NC0000272_Fact Sheet_20241021

Department of Environmental Qualityt and Natural Resources
Division of Water QualityResources
Fact Sheet fFor NPDES Permit NC0000272

Facility Information

Applicant/Facility Name4:
Blue Ridge Paper Products, Inc. dba Evergreen PackagingBlue Ridge Paper Products Inc. dba Evergreen Packaging

Applicant Address4:
P.O. Box 4000

Facility Address4:
175 Main Street

Permitted Flow2,4,7:
29.94.9 MGD

Type of Waste2,4,7:
Industrial, domestic, groundwater remediation, stormwater, and landfill leachate

Facility/Permit Status4:
RenewalMajor Modification

County2,4,7:
Haywood

Miscellaneous

Receiving Stream2,4:
Pigeon River

Stream Classification1,2:
C

303(d) Listed?5:
Yes. – Fish Advisory, Dioxins Biological impairment.

Subbasin2:
04-03-05

Drainage Area (mi2): [calculated]
130 mi2

Summer 7Q10 (cfs)6:
52 cfs at Canton and 120 cfs at Hepco

Winter 7Q10 (cfs)6:
63 cfs at Canton and 183 cfs at Hepco

30Q2
89.9 cfs at Canton

Average Flow (cfs)6:
325 cfs at Canton and 677 cfs at Hepco

IWC (%):
100% (See Text Below)

Primary SIC Code:
2621

Regional Office:
Asheville

USGS Topo Quad:
Canton (E 7 SE – State Grid)

Permit Writer:
Michael MyersSergei Chernikov, Ph.D.

Date:
FJuly 24ebruary 2June 28, 200920241

Summary

Background
Blue Ridge Paper Products Inc. has requested renewal of their National Pollutant Discharge Elimination System (NPDES) discharge permit NC0000272 allowing discharge of industrial, stormwater,
municipal and landfill leachate wastewaters to waters of the state. The NPDES permit will expire on November 30, 2001 and the application for renewal was received on February 23, 2001.
. This fact sheet summarizes the rationale used to develop the limits and monitoring conditions for the draft permit. North Carolina Division of Water Quality 's(Division) also recommends
renewal of the temperature variance and deletion of the color variance recommendations for the draft permit..
Background
The facilityBlue Ridge Paper was established in 1908 to produce pulp for the Champion paper mill in Hamilton, Ohio. Blue Ridge paper acquired ownership of the mill in May of 1999 from
Champion International. In 2007, the facility was purchased by the Rank Group and now operateswas operating as a
subsidiary of Evergreen Packaging. The company historically currently employeds about 1,500 people in North Carolina. The facility was shut down on May 24, 2023.

Currently the wastewater treatment plant primarily treats domestic wastewater from Canton (~1.1 MGD), the other miscellaneous sources include groundwater remediation, landfill leachate,
and stormwater. After facility completed the cleanup of the equipment at the end of 2023, the average effluent volume was 1.88 MGD, with the highest flow of 7.98 MGD. Therefore, the
permitted flow limit will be reduced to 4.9 MGD.

The facility is currently in escrow and the new owner will be TBD Utilities LLC negotiating the sale of the property to a redevelopment company. Upon completion of the sale, the new
owner would have to submit the Engineering Alternative Analysis to justify the requested flow limit.

The facility has been purchased by TBD Utilities LLC in 2024. In August 2024 the facility requested that groundwater remediation was explicitly added to the permit since the decision
has been made to conduct groundwater remediation activities at the site and approximately 0.25 MGD will be added to treatment. The new RPA was conducted based on the new Form 2C submitted
by the permittee, this Form 2C included groundwater data.
Blue Ridge Paper is an employee-owned and operated integrated, elemental chlorine free (ECF) bleached kraft pulp and paper mill with oxygen deligninifcation, and bleach filtrate recycle
, and paper mill in Canton, North Carolina. Processes at the mill include a pine bleach line; hardwood bleach line, paperboard and fine paper production lines. Pine and hardwood chips
are transported to the site via rail or truck and subsequently processed into pulp for paper or paperboard production.
In or around 1990, Champion International Corporation (Champion Paper - now Blue Ridge Paper) initiated a $300 million dollar modernization project termed the Canton Modernization Project
(CMP). This project eliminated the use of elemental chlorine and implemented significant changes to both the pine and hardwood bleaching lines.
The mill upgrade included two changes that significantlydramatically improved the mill’s environmental performanceimpact. The first major change was the use of oxygen delignification.
This process is used to separate the lignin from the fiber. This resulted in significant improvement in the mills environmental performance. The second major change was the implementation
of full-scale bleach filtrate recycle (BFR) on the pine bleach line and caustic extrationextraction stage (Eo) filtrate recycle (~20%) on the hardwood bleach line. For a more detailed
description of the mill improvements, refer to the Canton Modernization Project Section below..
The Canton Modernization Project greatly reduced the wastewater generated and eventually discharged to the Pigeon River. Even with these improvements, significant quantities of wastewater
are generated in the production of pulp and paper and proper treatment prior to discharge is required.
Wastewater generated by the Canton Mill, along with the Town of Canton’s domestic wastewater, is treated at Blue Ridge Paper’s Wastewater Treatment Plant. The treatment plant is a 29.9
MGD wastewater treatment system consisting of the following unit processes:
Grit Chamber
Bar screens
Lift pumps
Polymer addition
pH control (CO2 injection or H22SO44 backup)
Three primary clarifiers (one normally off-line)
Nutrient feed
Aeration basins
Three secondary clarifiers
Residual belt presses
Effluent flow measurement
Cascade aeration (with oxygen injection)
Oxygen injection facilities
Solids at this facility are deposited into a dedicated landfill. A portion of the energy at the facility is generated by burning coal. Coal ash is landfilled into a double-lined landfill,
which is equipped with leachate collection. Leachate is treated at the wastewater treatment system.

The history of this mill, under the ownership of Champion Paper and now Blue Ridge Paper, has been controversial. Under Champion Paper, the environmental impacts of the Canton Mill
were noted by concerned citizens, environmental groups, the State of Tennessee, State of North Carolina, and the United States Environmental Protection Agency (EPA). The issues raised
by these individuals and groups contributed to the Canton Mill’s improved environmental performance and resulted in a settlement agreement issued January 8, 1998. All the conditions
in the settlement agreement have been met.
Today the relationship among the various stakeholders has evolved to one of cooperation. The Division commends all the groups for their willingness to work together to improve water
quality. This permit has centered around four main issues associated withemanating from the mill’s discharge: color, temperature, oxygen consuming waste and dioxin, and a brief synopsis
follows.

Color
On July 13, 1988, Champion Paper was granted a variance from North Carolina's narrative water quality standard for color, which the EPA interpreted to be 50 color units. The EPA subsequently
issued a NPDES permit to Champion Paper facility in Canton, North Carolina.
In 1994, the EPA returned NPDES permitting authority for the Canton Mill back to North Carolina's Division of Water Quality. During the permit renewal the original color variance was
modified, and both the permit and the variance were issued inaround December 11-12, 1996. As outlined above, over the course of this variance the mill has initiated significant color
improvements, which have markedly dramatically reduced the color loading and other effluent characteristics.
Though the mill has made significanttremendous strides, color continues to be the major focal issuepoint surrounding this permit renewal.. The EPA chaired Technology Review Workgroup
(TRW) hasve recommended additional color reduction for this permit renewale up coming permit cycle. The recommendations issued by the Technology Review Workgroup wereincluded based
on the findings of a third party evaluation of Blue Ridge Paper’s Canton mill and athe report issued by the EPA Tech Team9. The evaluation conducted by Dr. Norm Liebergott in 2001
was co-sponsored by Blue Ridge Paper and several environmental groups andgroups and provided valuable information for the TRW8. The latest report of Dr. Liebergott was issued on July
7, 2006 and sponsored by Blue Ridge Paper. In addition, to identifying areas for improvement and available technologies, Dr. Liebergott compared the Canton mill to 76 similar mills
around the world. Dr. Liebergott concluded that the Canton mill’s environmental performance is among the best in the world. The latest TRW recommendations were issued on February
25, 2008 and are incorporated into this permit renewal. Color limits for the permit are developed in accordance with the TRW recommendations.

Though incredible work has been done, there continues to be a need to reduce color further. Blue Ridge Paper’s openness and willingness to work towards continued improvements has resulted
in an atmosphere of trust and cooperation among all the interested parties. This cooperation has been extremely valuable and will continue to be critical as the additional color reductions
recommended by the Technology Review Workgroup are implemented (see attached July 24, 2001, memo from the EPA Tech Team to the Technology Review Workgroup).
The Technology Review Workgroup report identifies process improvements that will result in permitted color reductions of 6,000 pounds per day. In addition, the report identifies process
improvements that will require further study but are likely to result in total color reductions in the range of 9,000 – 14,000 pounds per day. The mill will also evaluate the feasibility
of treating the highly colored low flow wastestream from the chloride removal process (CRP). The feasibility of additional color reductions associated with the treatment of the CRP
wastestream is highly uncertain and no color reductions have been established for this permit cycle. The result of a feasibility study on the Chloride Removal Process wastestream will
be evaluated for possible additional color reductions for the next permit cycle.

