Ver _Complete File_19880205 (2)

*1 - uw. ,
State of North Carolina _
aural Resources and Communi Develo ment
division of Environmental Management
Salisbury Street • Raleigh, North Carolina 27611
February 5, 1988
R. Paul Wilms
Director
Mr.'aBr a Barrett, Director
Water Management Division Fit
U.S. Environmental Protection Agency F?eB
Region IV
345 Courtland Street S-C
Atlanta, GA 30365;; R-•?,;. Cjj' 1
Subject: Water Quality Certification
Draft NPDES Permit
Champion International Corp.
Canton Mill
Haywood County
Dear Mr. Barrett:
In response to
your requests dated December 1 and
December 8, 1987, the Division of Environmental Management
has reviewed EPA's most recent draft of Champion's Canton
Mill NPDES Permit and supporting materials. In accordance
with the provisions of rules for processing Water Quality
Certifications contained in 15 NCAC 2H .0500, we published
public notice of your request for Certification on January
14, 1988.
Conditions of the EPA draft permit are sufficient to
assure compliance with Section 208(e), 301, 302, 303, 306,
and 307 of the Clean Water Act. The only additional
conditions which are recommended are relative to future
guidelines for dioxin. We recommend that dioxin be
monitored on a periodic basis in the Champion effluent and
that a specific reopener clause for dioxin be included in
the permit which will allow permit modification to
incorporate effluent limitations and/or strategies as
guidance is developed and adopted by EPA for dioxin in
effluents of this type. With the inclusion of these
conditions relative to dioxin, the draft NPDES permit is
hereby certified to assure compliance with Sections 208(e),
301, 302, 303, 306, and 307 of the Clean Water Act.
Pollution Pre"ho» Pays
PO. Box 27687, Rakigh, Nor+ Grohna 27611-7687 Tekphom 919-733-7015
I
It' .
Mr. Bruce Barrett
Page Two
February 5, 1988
In keeping with your request we-have determined that
-- --sever--ai--cond3?ions of the draft permit may be m5-36--ress
stringent without violating the requirements of StatW law,
including Water Quality Standards. These are as follows:
1. tToxicity - Effluent toxicity limits should be
based upon 7-day, 10-year low flow or minimum
instantaneous flow for Pigeon River considering
effects of flow releases from Lake Logan which.A_s__?, _
controlled by the Permittee. Continued chronic
effluent testing by Champion should be required to
establish the minimum instantaneous flow which
must be maintained from Lake Logan sufficient to
provide an instream wastewater percentage at which
chronic toxicity will'be prevented. [15 NCAC 2B
.0206(a)(4)]
2. Chloroform - The proposed chloroform limit appears
to be based on EPA's 1985 criteria .. documentandc;, .2
EPA's Technical Support"l5ocument.&- Water Based
Toxics Control. The limit is based on the 10
risk level and a 30-day, 5 year (3005) low flow.
We are presently evaluating protection of human
health via the fish consumption exposure route as
a part of our triennial review of water quality
standards. At present, we see no justification
for use of a 30Q5 low flow and feel a mean annual
flow is more appropriate to protect human health
over-the long term. Also, we have not made a
decision on whether 6.5 gm. fish/day used by EPA
in calculating criteria is an appropriate
co_n6sumption rate. We do concur with the use of a
10 risk level. Because we are still working on
this issue, we recommend no specific limit on
chloroform at present and Champion should be
required to further evaluate chloroform in their
effluent and in fish tissue in the river. A
reopener clause could be included to add any
limits appropriately based on study results or the
outcome of the triennial review. Alternatively, a
chloroform limit could be included in the permit
but should be based on mean annual flow rather
than 3005 low flow.
3. Dissolved Oxygen Augmentation - The limitation in
Part III C. (2 c) that requires a minimum of 8.2
mg/1 dissolved oxygen in the Pigeon River at river
mile 55.5 is unsupportable under our Water Quality
Standards. While additional evaluation of the
effects of the Waynesville discharge upon
s ?
,w
Mr. Bruce Barrett
Page Three-
February 5, 1988

dissolved oxygen in the river is needed, the
"requirement for additional augmentation by
Champion to meet 8.2 mg/1 at mile 55.5 is not
clearly--demonstrated without further study. The
requirement for 8.2 mg/1 of dissolved oxygen could
_ b d i a..and substituted by a requirement that
Champion perform an evaluation of the influence
-and relative contributions of oxygen-demanding
materials from the mill and downstream dischargers
and possibilities of additional dissolved oxygen
augmentation to assure compliance with the
dissolved oxygen standard of 5.0 mg/1 daily
average concentration and an instantaneous value
of no less than 4.0 mg/1 in.-the entire reach of
the river affected by the discharge [2B .0211
(b) (3) (B) ] . We agree with the intent of the
requirement, but believe more information is
needed about factors affecting dissolved oxygen
and kinetics associated with super-saturated.
oxygen addition:. -.f
4. Color - The draft permit requirements for color
are inconsistent with our interpretation of North
Carolina Water Quality Standards. Color
requirements in the permit should be revised to
coincide with the requirement of Permit No.
NC0000272 issued by this Division on May 14, 1985,
Part III.F. (Color Removal). That requirement of
the State-issued permit reflects the Environmental
Management Commission (EMC) interpretation of 2B
.0211 (b) (3) (F) .
The interpretation of this standard as a number
was not contemplated by the EMC during the
proceedings leading to adoption of this standard.
If you object to this interpretation, we maintain
that it is most appropriate to disapprove our
standard rather than re-interpreting our standard.
However, in order to cooperate in a resolution of
this issue, we are prepared to consider Champion's
request for relief from EPA's interpretation of
our narrative standard.
5. Compliance Schedule - The compliance schedule for
meeting color and chloroform limitations should be
deleted from the permit based upon the comments
already made concerning these limitations.
e° O J i
Page Four
February 5, 1988
This Certification is being issued consistent with therequirements of 40 CFR 124.53 and with your request of
December 1, 1987. We have responded to all points of your
request and do not waive any of o.u=...xAQhts -te---cert+fication
or object to any conditions or limitations which are
contained in either the current or future versions of the
draft EPA permit. If you have questions regarding this
matter, please contact me.
XR 'c e ,
S. P ul Wilms
cc: Steve;!Tedder
Forrest Westall
,,,ME
FROM: R. Paul Wilms, Director
Division of Environmental
.rte
TO:
Ago"
,. r
Date:.?,j C • 0
Subject:
awwot
North Carolina Departme
? s
Resources & Communit
y? ulxl vy y
QWMVM'
?b
nt of Natural
Development
A Tt
Permit No. NCOOO0272
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
343 COURTLAND STREET
ATLANTA. GEORGIA 30765
A MRIZATICN Tn DISCHARGE UNDER THE
NAT aiAL POLUMANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Clean Water Act, as amended (33
U.S.C. 1251 et seq. the "Act"),
Champion International Corporation
ChaQrpion Papers Division
is authorized to discharge from a facility located at
Main Street
- Canton, North Carolina
to receiving waters named
the Pigeon kiver
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth herein. The permit consists of this cover sheet, Part
I 4 page(s), Part II 15 page(s) and Part III 3
Page(s).
This permit shall beoome effective on
This permit and the authorization to discharge shall expire at midnight,
K, . fit
LOF.F
N O V 3 0 1987
Date Signed Bruce R. Barrett, Director
Water Management Division

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Part I
-.-Page- I-2
Permit No. N00000272

2• T monthly average instream temperature measured at a
-- --downstream of the discharge point 0.4 miles
months of July, rge location shall not exceed 32.0°C during the
The and shall not exceed 29.0°C during
the months of October th?rough June. September
tore measured at this location shall monthly average instream telqpera_
not exceed the monthly average
instream temperature of the upstream monitoring location by Here than
13.9°C.
3. The concentration of dissolved oxygen
than 6.0 mg/1. in the effluent shall not be less
4. The effluent pH shall not be less than 6.0 standard units or greater
than 9.0 standard units. n

5• (a) Monitoring requirements for
Influent and effluent shall be mo appant
once color are as follows:
sample. Per day by a composite
(b). 7be, __discha
sWl not cause apparent color in the Pi
exceed 30 Platinum geon River to
Cobalt color units downstream of the discharges..
CORPlianoe with this permit condition will be measured in the
following manner:
The downstream apparent color value will be calculated by the
following equation:
Downstream-
_
Qdischarge Effluent
Color Value
X
upstream Color Value
where 4lischarrge s effluent flow (in mgd)
Qupstream - Pigeon River flow (in mgd) at river mile
63.5 (upstream of the point of discharge)
If the calculated downstream apparent color value exceeds 50 Platinum
Cobalt color units, then an analysis for true color must be performed
on the effluent sample gathered for that day. Using this effluent
true color measurement, a value for the
downstream be calculated based on the above n. I true color value
downstream true color value exceeds 50 Platinum Cobalt color units,
this represents a violation of this permit.
(c) The method of analyses used to measure color shall be Method 204A of
Standard Methods for the Examination of Water and Wastewater, 1985,
6th Edition, or an alternate method approved by the
regulatory authority. permit issuing/
Part I
Page I-3
Permit No. N00000272
6. The no effect chronic level (NOEL) of the discharge shall not be less
than the instream waste concentration (IWC) expressed as a percent value.
The no effect chronic level shall be determined utilizing an acceptable
biaronitoring procedure developed under Part III C, Item 1, on Page III-2
of the permit. The IWC for each sampling period shall be calculated by
dividing the average discharge flow by the average instream flow downstream
of the outfall. For each case, the average flow shall be calculated-as a
seven day average flow, with-the di+y` of actual sanple collection being
the fourth day of a seven consecutive day averaging period. Instream
flow shall be estimated using data from the gaging station located at
river mile 63.5 (at the point of sampling to meet the requirements of
"upstream" monitoring on Page I-1 of this permit).

7. Where composite sanples are specified in the monitoring requirements of
this permit, a 24 hour composite sample is required.
B. SCI EWLE AF -,ODMPi:IANCE
1. The permittee shall achieve conpliance with the effluent limitations
specified for discharges in accordance with the following schedule:
a. The effluent limitations for color and chloroform shall became
effective in accordance with the following schedule:
Date
(1) Effective Date + 6 months
(2) Effective Date + 1 year
(3) Effective Date + 18 months
(4) Effective Date + 2 years
Required Action
Status Report
Status Report
Status Report
(a) Status Report
(b) Begin pilot wastewater
treatment studies
(5) Effective Date + 30 months
(6) Effective Date + 3 years
(7) Effective Date + 42 months
Status Report
Status Report
Status Report
i

Part I
Page-_.h4
Permit No. N00000272
(8) Effective Date + 4 years
(a) Status Report
(b) Select treatment alternative
(9) Effective -Draite_+
- W-"Mths Status Report
(10) Effective Date + 5 years
Achieve oortPlianos with
effluent limits for color
and chloroform
b. The effluent limitations for all other
shall become
Parameters upon the effective date of this Permit.
permit. 3
2. No'later than 14 calendar d
above schedule of ?Qlianoe,s hollering a date identified in the
r'aP't of progress or in the-Pe?ittee shall submit either a -
by identified dates a case of specific actions being required
In the latter ' written notice of OO nplianPg=?m noncompliance. T
-,
case... the notice
sha, include the causeof non-
medial=aetions
scheduled ' and the Probability of meeting O0"?liance,
requirement. y the next
?... n .. _ PART III
Page III-2
Permits NC0000272

C- Special ()onditions
1. The pemittee is required to develop a Plan of Study and conduct appropriate
effluent toxicity testing in order to measure conplianoe with Item 6 on
Page I-3 of the permit. All test organisms, .procedures, and quality
assurance criteria used shall be in accordance with "Short-term Methods
for Estimating the Chronic Toxicity of Effluents and Receiving Waters to
Freshwater Organisms," EPA-600/4-85-014, or other methods approved by
EPA. Chronic toxicity testing will be required for two test organisms;
testing will be used to determine the effects of the effluent on survival,
reproduction, and/or growth of the test organisms. The requirements for
two test organisms may be waived upon adequate determination of the more
sensitive test organism. This determination shall include an analysis of
the testing results from at least four toxicity tests required by this
permit. For the period of one year following initiation of the tests,
toxicity testing will be conducted once per month during July, August and
September, and once every quarter for the remainder of the year. After
the first year of testing, toxicity testing will be conducted once every
six months for the duration of the permit. One of these tQxoty
tuts
kill-be Conducted during the months of Jul. _ AuM - "t
Y• 9? . _ 9r September. If
_
any one test ,indicates that_the-NOEL is less than the IWC for a specific
sampling period= a tcry °toxicity test using the specified,method-
1ogy?7 " tkie sage test species shall be conducted within 2 weeks. If
this confirmatory test indicates that the NOEL is less than the IK for
the confirmatory test, this will constitute a violation of the permit.
In the event a violation of the toxicity limit results in an enforcement
action, any different or more stringent monitoring requirements imposed
in that enforcement action shall apply in lieu of this permit condition
for whatever period of time is specified by EPA in the enforcement action.
The permittee shall submit the Plan of Study to EPA within sixty (60)
days of the effective date of this permit. The EPA will review the Plan
of Study within thirty (30) days of its receipt and, upon approval, the
Plan of Study will became an enforceable part of this permit. Toxicity
testing shall commence no later than one-hundred and twenty (120) days
after the effective date of this permit.
2. The permittee is required to operate oxygen injection facilities at the
outfall structure, at 0.9 miles downstream of the discharge, and at 2.1
miles downstream of the discharge. These facilities shall be operated in
a manner which will maintain the water quality standard for dissolved
oxygen in the Pigeon River downstream of the discharge.

