Initial pH and 00 are
also recorded. The effluent is then diluted with 0. pulex culture water, typically to
seven concentrations (with replicates) from 0 to 90% effluent. Each test chamber
receives 100 mis total volume and ten 24 hour old D. pulex test organisms. The test
is conducted in a 20 degree centigrade incubator with a 14:10 hour Iight:dark cycle.
Mortality of the D. pulex is recorded after 48 hours, along with final pH and
dissolved aocygm.
A 48 hour LCBg, or concentration of effluent lethal to 50% of the test organisms in
48 hours, is calculated from the mortality data. An instream waste concentration
(IWC) for the effkient in the receiving stream is calculated using the treatment
system design flow and low —flow (7Q10) stream flow. The LC50 and IWC are then
used to predict instream toxicity. If the effluent toxicity and/or the IWC are high. a
persistence bioassays may be conducted. This involves a second 48 hour static D. pulex
bioassay on the same effluent sample after it has been exposed to light and aeration
for an additional 48 hours. If there is a 100% reduction in the LCS0. the effluent is
considered to be non—persistant.
-25-

96 Hour On —site Flowthrough Bioassay
Aquatic Toxicology Group
N. C. Division of Environmental Management
Candidacy for an on —site toxicity evaluation by the Aquatic Toxicology Group is
determined on the basis of acute toxicity of the effluent in comparison with
instream waste concentration. Acute toxicity is determined by a 48 hour screeninq
static bioassay using Daphnia pulex.
For each on —site, flowthrough bioassay, a pre —test site inspection is performed in
order to:
1) Determine appropriate areas for physical placement of the mobile laboratory.
2) Acquire proper equipment and installation needed for electrical service.
3) Determine appropriate areas for effluent sampling and equipment needed for such.
Sampling is done above chlorination unless otherwise specified.
4) Determine possible areas for dilution sampling (actual receiving waters or other
unstressed streams in the area) and equipment needed for such.
5) Collect additional samples of effluent and possible dilution waters for further
static Daphnia up lex acute and static renewal Ceriodaphnia sp. reproduction bioassays
to determine the range of concentrations of effluent for the flowthrough bioassay, to
test for potential toxicity of possible dilution waters, and for fish acclimation to
the chosen dilution water.
6) Determine route suitability to the facility for the mobile laboratory (eg. low
clearances, poor road conditions).
--7') Discuss test procedures and requirements with appropriate facility personnel.
8 Determine appropriate sampling sites and techniques for benthic
macro invertebrate surveys.
Upon actual arrival on —site with the mobile laboratory, dilution water is obtained
and dilution and effluent pumping systems are set up and tested. Two to three week
old fathead minnows are wet transferred to the test chambers (containing
approximately one liter of dilution water), ten fish to a chamber. Seven
concentrations (with replicates) including a control are used. The second day on —site
the dilutor and the dilution and effluent pumping systems are turned on and the
fathead minnow flowthrough bioassay is begun. A water bath is utilized to bring the
effluent and dilution water to a constant 20 degrees centigrade. Test organisms are
fed newly hatched brine shrimp twice daily throughout the test.
A Ceriodaphnia static renewal reproduction bioassay using newborn organisms is
begun the first day on —site. The organisms are transfered to fresh dilution and
effluent solutions daily and initial and final pH and dissolved oxygen are recorded.
The number of young born per organism per day is recorded and mean cumulative
reproduction is calculated for each concentration. The test is conducted in a 25
degree centigade incubator with 10 light:14 dark photoperiod. Test organisms are fed
a mixture of yeast and algae.
Individual chemical/physical parameter meters are calibrated daily according to DEM
standards. Hydrolab systems measure and record dissolved oxygen, pH, temperature,
and specific conductance in the test chambers with the highest and lowest
concentration of effluent at 15 minute intervals throughout the test. These systems
are calibrated at test initiation, the mid —point of the test, and test
term ination.Data from these systems is recovered daily and stored on magnetic tape
and hard copy. On alternate days, samples of dilution water, effluent at the sampling
site, final effluent, and the receiving stream upstream and downstream of the
-26-