As shown in Table 1, the 6,000 pound per day annual average color reduction will become effective on December 1, 2003. Additionally, the mill will evaluate additional process improvements
in order to achieve an annual average effluent color loading of 34,000 – 39,000 pounds per day. If the limits determined to be achievable are within the target range, the limits shall
become effective on December March 1, 2005, by written notification from the Director. In the event that the achievable limits are outside of this range then
the NPDES will be reopened. At that time, public comments will be gathered and the permit may be modified.

Table 1. Major Dates for Compliance/Reports.
Submittal/Compliance Date
Requirement

2002
Fish Tissue Study Report

October 1, 2003
Statistical evaluation of performance for determination of the monthly average effluent color limit

December 1, 2003
First reduction in effluent color limit

December 1, 2003
Feasibility report on additional process improvements for further color reductions

2004
Fish Tissue Study Report

December 1, 2005
Statistical analysis and feasibility report on treatment of CRP wastestream

March 1, 2006
Second reduction in effluent color limit

March 1, 2006
Comparative Evaluation Report

May 1, 2006
Balanced and Indigenous Species Study Report



Temperature
The facility first requested and received a 316 (a) variance (approved by EPA) for temperature on August 6, 1985. This determination demonstrated that the effluent limitations relating
to the thermal component of the Champion discharge were more stringent than necessary to assure protection and propagation of a balanced indigenous population of shellfish, fish, and
wildlife in the Pigeon River. Therefore, the 316(a) temperature variancedetermination was approved based on protection of the appropriate use classification of the Pigeon River.
The temperature variance was reviewed and renewed as part of the Triennial Review in 1997.
Blue Ridge Paper submitted a Balanced and Indigenous Species Study on the Pigeon River in May of 2006on June 1, 2001. The study was conducted by the University of Tennessee. DWRQ scientists
have reviewed the report and concluded that continuance of the temperature variance is appropriate. Therefore, the Division of Water Quality is recommending continuation of the temperature
variance with reporting requirements consistent with the previous permits (see Table 1). [balanced, indigenous populatioSince the facility no longer generates heated wastewater, the
variance is no longer necessary and will be removed from the permit.n]

Oxygen Consuming Waste
An EPA approved model predicted that even with a BOD5 loading of 1209 lb/day (5.0 mg/L at 29 MGD) that the dissolved oxygen in the Pigeon River would not be protected. Since Blue Ridge
Paper cannot comply with such stringent effluent limitations, an instream oxygen augmentation method was implemented to protect the dissolved oxygen in the receiving stream. For further
discussion on this subject refer to the Oxygen Consuming Waste conventional Ppollutants section below.
Dioxins
Elevated levels of dioxins were found in fish tissue in the Pigeon River (around the late 1980s). Subsequently, a a fishfish consumption advisory was issued for sport fish, catfish,
and carp. The Canton Mill has not discharged any detectable levels of 2,3,7,8- TCDD to the Pigeon River (since 1989) and dioxin in ffish tissue continues to decline. Currently, a fish
consumption advisory continues for carp and catfish. North Carolina has lifted the advisory on sport fish. However, the State of Tennessee continues to post a precautionary fish consumption
advisory for carp, catfish and red breasted sunfish.

MostThe fish consumption advisories in North Carolina and Tennessee were removed in 1998 and 2002. are currently under review for possible modification of the advisories. The North
Carolina Division of Environmental Health (DEH) has initiated a review of the fish consumption advisory on Pigeon River and Waterville Lake. DEH is evaluating dropping the advisory
on catfish in the North Carolina portion of the
Pigeon River and limiting The last fishthe advisory foron Common Carp into Waterville Lake was removed on January 7, 2007. There are no fish advisories in the Pigeon River at this time.

The May 2010 NPDES Permit for the Blue Ridge Canton Mill required three (3) additional years of fish tissue sampling and surveillance. During the sampling years between 2008-2013 the
concentrations in fish tissue fillets were below the NC DHHS 4 ppt TEQ [toxic equivalency] action level for fish consumption advisory. In 2014, TEQ values were below detection for channel
catfish for both sampling Stations; however, in Common Carp, TEQ values were 9.619 ppt for Station 4A and 2.928 for Station 4B.
The TEQ results for Common Carp fillets in 2014 and 2007 could be anomalies, or could indicate that some fish are present in the population with relatively higher TEQ values.

EPA conducted a High Volume dioxin sampling in the Pigeon River in 2014 and concluded that “the most potent of congeners in the series, 2,3,7,8 – TCDD, was not detected in dissolved
samples at the reporting limit of 0.0012 parts per quadrillion at any station”. A final determination may not be finalized prior to permit renewal, therefore, recommendations presented
in this permit do not reflect this evaluation.

During the previous permit renewal all sampling results showed results below TEQ action level. Since the fish dioxin concentration have been reduced steadily during the last several
decades, the facility had no dioxin detection in it’s effluent since 1989, the production of pulp and paper has been eliminated, and based on the EPA High Volume dioxin sampling results,
the fish tissue sampling requirement in the permit will be eliminated.

316(b)
Since the cessation of production, the facility withdraws less than 2.0 MGD from the Pigeon River and is not subStream Conditions
ject to 316b rule.

Instream Monitoring The facility discharges to the Pigeon River near Canton, North Carolina. The Pigeon River from Canton to Hurricane Creek is listed as an impaired water, according
to North Carolina’s 2000 Draft 303(d) List, due to a fish consumption advisory for dioxins. Recent data indicate that the dioxin levels in fish tissue continue to decline. There has
been no detection of 2,3,7,8 TCDD in sport fish since 1995 and below North Carolina’s fish consumption advisory level for 2,3,7,8 TCDD in catfish since 1997, based on Blue Ridge Paper’s
data. 2,3,7,8 TCDD continues to be detected in carp, though levels continue to decline and are below North Carolina’s advisory level.

The Pigeon River has been experiencing extremely low flows, due to extended drought conditions in the western part of the state, with flows often less than the 7Q10 flows of 52 cfs (near
Canton). Curtis Weaver, with the USGS, provided the updated low flow statistics noted above using data from 1933 through 1999. The low flow statistics at Canton include the influence
of Lake Logan, which was constructed in 1932 and the influence of both Lake Logan and Lake Junaluska (constructed in 1913). This reflects the current hydrography within the watershed
and does not reflect conditions prior to construction of the lakes.

The impact of this reevaluation of the low flow statistics is that the lowest seven day average flow expected once in ten years (7Q10) has been reduced from 54 cfs to 52 cfs. This affects
the instream waste concentration which is used to determine the limits for the toxicity testing (discussed later).
Instream Monitoring
The current permit requires Blue Ridge Paper to conduct an extensive instream monitoring program consisting of 912 monitoring sites (1-upstream of mill in Pigeon River, 3-Waterville
Reservoir, and 77-downstream of mill in Pigeon River and 1-Big Creek; See Figure 1 and Table 12).

Instream Monitoring by Parameter

Blue Ridge Paper is required to monitor fecal coliform upstream (at station UP) and downstream of the discharge (at station DN1). Analysis indicates no discernable difference between
the upstream and downstream fecal coliform levels. Upstream fecal coliform is generally in the range of 100 to 200 /100ml. The same trend is evident at the downstream sampling point.
These data suggest that Blue Ridge Paper does not contribute significant levels of fecal coliform. Monitoring of the effluent is sufficient to monitor the mill’s impact on the river.
Blue Ridge Paper has volunteered to conduct upstream sampling and this requirement will remain as a condition in the permit. Thus, the Division’s recommendation is the elimination
of the downstream fecal monitoring and once per week fecal monitoring upstream.

Blue Ridge Paper is required to monitor conductivity upstream (at station UP) and downstream (at station DN1). There is a significant increase in conductivity between the upstream and
downstream monitoring sites. Conductivity measurements are less than 50 umhos/cm2 at the upstream monitoring station and generally greater than 250 umhos/cm2 at the Fiberville Bridge.
This increase in conductivity is expected since conductivity is a measure of inorganic material. Thus, the Division’s recommends that conductivity monitoring continue as required
by 15A NCAC 2B .0508(d).

Figure 1. Instream Monitoring Stations for Blue Ridge Paper Products – Canton Mill.

Historically,

The facility is required to monitor 5-day Biochemical Oxygen Demand (BOD5) upstream at station UP and downstream of the discharge at the station DN7. Levels of BOD5 have been less than
2.0 mg/L. Based on this information and the Division's lack of need for the data, it is recommended that instream BOD5 monitoring be eliminated from the permit.