The Permittee shall monitor the Pigeon
of the discharge. The locations ofinstream monitoring stations show as
miles upstream of the confluenoe with the French Broad River) are listed
below:
River Mile
62.9
57.7
55.5
53.5
48.2
42.6
3.
Monitoring requirements for this sampling program are specified below:
a) Sampling for dissolved oxygen and t
shall be conducted once
per week for all stations. A minimum of two
for dissolved oxygen and sariQles shall be collected
at each sta.tion_for each day
sanples are"`?llected: The _ . _. ,
svnPe type for iristream dissolved n-
and temperature monitoring is "grab." xY9en
b) Monitoring for five day biochemical oxygen demand (HODS) shall be
conducted once per week for all stations. The sample type for instream
BOD5 sanples is "grab."
c) Average daily flows shall be measured at river mile 55.5.
Limitations to measure conpliance with the requirements of this special
condition are as follows:
a) The average daily dissolved oxygen concentration measured at river
mile 62.9 and 57.7 shall not be less than 5.0 mg/1 and the instantaneous
minimum dissolved oxygen concentration shall not be less than 4.0 mg/1.
b) During periods in which the flow at river mile 55.5 is equal to or
greater than 100 cfs, the average daily dissolved oxygen concentration
measured at river mile 55.5 shall not be less than 5.0 mg/l and the
instantaneous minimum dissolved oxygen concentration shall not be
less than 4.0 mg/l.
C) During periods in which the flow at mile 55.5 is less than 100 cfs,
the average daily dissolved oxygen concentration measured at river
mile 55.5 shall not be less than 8.2 mg/1.
3. Within 60 days after the effective date of this permit, the permittee
shall submit a study plan acceptable to EPA to further evaluate the
levels of chloroform in the effluent and the fate of chloroform in the
Pigeon River downstream of the discharge. The EPA will review the study
plan within thirty days of its receipt and, upon approval, the study plan
will becam an enforceable part of this permit.
?
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INVOICE-STATEMENT ACCOUNT NUMBER PAGE NM
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©?
Administrative Ssrvices Section
6
EVE
h?a ,J
B???f7 ? IYfF;
NRCp A?EMENT
PREVIOUSBALANCE PAYMENTS Moo. MWICREDIT . PAST DINE BALANCE CURRENT CHARGES - LATE CHARGE NEW BALANCE
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ADVERTISER, WITHIN TEN (10) DAYS FROM THE MAILING OF SAID STATEMENT NOTIFIES PUBLISHER IN WRITING THAT SAME IS INCORRECT. A 1 %% LATE CHARGE WILL BE APPLIED
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ACCOUNT NUMBER 2 108 --- 1.63•-7
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A!
THE ASHEVILLE CITIZEN
ASHEVILLE CITIZEN-TIMES PUBLISHING COMPANY
THE ASHEVILLE TIMES
ASHEVILLE CITIZEN-TIMES
e,
AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
NORTH CAROLINA ss.
PUBLIC NOTICE
FORWATERQUALITY '
CERTIFICATION
The North Carolina Division of
Environmental mono emon
of the Department of Natura
Resources and Community
DevFilopcrlflnt ho3 received an
appp) cation from the U S. En-
viranmental Protection Agen-
YY Region I V, 345 Courtland
?Str ef, Atianta, ear lo, or a
Wager Quality Certlfica Ion,
purtSSUant tp Section 401 of the
Federo1 Clean Water`Acta3 iT
amended, for the draft
NPOES Permit proposed by
EPA for continued discharge
of treated wastewater by
Champion International Cor-
poration Into Pigeon Riverln
Canton Hayvwood County,
North G?arotino. The Water
Quality Certification is a
determination by the State
agency responsible for water
quality Protection that the pro-
posed permit by the Federal
agency will not cause violation
of water quality standards and
effluent limitations required
by Sectlons 301, 302 303, 306,
and 307 of the Clean V{later Act.
The public is Invited to Com-
ment on the application for
Water Quality Certification. A
copy off the application may be
Inspected at the Department's
office In Raleigh, Archdale
Building, 512 N. Salisbury
Street Room 904E or the Ashe-
ville Regional Office, Inter-
change Building, 59 Woodfln
Place, Asheville, N.C., during
normal work hours Com-1
ments must be submitted in)
writing no later than January!
29, 1988. Any comments should`
be addressed to the N.C. Dlvl-l
Sion of Environmental Man-
agement, Water Quallty Sec',.
Lion, P.O. Box 27687, Raleigh,;
N. C. 27611. Any questions re
garding the Application con be,
directed to Mr. W1111am Milis?
at [phone], Ext. 186.
R. Paul Wilms'
Director,
N.C. Division of
Environmental Management,
January 14, 1988 m
(4560) ,
ASHEVILLE, iioirrH CAROLINA 28802
Before the undersigned, a Notary Public of said County and State, duly
commissioned, qualified, and authorized by law to administer oaths, personally
appeared Sharon Brown
Who, being first duly sworn, deposes and says: that he (she) is
Classified Phone Room Supervisor
(Owner, partner, publisher, or other officer or employee authorized to make this affidavit).
of ASHEVILLE CITIZEN-TIMES COMPANY,
(Name of Publishing Concern)
engaged in the publication of a newspaper known as
The Asheville Citizen Times
(Name of Newspaper)
published, issued, and entered as second class mail in the City of Asheville, in
said County and State; that he (she) is authorized to make this affidavit and
sworn , statement;. that the notice or other legal advertisement, a true copy of
which is attached hereto, was published in
The Asheville Citizen Times
(Name of Newspaper)
on the following dates
January 14, 1988
and that the said newspaper in which said notice, paper, document, or legal
advertisement was published was, at the time of each and every publication, a
newspaper meeting all of the requirements and qualifications of Section 1-597
of the General Statutes of North Carolina and was a qualified newspaper within
the meaning of Section 1-597 of the General Statutes of North Carolina.
RR
2011 da of .TanrlarY -,19
This ?
(Siganture of person making affidavit)
Sworn to and subscribed before me.
this ?Ot-h day of T ,19 as
t
(Notary Public)
My Commission expires
October 22, 1991
dm°
vd0
ITLJ LET i rr-m? d 1 !=1
•j G"1 E
State of North Carolina
Department of Natural Resources and Community Development
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor S. Thomas Rhodes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section
?hev? lle ??? $ 'ernes
?Q ?X aD9o Attn: Legal Ad Department
-Dear-'Sir:
Please find attached a Public Notice regarding a Water Quality Certi-
fication. Please publish the Notice one time in your newspaper on or before
The invoice in duplicate and three copies of the affidavit of publication
should be sent to:
N.C. Division of Environmental Management
Water-Quality Section
P.O. Box 27687
Raleigh,-NC 27611
Attn: William Mills
Payment cannot be authorized unless the affidavit of publication is
submitted. If you have any questions, please contact me at [phone]. -
Sincerely,
vaze-j)?!1' _
William C: Mills
WCM/bm
Attachment
'` P.O. Box 27687, Rakigh, North Carolina 27611-7687 Telephone [phone]
Ja?jeo ST,?S
s
UNI D TATES ENVIRONMENTAL PROTECTION AGERY
REGION IV
345 COURTLAND STREET r,.
ATLANTA,, GEORGIA 30365
;t vC 1 ? ?8`l
C 8 1987 1M14ronrrjentaf
" wogh, N. C. ?.
REF: 4M-FP
Mr. R. Paul Wilms, Director
Division of Environmental Management
North Carolina Department of Natural
Resources and Colmnunity Development
Raleigh, North Carolina 27611-7687
RE: Champion International Corporation
NPDES No. N00000272 n
Dear >x,. s:
s were included in my December 1, 1987, letter requesting 401
n of the referenced draft NPDES permit. The application for
Sincerely yours,
Bruce R. Barrett
Director .
Water Management Division
Enclosure

Enclosed are copies of two letters dated April 7, 1986, andJune 9, 1986p
which constitute Champion's application. Please excuse any inconvenience
which may have been caused by this omission. The sixty day period for the
State to certify is now extended and will conclude sixty days from the date
of this letter.
K ( Canton NA ;
DOx C-1 C f
Canton, North Carolina 2876
V Champion
Champion International Corporation
June 9, 1986
Mr. Bruce Barrett
Director Water Management Division
USEPA Region IV
345 Courtland Street
Atlanta-. Georgia 30365
Dear Mr. Barrett:
This letter is in response to your letter to Mr. Oliver
Blackwell dated May 15, 1986 requesting the additional
information regarding Champion International Corporation's
Canton Mill NPDES permit application.
Form 2C-Part III (Maximum Production)
yey"mont,
Production data for the lash five calendar
is provided on Table 1. As can be seen, the data is variable
from month to month. Conversation with members of your staff
indicated that they have interpreted the regulation to require
annual average production data to set monthly effluent limit-
ations. We would like to call you attention to the Wednesday
September 26, 1984 Federal Register 40 CFR 122.45 (b)(2)(i)
which states:
"Except in the case of POTWs or as provided in
paragraph (b)(2)(2i) of this section, calcul-
ation of any permit limitations, standards, or
prohibitions which are based on production (or
other measure of operation) shall be based not
upon design production capability but rather upon
a reasonable measure of actual production of the
facility. For new sources of new discharge actual
production shall be estimated using projected
production. The time period of the measure of
production shall correspond to the time period of
the calculated permit limitations: for example,
monthly production shall be used to calculate
average monthly discharge limitations."
Champion International Corporation.
f
r
Our understanding of this regulation is that the high monthly
average production may be used to set applicable monthly
effluent limitations. The month of May 1984 represents the
highest production month in the past five years for the
Canton Mill. .
The Canton Mill no longer ships market pulp and does not have
any future plans to do so. The market pulp subcategory should
be eliminated. The mill does not have any of the following
operations: (1) wet barking, (2) log or chip washing, or (3)
log flumes or ponds.
»nn- Characteristics )
Part B (c) - The concentration units specified for the para-
meter "Color" are expressed in 11mg/1" as Platinum Cobalt color
units (p.c.u.). The test method used by Champion was developed
by the National Council for Air and Stream Improvement (NCASI)
for the pulp and paper industry in Technical Bulletin No. 253,
December 1971. This procedure was adopted by EPA for-the
measurement of pulp and paper mill effluent color (Federal
Register Vol. 39, No. 104 (18742-18754) May 29, 1974). The
me w -_ f hir =reversed- Eby NC??I ---Special..:Repoact r-they s
Investigations of the Color Nteasurem t Procedure to-- Improve
its Utilitv. June 1981.
Part B (d) - The number of analysis performed for fecal
coliform was fifty two (52).
On review of the completed application for 2C-V, Part A, we
found two errors in reporting which are corrected on the
attached corrected copy of that page. We hope that this has
not caused you any inconvenience.
Form 2C - Part VII (Biological Toxicity T,@sting Data)
Tables II - IV attached, give the result of various bioassay
tests performed on the mill effluent.
Reports which were submitted to the State of North Carolina to
comply with the June 19, 1981 NPDES permit Part III, Item F are
enclosed. These are: (1) Biological Studies of the Pigeon
River Near Canton, North Carolina - 1980 through 1982, With An
Overview of the Monitoring Study Series, December 30, 1982
submitted as an interim report), An Evaluation Of The
Pigeon River As Habitat For Smallmouth Bass, January 1983, and
3 Temperature Evaluation Of The Pigeon River Downstream of
Canton, North Carolina For Five Representative Fish Species,
January 1983.

Champion International Corporation
Use of Penta - or Tri-Chlorophenol
The Canton Mill does not use biocides containing penta- or
tri-Chlorophenol.
We believe this material meets the request for information
under section 308 of the Clean Water Act, 33 U.S.C. Section
1318. We are in the process of preparing a response to your
request for information regarding side stream oxygenation.
The information provided herein continues to be subject to the
reservation of rights in Mr. Oliver Blackwell's letter to you
April / ?s1 1---% a are s r•l relating to the propriety of EPA imposing limitations other
than a color limitation.
Please contact me should you have additional needs or wish
explanation of this material. Your staff has been helpful
in preparing the reply and we appreciate their cooperation.
Respectfully,
Ma ee Ransmeier
Environmental Control Supervisor
Enclosures
Copy: J. Oliver Blackwell
Vice President - Operations Manager
Champion International Corporation
Canton Mill
Canton, North Carolina 28716
R. Paul Wilms
Director, Division of Environmental Management
NCDNRCD
512 North Salisbury Street
Raleigh, North Carolina 27611
Dick Wigger
Vice President - Environmental Affairs
Champion International
One Champion Plaza
Stamford, Connecticut 06921
JK 4.
TABLE I
C8ANPION INTERNATIONAL CORPORATION
CANTON MILL PRODUCTION RATES
Production Subcate o
Number of BCT* ine Mar et u p Total
Date Operating Days Tons/Day Tons/pay Tons/pay Tons/pay
1961 January 31 730
682 925
920 0
0 1655
1602
February
March 28
31 738 955 41 1734
April 30 746 949 41 1736
may 31 729 958 0 1687
June 30 769 960 0 1729
July 31 697 917 0 1614
August 31 707 882 0 1589
September 30 700 959 0 1659
October 29 (**) 729 959 0 1688
November 30 705
621 950
797 0
119 1655
1537
December 31
All -91% 7 17 1657
1982 January 31 740 927 35 1702
February 28 760 955 9 1724
March 31 680 942 8 1630
April 30 686 916. 0 1602
May 31 677 963 0 1640
June 30 638 940 0 1578
July 31 613 883 0 1496
Jlul- t .31 630 922
#23 0
0 1552
1447
September
October .30
31 324
657 954 0 1611
November 30 622 958 0
0 1590
1560
uzmM ?asciftbar 31 $96 964
- Averag "S, °(Total-) fit ?4f 4_ I?394=-
1983 January 31 617 973 0
0 1590
1577
February 28
31 640
677 937
938 0 1615
March
April 30 680 959 0 1639
May 31
30 681
680 996
978 0
0 1677
1658
June
July 31 665 970 0 1635
August 31 672 967 •0 1639
September 30 597 967 0 1564
October 31 682 949 0 1631
November 30 694 982
992 0
0 1576
1626
- December 31 634
Average 365 (Total) 660 968 0 1628
1984 January 31 628 1024 0
0 1652
1723
February 29
31 720
713 1003
1000 0 1713
March
April 30 725 1034 0 1759
May 31 762 1015 0 1777 (max.)
June 30 669 1024 0 1693
July 31 632 1009 0 1641
August 31 698 987 0
0 1685
1673
September 28 (*_)
31 678
694 995
1025 0 1719
October
November 30 709 1028 A 1737
December 31 697 1015 0 1712
Average 364 (Total) 693 1014 0 1707
1985 January 31 612 1001 0 1612
February 26 701 1006 0
0 1708
1585
March
April 31
30 565
738 1020
1001 0 1739
May 31 676 1016 0 1694
June 30 648 991 0 1639
July 31 603 996 0 1599
August 31 737 998 0 1734
September 30 679 1025 0 1704
1611
October
November 31
30 554
598 1057
1029 0
0 1627
December 31 667 1030 0 1697
Average 365 (Total) 648 1014 0 1662
*Board, Coarse, Tissue
"Shutdown

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Canton Mill
Box C-10
4 Canton, North Carolina 28716
704 646-2000
V Champion
Champion International Corporation
April 7, 1986
Paper Division
Mr. Bruce Barrett
Director Water Management Division
USEPA Region IV
345 Courtland Street
Atlanta, Georgia 30365
Dear Mr. Barrett:
Enclosed are forms 1 and 2C as requested by your letter of
March 11, 1986, to complete the application of Champion
International Corporation for a wastewater discharge permit
to be issued by USEPA.
Champio is submittingahese forms for application under
pretest on the gxou"s :that the permf ssuied b•--theState
of North Carolina on May 14, 1986 satisfies all of the
requirements of state and federal law and is a valid NPDES
Permit.
Champion believes that the assumption of permitting authority
by the USEPA is legally invalid and, as you know, we have
presented that claim to a federal court in North Carolina.
We reserve the right to appeal from the issuance of any permit
by the USEPA on that basis.
For any further information regarding this application, you
may contact Mary Lee Ransmeier at the Canton Mill.
Sincerely,
J. Oliver Blackwell
Vice President
Operations Manager
Enclosure
Cop
R. au1 Wilms
Director, Division of Environmental Management
NCDNRCD
512 North Salisbury Street
Raleigh, North Carolina 27611
Please Print or type in the unshaded areas only
Is:u ...rt.. el:. f9rhnr?rorcrnrhl
Form Annramd r)MR Nn 2nf)n_fM7A F-1- ?_?t_AQ
FORI* U.S. ENVIRONMENTAL PROTECTION AGENCY 1. EPA I.D. NUMBER
A GENERAL INFORMATION C
E PA Consolidated Permits Program F N 0 0 0 0 0 2 7 2_113
GENERAL (Read the "General Instructions" before starting.) 1 2
GENERAL INSTRUCTIONS
1. EPA' I.D. NUMisER If a preprinted label has been provided, affix
it in the designated space. Review the inform-
ation carefully; if any of it is incorrect, cross
111. FACILITY AME through it and enter the correct data in the
appropriete fill-in area below. Also, if any of
the preprinted data is absent fthe area to the r
ACILiTY left of the label space lists the information
V. MAILIN ADDRESS11 P EASE PLAC LABEL IN THIS SP AC that should appear), please provide it in the
proper fill-in area(s) below. If the label is
complete and correct, you need not complete
Items 1, fit, V, and VI (except Vl-B which
must be completed regardless(. Complete all
FA ILITY items if no label has been provided. Refer to
LOCATION the instructions for detailed item descrip-
tions and for the legal authorizations under
which this data is collected.
IL POLLUTANT CHARACTERISTICS
INSTRUCTIONS: Complete A through J to determine whether you need to submit any permit application forms to the EPA. If you answer "yes" to any
questions, you must submit this form and the supplemental form listed in the parenthesis following the question. Mark "X" in the box in the third column
if the supplemental form is attached. if you answer "no" to each question, you need not submit any of these forms. You may answer "no" if your activity
is excluded from permit requirements; see Section C of the instructions. See also, Section D of the instructions for definitions of bold-faced terms,