discharge point are analyzed for hardness. On variable effluents, daily residual
chlorine measurements will be made at the above described sites.
During the on —site evaluation, Biological Monitoring Group personnel collect benthos
samples at the upstream, downstream and dilution sites (see Benthic
Macro invertebrate Survey appendix). Where appropriate, electrofishing is undertaken
upstream and downstream of the discharge to obtain resident fish population data.
On a site —specific basis, various other efforts are undertaken, such as monitoring
dissolved oxygen levels in the receiving stream.
On a daily basis, test chamber screens are cleaned, dilution water is collected (where
appropriate), effluent and dilution pumping systems are checked and adjusted as
necessary, and pH, dissolved oxygen, and fish mortalities are recorded for each
chamber.
Two separate 24 hour composite samples of effluent are collected by means of an
automatic sampler for chemical analysis. Receiving stream and dilution water
samples are also taken for chemical testing.
Static 48 hour Daphnia up lex bioassays are conducted on a 24 hour composite sample
of the effluent and a grab sample of the influent.
A photographic record is made of the treatment facility, sampling points, receiving
stream, and sampling procedures while on —site.
At the end of the 96 hour test period, the dilutor is turned off and final mortality
observations are made. Breakdown and packing routines are performed and the mobile
laboratory is transported back to the Cary Aquatic Toxicology Laboratory.
Several special care operating procedures should be mentioned. At facilities that
discharge for only a portion of the day, effluent samples are composited by the
dilutor system into a large reservoir on board the mobile laboratory for use as the
effluent while discharge is not in progress. If the effluent has a high oxygen demand,
aeration systems for the test chambers are utilized and dissolved oxygen levels in the
chambers are monitored closely in order to prevent levels from dropping below 40%
saturation at test temperatures. In the event that actual receiving waters are
deemed unfit for the test (i.e. potentially toxic), an alternate source of dilution
water is sought in the vicinity.
-27-

Ceriodaphnia sp. Reproduction Bioassay Procedure
Aquatic Toxicology Group
N. C. Division of Environmental Management
The Ceriodaphnia aquatic bioassay is oonducted to estimate the effect of an
effluent or other water sample on reproductivity. The cladoceran Ceriodaphnia
sp.. is used as test organism in a 7 day static renewal bioassay. A control and 8
concentrations of effluent ranging from 0.01% to 100% are typically used. There
are 10 animals per concentration, each animal in a one ounce polystyrene test
chamber with 15 mis of solution. The test is conducted in a 25 degree centigrade
incubator with a 14 light/ 10 dark photoperiod.
The test is initiated with newborn animals, or neonates. Adults having brood
sacs of 5 or more eggs with visible eyespots (indicating eggs are about to be
released) are isolated and checked periodically. Neonates are removed and
grouped according to time of birth. Selected groups are then composited to make
the youngest set of 90 or more neonates born within a 4 hour period. The test is
begun when the neonates are introduced into the test chambers. Temperatures must
be within 2 degrees centigrade for transfer.
The animals are transferred daily to new test chambers containing freshly mixed
solutions. Chemical/physical parameters are measured twice for each batch of
solutions. The initial Xalue is taken before the animal is introduced and the
final value after the animal has been transferred out the next day. Dissolved
oxygen of greater than 40% saturation is necessary.
The animals are fed daily, just after transfer. Each animal receives 1/2
standard dose of yeast and 1/2 standard dose algae (one drop or 0.05 mis of a
solution made by dissolving 0.25 grams active dry baker's yeast in 100 mis of
distilled water plus one drop of a solution of 1.71 x 106 cells/ml Selenastrum
capricornutum).
As reproduction begins, only the adult is transferred to a new chamber. A drop
of concentrated nitric acid is added to the old chamber. This kills the young so
they can be easily counted under a dissecting microscope. A mean number of young
produced per adult is calculated for each concentration. Mortality of greater
than 10% in control test organisms invalidates a test.