Instream Monitoring by Parameter

Blue Ridge Paper conducted extensive stream monitoring, including one upstream and seven downstream monitoring stations. Since the facility was shut down in 2023, this regime is no longer
necessary and only one downstream monitoring station will remain in the permit to estimate impact from miscellaneous waste streams such as landfill leachate. is required to monitor
conductivity upstream (at station UP) and downstream (at station DN1). The Division’s recommends that conductivity monitoring continue as required by 15A NCAC 2B .0508(d).

Blue Ridge Paper monitors temperature upstream at station UP and downstream at all monitoring stations except station DN6 and station BC. Review of the data from 01/01/2004 through
12/31/2008 indicated that the monthly average temperature of the Pigeon River did not exceed the permitted limits of 32 °C (summer) or 29 °C (winter).

Blue Ridge Paper monitors dissolved oxygen (DO) at all the instream stations except station DN6 and station BC. Over the period of review (01/01/2004-12/31/2008), daily average dissolved
oxygen concentration did not drop below the North Carolina's standard of 5.0 mg/L for Class C streams at any of the instream monitoring locations. The lowest oxygen concentrations
occurred at the DN2 monitoring stations.

Table 12. Instream Monitoring Requirements According to the 1997 NPDES Permit and Color Variance.

Stream
Designation
Mile
Marker
Location Description
Parameter
Frequency

UP
63.8
Pigeon River upstream of the waste treatment plant outfall (prior to mixing with the discharge)
Temperature
D.O.
BOD5
Conductivity
Color
Flow
Fecal coliform
Daily
Daily
1/Week
Daily
2/Week
Daily
1/Week

DN1
62.9
Pigeon River at Fiberville Bridge
Temperature
D.O.
Conductivity
Fecal Coliform
Color
DailyWeekly
DailyWeekly
DailyWeekly
1/WeekWeekly
2/WeekWeekly

DN2
57.7
Pigeon River Above Clyde
Temperature
D.O.
Daily
Daily

DN3
55.5
Pigeon River Below Clyde
Temperature
D.O.
Color
1/Week
1/Week
22/Week

DN4
53.5
Pigeon River at NCSR 1625 bridge
Temperature
D.O.
Color
1/Week
1/Week
22/Week

DN5
42.6
Pigeon River at Hepco
Temperature
D.O.
Color
Flow
1/Week
1/Week
12/Week
Daily



Waterville Reservoir

Annually

DN6
26.0
Pigeon River prior to mixing with Big Creek
Color
12/Week

BC
~ 26.0
Mouth of Big Creek prior to mixing with the Pigeon River
Color
12/Week


DN7
24.7
Pigeon River at Browns Bridge
(~ NC/TNTENNESSEE State Line)
Temperature
D.O.
BOD5
Color
1/Week
1/Week
1/Week
12/Week



Blue Ridge Paper monitors temperature upstream at station UP and downstream at all monitoring stations except station DN6 and station BC. Comparing upstream to downstream, see Figure
2, the temperature difference ranged from between 1.78 °C and 11.65 °C. At no time did the monthly average temperature of the Pigeon River exceed the permitted limits of 32 °C (summer)
or 29 °C (winter).

Blue Ridge Paper monitors dissolved oxygen (DO) at all the instream stations except station DN6 and station BC. Over the period of review (1998 – 2000), dissolved oxygen did not drop
below the North Carolina's standard of 5.0 mg/L for Class C streams at any of the instream monitoring locations. Figure 3 summarizes the results of this analysis.

During the 1997-2001 previous permit cycle, an EPA-approved computer model indicated that BOD5 limits were required to protect North Carolina's instream dissolved oxygen standard of
5 mg/L for Class C waters. An economically feasible end-of-pipe technology capable of consistently treating to levels necessary to meet the limits specified by the model did not exist.
North Carolina agreed with the continuation of the requirement that Blue Ridge Paper meet the instream dissolved oxygen standard by use of sidestream oxygen injection facilities.
Blue Ridge Paper maintained these oxygen injection facilities at the effluent and at approximately 0.9, and 2.1, and 3.7 miles downstream of the discharge. The previous NPDES permit
required Blue Ridge Paper to maintain the oxygen injection facilities located 0.9 and 2.1 miles downstream.

To ensure compliance with the above requirement, the average daily instream dissolved oxygen levels at stations DN1, DN2 and DN3 were required to equal or exceed 5.0 mg/L and the minimum
instantaneous instream values were required to be greater than or equal to 4.0 mg/Ll. If dissolved oxygen drops below the prescribed values, Blue Ridge Paper shall utilize the instream
dissolved oxygen injection stations to increase the dissolved oxygen in the river.

This method fulfilled the requirements of 40 CFR 125.3 (f).

Blue Ridge Paper has compiled an extensive database on instream dissolved oxygen concentrations and stream flow. These data suggest that the dissolved oxygen sag occurs at station DN2.

Figure 2. Temperature in the Pigeon River Upstream and Downstream of Blue Ridge Paper’s NPDES Discharge.

Figure 3. Average and Minimum Dissolved Oxygen in the Pigeon River from River Mile 63.5 to the NC/TN State Line. (Average DO* = ln (DO))

Stations DN2 and DN3 were included because the dissolved oxygen model predicted that the DO sag occurred in this area and because they represented monitoring locations upstream and downstream
of Clyde's discharge. The Town of Clyde has recently removed their discharge and the Division has received a letter from the Town requesting rescission of the permit. Based on a review
of the instream data and the removal of Clyde's discharge, it is recommended that the dissolved oxygen compliance point at station DN3 be eliminated.

The Division reviewed the 1998 through 2000 instream dissolved oxygen data. Over this time period, Canton, North Carolina has experienced extreme drought conditions and flow in the
Pigeon River has often dropped below the updated 7Q10 stream flow. Under these conditions, the lowest dissolved oxygen level observed in the North Carolina portion of the Pigeon River
was 5.0 mg/L and occurred at river mile 57.7. Additionally, a review of the average daily instream dissolved oxygen data and the average over this time period indicates that the dissolved
oxygen sag occurs at river mile 57.7. Based on this analysis, the compliance point and monitoring requirement at river mile 55.5 have been dropped. The oxygen injection facilities
will continue to be maintained at the effluent, 0.9, and 2.1 miles downstream, and used as necessary to maintain an instream dissolved oxygen level of 5 mg/Ll. The condition to maintain
the instream dissolved oxygen stations shall remain a condition of the permit until such time that the permitted loading of oxygen consuming waste to the Pigeon River is less than or
equal to that proposed by an appropriate water quality model.

If dissolved oxygen at station 57.7 drops below 5.0 mg/L, the facility is required to monitor dissolved oxygen at river mile 55.5 and 53.5.

Instream monitoring continues to be required in order to assess Blue Ridge Paper 's impact on the Pigeon River and to ensure that the dissolved oxygen standard is maintained within the
river.

Color

The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco USGS gauge station. The new effluent limits in this permit are more stringent than
the provisions in the 1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is possible to calculate the monthly flow at the Canton gage station
above which instream color at the Fiberville Bridge will not exceed 50 true color units. Using the 55,000 pounds per day monthly average true color loading limit (implemented on the
effective date of the permit) the flow at the Canton Gage station, which will provide for color less than 50 true color units at the Fiberville Bridge is 171.8 MGD. Therefore, the
monthly average color in the Pigeon River at the Fiberville Bridge will be less than 50 true color units whenever the monthly average flow (at the Canton gage station) is greater than
171.8 MGD. North Carolina is recommending that the Fiberville bridge be the basis for the color variance.
The governing flow criterion for true color at Canton is 58.1 MGD (30Q2 stream flow). The flow established is greater than this 30Q2 stream flow, therefore, for flows less than the
171.8 MGD at the Canton Gage station but greater than 193.3 MGD at the Hepco gage station, the monthly average color in the Pigeon River at Hepco will be less than 50 true color units.
Currently, the basis for the color variance is the Hepco station (DN5) within North Carolina, therefore with the moving of the station from Hepco to Fiberville, DWQ recommends that the
mill monitor the Hepco station 2/week during the summer and once per week during the winter.

During the permit cycle, the effluent color limit will be reduced, therefore, the instream color criteria will be adjusted accordingly. The monthly average color in the Pigeon River
at the Fiberville Bridge will be less than 50 true color units whenever the flow at Canton is greater than the flow established using the following equation and based on the monthly
average effluent limit established per Special Condition A.(8.) Paragraph 4:

For flows at the Canton Gage station less than the flow established here but greater than 193.3 MGD at the Hepco gage station, the monthly average color in the Pigeon River at Hepco
will be less than 50 true color units.
Compliance Summary

The facility has a good compliance history. During the review period (01/0105/201904 through 12/3105/202308) the following NOVs (notices of violation) have been issued: 08/24/20064
- for violating whole effluent toxicity limit, 5 – for violating BOD limit, 6 – for violating Fecal Coliform limit. failure of the whole effluent toxicity test; 10/21/2005 and 10/22/2005
– violation of the BOD daily maximum limit.
The Compliance Evaluation Inspection conducted on 01/08/2009 found the facility to be in compliance. Previous inspections had identical findings.been in compliance with permit conditions
during this cycle.
Permitting Rationale – Toxicity Testing

Current Requirement: Chronic toxicity limit monitored quarterly @ 87%

The facility has consistently passed the chronic toxicity test at 90% effluent during the previous 5 years (19 of 20 tests passed). Therefore, chronic toxicity is not an issue. The permit
renewal retains the same chronic toxicity test limit. In December 1999 the facility reported a chronic level of 81% (with a state split sample greater than 87%), with the following
two months greater than 100. All other toxicity tests over the past four years were greater than the stipulated 87%.