`SPECIFIC QUESTIONS
r=s
no rover
fYwzNa P
SPECIFIC QUESTIONS
vis
No rover.
TTwcw.
A. Is this facility a publicly owned treatment works B. Does or will this facility (either existing or proposed)
which results in a discharge to Waters of the LOW include a concentrated animal feeding operation or
(FORM 2A) aquatic animal production facility which results in a
f
h
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S
2 X
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ae
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ORM
discharge to winters o
t
.? (
8)

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;
,°. 40tt A .. s 4 ., facil rty 4 er an ow descry
to `Waters of the U.S. other than those described in X a? ?'ir - M si d11*! r to X
" A _ta above? R M
W_
a
his #aClil tneat,,titv or dispose of
re
. '
?
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X. f,, Qo you or will.yp ? at this facility industrial or

municipal effluent tie low Via lowermost stratum con-

X
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k r0WI*1 ]I ." rw a o
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the
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y
? yy 1
tsa.:.. 73o -
G. Do you or will you inject at this act Ity any produced

water or other fluids which are brought to the surface
N. Do You or will you inject at this facility fluids for spa
4

in connection with conventional oil or natural gas pro cial processes such as mining of sulfur by the Frasch

l
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n
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i
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inject fluids used for enhanced recovery of X n
ng o
m
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ut
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com
us
s,
s
,
oil or natural gas, or inject fluids for storage of liquid tion of (FORM 4) fossil fuel, or recovery of geotherrr)sl energy?
h drocarbons? (FORM 4) ,. , so., 37_ 10 : .
s this ace ?ty a propose stationary source which is J. Is Is facility , a pircipowl Stationary source which is
one of the 28 industrial categories listed in the in- NOT one of the 28 industrial categories listed in the
structions and which will potentially emit 100 tons instructions and which will potentially emit 250 tons X
per year of any air pollutant regulated under the X per year of any air pollutant regulated under the Clean
Clean Air Act and may affect or be located in an Air Act and may affect or be located in an attainment "
attainment area? WORM 5) .e r, : area? (FORM 5) .. .. s
III. NAME OF FACILITY
1 sxln-CHAMPION INTERNATIONAL, C RP

IV. FACILITY CONTACT
A. NAME & TITLE (last. first, ,& title) H. pH ONE (area code
9 R A N S M E I E R MARY L E E E N V I
15 i 6 - R O. S U P R 7 0 4 6.4.6 2
- .S .. .d 49 S7 51 SS
V. FACILITY MAILING ADDRESS
A. STREET OR P.O. aOX - - - -
H P.O! BOX C- 1 0
IS 1 .
.r
H. CITY OR TOWN. - C.STATE G. zip CODE
- -
C
4 C A N T O N
fs 1s _. N C 2 8 7 1 6
VI. FACILITY LOCATION
A. STREET, ROUTE.NO.. OR OTHER SPECIFIC IDENTIFIER
M A I N S T R E E T
H. COUNTY NAME ..
H A Y 'W 0 0 D
C. CITY OR TOWN - .STATE E. =IP CODE - F. OU Q
fif known)
c
6 A N, Tp N
NC
2 8 7 6
.
a.1 44 52 - 54

EPA Form 3510-1 1 Rev. 10-80) CONTINUE ON REVERSE
IDES 14-digit, in order of Mority?
' A_-RIRST
a. SECOND
2 6 2 1 (specirv) Integrated Pulp Mill t7
• (specify)
.. ,. '.'D. FOURTH
C. THIRD, ,' ? .: :..
(specify)
(specify/
7
f' 04, ,.,. 16 0
Ail- OPERATOR INFORMATION
° "ame listed ,in
A.NAME
n
1 VIII-A also the
V
C H A M P I O N I N T E R N. A T I O N A L C
3 ORPORATI0N ®nE
? N0

C. STATUS OF OPERATOR (Enter the appropriate letter into the answer box; if "Other", specify.) D. PHONE (area code & no.)
FEDERAL PUBLIC (other than federal or state) p (specify) C
N 7
1 =
"+,S.- STATE. ` O -OTHER, (specify)' . 1

r;P - PRIVATE .
.. . as - u Its - :: :.
j- - B. STREET OR P.O. BOX
1 C H A M P I ON P L A Z A
_ as
F. CITY OR TOWN " G.STAT H. ZIP COPE' IX. INDIAN LAND
R D C T 0 6 9 2] Is the facility located on Indian tands7
L
l NO
[7 YES
at
+p ,: .40 :41 41 .. 47. , $1
iG1EXISTiNG ENVIRONMENTAL PERMITS
NPpis (Dischargesto Surface`Miter) D.'Pso (Air Emissions from Proposed Sources)
-
I r= I T ,.
T
N00000272 9 ,p.NF.20294
r
U
0
1

.
-
-
M11
T type YI
r , .. Attadtmient I
gum xt 77t,

taahis applicatlon,?A topographic map`of the area extending to'at.least one mile;beyond'pr erty Iiounderies.Ihiomap muuit. h ur
outline of the facility, she' location of eactr of its existing 'arid proposed intake and dischirge'structNres, each of its.hazardous waste
nt, storage, or disposal facilities, and each well where it injects fluids underground. Include all -iprings,' rivers and other, surface'
water. bodies in the `map area. Seelinstructions for precise' requirements.
L NATifREOF,SUSINESS (provide a'brief. description
The Canton Mill is an integrated bleached Kraft pulp and paper manufacturing facility
producing food board and fine paper.
Kill. CERTIFICATION (see Inamcdons)
k1 certify under penalty of law that / have personally examined add am familiar with the Information submitted in this application and all
attadlments and that, based on my inquiry of those persons immediately responsible for obtaining the information contained in the F
app/ication''/`believe that the information is true, accurate and complete. l am aware that there'are significantpenaltiesforsubmitting
fa/se'infonnatJon, including the possibility of fine and imprisonment

A. NAME 3 OFFICIAL TITLE (type or print). B. SIGNATURE C. DATE SIGNED
J. Oliver Blackwell, Vice President- 7/86
Operations Manager Canton Mill
POWENTS FOR OFFICIAL USE ONLY

Form 3510-1 (Rev. 10-80) Reverse * U. S. GOVERNMENT PRINTING OFFICE: 1983--661-937/125

Attachment 1
Champion International Corporation
Canton Mill
Canton, North Carolina
.X. Existing Perittits
A. NPDES N00000272
D. PSD 20294 WNC Regional Air
Poll. Control
Form 1
NC 0000272
Wastewater Treatment Facilit]
New Coal Fired Boiler
E. Other 44-01 N.C. Solid Waste No.5 Landfill
44-06 No.6 Landfill
f 20069 WNC Regional Air Coal Fired Boiler
- Poll. Control
20070 Coal Fired Boiler
2-0068 "Coal Fired -Boiler
20066 Bark/Coal Fired Boiler
20154 Oil Fired Boiler
20155 Oil Fired Boiler
20153 Bleach Absorber Scrubber
20149 Bleach Plant Scrubber
20148 Bleach Plant Scrubber
20150 Bleach Plant Scrubber
20249 Tall Oil Scrubber
20086 Bleach Plant Scrubber
20152 Black Liquor Oxidation
20248 Chlorine Dioxide Scrubber
20085 C102 Tower Scrubber
20065 Recovery Boiler
20067 Recovery Boiler
20055 Lime Kiln/NCG System
11740 N.C. DEM Pump Station for
No.6 Landfill Leachate
Collection
CHAMPION INTERNATIONAL
CANTON, NORTH CAROLINA
MILL WATER BALANCE
TOWN OF
CANTON •-0.5
WASTE WATER
RAW RIVER WATER 1.83
RAW
WATER
44.57 USES
FILTER 1.63
PLANT
RETURN 9.02 1.67
WARM H2O ,
0.20
COLD COLD COLD
5.26 21.08 27.58 CITY 0.20
WATER USES
EVAP.
0.5a
4.96 UTILITY o.?o
2.61 COOL
MOISTURE IN
STEAM WOOD CHIPS
19 CONDENSER 027 0.64
5.49
COOL# 1 EVAP. &
0.41 11.12 SLUDGE
# 11 CONDENSER
c.cer t.3a
PURCHASED WHITE WATER
PULP 14.30 PULP
MILL
EVi,P. .01 STOCK 30.E9
9.02
COOL 5.19 1.0 CHILL VACTOR
PAPER
MILL
EVAP. x.51
ri
0.5' WASTE
0.02 INATE R
'•? RE'ru-^ j TREATiMENT
TO RIVER PLANT
1
MQIS; U R E Iti
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EPA I.D. NUMBER(COpy Om Mein 1 O Orm 1)
,n
c,,..., dnnmvorlOMR Nn. f5R-Rnf73
I
Please print
_
FORM

2C

NPDES or type in the unsndueu alu- u-Y- - vvvv?

_
,. V.S. ENVIRONMENTAL PROTECTION AGENCY
/EPA APPLICATION FOR PERMIT TO DISCHARGE WASTEWATER
EXISTING MANUFACTURING, COMMERCIAL, MINING AND SILVICULTURAL OPERATIONS
Consolidated Permits Program
1.OUTFALL LOCATION
For each outfall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
L
U
. A ,
S. LATITUDE
C. LONGITUDE
D. RECEIVING WATER (name)

3E
R
M BE
NU
([st
1. 01116.
2. MIN.
7. Sac.
7. OCO.
1. MIN.
- D. Sac.
e_001 35 32 8 82 50 42 Pigeon River
-

It. FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES
A. Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater to the effluent,
and treatment units labeled to correspond to the more detailed descriptions in Item B. Construct a water balance on the line drawing by showing average
flows between intakes, operations, treatment units, and outfalls. If a water balance cannot be determined (e.g., for certain mining activities), provide a
pictorial description of the nature and amount of any sources of water and any collection or treatment measures.
a. For each outfall, provide a description of: (1) All operations contributing wastewater to the effluent, including process wastewater, sanitary wastewater,
cooling water, and storm water runoff; (2) The average flow contributed by each operation; and (3) The treatment received by the wastewater. Continue
on additional sheets if necessary.
-
/rALL.N-
(lift) '2.OPERATION(S) CONTRIBUTING FLOW
, b. AVERAGE FLOW
S. OPERATION (Itat) (include.unita) 3.TREATMENT -
. LIST CODES FROM
Via. DESCRIPTION TABLE 2C-I
001 u3:p Mill 30.7 mgd Grit Chamber, 32'1 x 8'w x 16 'd 1-m
hip cooking, Pulp washing
i 44 mgd, l minute retention
9r-.eg_Ujn .r_&,B.leaching Solids to.landfill 5-
ecovery & Regeneration `' -
f Cooking Chemicals - Bar Screens two 6ft wide ea ch 1-T
roduction of Bleaching H Control b CO in ection 2-K
hemicals Coagulation by Rol er addit on 2-D
001 Pa Der Mill 9.2 m d Disc Screens Two 10ft.diam. each 1-T
Production of Paper
and Dried Pulp
ard
a er Bo Primary clarifiers circular 1-u
_
_
Paper Board and Dried Pulp Two, 200' diam. x 14.75' deep
001 Utility a Water es 4.2 m d 19.2 m d each 4.3 hours rete ntion
alter Plant One, 125' diam. x 11' deep_
001 own of Canton 0.7 m d 5.6 m Ad, 4.3 hours retention
Skimmed floating solids to la ndfill 5-
Settled solids dewatered b -
belt press,
Landfill 5-
Secondar Treatment b Activa ted 3-A
Sludge Process Aeration Bas
M D capacity, 4 MGD + ec cle
4 hours retention

(See Attached Page)
.OFFICIAL USE ONLY (effluent guidelines au •cbtegori¢e) OnIVTINI IF ON R VER
EPA Form 3510-2C (6-80) PAGE 1 OF 4
II B. 3.
Secondary Clarifiers, circular- 1-u
Two, 200' diam. X 12' deep--
17 MGD each, 4 hrs retention
one, 150' X 14' deep
10 MGD, 4 hours retention
Aeration Cascade, discharge to 4-A
Pigeon River
Paqe la of 4
CONTINUED FROM THE FRONT
C. Except for storm runoff, leaks, or spills, are any Of the discharges described in Items 11-A or 8 intermittent or seasonal?
? Vas (complete the following table) aNo (go to Section III)
3. FREQUENCY 4. FLOW
I. OUTFALL
NUMBER 2. OPERATION(s) a. DAYS b. MONTHS a. FLOW RATE b. TOTAL VOLUME

(list) CONTRIBUTING FLOW
l PER WEER PER YEAR (in mgd) (specify with units) a OUR-
(
ist)
- -
' .' -- (specify
average) (Specify
avera
e) f. LONG TKR
AV<RAG6 2. MAxtM UM f. LONG TKRM 2. MAXIMUM ATION
.
. .. g . DAILY AVaRAGC . DAILY (in days)
111. MAXIMUM PRODUCTION
A. Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility? 1
YES (complete Item III-B) - No (to to section IV) -
S. Are the limitations in the applicable effluent guideline expressed in terms of production for other measure of
operation)?
-r we (complete Item 717-0 ONO (go to Section IV)
49.; If you -1 p- ra OVIE" to iewn I", Ue Mr
rIndic aprgNlff ale Your alntNslurn flplel of production. oltpr>pnd in tM lanna
and unitg used in the applicable effluent guideline, and indicate the'affected outfalls.
1. MAXIMUM 4UANJ-ITY
2. AFFECTED
°uAN77TY ?tw i?AY b, UNtyf6 or..lAlcAfuss .. ,, ..:; - _ .__. _
. t Eft>tAT10N AWdoueT:"?i/?'i?'Rtwi.:'rTe.
(sbecTfY) fiirtoutfali numbers)
May 1984
762 Tons/Day BCT Bleached Kraft 001 i
1
1015 Tons/Day Fine Bleached Kraft 001
A. Are you now required by any Federal, State or local authority to meet any implementation schedule for the construction, upgrading or operation of waste-
water treatment equipment or practices or any other` environmental programs which may affect the discharges described in this application? This includes,
but is not limited to, permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations. court orders, and grant
or loan conditions.
®Y Es (complete the following table) CD No (go to Item IV-B)
1. IDENTIFICATION OF CONDITION, 92. FFECTED OUTFALLB 4. FINAL COM-
AGREEMENT, ETC. IA E DATE
3. 11RIEF DESCRIPTION OF PROJECT
b, souncs or atsCNARGat 8. RE- 136 •RO-
Stormwater collection Coal Storage New coal fired boi er construct on °"'R`° ltCTCD
Pile includes modified coal handling syste
to include stormwater collection 1/87 1/87
Oxygen Enrichment Canton Mill WTP To install two side-stream oxygen en-
Pigeon River richment system on the Pigeon River, p
oxygen enrichment at discFiarge x+786 4/86
Ultrafiltration Bleach Plant To demonstrate technical & economic
Demonstration Effluent feasibility of OF to-remove bleach
plant color 4/86 4/86
B. OPTIONAL: You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect
your discharges) you now have underway or which you plan. Indicate whether each program is now underway or planned, and indicate your actual or
planned schedules for construction.' [:)M^Rk "X•' IF DESCRIPTION OF ADDITIONAL CONTROL PROGRAMS IS ATY.e-- cn
gr%-, T910-2C (6-80)
PAGE 2 OF 4
CONTINUE ON PAGE 3 125
PAGE 3 OF 4 CONTINUE ON REVERSE
EPA Form 3510-2C (Rev. 2-85)
ONTINUED FROM THE FRONT
lll, BIOl OGICAL TOXICITY TESTING DATA
Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a
receiving water in relation to your discharge within the last 3 years?
Yes (identify the test(s) and describe their purposes below) ?No (go to Section VIII)
o Six 48 hour static bioassays using"Daphnia pulex.
No toxicity indicated. (Champion or N.C.)
o Two 7 day growth tests using'Pimphales alas.
1 test indicating no problem EPA
1 test with questionalbe results due to problems in mid-range diluting (EPA.)
o Four 7 day reproduction potential tests using"Ceriodaphnia sp.
1 aborted due to lab equipment problems (EPA
1 questionable due to problem with dilution water and control group (Champion)
2 indicate some reduction in reproduction potential at higher concentrations.
UTA and Champion).
DN?f2ACT ?IAL??.,?S INFOtMA'?id
Were any of the analyses reported in Item V performed by a contract iaboratory o'r consulting firm?
YES (lietthe name, address, and telephone number of, and pollutants EXINo (go to Section IX) -
analyzed by, each such laboratory or firm below)
A. NAME S. ADDRESS NE POLLUTANT ANALYZED
(area code & no,) list
NA