Benthic Macroinvertebrate Procedure
Biological Monitoring Group
N.C. Division of Environmental Management
The sampling methodology requires that a stream or river be
wadable. High water conditions may severely impair sampling
efficiency by making critical habitats unaccessible. A fixed
number of samples are collected for each station. These include:
2 kick net samples of riffle and snag areas; 3 sweep net samples
of bank areas and macrophyte beds; 2 fine mesh washdown samples
of rocks and logs; 1 elutriated sand sample; 1 leafpack sample;
and 1 visual search of rocks, logs, leaves, and substrate. The
benthic macroinvertebrates are picked out with tweezers and
preserved in alcohol. A collection card is filled out which
includes such data as canopy cover, dissolved oxygen, pH, stream
temperature, substrate composition and stream morphology at the
site. Organisms are identified to the lowest possible taxonomic
level, generally to species. Density of each taxon is rated as
Rare (1 or 2 individuals), Common (3 to 9), Abundant (10 or
more). Most organisms may be identified using only a dissecting
microscope, but Oligochaeta and Chironomidae must be mounted and
identified with a compound microscope. Reference collections are
maintained and all samples are kept and stored by study area.
The first level of analysis summarizes the data by total number
of taxa or "taxa richness" (S) and density (N) for each
station.The association of good water quality with high taxa
richness is intuitively obvious even to the non -biologist.
Increasing levels of pollution gradually eliminate the more
sensitive taxa, leading to lower and lower taxa richness. Clean,
unstressed, aquatic communities are characterized by a density
(N) and taxa richness (S) above average levels. Toxic stress
(including pesticides and metals) reduces both S and N below the
average. Sediment stress, especially at low levels, tends to
decrease density, but affects taxe richness only slightly.
Finally, nutrient enrichment tends to increase the total number
of organisms, while selectively favoring a few types of organisms
tolerant to this type of pollution_
The second level of analysis summarizes data by taxonomic groups
(mostly orders of insects). A particularly useful parameter is
the "EPT" value: the sum of the taxa richness for the intolerant
insect groups Ephemoroptera, Plectoptera, and Trichoptera. The
EPT value is consistently related to water quality.
The final step in data analysis is to summarize the data
separately for each taxa.The presence or absence of individuals
of "indicator species" is, in itself, insufficient for
characterizing water quality. Tolerant species are present in all
aquatic habitats, however these species will usually become
dominant only in polluted systems. Information on pollution
tolerance of any given taxon, combined with quantitative data on
-29-

its distribution can often be related to specific chemical or
physical changes in the environment.
-30-

List of Definitions
Aquatic Toxicology Group
N. C. Division of Environmental Management
Acclimation - refers to the process of gradually adjusting organisms from water
of one type to another so that the organisms are not stressed from
radical changes in temperature, hardness, pH, ionic strength, etc.
Acute toxicity - the effect a short term exposure to a chemical or substance has
on an organism; usually defined as death of that organism.
Application factor - a value which estimates an instream toxicant level that
will be safe at a chronic level for resident organisms from acute
toxicity data, usually defined by a fraction of the LC50•
Aquatic - having to do with water.
Aquatic Toxicology Group - the group within the Biological Services Unit (Water
Quality Section) which performs aquatic bioassays for the Division of
Environmental Management. The Group is located at the Cary laboratory
facilities. All test organisms (including Daphnia pule x, Ceriodaphnia
and fathead minnows) are cultured at these facilities by Aquatic
Toxicology personnel.
Benthos/Benthic macroinvertebrates - a wide assemblage of invertebrate animals
(insects, crustaceans, molluscs, etc.) which live in streams, are an
important food source for fish populations, and are used as long term
water quality indicators.
Bioassay - a test used to determine the effects of a chemical or substance on an
organism.
Cadmium - one of the toxicants recommended by EPA for quality assurance testing
of the health of aquatic organisms.
Calibration - the adjustment of meters or systems with standards of known values
in order to assure the quality of data obtained from these meters or
systems.
Ceriodaphnia sp. - a small cladoceran crustacean. It is found throughout most of
North America and obtains a maximum size of approximately 1 mm. This
organism has been adopted for aquatic bioassay testing because of its
small size, ease of culture under laboratory conditions, stability of
genetic strains, and sensitivity to toxic substances. It is generally
used in a 7 day static renewal "mini -chronic" bioassay testing for
mortality, time to sexual maturity and reproductive rate. Ceriodaphnia
sp.. is accepted in the field of aquatic toxicology for testing in
moderately soft waters.
Chronic toxicity - the effect of a chemical or substance on an organise usually
during a longer period of time than that measured for acute toxicity.
This effect is usually measured as a non -fatal response (eg. reduction in
growth, egg production, predator avoidance, feeding rate, etc.). Test for
chronic toxicity are frequently performed during the entire life cycle of
the organism.
Composite - a sample or method of sampling used to obtain data on a substance
which may vary over time or space. For example, a time or temporal
composite of a stream would be one collected at intervals of time at the
same location. This is frequently accomplished with automatic sampling
devices.
-31-