The toxicity testing requirement is placed on all major facilities and other facilities with complex wastestreams. The toxicity limit is based on the instream waste concentration under
7Q10 conditions (52 cfs updated April 2001). For Blue Ridge Paper, the instream waste concentration was determined by also accounting for the out-take of surface water from the facility
(31.6 MGD, as per application) and water withdrawal by the Town of Canton (allocated 6.8 MGD). Therefore, the instream waste concentration was determined to be 100% under 7Q10 conditions.
The Division has set a ceiling on the toxicity test of 90%. This was done because of difficulties associated with averaging toxicity test with limits of 100%. The Division feels that
90% is sufficiently stringent to assess the chronic toxicity of an effluent, while allowing for the averaging of multiple tests.

The draft permit retains the Recommended Requirement: Quarterly Chronic Toxicity limit @ 90% effluentMar, Jun, Sep, Dec.

Blue Ridge Paper is required to perform the NC Whole Effluent Toxicity Test or an equivalent method (as approved by the Division) on a quarterly basis at 90%. Any equivalent method
shall also be performed on a quarterly basis.
Permitting Rationale – Color
The annual average color limit of 39,000 lb/day was established in accordance with the TRW recommendations. The company will have to achieve a new stricter limit of 37,000 lb/day by
the end of the permit cycle.
The monthly average color limit of 52,000 lb/day was established in accordance with the TRW recommendations
The newly established daily maximum color limit is 105,250 lb/day. This limit is based on best professional judgment. The established number is within 3 standard deviations from the
mean during the period from 1/1/1998 through 12/31/2009.

Permitting Rationale – Toxicants Analysis

The Division conducted EPA-recommended analyses to determine the reasonable potential for toxicants to be discharged at levels exceeding water quality standards/EPA criteria by this
facility. For the purposes of the RPA, the background concentrations for all parameters were assumed to be below detection levels. The RPA
uses 95% probability level and 95% confidence basis in accordance with the EPA Guidance entitled “Technical Support Document for Water Quality-based Toxics Control.” The RPA included
evaluation of dissolved metals’ standards, utilizing a default hardness value of 25 mg/L CaCO3 for hardness-dependent metals. The RPA spreadsheets are attached to this Fact Sheet.

The calculations included: As, Be, Cd, Total Phenols, Cr, Cu, CN, F, Pb, Hg, Mo, Ni, Se, Ag, and Zn. The new flow limit of 4.9 MGD was used for RPA. The discharge data on the EPA Form
2C and DMR reports was used for the RPA. The analysis indicates no reasonable potential to violate the surface water quality standards or EPA criteria.

The proposed permit requires that EPA methods 200.7 or 200.8 (or the most current versions) shall be used for analyses of all metals except for total mercury.
Using the self-monitoring data required per the NPDES permit for Outfall 001, reasonable potential analyses were conducted on the following toxicants: dioxinmercury, zinc, cadmium, selenium
and silver. The standards used for the analyses are consistent with North Carolina standards for a class C waterbody.

Cadmium – Based on the Division’s analysis of self-monitoring data, this discharge does not pose a reasonable potential to cause a violation of the North Carolina stream standard for
cadmium. Effluent monitoring of cadmium will be removed because all the values were below detection level.
shall continue since cadmium continues to be detected in the effluent.

Mercury – Based on the Division’s analysis of self-monitoring data, this discharge does not pose a reasonable potential to cause a violation of the North Carolina stream standard for
mercury. Additionally, all mercury samples analyzed since January 1999 have been below North Carolina’s accepted detection level of 0.2 (g/L. Results from the Division’s 1996 Fish
Tissue Mercury Assessment on the Pigeon River indicate, “total mercury results were comparable to ‘background’ levels expected for fish across North Carolina.” Based on the findings
in this report and the ‘Reasonable Potential’ Analysis, it is recommended that mercury monitoring and limitation be removed from the permit.

Silver - Based on the Division’s analysis of self-monitoring data, this discharge does pose a reasonable potential to cause an exceedence of the North Carolina’s Action Level Standard
for silver. Numerical limits for silver are not being included since silver is an action level water quality standard and the biomonitoring requirements are adequate to control toxicity
due to the presence of silver. Though no limit is proposed, if the facility experiences chronic toxicity violations, the discharge will be re-evaluated and a silver limit may be implemented
according to the Division’s Action Level Policy.Effluent monitoring of silver will be removed because all the values were below detection level.

Selenium – Based on the Division’s analysis of self-monitoring data, this discharge does not pose a reasonable potential to cause a violation of the North Carolina stream standard for
selenium. Therefore, the selenium limit will be removed and the effluent monitoring will be reduced to annual.
The Division’s analysis indicates that the maximum predicted concentration for selenium is greater than the allowable concentration. This analysis included only seven data points,
with six data points below the quantitation level. One sample indicated the presence of selenium, however the concentration reported was at the quantitation level for the method. Additionally,
the QA/QC data questions the validity of this data point. However, the Division has limited Blue Ridge Paper for Selenium. After collecting for one and half years (six data points)
of data, the facility can request that the Division review the Selenium data for possible elimination of the limit.

Zinc - Based on the Division’s analysis of self-monitoring data, this discharge does pose a reasonable potential to cause an exceedence of the North Carolina’s Action Level Standard
for zinc. However, Nnumerical limits for zinc are not being included since zinc is an action level water quality standard and the whole effluent toxicitybiomonitoring requirements are
adequate to control toxicity due to the presence of zinc in the facility effluent. Though no limit is proposed, if the facility experiences chronic toxicity violations the discharge
will be re-evaluated and a zinc limit may be implemented according to the
Division’s Action Level Policy. Monitoring requirements will be reduced to semi-annual due to the very good toxicity recordfor zinc are consistent with 15A NCAC 2H .0508 (d).

Dioxin – Based on the Division’s analysis of self-monitoring data, this discharge does not pose a reasonable potential to cause a violation of the North Carolina stream standard for
dioxin. However, the dioxin limit will be maintained because of the EPA requirement. Effluent monitoring will be reduced to annual because the facility had no dioxin detection in it’s
effluent since 1989. Currently, Blue Ridge Paper is required to monitor dioxin and dibenzofuran isomers from the influent, sludge, landfill leachate, and effluent. Based on an evaluation
of the data, the Division is recommending that the monitoring frequency in the draft permit be maintained

Annual dioxin fish tissue analysis shall continue through 2009 in accordance with the recommendations of the Division’s biologists.

Permitting Rationale – Oxygen Consuming Waste Pollutants

Oxygen Consuming Waste Pollutants

A site-specific Best Available Technology (BAT) based limit was calculated for the 2001 permit to determine the monthly average 5 - day biochemical oxygen demand (BOD5) limit. A site-specific
BAT approach was used because North Carolina’s Division of Water Quality continues to agree that an economically feasible end-of-pipe technology capable of reliably meeting the water
quality limit specified by the existing model does not exist at this time and no violations of the dissolved oxygen standard in the river have been observed in recent years.

The North Carolina Division of Water Quality’s recommendation for the 2001draft permit BOD5 limit wasis established based on the demonstrated level of performance for the existing treatment
plant. Data on treatment plant performance and influent loading from the Canton Mill (1998 through 2000) was evaluated and examined for outliers. As indicated in the “Bleach Environmental
Process Evaluation and Report”, the performance of this mill is among the best in the world. The maximum influent loading and lowest treatment plant performance were used to develop
the monthly average BOD5 limit. The data set was sufficient to account for the day to day variability of the treatment system.

Over the time period evaluated, the treatment plant has performed extremely well. The lowest percent removal was 96.9% and the highest influent loading was 414.9 mg/L. Based on this
analysis, North Carolina’s Division of Water Quality recommends to retain a monthly average BOD5 loading of 3205.0 lbs/day in the draft permit.

The limit presented in the draft permit represents and a 71-ton per year reduction in BOD5 loading to the Pigeon River. Because Blue Ridge Paper has oxygen injection facilities in place
to maintain the instream dissolved oxygen standard should instream dissolved oxygen dictate a need, Blue Ridge Paper complies with the conditions set forth by 40 CFR 125.3 (f).