IX.CERTiFICATION _..,_,,i
l 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 properlygather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or
thosepersonsdirectlyresponsibleforgatheringtheinformation,theinformationsubmittedis to the best ofmyknowledgeandbelief,true, accurate, andcomplete.
I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
A. NAME & OFFICIAL TITLE (type or print) B. PHONE NO. (area code & no.)
J. Oliver Blackwell, Vice President-Operations Manager 704-646-2611
CIGNA URE D. DATE SIGNED
ate -- /CXP
'orm 3510-2C (Rev. 2-85) PAGE 4 OF 4 s?.?
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
111)4_4 7017 REGION 1V
345 COURTLAND STREET
ATLANTA,. GEORGIA 30365
DEC 1 1987
REF: 4WM-FP
Mr. R. Paul Wilms, Director
Division of Environmental Management
North Carolina Department of Natural
Resources and Community Development
P.O. Box 27687
Raleigh, North Carolina 27611-7687
RE: Request for State Certification
Champion International Corporation
NPDES No. NC0000272
Dear Paul,
DEC 3 1987
Div. of ::nvironr iental Mgt.
Raieigh, N. C.
The, _Enyironmental Protection Agency (EPA) hereby requests state certification
ot t :-.awe A*tt 'fib DiS? qe Elimination system
(NPD ES) ,,permit. :.The sapplication,, draft permit and supporting miaCeriA
enclosed.
4f 14? t oai a r i?d r. _} nci t olase * °`drartt ° permkt.. The
draft permit also incorporates the requirements of the permit issued-by the
State on May 14, 1985, unless more restrictive conditions were established
based on our interpretation of North Carolina water quality standards. The
enclosed draft NPDES permit contains monitoring requirements, limitations and
measures of compliance necessary to meet a color level in the Pigeon River of
50 apparent color,'units. This instream color level represents our interpre-
tation of 15 N. C. Admin. Code 2B. 0211 (b) (3) (F) . Should the State decide that
a revision to the water quality standard is appropriate and grant a variance
to the standard, it must at a minimum require compliance with Tennessee's
water quality standard for color (Tenn. Admin. Comp. 1200-4-3-.03(4)(d)) at
the Tennessee/North Carolina state line. Any revision or variance to the
North Carolina standard must also comply with the provisions of federal water
quality standards regulations (40 CFR Part 131).
Please note that the draft NPDES permit has been modified to include a
schedule of compliance for color and chloroform limitations. The
justification for including the schedule of compliance for these parameters is
given in the fact sheet.
Under Section 401 of the Clean Water Act (33 U.S.C. 1251) and the NPDES
regulations (40 C.F.R. 124.53), your certification must be in writing and must
include:
(1) Conditions which are necessary to assure compliance with the applicable
provisions of Clean Water Act Sections 208(e), 301, 302, 303, 306, and
307 and with appropriate requirements of State law;
4FA
,

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41,.
-2-
(2) Any conditions more stringent than those in the draft permit which the
State finds necessary to meet the requirements listed in paragraph (1)
above. For each more stringent condition, the Clean Water Act or State
law references upon which that condition is based must be cited. Failure
to provide such a citation waives the right to certify with respect to
that condition; and
(3) A statement of the extent to which each condition of the draft permit can
be made less stringent without violating the requirements of State law,
including water quality standards. Failure to provide this statement, for
any condition waives the right to certify or object to any less stringent
condition which may be established during the EPA permit issuance process.
The draft NPDES permit contains a variable effluent toxicity limit based on
instream flow. EPA requests that the State include in the certification any
more stringent conditions necessary to meet the requirements of 15 N.C. Admin.
Code-2B .0206 (Flow Design Criteria for Effluent Limitations) for discharge of
toxic substances.
Under 40 C.F.R. 124.53(c), EPA cannot act on NPDES permits until the State has
or waived its right to certify. 'The,
zf additions ti is
?' ?n? 'two }31?e °mat'ure of?';?kle ?i?lay .afld a??t?c:,t?.;;
Sincerely yours,
Bruce R. Barrett, Director
Water Management Division
Enclosures
cc: J. Oliver Blackwell, Champion International/Canton, N.C.
Mary Lee Ransmeier, Champion International/Stamford, Conn.

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PUBLI c: NOTICE
U.S. Environmental Protection Agency
Region IV
Water Management Division - Facilities Performance Brancn
345 Courtland Street, N.E.
Atlanta, Georgia 30365
[phone]
Public Notice No. 87N00001B December 2, 1987
NOTICE OF PUBLIC HEARINGS ON PROP'JSED REISSUANCE OF
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PERII'1
Tne U.S. Envitonme ai Protection Agency (EPA„) intends to reissue a
National Pollutant Discharge Elimination System ice) permit to `tire ChaTpion
"nteaona?l Cgrporation, Stamford, Connecticut, for its Canton Mill located
an l+lalt?4i -y _,Litlb North Carolina. The Canton Mill is
an integrated bleached kra£?t' put and paper iaanu r? ti °n aci i y
.p ,
,At in,
food board and fine paper., The application, NPDES Number NC0002?2,`descr3i? .,
one point source which enters the Pigeon River, which is, classif ied as `Class C
Waters suitaole for secondary recreation and fish propagation.
The proposed NPDES permit contains limitations on the amounts of
pollutants allowed to be discharged and was drafted in accordance with the
provisions of the Clean Water Act (33 U.S.C. Section 1251 et seq.) and otner
lawful standards and regulations. The pollutant limitations and other permit
conditions are tentative and open to coixiient from the public. A similar
proposed permit was announced in Public Notice No. 87N00001 on April 9, 1987,
and the public conuaent period was extended in Public Notice No. 87liCU001A on
May 22, 1987. The limitation for color has generated significant public
comment. 9hat pennit provision was based on EPA's interpretation of the Nortn
Carolina water duality standard for color found at 15 N.C. Admin. Code
2B.0211(b)(3)(F) (1985). Should that standard for color be revised,, EPA will
seek comment on limitations based on such a revised standard at a later date.
Pursuant to 40 CFA 124.12, Public Hearings w11°Y .,;held to receive
comments on the Agency's tentative decision,"-to reissue thEis penr:it. TWO
hearings have been scheduled. The first will_tie he ti 'mod , nary 14,
1
1988, at Asheville CiIII, ' , *ywo street„ Asheville, North
carolj- ram 1:00 P.M. to 10:00 P.M. Zhe` second hearer will qe held
Thursday, January 21, 1988, at Knoxville CiV2c ;Cbaseum; 00 East Church
Avenue, Knoxville, Tennessee from 1:00 p.m. to 104Q p:mtie hearings will
be chaired by the EPA. The hearings will be
?ed ?oimally. Formal
rules of evidence will not apply. Both oral and ,(#ten c(=ents will be
accepted; however, the EPA Regional Administrator.-o is;; esignee reserves the
right to fix reasonable limits on the length .of.-oral presentation. Written
comments may also be submitted to the Virta Protection Agency, r'
Region IV, 345 Courtland Street, N.E., AtlantaGedt li -30365, ATTTE., ICN
Suzanne D. Potter, no later than February 22J. .1988. public notice nwriber
and NPDES =-.Der should be included in the first e =of comments.
comments received within the designated period --will' considered 'in "
formulation of final determinations regarding the pekAit'- '
After consideration of all comments and the
rgqurements ^and policies'
the Act and appropriate regulations, the EPA Regiohal iinistrator will
determinations regarding the permit issuance
.?ie determinations at
substantially unchanged from those announced by this n?ti ;;the EPA = ional
Administrator will :so notify all persons wno have;-eu0 itte ,*ritten c? .-ients
If the, determinations are substantially--change - the - EPA g
??e io
Administrator will issue a public noticIIndigat ng the revi
determinations. Requests for evidentiary _l acing --ray° t ,filed after t
Regional Administrator maKes the above-desctxb l;c,teai tions. Additi
information regarding an evidentiary hearing _ s available =in- 40 CFR art 12C
Subpart E, or by contacting _ the Office of Reg?orfal Cotknselat the addr
aoove or at [phone]. ?..,
Tne administrative record, including applioatzon fact sheet, arat
permit, a sketch snowing theexact location ?Of the discharge, comme
received, and additional information on hearuig r re _ ,is availa? le --
cost by writing the EPA address above, or " for x eu a copying at
Courtland Street, N.E., 3rd floor, Atlantai
Qe,fween the ;ors
8:15 a.m. and 4:30 p.m., Monday through Frida'-?t,Q ? W1I3 be provided at
.minimal cost per page. 1; J.
Please bring the foregoing to the attention of personso you .w wt
be interested in this matter. f °?r,Yt1,
### `-
?I.
Az,
F
f A Permit No. N00000272
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
?l?ttE REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 30365
ALIMRIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In ccnpliance with the provisions of the Clean Water Act, as amended (33
U.S.C. 1251 et seq. the "Act"),
Champion International Corporation
Champion Papers Division
is authorized to discharge from a facility located at
Main Street a
Canton, North Carolina
to receiving waters named
the Pigeon River
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth herein. The permit consists of this cover sheet, Part
I 4 page(s), Part II 15 page(s) and Part III 3 page(s).
This permit shall become effective on
This permit and the authorization to discharge shall expire at midnight,

N O V 3 0 1987
Date Signed Bruce R. Barrett, Director
Water Management Division
a
.

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Part I
Page I-2
Permit No. NC00OU272
2. The monthly average instream temperature measured at a point 0.4 miles
downstream of the discharge location shall not exceed 32.0°C during the
months of July, August, and September and shall not exceed 29.0°C during
the months of October through June. The monthly average instream tempera-
ture measured at this location shall not exceed the monthly average
instream temperature of the upstream monitoring location by more than
13.9°C.
3. The concentration of dissolved oxygen in the effluent shall not be less
than 6.0 mg/1.
4. The effluent pH shall not be less than 6.0 standard units nor greater
than 9.0 standard units.
5. (a) Monitoring requirements for apparent and true color are as follows:
Influent and effluent shall be monitored once per day by a omposite
sample.
(b) =The discharge-shall -not cause apparent-ca. orin the Pigeon' River to
exceed 50 Platinum Cobalt color units downstream of the discharge.
Compliance with this permit condition will be measured in the
following manner:
The downstream apparent color value will be calculated by the
following equation:
Downstream Udischarge Effluent
-- X
Color Value Qupstream Color Value
where Qdischarge = effluent flow (in mgd)
4upstream = Pigeon River flow (in mgd) at river mile
63.5 (upstream of the point of discharge)
If the calculated downstream apparent color value exceeds 50 Platinum
Cobalt color units, then an analysis for true color must be performed
on the effluent sample gathered for that day. Using this effluent
true color measurement, a value for the downstream true color value
will be calculated based on the above equation. If the calculated
downstream true color value exceeds 50 Platinum Cobalt color units,
this represents a violation of this permit.
(c) The method of analyses used to measure color shall be Method 204A of
Standard Methods for the Examination of Water and Wastewater, 1985,
16th Edition, or an alternate method approved by the permit issuing/
regulatory authority.

Part I
Page I-3
Permit No. N00000272
6. The no effect chronic level (NOEL) of the discharge shall not be less
than the instream waste concentration (IWC) expressed as a percent value.
The no effect chronic level shall be determined utilizing an acceptable
biomnitoring procedure developed under Part III C, Item 1, on Page III-2
of the permit. The IWC for each sampling period shall be calculated by
dividing the average discharge flow by the average instream flow downstream
of the outfall. For each case, the average flow shall be calculated as a
seven day average flow, with the day of actual sample collection being
the fourth day of a seven consecutive day averaging period. Instream
flow shall be estimated using data from the gaging station located at
river mile 63.5 (at the point of sampling to meet the requirements of
"upstream" monitoring on Page I-1 of this permit).
7. Where composite samples are specified in the monitoring requirements of
this permit, a 24 hour composite sample is required.
B. SCHEDULE OF COMPLIANCE
1. The permittee shall achieve compliance with the effluent limitations
specified for discharges in accordance with the following schedule:
a. The effluent limitations for color and chloroform shall become
effective in accordance with the following schedule:
Date
(1) Effective Date + 6 months
(2) Effective Date + 1 year
(3) Effective Date + 18 months
(4) Effective Date + 2 years
(5) Effective Date + 30 months
(6) Effective Date + 3 years
Required Action
Status Report
Status Report
Status Report
(a) Status Report
(b) Begin pilot wastewater
treatment studies
Status Report
Status Report
(7) Effective Date + 42 months Status Report
i

Part I
Page I-4
Permit No. N00000272
(8) Effective Date + 4 years
(9) Effective Date + 54 months
(10) Effective Date + 5 years
(a) Status Report
(b) Select treatment alternative
Status Report
Achieve compliance with
effluent limits for color
and chloroform
b. The effluent limitations for all other parameters shall become
- effective upon the effective date of this permit.
2. No later than 14 calendar days following a date identified in the
above schedule of compliance, the permittee shall submit either a '
report of progress or in the case of specific actions being mired
by identified dates, a written notice of ompliance or nonecapliance.
In the latter case, the notice shall include the cause of nonompliance,
any remedial actions taken, and the probability of meeting the next
scheduled --requikement:
i
S
t
Part 22
-Page 21.1
PART 21 1
sTAMMD CDNDZT2DM POR NPDlS PNPX12S
StCTION A. GMNL%L CDWDZTZDM
1* duty to Nes?aly
the persittee oast ee¦ply with all conditions of this Vomit. Any Permit
Sonomplianee constitutes a violation of the Clean water Act and is grounds
for enforcement actions for permit .terminations revocation and reissuance, or
nodifieations or for denial of a permit renewal application.
!.
'ABC aus"l +ibod"k6mme
Any person nbo violates a posit condition is subject to,a e_WX ona?ty sort
to dsl?iW0 O00= penE a ; *10 vt
iieA"li9tnt Y s o asni .resat AWAItlons .4s 4snaject .40 ?& ?Uae ,af cwt ems -than
02,500 mot more than $25,000 per day of violation, or by imprisonment for mot
nose than 1 tearp or both.
3. Duty to Mitioate
the permittee sball take all seasonable steps to minimise or prevent any
discharge in violation of this permit Web ads a reasonable likelihood of
adversely affecting busan health or the environment.
d. bruit Modification
After notice and opportunity for a bearing, this permit may be modified,
terminated or revoked tor- cause (as described in 10 CPR 122.62 et seq)
including, but mot limited to, the following$
a. Violation of any terms or conditions of this permits
b. Obtaining this permit by misrepresentation or failure to disclose
fully all relevant facts
e. A change in any conditions that requires either tennporary
interruption or elimination of the permitted disebarges or
d. Information 'newly acquired by the Agency indicating the discharge
poses a threat to human health or welfare.