Daphnia pulex (water flea) - a small cladoceran crustacean. It is found
throughout most of North America and obtains a maximum size of
approximately 3.5 mm. This organism has been adopted for aquatic bioassay
testing because of its small size, ease of culture under laboratory
conditions, stability of genetic strains, and sensitivity to toxic
substances. It is generally used in a 48 hour static bioassay testing for
mortality. D. pulex is widely accepted in the field of aquatic toxicology
for testing in moderately soft waters.
Design flow - the volume of water and waste that is initially planned to pass
through a facility or waste treatment plant and still allow maximum
operating efficiency. Design flow is usually expressed in millions of
gallons per day (mgd).
Dilution (water) - the water used in bioassay tests to dilute the waste water to
various concentrations (expressed as percent). Wherever possible, this
water is from the actual stream that receives the waste, upstream from
that waste. When this is not possible, other suitable water is obtained.
Dilutor - refers to a modified Mount and Brungs design serial dilution apparatus
which receives dilution water and effluent/waste and, through a series of
chambers and electrical solenoid valves, mixes the effluent and dilution
into a series of concentrations for the test (expressed as percentages of
100% effluent).
Electrofishing - method for collecting fish using electrical shock to
momentarily stun the fish so they float to the surface and are easily
netted.
Effluent - the waste water exiting a facility which is discharged as treated
waste to a stream or as untreated waste to some other facility.
Fathead minnow (Pimephelas promelas) - a small fish which occurs throughout much
of North America. It obtains a maximum size of approximately 100 mm and
is raised commercially as bait fish. The fathead minnow has been raised
for numerous generations in a number of laboratory culture for use in
toxicity testing. The fish can produce eggs year round in the laboratory
environment under correct conditions which produce test organisms as
needed.
Flow -through - the flow -through bioassay utilizes which either continuously of
occasionally replace effluent/toxicant concentrations throughout the test
in an attempt to simulate stream conditions where new effluent and
dilution water are continually flowing through an organism's habitat.
Hydrolab« - a multiparameter instrument which measures and records temperature,
pH, dissolved oxygen, and specific conductance of water.
Instream waste concentration (IWC) - the percent concentration of an
effluent/toxicant which ins present in a stream under assumed worst case
conditions. The INC is derived from the formula: [DF / (7Q10 + DF)] x 100
= IVC (%), where DF is the design flow (in cfs) of the facility in
question and 7Q10 is the 10 year, 7 day, low flow (in cfs) of the
receiving stream.
LCSO - that concentration or percentage of a waste/chemical/substance which is
lethal to 50% of test organisms over a stated period of time.
"Use of this tern or system does not constitute an endorsement.
—32—

NPDES - National Pollutant Discharge Elimination System. A system devised by the
Federal Government and adopted by North Carolina for the permitting,
monitoring, and pollution abatement of dischargers to surface raters.
Neonate - roughly translated to newly born. In reference to Daphnia pulex, the
neonate refers to the life stage in the first and early second instar,
generally the first 24 hours of its life.
Screening bioassay - a testing system established to determine general levels of
acutQ toxicity of compounds/discharges using 48 hour Daphnia pulex tests.
7Q10 - the measurement of a stream's lowest average daily flow over a 7 day
period during a 10 year span, generally stated as flow in cubic feet per
second (cfs).
Sodium pentachlorophenate - a chemical accepted by EPA as a toxicant for quality
assurance testing of the health of aquatic organisms. This chemical is an
organic pesticide.
Static - refers to an aquatic bioassay in which toxicant/effluent concentrations
are set up at the beginning of the test and not changed for the rest of
the test. This test is generally short term as compared to a flow -through
or replacement test because of potential degradation of the
toxicant/effluent.
Taxa - refers to a group of genetically related organisms, (i. e. genus, order,
species).
Taxa richness - number of taxa.
30Q2 - the measurement of a stream's lowest average daily flow over a 30 day
period during a 2 year span, generally stated as flow in cubic feet per
second (cfs).
Toxicity - the adverse effect of a chemical/substance on an organism. Toxicity
is usually defined as a fatal or non -fatal response over a give period of
time.
UT - Unnamed tributary - a term given to streams which have no accepted name.
-33-