The methodology used for the daily maximum 5 - day biochemical oxygen demand (BOD5) limit was developedrecommended during the 1997previous permit cycle. A site-specific daily maximum
to monthly average multiplier was used for determination of the recommended daily maximum limit. Using this methodology and reviewing data since the Canton Modernization Project (1998
– 2/2001) the recommended daily maximum limit was based on a multiplier of 3.4 (daily maximum/monthly average) is 10897 lb/day. The limit proposed represents an achievable level and
approximately a 12.5% reduction in the daily maximum BOD5 limit.
The draft Permit retains the existing BOD5 daily maximum limit. BOD

Limits for BOD have been converted to secondary treatment standards since the facility now primarily treats domestic wastewater.

Ammonia monitoring requirements are retained inincluded in the draft permit to provide data concerning levels of ammonia discharged to the Pigeon River (which may affect instream dissolved
oxygen).

Effluent dissolved oxygen is limited at no less than 6 mg/Ll based on the above discussion. Daily monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products, Class
IV facility.

Chemical Oxygen Demand (COD) monitoring is required to assess the potential impact of chemical oxygen demand from the Blue Ridge Paper wastewater effluent. Neither federal effluent
guidelines nor North Carolina water quality standards require a limit for COD. Though no limit is proposed, the EPA has reserved COD for potential future limits. Therefore, COD monitoring
will be continued.

Permitting Rationale – Nutrients

Nutrient Pollutant Analysis

Total phosphorus and total nitrogen monitoring is required by 15A NCAC 2b .05008 (d) (2) (A). Monthly monitoring is required to assess the contribution of nutrients from Blue Ridge
Paper and the potential impact to Waterville Reservoir.

Waterville Reservoir is to be monitored once annually (during opposite years of CP&L’s montioring) to assist in the continued characterization of nutrient impacts to the lake.

Toxicants

Permitting Rationale –Conventional Pollutants

There is currently a fish consumption advisory due to dioxin for the Pigeon River downstream of the discharge. Although the advisory was initially in effect for consumption of all fish
species, this advisory has been reduced to carp and catfish species only, reflecting continued improvements in the river.

Currently, Blue Ridge Paper is required to monitor dioxin and dibenzofuran isomers quarterly from the influent, sludge, landfill leachate, and effluent. Based on an evaluation of the
data, the Division is recommending a revision to the special condition requiring dioxin and dibenzofuran isomers monitoring. An improved knowledge of the dioxin and dibenzofuran isomers
indicates that only 2,3,7,8 TCDD and 2,3,7,8 TCDF are pollutants of concern. Therefore, it is recommended that the dioxin isomer special condition be modified to require monitoring
only for 2,3,7,8 TCDD and 2,3,7,8 TCDF.

It is further recommended that the monitoring frequencyies be modified based on the fact that measurable quantities of dioxins and dioxin isomers have not been detected in the influent
(since 1997), the effluent (since 19961989), sludge (since 1996) and the landfill leachate (since 1996).

The effluent limit for 2,3,7,8 TCDD has been reduced. During North Carolina’s development of the Total Maximum Daily Load for Dioxins on the Pigeon River, the EPA commented that the
chronic standard adopted by North Carolina should be applied as an effluent limit at the end of pipe. North Carolina did not agree with this methodology, since it is inconsistent with
the standard and North Carolina rules. In addition, the
management strategy implemented by North Carolina to address dioxins in the Pigeon River for several years and the data show that this management strategy is resulting in declining dioxin
levels in the Pigeon River. The EPA, NC DWQ and Blue Ridge Paper agreed that the TMDL requirement could be waived as long as Blue Ridge Paper’s effluent was limited at 0.014 pg/L.
Therefore, the dioxin limit has been reduced to 0.014 pg/L and no TMDL will be developed.

Annual fish tissue analysis shall continue to be performed by the facility in accordance with the monitoring plan approved by the Division until such time that the fish advisory is lifted
in both Tennessee and North Carolina, according to North Carolina’s delisting procedures.

Trichlorophenol/Pentachlorophenol limits and monitoring are not required. The permittee has certified that chlorophenolic biocides are not used at the facility. This certification
eliminates the requirement to include effluent limits for these two parameters based on 40 CFR 430. However, if the facility changes future operations to include chlorophenolic biocides,
limits and monitoring will be required.

Other Pollutants of Concern

The total suspended solids (TSS) limits were calculated using the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category - 40 CFR 430 Subpart B
and compared to existing limits . The TSS limits contained in the current NPDES permit are more stringent than the calculated federal effluent guidelines since the current limits are
based have been converted to secondary treatment standards since the facility now primarily treats domestic wastewater.
on the 1993 proposed guidelines for the oxygen delignification process. The Division recommends that tThe existing TSS limits remain unchanged for this permit renewal.cycle.

North Carolina does not have a numeric standard for TSS. The rules specifically regulate floating solids, settleable solids, and sludge deposits [ref. 15A NCAC 2B .0211(3)(c)]. The
draft permit restricts floating solids. Both benthic and IBI studies have indicated further improvement to the Pigeon River. Therefore, a monthly average TSS limit of 12,549 lbs/day
is recommended and a daily maximum TSS limit of 49560 lbs/day is recommended.

Daily monitoring is required based on 15A NCAC 2B .0508 (d), Class IV facility.

The temperature requirement is based on the State Rules a Section 316 (a) temperature variance determination issued by the NC Environmental Management Commission October 11, 1984 and
approved by EPA August 6, 1985.per 15A NCAC 2B .0200.

In making the recommendation to retain the current 316(a) temperature variance, DWRQ staffcientist evaluated Blue Ridge Paper’s Balanced and Indigenous Species Report and concluded that
temperature was could not be identified as prohibiting a Balanced and Indigenous population. In addition, DWRQ staff reviewed existing temperature data and concluded that although
some improvement in the instream temperature has occurred (most likely due to overall effluent flow decrease, associated with process improvements reducing temperature impacts), Blue
Ridge Paper still cannot meet the North Carolina temperature requirement as indicated in Figure 2 above. Therefore, DWRQ is recommending that the 316(a) temperature variance continue,
with Blue Ridge Paper conducting a Balanced and Indigenous Species Study prior to the next permit renewal.

The flow limit is based on Blue Ridge Paper's current flow values and post-CMP production, and includes plus 0.9 MGD for the Town of Canton's wastewater. Future plant improvements may
reduce the contribution of the mill’s wastewater, however the Town of Canton is proposing to increase their contribution to the treatment plant as they expand Canton’s municipal boundary.

Since flows are currently approximately 80% of the permitted capacity, tThis flowe Division recommends that the flow limit remains unchanged. During the next permit cycle the flow
limit should be re-evaluated and if appropriate adjusted. Due to potential inflow/infiltration from the Town of Canton, the Division continues the provision that requires Blue Ridge
Paper to work with Canton to reduce I/I problems.

Chemical Oxygen Demand (COD) monitoring is required to assess the potential impact of chemical oxygen demand from the Blue Ridge Paper wastewater effluent. Neither federal guidelines
nor NC water quality standards require a limit for COD. Though no limit is proposed, the EPA has reserved COD for potential future limits. Therefore, COD monitoring will be continued.

Limitations for fecal coliform are based on the contribution of domestic wastewater from the Town of Canton and the requirements of 15A NCAC 2B .020011 (b) (3) (E).

Metals toxicity is a function of water hardness, since Blue Ridge Paper has demonstrated reliable compliance with toxicity, the Division recommends the elimination of hardness monitoring.

Conductivity monitoring is required based on 15A NCAC 2B .05008 and remain unchanged until the new owner determines the type of wastewater that will be treated. (d), Paper and Allied
Products (Water Quality Limited Facilities), for a Class IV facility.

Monitoring for total residue/total dissolved solids is required according to the existing NPDES permit. The required conductivity monitoring is sufficient to assess Blue Ridge Paper’s
inorganic loading to the Pigeon River. Therefore, the Division recommends removal of total residue and total dissolved solids monitoring from the permit.

Limitations for pH 6.0 –9.0 are based on 15A NCAC 2B .020011 (b) (3) (G).

Toxicity Testing
(15A NCAC 2B.0200 and 15A NCAC 2B.0500)

Current Requirement: Outfall 001 – Chronic P/F @ 90% using Ceriodaphnia Dubia
Recommended Requirement: Outfall 001 – Chronic P/F @ 12.7% using Ceriodaphnia Dubia.

This facility failed 4 toxicity tests in 2023. However, the subsequent tests passed, please see attached. All tests conducted in 2020, 2021, 2022, and 2024 passed.

For the purposes of the permitting, the permitted flow was used in conjunction with the 7Q10 summer flow to calculate the percent effluent concentrations to be used for WET tests for
each facility.