Part II •'
Page 21-f .
If the permittee believes that any past or planned activity would be cause for
modification or revocation and reissuance under 40 CtR 122.62, the persittee
must report such information to the Persia Issuing Authority. ?be subaittal
-0f -s-re+r-spplieation =y ?e required of the se?ittee the tiling of a
request by the permitted for a permit modification, revocation and relesuance,
or termination, or a notification of planned changes or anticipated -
sonoampliance, does not stay any permit condition.
S. 20xic Pollutants
Matwithstanding Paragraph 11.1, above, if a toxic effluent standard or
prohibition (including any schedule of compliance specified in such effluent
standard or prohibition) is established ander Section 307(a) of the Act for a
toxic pollutant which is present in the discharge and such standard or
prohibition is sore stringent than any limitation for such pollutant in this
peralte. this permit shall be modified or revoked and reissued to sonfors to
the toxic effluent standard or prohibition and the permittee so notified.
The permitted shall comply with effluent standards or prohibitions established
under Section 307(x) of the Clean Water Act for toxic pollutants within the
Use *rovided An the regulations -that sstablish those standards or
prohibitions, even if the permit has not yet been modified to incorporate the
requirement. _ ___
6. Civil and Criminal Liability
Jkcept as provided in permit conditions on 'Sypassing ' Section be Paragraph
8.3, nothing in this permit shall be construed to relieve the permittee from
civil or criminal penalties for noncompliance.
7. Oil and Nasardous Substance Liability
tithing in this permit shall. be construed to preclude the institution of any
legal action or relieve the persittee twos any responsibilities, liabilities,
or penalties to which the permittee is or day be subject under Section 311 of
the, Act. .
S. State taws
lothing in this permit shall be construed to preclude the institution of any `
legal action or relieve the permittee from any responsibilities, liabilities,
or penalties established pursuant to any applicable State law or regulation
under authority preserved by Section 510 of the Act.
:z
9. Property !tights
The issuance of this permit does not convey any property rights of any sort,
or any exclusive privileges, nor does it authorise any injury to private
property or any invasion of personal rights, nor any infringement of federal,
State or local laws or regulations.

• o

Part 21
Page 11.2
10. gnshore or Offshore Ometruetion
this permit does not authorise or approve the construction of any onshore or
offshore physical structures or facilities or the undertaking of any work in
any raters of the Vatted States.
11. SeverabilitV
The provisions of this permit are severable, and if any provision of this
permit. or the application of any provision of this permit to any
eircumstance, is held invalid, the application of snob provision to other
eireumsLances, and the remainder of this permit, shall not be affected thereby.
12. Outs to Provide Information
The permittee shall furnish to the Permit Zooming Authority# within
soa@"able . + a Wit, MEM&O 0 MA,
"4001 to determine 4nnt#er eanse exists for s+odifYinp, revoking and
snieeo ag,= or terminating this 96ftit ° et . f &tero no Sa plis With thie,
wee-rai??a?- .ha11-:.==ln?t? toy=lbe==t?s-o1tt?g?=As>tbos ity -opoe?=
egeest .a+pies,.ef??eaozQr sequtTed'?o°? atpg ?r `Eb3s _ _ _
2CT3DW D. MRATIOW AXD MA2NT ARCM OF VOLWT209 Q111'Sl M
19 Proper Operation and Maintenance
the persittes shall at all times properly operate and maintain all facilities
and system of treatment and oantrol land related appurtenances) which are
installed or wed by the permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This
provision requires the operation of back-up or auxiliary facilities or similar
systems which are installed by a permittee only when the operation is
secessary to achieve compliance with the conditions of the permit.
2. steed to salt or 1leduee not a Defense
It shall not be a defense for a permutes in an enforcement action that it
would have been aeoessary to bait or reduce the permitted activity in order to
maintain compliance with the condition of this permit.
2. MMas of Treatment Peallities
a. Definitions
(1) eaypess' mans the intentional diversion of waste streams from
any portion of a treatment facility, which is not a designed or
established operating soft for the facility.

tart 11
Page 11-4 .
t21 `i.. ce property damage' means 'substantial pblelcal damage to
property. damage to the treatment facilities wPermanent loss bum
to boom* inoperable, or substantial and ccee to cocas in
nature a
the absence of • bypass. Severe property damage s no ,
economic loss caused by delays in production.
b. lypass not exceeding limitations.
?hs permittee may allay any bypass to occur rhich does mot cause
effluent limitations to be exceededs but only if it also is for
essential maintenance to assure efficient operation. %base bypasses
are not subject to the provisions of Paragraphs e. and d. of this
section.
e. woos .
(1) Anticipated bypass. Tf the permittee knows in advance of the
Deed for a bypass, it shall submit prior notice, if possible at
least ten days before the date of the bypass including an
evaluation "of the 'anntieipsted =quality =and ;effect of the bypass.
ss. lba....peraittse sball submit notice of an
(2)
unanticipated bypass as rapIte?d in, ieetro+ --o; tcrag:mph o.a .... _ _
(24-boor notice).
d. Probibition of bypass.
a) •ypess is prohibited and the Permit =suing Authority may take
enforcement action against a permittee for bypass# unless:
(a) %-p en was unavoidable to prevent leas of lifee personal
injury# or severe property damage=
tb) mere were so feasible alternatives to the wnwas# such as
the use of
untreated wastes, of maintenance during normal periods of
equipment downtime. this Condition is not satisfied if
adequate tact-up equipment sbould save been installed in
the exercise
wbich reasonable inormal periods o equipment
• bypass
aowntine of preventive maintenances and
it) The permittee submitted notices as required under Paragraph
e. of this section.
(2) the Permit Issuing authority may approve an anticipated byoasse
after considering its adverse effects, if the Permit legging
Authority determines that it will meet the three conditions
listed above in Paragraph 6.(1) of this section.

Part 22
Page 2I-5
d. MsLts
•opset• means an exceptional incident in which there is unintentional and
temporary noncompliance with technology based permit effluent limitations
because of fee:ors beyond the seasonable control of the permittee. Jln:
viset does not include nonoompiianoe to the extent 081000 by operational
u:ror, improperly designed treatment facilities, inadequate treatment
facilities, lack of preventive wintenance, or earelbs Of Improper
operation. An spot constitutes an affirmative defense to an action
brought for eon-compliance with ouch technology based permit limitation if
the requirements of 00 CPA 122.01 in1 IX are met.
S. 1lemoaed . Subs tone"
This permit does mot authorise discharge of solids, sludge, filter backwash,
or other pollutants removed in the course of treatment or Control of
wastewaters to waters of the Yhited States unless specifically limited in part
1.
SIMON C. MONMR2MC AND atC?RIX
1. entam
d?1 M! loud maAke"
males-e the monitored- d. ?lI asph 46all
be lumen
at "the monitoring 'points specified in *big permit and, unless otherwise
specified, before the effluent joins or is diluted by any other wastestream,
body of water, or substance. Ibaltoring points shall not be changed without
notification to and the approval of the Permit Issuing Rothority.
2. flow measurements
Appropriate flow measurement devices and motbods Consistent with accepted
scientific practices shall be selected and used to insure the accuracy and
reliability of measurements of the ootsms of monitored discharges. the
devices shall be Installed, Calibrated and Maintained to insure that the
accuracy of the rasurements _are consistent with the accepted Capability of
that type of device. Devices selected shall be capable of measuring fives
with a maximum deviation of less than 1 100 from the true discharge rates
throughout the tango of expected discharge "lusts. Once-tbrough condenser
Cooling water few which is monitored by pump logs, or pump bout meters as
specified in Part I of this permit and based on the manufacturer's pump curves
shall sot be subject to this requirement. abidance in selection,
Installation, calibration and operation of acceptable flow measurement devices
can be obtained from the following referancess
1. 'A abide of Ilethods and Standards for the Measurement of Inter Plow,
MS. Department of Co roe# Shtional Bureau of Standards, ns
Special Publication 421, llay 1975, 97 pp. (Available from the U.S.
abvermment Printing Office, Vashington, D.C. 20402. Order by SD
catalog lb: C13.10s421.1
2. -'Mater Measurement Manuals, O.S. Department -of Interior, Bureau of
fleclemation, Second alition, Reviaed Imprint, .1974, 327 pp.
(Available frois the O.S. Mvernment Printing Office, Washington,
D. C. 20402. Orde: by o*talow ib. 127.19/2ark211/2, Stock 1b. S/N
240,13-0027.)
Part 11
Page 11-6
(3) •tiw Measurement in Open lbannels and Closed Oonduits', O.S.
Depa•-tment of Commerce, optional Bureau of standards, .1BS Special
Publication 484, October 1977, 982 pp. (Available in papa
microfiche from Rtitional lkcbnical information ttsrtice (WTIS),
Springfield, 1h 22151. order by InTs Rb. 10-273 535/58T.)
(4) OWDLS am pl iance now Measurement Manual", O.S. 11hvironwnta
protection Agency, Office of Mater enforcement, Publication MCD-77,
September 1981, 135 pp. (Available from the General Services
Administration (=RQ& Centralised Mailing Lists Services, Building
41, Denver liederal Center, Denver, CD $0225.1
& !Monitoring Procedures
Monitoring must be conducted according to test procedures approved under 40
Matt tart 136, unless other test procedures have been specified in this permit.
d. renalties for lowering
Sbe.Clean Mater Act provides that any person who falsifies, tampers with, or
knowingly senders inaccurate, any switoring devioa or method required to be
maintained under this permit pball, upon conviction, be punished by a fine of
mot more .than 110A00 vev-violetion, v t by mpsisonment - or not -acre than 6
months per violation, or by both.
S. Notention of Records .
fte permittee sbail retain seoords of all monitoring
all calibration and maintenance records and all
recordings for continuous monitoring instrumentation,
required by this permit, and records of all data
application for this permit, for a period of at least ;
the sample, measurement, report or. application. 'ibis
• by the Permit Issuing Authority at any time.
S. Record Contents
Records of monitoring informhation aball includes

information, including
original strip chart
copies of all reports
used to complete the
rears from the date of
period say be estended
a. the date, etact place, and time of sampling or teasurementsl
b. The individual(s) who performed the sampling or rasuremhentst
a. the data($) analyses were performed= -
d. Me individual(s) who performed the analyses=
e0 she analytical techniques or methods Nadi and

f. She results of such analyses.
. 10

Part ti
page II-7
7. Inspection and Vhtry
1
The permittee shall allow the Permit Issuing Juthority, or an authorised
representative, upon the presentation of credentials and other documents as
may be required by law, tot -
a. lhter upon the permittee's premises where a regulated facility or
activity is located Or conducted, of where "Cords must be kept under
the conditions of this posits
b. Save oooess to and aopy, at reasonable times, any records that most
• be kept under the conditions of this permits
e. bhspeet -at reasonable time any facilities, equipment (includinq
monitoring and control equipment), practices, or operations regulated
W Enst d code's OU famits
d. Sample er 8061tor at reasonable times, --for the purposes of assuring
peh ?eoap1 a- .-Or ,as dlabe iae auEliorfiaid 0 ° !t"t Cl an Muss t
My aobaaaness Cr pari atifs a-C any 30at1on.
d2cTTDN D. REp amr, 1R=nt1"Wx
1. Mance in blecharve
2be peraittee shall give notice to the Permit Issuing Authority as soon as
possible of any planned physical alterations or additions to the permitted
facility. Ibtioe is required only wheat
a. The alteration or addition to a permitted facility may meet one of
the criteria for determining whether a facility to a new sources or
b. The alteration or addition could significantly obange the nature or
increase the quantity of pollutants discharged. This notification
applies to pollutants which are subject neither to affluent
limitations in the permit, mot to notification requirements under
Section D, Paragraph O-10(a).
2. Maticivated Ibnoompliance
the peraittee shill give aftance notice to the Permit Issuing Authority of any
planned change in the peraitted facility or activity wbicb 'my result in
noncompliance with permit requirements. Any maintenance of facilities, which
might necessitate unavoidable interruption of operation and degradation of
effluent quality, shall be scheduled during noncritical water quality periods
and carried out in a manner approved by the Permit Issuing Authority.

Part II
Page ii-t
3. transfer of Ownership or Cbntrol
t
h permit may be automatically transferred to another party its
a. The permittee notifies the Permit Issuing Authority of the proposed
transfer at least 30 days In advance of the proposed transfer dates
b. The motive includes a written agreement between the existing and new
permittees containing a specific date COS transfer of permit
responsibility, coverage, and liability between them= and
a. The Permit issuing Authority does not notify the existing permittee
of bis or bar Intent to modify or revoke and reissue the permit. if
this notice is mot received, the transfer is effective on the date
specified In the agreement mentioned In paragraph b.
d. Monitoring Y&Ports
See Part 212 of this permit.
Additional -Obnitorina- by -the =Permittee
;f. the...,.pesmittee-,monttors.....any.._.pollutant__mole. requan.tly_...taan--.required by this
permit, using test procedures approved under 40 CYR 136 or as specified in
this permit, the results of this monitoring shall be included in the
calculation and reporting of the data submitted in the Discharge Ibnitoring
Report (OM). Sikh increased frequency shall also be indicated.
S. Averaging of Measurements
Calcvlstions for limitations which squire averaging of measurements shall
utilise an arithmetic mean unless otherwise specified by the permit Issuing
Authority in the permit.
7. fterliance Schedules
Reports of compliance or noncompliance with, or any progress reports on,
interim and final requirements contained in any compliance schedule of this
permit shall be submitted no later than 14 days following each schedule date.
Any reports of noncompliance shall include the cause of nonoamplianoa, any
remedial actions taken, and the probability of seating the next scheduled
;equ irement. - +"

Y..
Part 21
Page 21-!
•. ?1?lntY-R.,. .us :'.eyortine
The permittee shall orally report any sonoompliance which 8V endanger health
or the environment, within 24 sours from the time the permittee becomes aware
of the circumstances. At written submission shall also be provided within S
days of the time the permittee becomes aware of the circumstances. She
written submission shall Umtata a description of the mormnelianee and its
eause, the period of aanoomplianee, including exact dates and tineat and it
the moncospliance has not been corrected, the anticipated time it is expected
to oantinue, and steps taken or planned to reduce, eliminate, and prevent
reoccurrence of the noncompliance. 42ho Permit Issuing Authority any verbally
*waive the written report, on a ease-by-ease basis, when the oral report is
made.
The following violations shall be included in the 24 hour report when they
sight endanger health or the environments
s- An ewIwtietle"d Wness WHO smads aft effluent limitation in the
permit.
O• . ,. a t esoeeea r quint 1isi sties.. in !ln--permit.
!. Oth e s lbncosmal i anee
The persittee shall report in narrative form, all instances of soneospliance
got previously reported under Section 0, Paragraphs O-2, O-d, O-7, and 0-8 at
the time monitoring reports are submittede lb* reports shall oontain the
information listed in Paragraph 0-89
10. Q,amts in Zdaebarges of 1bx1c Substances
The permittee shall notify the Vomit Issuing Authority as soon as it knows or
has reason to believe:
a. loot any activity has Occurred or will occur which would result in
the discharge, an a routine or frequent Oasis, of any toxic
substance (s) (listed at 40 QA 122, Appendix O, 'bbl* II and III)
which is not limited in the permit, it that discharge will exceed the
highest of the following 'notification levels:
(1) One hundred aierograas per liter (100 NIA) t
(2) 1WO hundred micrograms per liter (200 u9/1) for acrolein and
aerylonitrilet five hundred micrograms per liter (500 ug/1) for
2,d-dinitropbenol and for 2-01ethyl-44-dinitropbenolt and one
ailligraa per liter (1 mg/1) for antimonyt or
(3) dive (5) times the maximum concentration value reported for that
Pollutant (a) in the permit application.