0
cu
NPDES WASTE LOAD ALLOCATION 1-1-7 :534 :•�►
Facility Name: !4"�'J ( t' —0''40rar14 Date: Vf
Existing E/ Permit No.: Nct ooz! 21 Pipe No.: C 0 .1 County: l g.
Proposed Q Design Capacity (MGD) : 1 • `0
P 0 Industrial (% of Flow) : Domestic (% of Flow) : '�—
Receiving Stream: t"W 4620- Z-11r2 / Class: C�- Sub -Bassin: 4o-3" 4o
Al 3 y 30 - 4/ 76r v,�7- „ra ^- rr_�� /�T�C% IC /DNS
Reference USGS Quad: - s3 +_�+fPlease attach) Requesto Regional Office
(Guideline limitations, if applicable, are to be listed on the back of this form.)
Design Temp.: I Drainage Area: "f�`� < Avg. Streamflow: ��'0 `�{S'
7Q10: Winter 7Q10: 30Q2:
r' Location of D.O.minimum (miles below outfall): Slope:_0P S
as
Velocity (fps): Aq 3q K1 (base e, per day, 200C): K2 (base e, per day, 200C):
0
c.*4 ,
Effluentcs;l�
Characteristics
Average
Comments
Sob
332
664
- 01
[ ((o
4/0
`T Sc�
35S
3 to
4..� (a
Original Allocation
Revised Allocation
Prepared By:
(Effluent I Monthly
!Characteristics Average Comments f
Date(s) of Revision(s)
(Please attach previous allocation)
Reviewed B �?��_.
y : Date: /..3 /— �

For Appropriate Dischargers, List
Complete Guideline limitations Below
Effluent
Characteristics
Average
Maximum Daily
Ate,
Comments
3
Type of Product Produced
Lbs/Day Produced
Effluent Guideline Reference

Form #001 =
WASTE LOAD ALLOCATION APPROVAL FORM
i Facility Name: glpilCi c6kytoSk Corp•
County: v► Sub —basin: O';O } l
Regional Office: Requestor: 'r>a�
Type of Wastewater: Vndustrial 100
Domestic % f
If industrial, specify type(s) of industry: act Le", Go'�van luv.'l�'� O,_ ILS
Receiving stream: L,IIbZA Class: Cl-
Other stream(s) affected: Class,.
7Q10 flow at point of discharge: I't0 C_4-�
30Q2 flow at point of discharge:
Natural stream drainage area at discharge point:
Recommended Effluent Limitations
i S cZP T
Z>,LI
.obs
33z era
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NN3 as
ASS
355 '/a
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P
R E E r
6 --
.' a'N 3 01994
tYATER Q;;ALI Y SECTION
This allocation is: /_/ for a proposed facility
for a new (existing) facility
/-✓/ a revision of existing limitations
Recommended ana
Head, Te
Reviewed by:
Regional
Permits
Approved by:
Division Director
a confirmation of existing limitations
ErpJAiJ 2f)
Date:
Date:��-8
Date:
Date:
Date:
ENV. VA, . A'_:�EMEN
TI
FA

-tt 101 Z
(.vM13(t* RiV4 e
j', � 1�►� 1, a(a
a�lo 131 cry
J TC-
<
BPT" g67D5 = 3-& z l"/d
= z't,Q
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Cis = � Ko e.•F�
q !
S = 3i°���.5 x g,3a� 3a !Q = 2H•9 —10 30
gIli
m ti6'� eQ Icz,to ma IS
= 0.6 !�'4 010 010
�(ro O O O O
AvG 'f:6C 3• t3 1 0
Sl ope = 2.2 -ePo^ Z Z , Z
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NPDES WASTE LOAD ALLOCATION C"
Facility Name: A4AM CtrL,CMA,0SE CO�Qp Date: -gwe t 1W
Existing a Permit No.: N4000.5-3.ZP / Pipe No.: 001 County: 40efLoN
Proposed
Design Capacity (MGD) : 'Z • "7 Industrial (% of Flow) : I DO % Domestic (% of Flow) :
Receiving Stream: /-l//e/RER l'/'VEg Class: C Sub -Basin :/ 03 -07- Sj
rZeferei��C JSGS Quad: t� APEA1evRo i5" (Please attach) Requestor:. �0 �( Regional Office FX0
2,3
(Guideline limitations, if applicable, are to be listed on the back of this form.)
Design Temp.: oZ61*C. Drainage Area: 7144 Ltiv ' Avg. Streamflow:
7Q10 : I`A U iS -Winter 7Q10 : 30Q2 :
Location of D.O.minimum (miles below outfall): Slope:_ q a
Velocity (fps): C�,C1 % Kl (base e, per day, 200C): C�' 5 O K2 (base e, per day, 200C):
4h Lurr,bL-A(j)— wuu,iP G 7 M O 1 f f �^
ecI Iv
UJ T l- um�EC�c�r� 1 " WTP Q) 15 w r ,
Effluent
Characteristics
ronthl�
Average
M A
Comments
i 210015
a�' mrn
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3, T,9
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Original Allocation
Revised Allocation
by crs�-
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41L C2 u
Effluent
Characteristics
Monthly
Average
Comments
a c� 5
asowla
N H3-N
�r s t,-. 4_ rzrcF-r-c1 C'
Date(s) of Revision(s)
(Please attach previous allocation)
Prepared By: �4,s n e'i"c t�y Zli r� Reviewed By: Date
711T �
mil/"