Permitting Rationale – EPA Effluent Guidelines

Issues Associated with Effluent Guideline Implementation
Relevant Background Information
Over the past five-year permitting cycle, the maximum 12-month production occurred from May 1999 through April 2000. Table 3 outlines the total production of various products generated
at the Canton Mill over this time period.
Pulp produced at the Canton Mill is supplemented with pine and hardwood pulp purchased from off-site and pulp produced from trim or broke paper off the paper machines. The pulp is then
used in paperboard and fine paper production using one of the four paper machines on-site.
Table 3. Itemized Production Figures for the Maximum 12 Month Average Production Period.
Product
Total for 12 Month Period
Units


Pine Pulp
217,634.48
Air Dried Tons

Hardwood Pulp
298,833.91
Air Dried Tons

Purchased Pine Pulp
24,306.87
Air Dried Tons

Purchased Hardwood Pulp
22,252.21
Air Dried Tons

Broke Paper or Trim Pulp
46,559.08
Air Dried Tons

Paperboard Production
313,625.90
Off Machine Tons

Fine Paper Production
321,264.00
Off machine Tons

The facility is subject to the Cluster Rules (40 CFR 430 Subpart B). The Pulp and Paper Cluster Rule was established by EPA to protect human health and the environment by reducing toxic
releases to the air and water from U.S. pulp and paper mills.

Blue Ridge Paper has not joined the Voluntary Advanced Technology Incentives Program (VATIP) for existing direct or new direct dischargers as outlined in 40 CFR 430 Subpart B. The VATI
Program was set up for new or existing direct dischargers whereby mills agree to accept enforceable effluent limitations and conditions in their NPDES permits that are more stringent
than the BAT limitations, in exchange for regulatory and enforcement related rewards and incentives.

Blue Ridge Paper will use steam stripping to treat process condensates, rather than hardpiping to the WWTP; thus interface with the Division of Air Quality is not necessary.

Adsorable Organic Halides (AOX). WeeklyRelevant Issues

Daily effluent monitoring and limits for Adsorable Organic Halides (AOX) is required. AOX is an overall test for adsorbable organic halides, which includes chlorinated organics. Trends
in concentration changes have been observed between AOX and specific pollutants (dioxins, chlorinated organics) at pulp and paper mills. Therefore, any decrease in AOX may also indicate
a decrease in chlorinated organics. Limits and daily monitoring for AOX are required in the EPA Cluster Rules. The cluster rules are the combined air and water rules issued by the
EPA for the pulp and paper industry. The compliance/monitoring point for the AOX limits shall be as defined in the sampling plan.

During the next permit cycle, the Division will review the AOX data for possible reduction in monitoring frequencies.

Chloroform. Chloroform monitoring/limits for bleach plants have been recalculated for the proposed added to the permit. During the previous permitting cycle, it was determined that
the discharge from Blue Ridge Paper did not have a reasonable potential to exceed the allowable level. Therefore, no effluent limit is proposed. Limits contained in the NPDES permit
on the bleach plant effluent are based on the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category. Since Blue Ridge Paper operates two separate
fiber lines, there shall be two compliance points for chloroform as stipulated in the sampling plan.

Dioxin. In addition to the dioxin limits and conditions stated in the “Permitting Rationale – Toxicants” section, above, dioxins shall be limited and monitored on the effluent from the
each bleach plant. 2,3,7,8 TCDD and 2,3,7,8 TCDF limits are based on the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category. The compliance/monitoring
points for each bleach plant is required as stipulated in the sampling plan.

Chlorinated Phenolics. Per 40 CFR 430.24, the daily maximum limits for 12 chlorinated phenolics are "less than Minimum Level" (<ML as specified in 40 CFR 430.01.

Trichlorophenol/Pentachlorophenol limits and monitoring are not required. The permittee has certified that chlorophenolic biocides are not used at the facility. This certification
eliminates the requirement to include effluent limits for these two parameters based on 40 CFR 430. However, if the facility changes future operations to include chlorophenolic biocides,
limits and monitoring will be required. Limits for these parameters were recalculated to reflect the current level of the production (please see attached).

Best Management Practices (BMPs) requirements have been added for spent pulping liquors, turpentine, and soap have been maintained in the permit. At this time, Blue Ridge Paper is in
compliance with the best management practices stipulated in the EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category.
with one remaining issue.

The remaining issue deals with the BMP Plan. As part of the EPA promulgated effluent guidelines, facilities, which fall under subpart B, must develop a BMP Plan. This plan does not
require the approval of any regulatory authority, but must be certified by the mill manager. Currently, the BMP Plan is in the development process and it is anticipated that this requirement
will be completed prior to issuance of this NPDES permit.

Per 40 CFR 430.24, the daily maximum limits for 12 chlorinated phenolics are "less than Minimum Level" (<ML) as specified in 40 CFR 430.01. The compliance/monitoring point shall be
set at the effluent from the bleach plants as outlined in the sampling plan.

Blue Ridge Paper has not joined the Voluntary Advanced Technology Incentives Program (VATIP) for existing direct or new direct dischargers as outlined in 40 CFR 430 Subpart B. The VATI
P program was set up for new or existing direct dischargers whereby mills agree to accept enforceable effluent limitations and conditions in their NPDES permits that are more stringent
than the BAT limitations, in exchange for regulatory and enforcement related rewards and incentives.

Blue Ridge Paper will use steam stripping to treat process condensates, rather than hard piping to the WWTP; thus interface with the Division of Air Quality is not necessary.
SUMMARY - Proposed PERMIT Changes from the Current NPDES Permit
Section A. (8.) Requirements for Color Analysis and Compliance Special Condition of the permit has been updated in accordance with the latest EPA Technology Review Workgroup (TRW) recommendations.
Annual average color limit has been reduced from 42,000 lb/day to 39,000 lb/day in accordance with the latest TRW recommendations (Outfall 001), and will be reduced to 37,000 lb/day
based on the performance of the facility but no later than 4 years after permit effective date. See A. (8.) Color Analysis and Compliance Special Condition.
Monthly average color limit has been reduced from 55,000 lb/day to 52,000 lb/day (Outfall 001).
The daily maximum color limit of 105,250 lb/day has been added to the permit in accordance with the latest TRW recommendations (Outfall 001). This limit is based on the analysis of the
color discharge data from Outfall 001.
Section A. (12.) Waterville Reservoir Sampling Special Condition was removed from the permit due to the elimination of the Color Variance and all fish consumption advisories in North
Carolina and Tennessee. The application to remove the Color Variance has been filed.
Color monitoring at the following stations have been reduced to weekly (summer and winter) due to the improved stream conditions: DN5, DN6, BC, and DN7.
Chloroform limits have been recalculated to reflect the current production level (Outfalls 002 and 003).
Monitoring frequencies for chloroform have been reduced to quarterly (Outfalls 002 and 003).
AOX (adsorbable organic halides) limits have been recalculated to reflect the current production level (Outfall 001).
Monitoring frequency for AOX has been reduced to weekly (Outfall 001).
Pentachlorophenol and trichlorophenol limits have been recalculated to reflect the current production level (Outfall 001).

Low flow condition requiring that facility will not plan any outages during the low flow periods was added to the permit (Section A. (8.)).
The daily maximum limit for selenium was removed from the permit based on a statistical analysis of the effluent data (Outfall 001).
Monitoring frequency for selenium has been reduced to annual due to the removal of the limit (Outfall 001).
Monitoring frequency for pentachlorophenol has been reduced to quarterly (Outfalls 002 and 003).
The daily maximum limit for dioxin was re-calculated based on the average flow in the receiving stream. (Outfall 001).
Monitoring frequency for dioxin has been reduced to annual because this parameter was consistently below detection level during the past permit cycle. (Outfall 001).
Monitoring frequency for dioxin has been reduced to annual (Outfalls 002 and 003).
Monitoring for cadmium has been removed from the permit based on a statistical analysis of the effluent data (Outfall 001).
Monitoring for silver has been removed from the permit based on a statistical analysis of the effluent data (Outfall 001).

Rationale for Temperature Variance Renewal
Blue Ridge Paper submitted the latest Balanced and Indigenous Species Study on the Pigeon River in May of 2006. The study was conducted by the University of Tennessee. DWRQ biologists
have reviewed the report and concluded that continuance of the temperature variance is appropriate. Therefore, the Division of Water Quality is recommending continuation of the temperature
variance with reporting requirements consistent with the previous permits. The facility will be required to provide a new Balanced and Indigenous Species Study prior to the permit renewal.
Monthly average BOD5 limit reduced 71 tons per year to 3205 lb/day.
Daily maximum BOD5 limit reduced 12.5% to 10897 lb/day.
Toxicity testing concentration increased to 90%.
Removal of downstream fecal coliform monitoring with once per week upstream fecal monitoring.
Removal of instream BOD5 monitoring.
Removal of instream monitoring station 55.5.
Removal of instream monitoring station 53.5.
Reduce monitoring frequency at NC/TN monitoring station.
Eliminate mercury monitoring and limitation.
Add selenium limit.
Trichlorophenol/pentachlorophenol monitoring has been removed.
The upstream river mile marker now indicates that the upstream monitoring location is located at river mile 63.8.
The dioxin special condition has been modified to require 2,3,7,8 TCDD and 2,3,7,8 TCDF individual isomer monitoring and to reduce the monitoring frequency of the sludge and landfill
leachate.
The 2,3,7,8 TCDD effluent limit has been modified to 0.014 pg/L.
Two internal outfalls (002 and 003) have been added.
Removal of hardness monitoring.
Removal of total dissolved solids monitoring.
Removal of total residue monitoring.