-- Part 11
Page 21-10
b. That any activity has occurred or will occur which would result in
any discharge, on a son-routine or infrequent Oasis, of a toxic
pollutant (listed at 40 CPA 122, appendix O. Table ti and iii) which
is not limited in the permit, if that discharge will exceed the
highest of the following Inotifieation levels':
(1) live hundred microgram per liter (500 v9A)s
(2) an ailligras per liter Q tgA) for antimonyt gr
(_) Un (10) times the maximum concentration Value reported for that
pollutant (a) in the permit application.
11. Duty to sesooly
If the permittee wisbes to continue an activity regulated by this permit after
the expiration date of this permit, the pernittee must apply for and obtain a
mew permit. the application sbould be submitted at least 180 days before the
expiration date of this permit. The Permit Issuing authority my grant
permission to submit an application less than 180 days in advance but not
later than the permit expiration date.
More =PA is the Permit Issuing authority, the terns and conditions of this
permit are automatically continued in accordance with 40 CPR 122.6, only where
the permittee has submitted a timely and sufficient application for a renewal
permit and the Permit Issuing authority is unable through so fault of the
permittee to Issue a sew,..,Veralt before Abe< expiration =date.
2. signatory Regu irovents
All applications, reports, or information submitted to the permit Issuing
authority abali be signed and certified,
a. All permit applications aball be signed as follows:
(1) Pbr a corporation: by a responsible corporate officer. Par
the purpose of this section, a responsible corporate officer
weans: (1) a president, secretary, treasurer or vice president
of the corporation in charge of a principal business function,
or any other person who performs similar policy - or
decision-taking functions for the corporation, or (2) the
tanager of one or tore manufacturing production or operating
facilities employing more than 250 persons or having gross
annual sales or expenditures exceeding 25 million (in second
quarter 1980 dollars), if authority to sign documents has been
assigned or delegated to the manager in accordance with
corporate procedures.
(2) sbr a partnership or sole proprietorship: by a general partner
or the proprietor, respectively= or
(2) lbr a municipality, state, hderal, or other public agency: by
either a principal executive officer or ranking elected official.
b. All reports required by the permit and other information requested by
the Permit Issu ng Authority shall be signed by a person described
above or by a duly authc-ritsd representative of that person. A
person is s duly authorised representative only if:

part IZ
page I2-11

(1) The authorisation Is Met In writing by a person, described above=
• (2) ibe authoriv :ion specifies either an Individual or' a position
having .., • • !oiti-y for the overall operation of the regulated
facility or sativity, such as the position of plant manager,
operator of a well or a well field, superintendent, position of
equivalent responsibility, or an individual of position having
overall responsibility for environmental matters for the
company. CA duly authorised representative may thus be either a
mamed Individual or any individual occupying a eased position.):
and
(3) Um written authorisation is submitted to the permit Issuing
authority.
e. Ctrtifiostion. Any person signing a Oxa esnt under paragraphs (a) or
(b) of this section shall mate the following certifications
wf certify
attachments
a00DrdanC!
"to '

under penalty of law that this doauaent and all
were prepared ender the direction or supervision in
1e10 a meta -11111110111111" 1+
eflr pthir and . evaluate the information
Mased on slaw imgvt uy` of th0 ill abet Ot "ptlaons wlfo
Est' '° y `°lse?+?i lgs "-'d "biallat, °true, accurate, and eomplete?
I p aware that there are significant penalties for •ubaitting
false Inforiaation# including the possibility of fine and
imprisonment for knowing violations.•
13. Availability of Oaoorts
Ikeept for data determined to be confidential under 40 CPA part 2, all reports
prepared In accordance with the terms of this permit shall be available for
public inspection at,the offices of the permit Issuing Authority. As required
by the Act, permit applications, permits and effluent data shall not be
considered confidential.
14. Penalties for falsification of Lfoorta
The Clean Mter Act provides that any person who knowingly Dates any false
statement, representation, or certification In any record or other docusent
submitted or required to be maintained under this permit, including monitoring
seports or reports of compliance or noncompliance shall, upon conviction, be
punished by a fist of mot note than 810.000 per violation, or by Imprisonment
tot not afore than i months per violation, or by both.
S T3DN a DV=XTa=
1. permit issuita Antbority
The Magional Administrator of Sk legion iv or his designee, unless at some
time in the future the hate .tecei"s authority to administer Ire NPDLS
Program and' assuges irrisdictton.ove?r the prmits at which tima'; zbe Director
of the hats prograa receiving authorisation beoepaes the isleuiag auther1ty.

Part 22
Page II-12
2. let
'Act' means the Clean ft ter Act (formerly
Pollution Oontrol Act) Public tow 12-S00, as
Public taw 9S-S76. 11 0. i. C. 1251 at seq.
referred to as the lbderal Mates
amended by Public taw 95-217 and
1
3. .llassAXY Measurements
a. 2be 'average monthly Discharge' is defined as the total mats of all
daily discharges sampled and/or measured during a =dander month on
which daily discharges are sampled and measured, divided by the
number of daily discharges sampled and/or measured during such
month. It is therefore, an arithmetic mean found by adding the
weights of the pollutant found each day of the month and then
dividing this son by the number of days the tests were reported. the
limitation is identified as 'Daily Average' or Onontaly Average' in
Part I of the permit and the average monthly discbarge value is
reported in the • Average' column mnder 'Quantity' on the Discharge
Ibnitoring Faport (MR)*
b. The 'average weekly disebarge' is defined as the total met of all
daily discharges sampled and/or measured during the calendar meek an
which daily discharges are sampled and measured, divided by the
number of daily discharges sampled and/or measured during such reek.
_-St ,4s. A.berafore. An Arithattic mean -Pound --by adding Abe :-weights of
pollutants found each day of the week and then dividing this sus by
iaiLtion is
identified as 'Meekly Average' in Part I of the pesait and the
average weekly discharge value is reported in the lkaximua' column
under 'Quantity' on the DIR.
a. The %aximus daily discharge' is the total bass Neigbt) of a
pollutant discharged during a calendar day. If only one sample is
taken during any calendar day the weight of pollutant calculated from
it is the %sxLm daily discharge'. This limitation is identified
as* 'Daily llaximun', in Part I of the permit and the highest such
value recorded during the reporting period is reported in the
'Maxima' column under 'Quantity' on the STIR.
d. the 'average annual discharge' is defined as the total arts of all
daily discharges sampled and/or assured during the calendar year an
which daily discharges are sampled and measurede divided by the
number of daily discharges sampled and/or measured during such year.
It is, therefore, an arithmetic *tan found by adding the weights of
pollutants found each day of the year and then dividing this sun by
the somber of days the tests ware reported. this, limitation is
defined as 'Annual Average' in Part I of the permit and the average
annual discharge value is reported in the 'Average'- column under
!Quantity' on the SxR, The LKR for this report oball be subaitted in
January for the previous reporting calendar year.

Part 11
Page 11.13
t. 2meentration massurements 1
a.
b.
The 'leverage mionthly concentration% other than !or fecal coliform
bacteria/ is the sun of the concentrations of all daily discharges
sampled and/or measured during a calendar month an wbich daily
discharges use sampled and, measured/ divided by the number of daily
discharges sampled and/or measured during sueb month (arithnstic mean
of the daily concentration values). the daily concentration value is
equal to the concentration of a composite sample or in the case of
drab samples is the arithmetic mean 40e1glhted by SLOW value) of all
the samples collected during that calendar day. Me average monthly
count for fecal ooliforn bacteria is the Isometric mean of the counts
for samples collected during a calendar month. We limitation is
identified as 'Monthly Average. or •oaily Average', under OOther
&68AV?* Ja 41WW "Salt 00 p at#c1h
Value is reported under the .Aware" eolaM under iQnality• an the*
the. "?velalge .vr_v? 1 aft2la! tltan Los traat.z.
baetesia. to the sun at Ahe. concentrations of ail 11aYly "d stiharges
sampled and/or measured during a calendar greet an which daily,
discharges are ssmpled and measured divided by the number of daily
discharges sampled and/or *assured during such week (arithmstie mean
of the daily concentration values)* the daily concentration value is
equal to the concentration of a composite sample or to the case of
drab samples is the arithastie man lbeigbted by flow value) of all
the samples collected during that calendar day. The average weekly
count for fecal ooliforn bacteria is the 4eomettle mean of the counts
for samples collected during a calendar week. We limitation is
identified as 'Meekly Average. under .Other Leans. in Part 2 of the
permit and the average weekly concentration value is reported under
the •/Iasimum• column under .Quality an the MR.
e. The %&ximhnn daily concentration. is the concentration of a pollutant
discharge during a calendar day. Tt is identified as •Oaily Haxinnm•
under .other Liaits• in Part i of the permit and the highest such
value recorded during the reporting period is reported under the
'Maximum' column under .Quality on the OM
d. The •avsrage annual soncentratiOA•/ other than for fecal soliform
bacteria/ is the sum of the concentrations of all daily discharges
sampled and/or wasured daring a calendar year an which daily
discharges are sampled and wasured divided by the somber of daily
discharges sampled and/or measured daring such year (arithmetic mean
of the daily concentration values). The daily concentration value is
equal to the Ooncentration of a composite sample or in the case of
grab samples is the arithmetic mean heighted by flow value) of all
the samples collected during that Calendar day. The average yearly
court for fecal aolifzre haeteria is 0.0 geometric mean of the merts

•i
Part it
page 21-11
for samples Collected during a calendar year, This limitation is identified
as 'Annual Average' under 'other Units' in part i of the permit and the
average annual concentration Value is reported under the 'Average' column
under 'Quality' on the QlR. The ZKR for this report aball be submitted in
January for the previous reporting year.
• u amen _
a. Me effluent flow etpressed as Ml/daY 010D) is the 24 hour average
now averaged monthly. it is the arithmetic mean of the total daily
flows recorded during the calendar month. Mara monitoring
requirements for flow are specified in Part i of the permit the flow
rate values are reported to the SAVOTage• column under 'Quantity' on
the OM.
b. An elastantaneous flow mrasurement• is a meant* of flow taken at the
Use, of sampling, when both the sample and flow will be
representative of the total discharge. .
e. Nbers monitoring requirements for pv, dissolved mygen or fecal
eoliform bacteria are specified in part i of the permit, the values
art generally reported to the 'Quality or Concentration' column on
the UM
So =05 of iamoles
a. tbspcsite Sample: A •cosposite sample' is a combination of not less
than • influent or effluent portions, of at least 100 ml, collected
over the fall time period specified in part I.A. the composite
ample must be flow proportioned by either time interval between each
aliquot or by volume as it relates to effluent flow at the time of
sampling or total flow slam collection of the previous aliquot.
Aliquots may be collected manually or automatically.
b. Grab Sample= A 'grab sample' is a single influent or effluent
portion which is not a composite sample. 2be sample(s) shall be
collected at the period(s) most representative of the total discharge.
7. Dlculation of Means
So Arithmetic Nsan: The arithmetic mean of any set of Values is the
summation of the individual values divided by the number of
individual values.
n- :.s
b• aometrie ftan: The geometric mean of any set of valuee is the 11th
root of the product of the individual values where a is equal to the
number of individual values* 2be geometric mean is equivalent to the
antiloq of the arith"tie mean of the logarithms of the individual
values. !br purposes of calculating the geometric mean, values of
sero (0) shall be considered to be one (1).
k
i
P
Part It
Page 11-1S
a, weighted by Clow Valus: Weighted by flow value mans the sus ticn
of eacb concentration time its respective flow divided by the
susnation of the respective flows.
s. Calendar DIV
A calendar day is defined as the period from midnight of one day until
midnight of the cost day. Slowever, for purposes of this perait, any
consecutive 26-hour period that reasonably represents the calendar day my be
used for sanpl ing .
to Masardous Substance
A basardous substance means any substance designated under 40 CYR part 116
pursuant to section 111 of the Clean water bct.'
10. mxic Pollutant
tssls odiS t fs lntsst iZs ar toasts mks ifl7?sf a1 of
the Clean lister hot.

1

PART III
Page III-1
Permit No. NC0000272
PART III
OTHER REQUIREMENTS
A. Reporting of Monitoring Results
Monitoring results obtained each calendar month must be summarized for that
month and reported on a Discharge Monitoring Report Form (EPA No. 3320-1),
postmarked no later than the 28th day of the month following the ompleted
calendar month. (For exanQle, data for January shall be submitted by
February 28.) Duplicate signed copies of these, and all other reports
required by Section D of Part II, Reporting Requirements, shall be submitted
to the Permit Issuing Authority at the following address:
Environmental Protection Agency
Region N
Facilities Performance Branch
Water Management Division
345 Court A-M 6treet,--N-.E.._ ,.
Atlanta, Georgia 30365
B. Reopener Clause
This permit shall be modified, or alternatively revoked and reissued, to comply
with any applicable effluent standard or limitation issued or approved under
Sections 301(b)(2)(C), and (D), 304(b)(2), and 307(a)(2) of the Clead Water Act,
if the effluent standard or limitation so issued or approved:
1. Contains different conditions or is otherwise more stringent than any
effluent limitation in the permit; or
2. Controls any pollutant not limited in the permit.
The permit as modified or reissued under this paragraph shall also contain any
other requirements of the Act then applicable.
.1

PART III
Page III-2
Permit No. N00000272
C.
1.
Special Conditions
The permittee is required to develop a Plan of Study and conduct appropriate
effluent toxicity testing in order to measure oonpliance with Item 6 on
Page I-3 of the permit. All test organisms,.procedures, and quality
assurance criteria used shall be in accordance with "Short-term Methods
for Estimating the Chronic Toxicity of Effluents and Receiving Waters to
Freshwater Organisms," EPA-600/4-85-014, or other methods approved by
EPA. Chronic toxicity testing will be required for two test organisms;
testing will be used to determine the effects of the effluent on survival,
reproduction, and/or growth of the test organisms.. The requirements for
two test organisms may be waived upon adequate determination of the more
sensitive test organism. This determination shall include an analysis of
the testing results fram at least four toxicity tests required by this
permit. For the period of one year following initiation of the tests,
toxicity testing will be conducted once per month during July, August and
Septe rs and once every quarter for the remainder of the year. After
the first year of testing, toxicity testing will be oonducted once every
six months for the duration of the permit. One of these toxicity tests
will be conducted;-:during the; months, of July, August, or September. If
any one test `indicates that the NOEL is less than the,IWC For a specific
sampling period, a confirmatory toxicity test using the specified method"
ology and the same test species shall be conducted within 2 weeks. If
this confirmatory test indicates that the NOEL is less than the IWC for
the confirmatory test, this will constitute a violation of the permit.
In the event a violation of the toxicity limit results in an enforcement
action, any different or more stringent monitoring requirements imposed
in that enforcement action shall apply in lieu of this permit condition
for whatever period of time is specified by EPA in the enforcement action.
The permittee shall submit the Plan of Study to EPA within sixty (60)
days of the effective date of this permit. The EPA will review the Plan
of Study within thirty (30) days of its receipt and, upon approval, the
Plan of Study will became an enforceable part of this permit. Toxicity
testing shall cc mence no later than one-hundred and twenty (120) days
after the effective date of this permit.
2. The permittee is required to operate oxygen injection facilities at the
cutfall structure, at 0.9 miles downstream of the discharge, and at 2.1
miles downstream of the discharge. These facilities shall be operated in
a manner which will maintain the water quality standard for dissolved
oxygen in the Pigeon River downstream of the discharge.