1
For Appropriate Dischargers, List Complete Guideline Limitations Below
Effluent Monthly Maximum Daily
Characteristics Average Average Comments
.- of Product Produced
. 1- •i -.
Effluent Guideline
/ i 4 �- i �L i a/ ttt is t- I
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Form #0K
WASTE LOAD ALLOCATION APPROVAL FORM
#113
Facility Name: Alpha Cellulose
County: Robeson Sub -basin: 03-07-51
Regional Office: Fayetteville Requestor: Mick Noland
Type of Wastewater: Industrial 100
Domestic °a
If industrial, specify type(s) of industry: produce cotton linter pulp
Receiving stream: Lumber River
Other stream(s) affected:
7Q10 flow at point of discharge: 140 cfs
30Q2 flow at point of discharge:
Natural stream drainage area at discharge point:
With Lumberton WWTP
BOD5 = 28 mg/1*
NH3-N = 7 mg/l*
TSS = 30 mg/1*
DO = 5 mg/1
PH = 6-9 SU
Class: C
Class:
Recommended Effluent Limitations
mi2
Monthly Avg
7 MGD With Lumberton WWTP
BOD5 = 22 mg/l*
NH3-N = 6 m,9/1*
TSS = 30 mg/1
DO = 5 mg/l
PH = 6-9 SU
MGD
JUL 8 1981
ENV. OPERATIONS
Fayetteville Reg. Office
Temp. = discharge shall not cause Temp. = discharge shall not cause the
the receiving water to exceed 2.80C receiving water to exceed 2.80C above
above natural water temp, and in no natural water temp, and in no case
case shall cause the receiving water shall cause the receiving water to
to exceed 320C. exceed 320C.
*based on BPT-type limits developed *water quality limited
previously by Regional Office & EPA.
These limits are more restrictive
than water quality limits for this
case.
This allocation is: /X/ for a proposed expansion.
for a new (existing) facility
a revision of existing limitations
a confirmation of existing limitations
Recommended and reviewed by:
Date:
Head, Techncial Services Br nch Date:4;�&
Reviewed by:
Regional Supervisor ' Date: 7 � Y
Permits Manager Date: / p
Approved by: 7 n/
Division Director Date: �`

C>3 -07 -,51
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DIVISION OF ENVIRONMENTAL MANAGEPIENT
June 26, 1981
MLMORANDUM
TO: Mick Noland, Environmental Engineer
Fayetteville Regional Office
FROM: Forrest Westall, head
Technical Services Branch
SUBJECT: Proposed Alpha Cellulose Expansion Wasteload Allocation
Robeson County
The Alpha Cellulose allocation, at their proposed flow of 2.4 MGD, is
affected by the proposed expansion of the Lumberton WWTP from the
c1_irrent design flow of 7 MGD to 15 MGD. Therefore, two sets of
allocations were alone for Alpha Cellulose: one with Lumberton at
7 MGD and one with Lumberton at 15 MGD.
Case 1 - Lumberton at 7 MGD:
Using parameters developed for the most recent (10-78) allocation
for Alpha Cellulose, BPT applies for a discharge of up to 4 MGD,
provided that the other discharges (West Point Pepperell, Lumberton
and Kendall Corp) which interact with Alpha Cellulose, remain at
the same flow level. Therefore, with Lumberton at 7 MGD, Alpha
Cellulose can receive an allocation of 28 mg/1 BOD5, 7 m9/1 NH3-N
and 30 mg/l TSS.
Case 2 - Lumberton at 15 MGD:
With the Lumberton discharge at 15 MGD, the Lumber River is water
Quality limited with respect to the Alpha Cellulose discharge.
The BOD-ultimate limit is 93 mg/l, which can be broken down into
an allocation of 22 mg/l BOD5 and 5 mg/l NH3-N according to the
formula
BOD-ultimate - (3 X BOD5) + (4.5 X NH3-N).
This formula was developed assuming a CBOD: BOD5 ratio of 3:1, as
you discussed with Ms. Jennifer Buzun in a telephone conversation
on 6-24-81.