An AOX limit and daily monitoring has been added to the permit per EPA Cluster Rules.
Dioxin, chlorophenolics and chloroform limits/monitoring have been added for the effluent from the pine and hardwood line bleach plants per EPA cluster rule.
The BMP special condition has been updated according to the requirements of the EPA Cluster Rule.
For color recommendations refer to the July 24, 2001, memo from the EPA Tech Team to the Technology Review Workgroup.

This fact sheet represents North Carolina’s recommendations. The Division will review all pertinent comments received during the public comment period and the September 6, 2001 public
hearing. After reviewing all public comments, the Director of the Division of Water Quality and the NPDES Committee of the Environmental Management Commission will make their recommendations.
Proposed Schedule for Permit Issuance
Public Notice Draft Permit, temperature variance, color variance and Public Hearing
August 3, 2001

Public Hearing
September 6, 2001



Additional Information
Canton Modernization Project
Prior to 1993, knotting hardwood brownstock was washed through one of two brownstock washer lines. After washing brownstock was screened using a two-stage fine screening process and
bleached in one of the two bleaching lines. The two bleaching lines were operated independently for ‘low’ brightness and ‘high’ brightness.
Since 1993, the hardwood fiberline has incorporated numerous modifications designed to increase mill performance from both an environmental and product quality standpoint. Currently,
the hardwood fiberline consist of two stage knotting followed by pre-oxygen delignification washers. After pulp is processed through the oxygen delignification unit, it is washed again
prior to the four stage pressurized fine screening. After screening, the pulp is bleached through one medium consistency bleach line.
Prior to 1992, pine (softwood) pulp was processed through one brownstock washing line prior to the two stage screening process. After screening, pulp was processed through one of the
two bleaching lines. Similar to the hardwood fiberline, the softwood fiberline bleaching was operated independently for ‘low’ brightness and ‘high’ brightness.
Like the hardwood fiberline, the softwood fiberline has incorporated numerous modifications in order to enhance product quality and environmental performance. Currently, the softwood
fiberline process consist of two stage knotting followed by a brownstock pre-oxygen delignification line. After the initial washing the pulp is processed through the oxygen delignification
unit followed by another washing. After the second washing pulp is screened using four stage pressurized fine screen before entering a medium consistency bleach line.
In addition to the improvements noted, the facility has implemented full scale bleach filtrate recycle of the pine bleach line and caustic extraction stage (Eo) recycle on the hardwood
bleach line.

References
Division of Water Quality’s Basinwide Information Management System, April 20, 2001, http://h2o.enr.state.nc.us/bims/reports/basinsandwaterbodies/alpha/Neuse.pdf
1995. NPDES Regional Staff Report for NPDES Permit NC0000272, January 18, 1995, Asheville Regional Office.
2000. French Broad River Basinwide Water Quality Plan. North Carolina Division of Water Quality, Water Quality Section.
2001. NPDES Permit Application EPA Forms 1 and 2C, Blue Ridge Paper Products Inc.
2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of Water Quality, Water Quality Section. Copies obtained through Planning Branch, Archdale Building,
512 N. Salisbury St., Raleigh, North Carolina.
1993. Low Flow Characteristics of Streams in North Carolina, United States Geological Survey Water-Supply Paper 2403. Copies obtained at U.S. Geological Survey, Map Distribution, Box
25286, MS306, Federal Center, Denver, CO 80225.
1997. NC0000272 NPDES Permit. Issued to Champion Paper, expiration November 30, 2001. Copies obtained through The Division of Water Quality, Central Files, Archdale Building, 512
N. Salisbury St., Raleigh, North Carolina.
2001. Bleach Environmental Process Evaluation and Report. Dr. Norman Liebergott, PhD, Liebergott and Associates Consulting, Inc. and Lew Shackford, June 8, 2001.
2001. Additional Color Removal Technologies and Their Economic impacts on Blue Ridge Paper Products, Canton, NC. July 25, 2001 Memorandum from EPA Tech Team to Technology Review Workgroup.
State Contact
If you have any questions on any of the above information or on the attached permit, please contact Michael Myers at [phone] ext. 508.
Name: Date:
NPDES Supervisor
Name: Date:

Color Variance Removal Rationale
[Platinum-Cobalt units]Blue Ridge Paper Plant
On July 13, 1988, Champion Paper was granted a variance from North Carolina's narrative water quality standard for color. The Color Variance was last renewed in 2001, and the variance
requirements were implemented as a Special Condition in the NPDES permit issued in 2001. A goal of this Color Special Condition was to achieve color reductions indentified by the TRW
and lay the foundation for removal of the Color Variance prior to the next permit renewal. Blue Ridge Paper is requesting removal of the Color Variance, based on improvements in effluent
color and instream conditions.

During the last 30 years Blue Ridge Paper has made significant improvements to the facility in order to reduce effluent color load and improve it’s overall environmental performance.
As a result, the annual average effluent color loading has been reduced from 380,000 lb/day in 1988 to 38,000 lb/day today (Fig. 2). Since 1997 the color in the effluent has decreased
from 60,000 lbs/day to 38,000 lbs/day.

In order to achieve this result, the mill has spent over $526 million in expenditures on environmental process improvement since 1990. One of the major accomplishments was development
of a unique technology – BFR (bleach filtrate recycling process). BFR removes color from the effluent. It was installed in 1998 at a capital cost of $30 million.

Fig. 2. Annual Average Effluent True Color
Blue Ridge Paper, 1988 through 2008

According to the latest report of consultant Dr. Liebergott (issued on July 7, 2006) the mill is ranked # 1 in the world in regards to the BOD, COD, and color removal. Dr. Liebergott
was originally hired in 2001 by the consortium of environmental groups to evaluate the facility for color reduction options. Dr. Liebergott also concluded, after evaluating data from
76 similar mills around the world, that BRPP is ranked # 2 in the world in regards to the TSS and AOX (adsorbable organic halides) removal.

During the period from 2001 through 2006 (last permit term) the mill spent almost $6 million dollars to undertake 35 separate color reduction initiatives. Some for these initiatives
were recommended by the TRW, and some of them were independently identified by the BRP staff.

During the last permit term the permit color limit was reduced from 48,000 lb/day to 42,000 lb/day. This draft renewal will require the end of the pipe limit of 39,000 lb/day, decreasing
to 37,000 lb/day after 4 years.

A biological study conducted by the University of Tennessee in 2005 concluded that the Pigeon River has a “balanced and indigenous fish community”. This study also found a diverse and
healthy macroinvertebrate community in the Pigeon River. Although, according to the North Carolina indicators, the benthic community in the Pigeon River is currently deemed “impaired”
and is listed on the state’s 303(d) list. The Division believes that this impairment is not caused by the color constituents in the mill discharge, it is likely
a combination of many factors. Scientific studies indicate that stream color concentrations below 100 color units have no effect on health of aquatic organisms (NCASI Special Report
9407, Human Perception and Biological Impacts of Kraft Mill Effluent Color, June 1994).

According to the information the Division received from the state of Tennessee, the River Run Walleye has returned to the Pigeon River. This is a very sensitive species that indicate
high water quality. The Pigeon River has also become a trophy smallmouth bass fishery and the number of rafters in Tennessee has increased from ~21,000 in 1995 to almost 150,000 in
2007.

Figures 3 through 5 demonstrate trends in the color conditions of the receiving stream. It is necessary to mention that the exceptional drought of 2007- 2008 made a significant negative
impact on the color conditions in the Pigeon River.

During the 3 years beginning December 2002, monthly average color at Fiberville (0.4 miles below discharge) has been 31 true color units. The exceptional drought that began in 2007 has
shifted the general downward color trend, and color values have increased substantially.

Monthly average color at HEPCO (20 miles below discharge) during the last Permit term beginning December 2001 has averaged 24 true color units.

Monthly average color at the North Carolina/Tennessee line during the last Permit term has averaged 17 true color units, which is significantly below the value that was interpreted by
EPA as the color water quality standard agreed upon by both states – 50 color units. Figure 5 indicates there is no significant difference between color concentration upstream of the
mill and at the state line. Review of the data for the period beginning on 01/01/2004 through 12/31/2008 indicates that monthly average limit of 50 at the state line was never exceeded,
there were only two daily maximum exceedences during extreme drought: 09/26/2007 – 52 color units, 08/27/2008 – 65 color units. This drought (2007-2008) was so severe that the water
flow in the Pigeon River was below 7Q10 for 6 weeks, and below 30Q2 for 32 weeks.

In order to evaluate the color compliance we need to review the color narrative water quality standard definition from the North Carolina Administrative code. 15A NCAC 2B.0211 Fresh
Surface Water Quality Standards for Class C Waters:

Oils, deleterious substances; color or other wastes: only such amounts as shall not render the waters injurious to public health, secondary recreation or to aquatic life and wildlife
or adversely affect the palatability of fish, aesthetic quality or impair the waters for any designated uses ….