1*
PART III
Page III-3
Permit No. NC0000272
The permittee shall monitor the Pigeon River at six locations downstream
of the discharge. The locations of instream monitoring stations.(show as
miles upstream of the confluence with the French Broad River) are listed
below:
River Mile
62.9
57.7
55.5
53.5
48.2
42.6
Monitoring requirements for this sampling program are specified below:
a) Sampling for dissolved oxygen and temperature shall be conducted once
per week for all stations. A minimum of two samples shall be collected
for dissolved oxyW and temFerature at each station for each day
samples are ollected. The sample type for instream dissolved oxygen
and temperature monitoring is "grab."
b) Monitoring for five day biochemical oxygen demand (BOD5) shall be'
conducted once per week for all stations. The sample type for instream
BOD5 samples is "grab."
c) Average daily flows shall be measured at river mile 55.5.
Limitations to measure compliance with the requirements of this special
condition are as follows:
a) The average daily dissolved oxygen concentration measured at river
mile 62.9 and 57.7 shall not be less than 5.0 mg/1 and the instantaneous
minimum dissolved oxygen concentration shall not be less than 4.0 mg/1.
b) During periods in which the flow at river mile 55.5 is equal to or
greater than 100 cfs, the average daily dissolved oxygen concentration
measured at river mile 55.5 shall not be less than 5.0 mg/l and the
instantaneous minimum dissolved oxygen concentration shall not be
less than 4.0 mg/1.
c) During periods in which the flow at mile 55.5 is less than 100 cfs,
the average daily dissolved oxygen concentration measured at river
mile 55.5 shall not be less than 8.2 mg/1.
3. Within 60 days after the effective date of this permit, the permittee
shall submit a study plan acceptable to EPA to further evaluate the
levels of chloroform in the effluent and the fate of chloroform in the
Pigeon River downstream of the discharge. The EPA will review the study
plan within thirty days of its receipt and, upon approval, the study plan
will become an enforceable part of this permit.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 30365
FACT SHEET
APPLICATION FOR
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
PERMIT 710 DISCHARGE TREATED WASTEWATER
710 U. S. WATERS
Application No: N00000272
1. SYNOPSIS OF APPLICATION
a. Name and Address of Applicant
Date: N O V 3 0 1987
Champion International Corporation
chaVion Papers Division
Main Street
Canton, Haywood County, North Carolina 28716
b. Description Of Applicant's Operation
Integrated bleached Kraft pulp and paper manufacturing facility
producing food board and fine paper.
c. Production Capacity of Facility (January December 1984)
694 tons per day BCT bleached Kraft
1013 tons per day fine bleached Kraft
d. Applicant's Receiving Water
The Pigeon River
For a sketch showing the location of the discharge(s), see attached map.
e. Description of Existing Pollution Abatement Facilities
Wastewater is treated by the following unit operations:
Grit removal, bar screening, pH control by C02 injection, coagulation
with polymer addition, disc screening, primary clarification, secondary
treatment by activated sludge, secondary clarification, and cascade
aeration. Domestic wastewater is chlorinated prior to blending with
process wastewater.

,,
f. Description of Discharges (data from April 7, 1986 application)
PRESENT OPERATION
Serial 001.- (process wastewater and Town of Canton domestic
wastewater)
Average Flaw - 44.4 MGD
Average Winter Temperature - 30.0°C
Average Summer Temperature - 36.20C
pH Range (std. units) - 6.6 - 8.5
Pollutants which are present in significant quantities or which are
subject to effluent limitation are as follows:
Effluent Characteristic
Reported Values
(from application - April 7, 1986)
Daily Average Daily Maximum
BOD5 14.4 mg/l 84.6 mg/1
TSS 19,130 lbs/day 47,986 lbs/day
Fecal Coliform 87/100 ml 640/100 ml
COD 266 mg/l 460 rg/l
Ammonia 2.17 mg/l 9.8 mg/l
-:True Color 782 std. units 1385 std. units
2;4,6 Trichlorophenol - Less •than=.l0,ug/1
Pentachlorophenol Less than 10 ug/1
Zinc (one sample) 80 ug/l
Chloroform (one sample) 86.3 ug/l*
* Analysis of 12 effluent samples collected by the permittee for the
period of February 11 through February 21, 1987 gave an average
effluent chloroform concentration of 350 ug/1 and a daily maximum
value of 480 ug/1.
2. PROPOSED EFFLUENT LIMITATIONS
Serial 001
See attached Parts I and III of the draft NPDES permit.
3. BASIS FOR EFFLUENT LIMITS AND PERMIT CONDITIONS
This NPDES permit contains effluent limitations and monitoring require-
ments included in the permit issued by the State of North Carolina cn
May 14, 1985, where appropriate. These requirements are included in the
NPDES permit as a result of the State of North Carolina's interpretation
of State Water Quality Standards as they apply to the Champion - Canton
Mill discharge.
1
.14
Total Suspended Solids (TSS):
This parameter is addressed in effluent guidelines developed for the BCT
Bleached Kraft Subcategory (40 CFR 430.80) and Fine Bleached Kraft Sub-
category (40 CFR 430.90) of the Pulp, Paper, and Paperboard Point Source
Category. The production values for the Canton Mill used to determine
appropriate limitations were established based on the definition contained
in 4U CFR 430.01(a) relating to annual production. No wet barking opera-
tions, log or chip washing or log flumes or log ponds are present at the
Canton Mill. Based on a review of production at the Canton Mill from
January 1981 to December 1985, the twelve month period from January 1984
to December 1984 was selected as the maximum annual production.
Guideline Factor Limits (lb/day)
Subcategory Production (1000 lb/day) Ave. Max. Ave. Max.
BCT Bleached Kraft 1387.5 12.9 24.0 17,899 33,300
(43U.82)
Fine Bleached Kraft 2026.5 11.9 22.15 24,115 44,887
(430.92)
Total Limitation 42,014 78,187
BOD
This parameter is addressed in effluent-guidelines developed for the BCT'
Bleached Kraft and Fine Bleached Kraft subcategories of the Pulp, Paper, and
Paperboard Point Source Category.
Subcategory
BCr Bleached Kraft
Fine Bleached Kraft
Guideline Factor Limits (lb/day)
Production (1000 lb/day) Ave. Max. Ave. ' Max.
1387.5 7.1
2026.5 5.5
Total Limitation
13.65 9851 18,939
10.6 11,146 21,481
20,997 40,420
Based on a wasteload allocation performed by the North Carolina Division of
Environmental Management (NCDEM), the effluent guideline-based limitation
for BOD5 is not sufficient to maintain the dissolved oxygen standard for
the Pigeon River. A copy of the wasteload allocation report is included as
Attachment 1. The conclusion of the report is that effluent limitations of
4 mg/l BOD5, 1 mg/l ammonia (expressed as nitrogen), and 6 mg/l dissolved
oxygen will maintain the water quality standard for dissolved oxygen in the
Pigeon River.

After a review of the environmental and economic impacts of meeting the
above water quality-based limits, the permittee has installed side stream
oxygenation facilities which serve to elevate the dissolved oxygen levels
in the Pigeon River. These oxygenation facilities are located at points
0.9 and 2.1 miles downstream of the facility outfall. This method of
achieving water quality standards has been determined to be acceptable
based on the requirements of 40 CFR 125.3(f):
(1) The technology-based treatment requirements applicable to the
discharge are not sufficient to achieve the standards;
(2) The discharger agrees to waive any opportunity to request a
variance under sections 301(c) or (g) of the Act; and
(3) The discharger demonstrates that such a technique is the preferred
environmental and economic method to achieve the standards after
consideration of alternatives such as advanced waste treatment,
recycle and reuse, land disposal, changes in operating methods,
and other available methods.
The requirements of this NPDES permit relative to effluent BOD5 limitations,
operation of side stream oxygen injection facilities, and instream dissolved
oxygen monitoring requirements are c nsistent with the terms of the permit
issued by the State of North Carolina on May 14, 1985. Based on review
of available data and the demonstration by.the permittee that requirements
of .40 CF12 325_.3( )"heve beenR-met, EPA concurs-,that,:the_ prapcssed ]imitations
for BOD5 in conjunction with proper operation of the oxygenation facilities
are adequate controls for the contribution of the Champion effluent to meet
the dissolved oxygen standard for the Pigeon River.
Compliance with the requirement to operate the side stream oxygenation
facilities is measured by monitoring instream dissolved oxygen levels in
the Pigeon River at stations located at mile 62.9, 57.7 and 55.5.' The
locations were selected due to the possible influence from the Waynesville
municipal wastewater treatment facility on downstream dissolved oxygen
levels. At the stations located at river mile 62.9 and 57.7, the average
daily dissolved oxygen concentrations must not be less than 5.0 mg/l. At
7Q10 flow conditions, the average daily dissolved oxygen concentration at
mile 55.0 required to meet the dissovled oxygen criteria for the Pigeon
River downstream of river mile 55.0 is 8.2 mg/l.
This instream dissolved oxygen limitation was calculated using the model
calibrated for the Pigeon River by NCDEM to simulate the CBOD and ammonia
levels in the Pigeon River downstream of the Champion discharge. At
flaws greater than 100 cfs, an average dissovled oxygen concentration of
5 mg/1 is required to maintain water quality standards for dissolved
oxygen downstream of river mile 55.5.

. •
Ammonia
An effluent limitation for ammonia was established by the NCDEM in order
to maintain the water quality standard for dissolved oxygen in the Pigeon
River. The measure of ccmplianoe in meeting this standard was replaced
with the permit requirements to operate oxygenation facilities and the
permit limits for dissolved oxygen as monitored at six locations in the
Pigeon River downstream of the outfall. Monitoring requirements are
included in the permit to provide data concerning levels of ammonia
discharged to the Pigeon River.
Effluent Dissolved Oxygen (D.O.)
The effluent limit for D.O. is based on the previously mentioned waste-
load allocation performed by the NCDEM and the requirements of the permit
issued by the State of-North Carolina on May 14, 1985.
Instream Dissolved Oxygen
See discussion of BOD5 above.
Color
The limitation for color is based upon meeting the North Carolina Water
Quality Standard for color (MAC 2B .0211(b)(3)(F)). The requirement to
meet an instream concentration for apparent color of 50 mg/1 Platinum
Cobalt units is based on EPA's interpretation of the North Carolina
narratlvstai?idard -for-
"--- Dolor SPA--requested ,that :North. Caro n a provide .
an interpretation of this standar"d on May 13, 1986-. North Carolina
failed to provide an adequate interpretation to assure om pliance with
the standard. In the December 1, 1986 Memorandum of Decision of the
Federal District Court for the Western District of North Carolina
(Champion vs. EPA), the Court upheld EPA's authority to object to the
North Carolina permit on the grounds that it failed to comply with
the requirements of the Clean Water Act-1 See Attachment 2. At this
point, it became necessary for EPA to interpret the standard in order to
develop federal permit limits for color that would meet North Carolina
and Tennessee law.
The basis for EPA's selection of a value of 5U color units for apparent
color as a numerical interpretation.of the North Carolina color standard
is similar to EPA's rationale for selecting 50 color units for the
Pigeon River in Tennessee based on interpretation of the State of Tennessee
Water Quality Standards. The narrative criterion for color in the water
quality standards for North Carolina and Tennessee provide the same level
of protection for aesthetic quality. Selection of the 50 color unit
value was based on information contained in "Water Quality Criteria"
(1968, Federal Water Pollution Control Administration), Quality Criteria
for Water (July 1976, U.S. EPA), and "Report on the Pollution of the
Interstate Waters of the Pigeon River" (February 1968, Federal Water
Pollution Control Administration).
1 The decision of the District Court has been appealed by Champion and is
currently under consideration by the United States Court of Appeals for
the Fourth Circuit.
1 1
•4
Permit compliance with the effluent limitation based on the color standard
is measured by the contribution of the facility effluent to the levels of
true color in the Pigeon River.
Since the narrative color provision of North Carolina Water Quality Stan-
dards was adopted after July 1, 1977, the permit includes a compliance
schedule to meet the final permit limit for color.
TrichlorophenolAgntachlorcphenol
The permittee certified that biocides used at the facility do not contain
either of these two compounds. This certification eliminates the require-
ment to include effluent limits for these two parameters based on the
provisions of 40 CFR 430.84 and 40 CFR 430.94. Quarterly monitoring
requirements for these two parameters were included in the NPDES permit
based on the requirements of the permit issued by the State of North
Carolina on May 14, 1985.
The monitoring requirements for trichlorophenol and pentachlorophenol
may be deleted from the draft NPDES permit based on information supplied
by either the State of North Carolina or the permittee which states that
the monitoring requirements contained in the permit issued by the State
on May 14, 1985 have been deleted from the terms of than permit.
Fec41--.Coliform Bacteria
Limitations in the NPDES permit for fecal coliform. bacteria are based on
the requirements of the permit issued by the State on May 14, 1985.
These limits are necessary to maintain water quality standards for the
receiving stream (15 NCAC 2B .0211(b)(3)(E)).
p
Limitations for pH are based on the requirements of the permit issued by
the State on May 14, 1985. These limits are necessary to maintain water
quality standards for the receiving stream (15 NCAC 2B .0211(b)(3)(G)).
Temperature
The requirements of the NPDES permit relating to temperature are based on
the conditions of the permit issued by the State on May 14, 1985. These
limitations and monitoring requirements as specified in the NPDES permit
are necessary to meet the requirements of the Section 316(a) determination
completed by the State and approved by EPA on August 6, 1985. (See Item
4 of this Fact Sheet.)
Flora
The daily average flow limitation is based on the requirements of the
permit issued by the State on May 14, 1985.

a
Monitorina Reauirements
With the exception of the monitoring requirements for temperature and
ammonia discussed above, all measurement frequencies, sample types, and
sample locations are based on the requirements of the permit issued by
the State on May 14, 1985. This includes COD, total residue, and settle-
able matter which are not limited but for which monitoring is required in
the NPDES permit.
Effluent Toxicity Requirements/Zinc
The effluent toxicity requirements and limitations are based on application
of North Carolina Water Quality Standards and previous effluent data for
the Champion facility relating to toxicity. 15 NCAC 02B .0208 states:
"The concentration of toxic substances in the receiving water, (either
alone or in combination, when affirmatively demonstrated to be non
bioaccumulative) when not specified elsewhere in this Section, shall
not exceed the concentration specified by the fraction of the 96-hour
LC50 value which predicts a no effect chronic level (as determined
through the use of acute/chronic ratios)."
NCAC 02B -O U (b) (4) (.jj) (*Action jawls for Toxic Subogtwoces" ) also applies
to the Champion discharge since the reported effluent concentration and
_ resulting instream concentration for zinc exceeds the action level for
this parameter.
Monitoring requirements for zinc have been included in the NPDES permit.
These monitoring requirements are also based on 15 NCAC 02B .0211(b)(4)(D).
Numerical limits for zinc are not being included in the NPDES permit
since the State Water Quality Standards do not contain a numerical
criteria for zinc and the biamnitoring requirements of the NPDES permit
are adequate to control toxicity due to the presence of zinc in the
facility effluent.
Previous bioassays conducted by EPA personnel have shown both acute and
chronic toxicity in the Champion effluent. In two chronic tests performed
on December 2 and December 7, 1983, chronic effects on reproduction and
growth occurred between 25% and 50% (expressed as effluent concentrations)
for Ceriodaphnia reticulata and Pimephales promelas, respectively.
In June 1987, toxicity tests were performed by North Carolina Division of
Environmental Management staff on the Champion discharge using Ceriodaphnia
as the test species. No chronic toxicity was exhibited during these test
using 100% effluent. The toxicity testing required in the permit is
necessary, therefore, to determine the variability of effluent toxicity
of the effluent and to provide a basis to measure eenpliance with North
Carolina water quality standards. Based on a satisfactory demonstration
that the discharge meets North Carolina water quality standards for instream
toxicity, the requirements of the permit allow for reduction in frequency
of the testing requirements after the. first year of testing.