continued Mick Noland
- page #two -
Additionally, it should be noted that the increase in Alpha Cellulose's
flow would reduce the BOD-ultimate allocation for Lumberton at
15 MGD from the formerly projected 94 mg/1 to a BOIhilt. of 93 mg/l.
If you have any further questions, please do not hesitate to contact
us.
FWacs
cc: Jennifer Busua
Bill Mills

0
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 19, 1979
Mr. Richard R. Peck, Technical Director
Alpha Cellulose Corporation
Box 1305
Lumberton, North Carolina 28358
SUBJECT: Permit No. NC0005321
Authorization to Construct
Alpha Cellulose Corporation
Wastewater Treatment Plant Clarifier
and Aerator Additions
Lumberton, North Carolina
Robeson County
Dear Mr. Peck:
The final plans and specifications for the subject project have been reviewed
and found to be satisfactory. Authorization is hereby granted for the construction
of a 55-foot diameter clarifier and the installation of five (5) - 40 hp floating
aerators as additions to the existing 1.42 MGD extended aeration wastewater treat-
ment plant serving the Alpha Cellulose Corporation, Cotton Linter Pulp Mill.
This is a Class II Wastewater Treatment Plant which requires that the operator
in responsible charge hold a valid Grade II Certificate.
This Authorization to Construct shall be subject to revocation unless the waste-
water treatment facility additions are constructed in accordance with the conditions
and limitations specified in Permit No. NC0005321.
Also, enclosed is a copy of WPC Form f50 "Cost of Wastewater Treatment Works."
This form is to be completed and returned to this office within thirty (30) days
after the project is completed.
One (1) set of approved plans and specifications is being returned to you.
Sincerely your:,
A. F. McRorie
Director
Enclosures
cc: Environmental Protection Agency
Robeson County Health De artment
Mr. Dennis Ramsey
Mr. A. C. Turnage, Jr.
Information Services

Yi�6/�� 6/ NPDES WASTE LOAD ALLOCATION
Rousing on Reverse ide
Facility Name: Date: 101,)317 �
County: Permit No.Pipe No.:
Receiving Stream: �G//!1/.3C-/,� /�G'� /� Class:
Design Capacity (WD): yz Design Temp.Requestor: �� FBI L2
Sub —basin: 5-/ Drainage Area: 7 O 7ra10: 1LLC
Other Stream Affected: Class:
Limits (circle one) : Effluent or war•. Quality Avg. Stream Flow: %/ D DO Sag Pt. (mi.) /6..2 Xy1i —,s
A049A)6ipC-91'1 a f
atJ�/a r'oituL�CL
hffluent
14
V170-�_
t' %W"W4
Me M-
wmw .'Ii
Prepared by:
Reviewed by:� Date:
IS -3/78

For Industrial Dischargers List BPT Below
,Characteristics
160 M;
'Fecal Coliform
4d.solved- Oxygen
(•
Industrial SIC Code:
Type of Waste:
Effluent Guideline Reference:
Routing
To Initial
Information Services
Modeling and Alloc.
Regional Office
.r�

/pDigESG•✓ Co
l 7. 3 b
4c� _ 3 7. 5
7. 3G

r�
.2
7-/
L�aSr�t�3
p oY,
�- u
IL7 L 74 a o
L4�.4 = 76 0
A = 71v
POIA)T Pr-PPL)el4.1-- A)C
4w = a, S A c —
(tomGsi ,c E OV
IS — G+ TY OF �CUt ge P%o•✓ wwT/°
Qcu - % o A; G /,) 61J d r►�e�s i i
d S Caip�.
(�w — �• '� � (�itJAGr S i ,Pi9 � L!%AS % � S J
Q = 0.o0 (koA/ilc
cu
To ",4 G /t/ /'�Aa4-,� _ A)- iD i /1-6 0
, /s 6,
hum,8e ? /1-
9/ o o v 0
7. S
CAA = 72 S Qq 76 U
_3 c� 7/ 1r