Therefore, the narrative color standard consists of several components, and each of the components has to be evaluated:

Public Health - There has never been a public health advisory related to color in North Carolina.

2) Aquatic Life and Wildlife - The University of Tennessee biological study conducted in 2005 concluded that the Pigeon River has a “balanced and indigenous fish community in the Pigeon
River below the mill’s discharge”. The facility is also consistently passing WET tests during the last 5 years and for an extended time period before that. Therefore, the benthic macroinvertebrate
impairment is not believed to be associated with the color discharge.

Palatability of Fish – Color is not a parameter associated with fish palatability.

Secondary Recreation - Pigeon River in North Carolina continues to be used for secondary recreation. Division’s employees from the central office and the regional office have observed
people fishing below the discharge on numerous occasions.

5) Aesthetic Quality- NC has generally viewed color as primarily an aesthetic issue, and the interpretation of color as an aesthetic impact is subjective. Similar to odor issues, the
number of complaints received serves as one means to gage public perception of color impact. The NC DWQ regional office in Asheville has received only one color complaint in recent
years. Aside from actual color complaints, the most definitive color perception research on pulp mill color discharges has been conducted by Dr. Prestrude of Virginia Tech Department
of Psychology. His research was funded in part by the State of Tennessee, and included color perception studies in both Tennessee and North Carolina waters (Pigeon River). Prestrude
(July 1996) reported that the vast majority of persons participating in the research projects considered water quality color in the receiving stream as aesthetically acceptable in the
100-110 PCU color range. This instream color range is generally achieved by Blue Ridge Paper over the past seven years, except under extreme low flow conditions:

Instream Color at Fiberville (0.4 miles below Blue Ridge Paper discharge). Between CY2002-08, there were 64 of 592 individual instream samples (10.8%) that exceeded 100 PCU. The majority
of values exceeding 100 PCU occurred during extreme drought conditions in 2002 and 2007-2008, when instream flows fell below 30Q2 and sometimes below 7Q10. In more typical water years,
there were no individual values >100 PCU in 2003 and 2004, and only 1 value >100 PCU in 2005 and 2006.
Instream Color at HEPCO (20 miles below Blue Ridge Paper discharge). Between CY2002-08, there were 3 of 592 individual instream samples (0.5%) that exceeded 100 PCU.
Instream Color at NC/TN state line (38 miles below Blue Ridge Paper discharge). Between CY2002-08, there were 0 individual instream samples that exceeded 100 PCU. The instream color
at the state line was compliant with the 50 PCU instream color standard for 577 of 579 individual samples (a 99.6% compliance rate), despite extreme drought conditions and no consideration
for background color.

Based on actual instream color measured between 2002-08, DWQ believes that compliance with the effluent color limits established in the 2001 permit were protective of NC’s narrative
water quality color standard. Only under extreme drought conditions (below 30Q2/7Q10 flows) were instream color values reported to exceed the Prestrude aesthetic threshold of 100 PCU,
and NC regulations do not consider aesthetic color standards violated by the permittee when stream flows fall below 30Q2 design flow. Further downstream at the NC/TN state line, the
instream color limit of 50 PCU has been consistently met despite extreme low stream flows and no consideration of background color. DWQ believes the Draft 2009 permit, which proposes
even more stringent effluent color limits, will continue to be protective of NC’s narrative color water quality standard, as well as the 50 PCU color limit established at the NC/TN
line for protection of Tennessee’s color standard. In the future, NC DWQ will continue to evaluate aesthetic color impact based on color complaints received by the Asheville Regional
Office, in tandem with color perception guidelines established by the Prestrude color studies conducted in Tennessee and Pigeon River.

6) Designated Uses - The Pigeon River is classified as “Class C waters” - aquatic life propagation and survival, fishing, wildlife, secondary recreation, and agriculture. All designated
uses are currently being met, benthic macroinvertebrate impairment in some segments of the Pigeon River cannot be attributed to color discharges and is likely the result of habitat
degradation and NPS pollution.

Based on the evidence presented, the Division believes that the current discharge does not cause violation of the North Carolina Color Standard and the Color Variance should be removed
from the permit. The facility will continue to implement color reduction measures identified by the TRW. The facility will also continue to investigate feasibility of the new technologies
that will reduce color in the effluent and implement them (if economically achievable).

Additional Information
Canton Modernization Project
Prior to 1993, knotting hardwood brownstock was washed through one of two brownstock washer lines. After washing brownstock was screened using a two-stage fine screening process and
bleached in one of the two bleaching lines. The two bleaching lines were operated independently for ‘low’ brightness and ‘high’ brightness.
Since 1993, the hardwood fiberline has incorporated numerous modifications designed to increase mill performance from both an environmental and product quality standpoint. Currently,
the hardwood fiberline consist of two stage knotting followed by pre-oxygen delignification washers. After pulp is processed through the oxygen delignification unit, it is washed again
prior to the four stage pressurized fine screening. After screening, the pulp is bleached through one medium consistency bleach line.
Prior to 1992, pine (softwood) pulp was processed through one brownstock washing line prior to the two stage screening process. After screening, pulp was processed through one of the
two bleaching lines. Similar to the hardwood fiberline, the softwood fiberline bleaching was operated independently for ‘low’ brightness and ‘high’ brightness.
Like the hardwood fiberline, the softwood fiberline has incorporated numerous modifications in order to enhance product quality and environmental performance. Currently, the softwood
fiberline process consists of two stage knotting followed by a brownstock pre-oxygen delignification line. After the initial washing the pulp is processed through the oxygen delignification
unit followed by another washing. After the second washing pulp is screened using four stage pressurized fine screen before entering a medium consistency bleach line.
In addition to the improvements noted, the facility has implemented full scale bleach filtrate recycle of the pine bleach line and partial caustic extraction stage (Eo) recycle on the
hardwood bleach line.
Proposed Permit Changes

The following changes have been made due to the cessation of all manufacturing processes:
The limits and/or monitoring for the following compounds at Outfall 001 have been eliminated: 2,3,7,8-Tetrachloro-dibenzo-p-dioxin, Trichlorophenol, Pentachlorophenol, Adsorbable Organic
Halides, Chemical Oxygen Demand, Total Copper, and Total Zinc.
Mass color limits and instream color limits have been eliminated.
The flow limit was reduced to 4.9 MGD.
Instream Waste Concentration for toxicity test was reduced to 12.7%.
Internal Outfall 002 and Internal Outfall 003 have been eliminated.
Instream Sampling at the following locations has been eliminated: UP (upstream), DN2 (Downstream 2), DN3, DN4, DN6, BC, DN7.
Frequency of instream sampling at DN1 has been reduced to weekly for the following parameters: Temperature, DO, Conductivity, and Color.
Dioxin Monitoring Special Condition has been eliminated.
Clean Water Act Section 316(a) Thermal Variance Special Condition has been eliminated.
Best Management Practices Special Condition has been eliminated.
Effluent Guideline Sampling Plan Special Condition has been eliminated.
The requirement for Color Analysis and Compliance Special Condition has been eliminated.
Dissolved Oxygen Special Condition has been eliminated.
Limits for BOD and TSS have been converted to secondary treatment standards since the facility now primarily treats domestic wastewater.

Engineering Alternative Analysis Special Condition was added to the permit to assure that the new owner has a justification for the permitted flow volume in accordance with the state
rules.
Major Modification Application Special Condition was added to the permit to assure that the potential new waste streams comply with the state rules.

Public Notice

Proposed Schedule for Permit Issuance
This fact sheet represents North Carolina’s recommendations. The Division will review all pertinent comments received during the public comment period and the public hearing. After
reviewing all public comments, the Director of the Division of Water Quality and the NPDES Committee of the Environmental Management Commission will make their recommendations.

Public Notice Draft Permit, temperature variance, color variance and Public Hearing


Public Hearing


Permit to Public Notice: 07/23/2024

Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following the publication date of the public notice. Any request for a public hearing shall
be submitted to the Director within the 30-day comment period indicating the interest of the party filing such request and the reasons why a hearing is warranted.

State Contact

If you have any questions on any of the above information or on the attached permit, please contact Sergei Chernikov at (919) 7807-6393.Regional Office Comment

Regional Office Reviewer
Name: Date:
Regional Supervisor
Name: Date: 3606 or [e-mail].

Changes in the Final Permit

The requirement to complete EPA Form 2C within 180 days from the permit effective date was added to the permit to conduct secondary evaluation of treated groundwater addition to the
facility’s effluent. This change was made in response to the comment from the SELC.
The wastewater description was updated in response to the comment from the Town of Canton.
The recovered treated groundwater was added to the list of authorized waste stream in response to the request from the permit holder and after a new statistical evaluation of the effluent.
The upstream sampling for fecal coliforms and DO was restored in the permit in response to the comment from the Town of Canton.

The influent sampling for fecal coliforms was added to the permit to determine the cause of fecal coliform violations.
Semi-annual PFAS monitoring was added to Outfall 001 based on the EPA Guidance.