C
X =v
7
Sl 75,O c �=S C�✓ _ �� o
A = 7 / 4e
,06A
AU = 7G o + 3 S 71
71
�GOv 0-0' .�Cr�i. �u4i i %' ib i4/. f'.�/iq C�.s •c t�.caS� co ?/� J
4AI = 7 0
//,� . . Yr40, 3s) t- ./zs(a,/��)
" /.iy, 8 7 -
/�
7/{vG 761.
(74/. 4 7)"

f. • ' `�
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----____..-. ---- _ -.. .�._., ._----�.,�.-_y_.r_.___�___
:I

O
t
-
TH
1.�-7,o7 cvs
Q90G/ 7G o •7L x y o ( z- o z) = 7c,z_ 8 3
-7::: �2 7 ( /S 7, 0 7
Go- TO
%�tiGTff /U�
� uG
WiUG,, nUG - 7ba 0 Z) = 7c 7, 76
�9 ,f

AS, //i?/r-S 0AiS%� 4f4)4.,C, 5TRr-_AM CoJ6
/lIq
tiH� -�v 83 7.o
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I

Part V
A. Dioxin Monitoring
For permit compliance purposes, the point of compliance shall be defined as the final
effluent before discharge. Compliance with the daily maximum permit limit shall be
deomonstrated by determining the TCDD concentration at the final discharge point.
Adequate sample volume shall be collected to perform the analysis. The total sample
volume shall be collected and preserved in accordance with Part II, Section C
Monitoring and Records. The sample shall be analyzed in accordance with the
appropriate method of analysis specified in Analytical Procedures and Quality
Assurance for Multimedia Analysis of Polychlorinated Dibenzo-para-dioxins and
Polychlorinated Dibenzofurans by High Resolution Gas Chromatography/High
Resolution Mass Spectrometry, EPA, 1987 (EPA Method 8290), or another
equivalent analytical protocol approved by DEM. A single sample may be analyzed
to determine compliance with the daily maximum effluent limitation. Alternatively, a
sample volume may be collected to enable the sample to be split (duplicate analysis).
If the analysis of either split sample is below the detection limit, the quantity, for the
purposes of compliance evaluation, is considered to be zero. If both splits are
positive, the results of the two analyses shall be averaged to determine compliance
with the daily maximum effluent limitiation. If the measurement is below detection
limits the quantity for the purposes of compliance evaluation is considered to be zero.
The detection limit using these methods for the purpose of compliance evaluation is
considered to be 10 picograms per liter. The dioxin isomer to be monitored and
limited by this permit is 2,3,7, 8, TCDD.
Fish tissue analysis will be performed, as a minimum, at one station established
upstream of the discharge and at two stations downstream in accordance with the
Division of Environmental Management approved monitoring plan. The monitoring
plan is an eforceable part of this permit. All dioxin data collected as part of this
monitoring requirement will be reported within three months after collection.
The permittee shall perform the following analyses for dioxin in addition to
monitoring the effluent as specified on the effluent pages:
1. Influent to wastewater treatment facility Quarterly GRAB (2378 TCDD)
2. Sludge Quarterly GRAB (2378 TCDD)
3. Fish tissue analysis Annually (TCDD and TCDF)
70o
/MA`S&ti 14(5 ire Fo q'ct Wo-Tib 3AY s C#0uP. 02 'C64Q k(7-kL, P'L-t ,
1-NO W . t KT tF �V u CALAI 4,q-rJ D 5 ON 1 1 S,

U
Page 1
Note for Carla Sanderson
From: Carla Sanderson
Date: Fri, Jul 8, 1994 4:45 PM
Subject: Alpha Cellulose
To: Susan Wilson
What do you know about this facility meeting a Dioxin limt? The last WLA recommended a
limit of 1.9 pq/1, but on the limits page beside Dioxin, the permit has (2378-TCDD)***** or
see part V of this permit. The DMRs say NOL for Dioxin. The Last WLA in 5/92 requests
that the facility submit a dioxin control plan (DCP) within 120 days of the effective date of
the permit.
Anyway - I just would like to know what kind of language is in pert V and if they have done
anything to meet the dioxin limit?
If you have the permit down there - maybe I will come take a look.
Please let me know. Thanks!