.,,.
Chloroform
The limitation for chloroform was established based on application of the
EPA ambient water quality criteria for protection of human health consid-
erations through ingestion of contaminated aquatic organisms. A risk
level of 10-6 was used to determine the appropriate instream criterion.
This criterion is a result of EPA's interpretation of 15 NCAC 02B .0211
(b)(3)(L).
Recent data are available to update the, criteria for protection of human
health established in the "Ambient Water Quality Criteria Document for
Chloroform" (October, 1980). These data, summarized in "Health Assessment
Document for Chloroform" (September, 1986) can be used to update the 1980
criteria using a new dose-risk slope value. Using this information, an
instream criteria of 0.036 mg/l can be calculated for protection of human
health through ingestion of contaminated organisms. This criteria was
applied at the 30Q5 flow for the Pigeon River at the discharge point.
EPA is applying for the first time the narrative toxicity criteria of _
North Carolina water quality standards to the Pigeon River in establishing
the limit for this permit. Since a chloroform limit has not been previously
applied to the Champion discharge, the NPDES permit includes a compliance
schedule to mat the final permit limit for chloroform.
Total Dissolved Solids (TDB)
The monitoring requirements are included in the permit in order to provide
data concerning levels of TDS discharged into the Pigeon River.
4. REQUESTED VARIANCES OR ALTERNATIVES TO REQUIRED STANUNRDS
On August 6, 1985, EPA approved the Section 316(a) determination as issued
by the North Carolina Environmental Management Commission on October 11,
1984. This determination demonstrated that the effluent limitations
relating to the thermal component of the Champion discharge based on
application of North Carolina Water Quality Standards were more stringent
than necessary to assure the protection and propagation of a balanced,
indigenous population of shellfish, fish, and wildlife in the Pigeon River.
Therefore, the 316(a) determination was approved based on protection of
the appropriate use classification of the Pigeon River.
In a letter dated April 6, 1987, Champion requested a revision to North
Carolina's water quality standard for color pursuant to N.C. Gen. Stat.
§143-215.4. At this time, the State has not acted on that request.
Any revision to the standard must, at a minimum, meet Tennessee's water
quality standard for color, and must be adopted according to federal
water quality standards regulations (40 C.F.R. Part 131).

K
At the Tennessee state line, the Pigeon River is classified for the
following uses: industrial water supply, fish and aquatic life, recreation,
irrigation, and livestock watering and wildlife. The State of Tennessee
has interpreted Section 1200-4-3-.03(4)(d) of the Rules of Tennessee Depart-
ment of Health and Environment, Bureau of Environment, Division of Water
Pollution Control, to require that the Pigeon River must be at an instream
color level of 50 apparent color units in order to meet the narrative
water quality criteria for the recreational use classification. Should
North Carolina's standard be revised, EPA will seek o mnt on limitations
based on such a revision at a later date.
5. ADMINISTRATIVE RECORD
The administrative record, including application, draft permit, fact sheet,
public notice, State Certification, ccmmnts received, and additional
information is available by writing EPA, Region IV or for review and
copying at 345 Courtland Street, N.E., 2nd Floor, Atlanta, Georgia 30365
between the hours of 8:15 A.M. and 4:30 P.M., Monday through Friday.
Copies will be provided at a minimal charge per page.
6. REFERENCES AND CITED Doame rS
All materials and documents referenced or cited in this fact sheet are
eithee a` Dart--bf the Adin nistrat ve5-<Revord. as de.scribed] -in item 7: or are
readily available at EPA, Region IV. Information regarding these materials
may be obtained from the person listed below.
7. EPA CONTACT
Additional information concerning the permit may be obtained at the address
and during the hours noted in item 5, from:
Ms. Suzanne D. Potter
404/347-3004
8. PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Public Notice December 2, 1987
Public Hearings January 14 and 21, 1988
Final Permit Issued March 21, 1988
sy
Nr
.
9. PROCEDURES FOR THE FORMI AMN OF FINAL DETERMINATMN1S
a. Ommment Period
The Rnvironmental Protection Agency proposes to issue an NPDES permit
to this applicant subject to the aforementioned effluent limitations and
special conditions. 7hese determinations are tentative and open to
co,mont from the public.
Interested persons are invited to submit written comments -regarding
permit issuance or the proposed permit limitations and conditions.to the
following address:
Environmental Protection Agency
345 Cburtland Street, NE
Atlanta, Georgia 30365
ATTN: Ms. Suzanne D. Potter
All a fts received within thirty (30) days following the date of
public notice will be considered in the foaaulation of final
determinations with regard to proposed permit issuance.
b. Public Hearing
`7he EPA Regional Administrator will hold a public hearing if there is
a significant degree of public interest in a proposed permit or group of
permits, or if he determines that usefut information and data may be
obtained thereby. Public Notice of such a hearing will be circulated at
least thirty days prior to the hearing.
c. Issuance of the Permit
After consideration of all written comments and of the requirements
and policies in the Act and appropriate regulations, and, if a public
hearing is held, after consideration of all comments, statements and data
presented at the hearing, the EPA Regional Administrator will make
determinations regarding the permit issuance. If the determinations are
substantially unchanged from the tentative determinations outlined above,
the Regional Administrator will so notify all persons submitting written
comments, and, if a public hearing was held, all persons participating in
the hearing. If the determinations are substantially changed, the EPA
Regional Administrator will issue a public notice indicating the revised
determinations.
Unless a request for an evidentiary hearing is granted, the proposed
permit contained in the Regional Administrator's determinations shall
become issued and effective and will be the final action of the U. S.
fhvironmental Protection Agency.
s
a
ti
d. Evidentiary Hearing
If the determination are substantially unchanged, any interested
person may submit a request for an evidentiary hearing on the permit and
its conditions within thirty (30) days of the receipt of the notice
described in section c. If the determinations are substantially ganged,
any interested person may submit a request for an evidentiary hearing
within thirty days of the date of the public notice or of the date of
becoming aware of the determinations, which ever comes first. Such
requests will be within the time period if mailed by Certified lfeil
within the thirty day period to the Regional Hearing Clerk, Environmental
protection agency, 345 aurtland Street, N.E., Atlanta, Georgia 30365.
All requests must contain:
(1) The name, mailing address and telephone number of the person
making such request;
(2) A clear and concise factual statement of the nature and scope of
the interest of the requester;
(3) 7he names and addresses of all persons wham the requester
represents; and
(4) A statement bl' the requester that, upon motion of any party, or
wonte- by the Sres -Officer and without cast or voe a to any
a
other party, the requester shall make available to appear and testify,
the following:
(i) 7he requester;
(ii) All persons represented by the requester, and
(iii) All officers, directors, employees, consultants and agents of
the requester and the persons represented by the requester.
(5) Specific references to the contested permit terms and conditions,
as well as suggested revised or alternative permit terms and conditions
(not excluding permit denial) which, in the judgement of the requester,
would be required to implement the purposes and policies of the Act.
(6) In the case of challenges to the application of control or
treatment technologies identified in the statement of basis or fact
sheet, identification of the basis for the objection, and the alternative
technologies or combination of technologies which the requester believes
are necessary to meet the requirements of the act.
(7) Specific identification of each of the.. discharger's obligations
which should be stayed if the request is granted. If the request
contests more than one permit term or condition then each obligation
which is proposed to be stayed must be referenced to the particular
contested term warranting the stay.

(8) Each legal or factual question alleged to be at issue and its
relevance to the permit decision.
(9) An estimate of the hearing time necessary for adjudication.
(10) Information supporting the request or relied upon which is not
already a part.of the administrative record required by 40 CPR 124.18 (48
Fed. Meg. 142721 April 1, 1983).
2he granting of a request will stay only the contested portions of
the permit. Uwontested provisions of the permit shall be considered
issued and effective and the permittee must comply with such provisions.
Except, if the permit is for a new source or new discharge, the applicant
will be without a permit for the proposed new source or new discharge,
pending final agency action. She final agency decision on the permit
provisions contested at an evidentiary hearing will be made in accordance
with TLtle 40, Code of Federal Regulation, Subpart E, found at 48 Federal
Register 14278, et m.
e. Panel Hearing
In the case of an "Initial liewse,' including the first grant of an
NODES permit, -.or the first decision on a requested variance, if the
Reg4na1_AdQas?trator. elects to apply the provisions of subpart F and so
states in-the- publ-ic - Aotice ''Of F ?r f t permit, and.. -peF-ss max. request
the- Regional administrator to hold a panel tearing Dn the #t. ?iucta a
request must be made within the comment period of the notice described
above. Requests will be considered timely if mailed by certified mail
within the comment period. All requests must contain:
(1) A brief statement of the interest of the person requesting the
hearing;
(2) A statement of any objections to the draft permit;
(3) A statement of the issues which such person proposes to raise for
consideration of such hearing;
(4) She name, mailing address and telephone number of the person
making such request;
(5) A clear and concise factual statement of the nature and scope of
the interest of the requester;
(6) 11he names and addresses of all persons whom the requester
represents; and
(7) A statement by* the requester that, upon motion of any party, or
sua s, orate by the 'Presiding Officer and without cost or expense to any
other party, the requester shall make available to appear and testify,
the following:

(i) Zhe requester;
(ii) All persons represented by the requester, and
(iii) All officers, directors, employees, consultants and agents of
the requester and the persons represented by the requester.
(8) Specific referencesto the contested permit terms and conditions,
as well as suggested revised or alternative permit terms and conditions
(not excluding permit denial) which, in the judgement of the requester,
would be required to implement the purposes and policies of the Act.
If the permit for which a panel hearing is requested is a new source
or new discharger-the applicant will be without a permit for the proposed
new source or new discharger pending final Agency action. Panel hearings
will be conducted in accordance with title 40, Obde of Federal
Regulations, Subpart F, at 48 Federal Register 14285, It seq.

Cos
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p C O lltl'4 c 'ir<' w k t: I. f f_at
(Property Boundary Shaded
OYnf Ie ,• ?. ITT ?,
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a w0 Ae iii / • •? • •?• • u t , ' - •s:?; \'\ I `d r
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10 000 FEET!! ?.3I Ml. TO N.S. 276 1 332 1333 50' 1 4 331 1335
tted by Tennessee Valley Authority
by the Geological Survey
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'A in 1967 by Dhotogrammetnc methods using
aphs taken 1966 and by reference to TVA. USGS i• .;' ?,`
ted 1941. Mao field checked by TVA. 1967 36 MlLs , 1603'
;:I 19 M,LS NATIONAL !
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e

-A. Introduction
In August of 1980, a fluorescent dye time-of-travel study and an intensive
water quality survey were performed in the Pigeon River in western, N.C. between
the T-_wns of Canton end Revco. Data collected during these studies were used to
calibrate r .rate: quality _aodel to determine a wasteload allocation for the
Champion Paper Mill in Canton. The resulting allocation curve for a waste D.O.
of 6 mg/lAis shown in Figure 6 of this report. Any combination of GODS and
NH3-N on or below the curve represents an acceptable allocation for Champion.
A reasonable combination would be a SODS of 4 mg/l and a NH3-N concentration
of 1-mg/l. At these concentrations, Abe 9.0. of the modeled 20 mile reach of
the.Pigeoa River will not fall below S mg/l. if the River conditions are less
restructive or the same as design cond`irionw-used--in the 11!04a1.
8. Model Development
The EPA stream quality model (QUALL II) uses a combination of the hydraulic
characteristics of a stream and the system's chemical and biological reaction
rates to predict in-stream trends in water qualit/ parameters. The hydraulic
portion of the model requires functions describing the relationships between
flow, velocity, depth and reaeration (K2). Developed to predict measured
conditions in the stream, these functions theoretically adjust velocity, depth
and K2 to changes in stream flow. Calibration of the model's chemical parameter
predictions involves adjusting oxidation rates for organic nitrogen, ammonia
nitrogen and C80D to best predict the observed in-stream decay of these substances.
These rates are assumed to be independent of stream flow but vary with Ownbinb
temperatures. The calibrated Quall II model is adjusted to 7/10 low flows and
design temperatures for the final allocation calculations.
The Pigeon River hydraulic model was primarily based on data collected
-2-
by the N.C. Dept. of Natural Resources and Community Development (NRCD) in
August of 1980. This information was supplemented by data from a 1965 report
by the Department of the Interior on a biological investigation of-the Pigeon
and a 1980 N.C. Wildlife Department report by Wingate and Davies. Pigeon River
calibration flows were calculated from measured tributary discharges, ScIf-monitoring
data from Champion Papers and the Towns of Clyde and Waynesville and conservative
substance mass balances. Table l shows the measured-tributary and waste flows
used to calibrate the model. Additional stream flow contributeJ by snwll
tributaries and land runoff was estimated from mass balances of oeaaured
concentrations of total dissolved solids and chloride at the various stream
stations.
The Pigeon River's velocity at the time of the survey was calculated from
data.collected during a fluorescent dye time-of-travel study on the 25 and 26 of
August. The River's velocity changes only slightly over the twenty miles modeled
reflecting the relatively constant slope of 15 ft/mi. The average measured
velocity was 0.65 fps. Time-of-travel data-from a 5965 Dept. of.the interior
study of the Pigeon River was combined with the 1980 data to develop a power
function relationship between velocity and flow. Between 1965 and 1980, the
introduction of secondary waste treatment at the Champion Plant has changed the
water quality of the Pigeon River considerably. Despite these improvements in
water quality, the flow-velocity relationships measured in the two studies were
reasonably consistent. The constant velocity of 0.76 fps measured in 1965
reflected flows somewhat greater than those measured in 1980. The two sets
of data were combined to calculate the velocity power equation:
V - 0.143 Q(0.310)
The reaeration constant M) for the Pigeon model was calculated using
Owen's relationship between R29 velocity and depth:
K2 - 2.31 (9.41 (Velocity)0.67/(depth)1.85)
Cross sectional ?reaa between stations were estimated from velocity and flow data.
These were combined with widths measured for a 1980 N.C. Wildlife Study of the
liver's fisheries to calculate average depths along the modeled reach. The resulting
r. 3-
R2 of 2.01 day 1 was assumed to be constant for the entire model.
A relationship between depth and river flow was calculated with the:
following relationships:
A
?•A• ixd
d • VVW. (Q)
d • 0.026 Q
Where: V average river velocity
Q • average river flow
A • average cross;eectional area
W • average width*
d • average -depth
Temperatures measured in the Pigeon during the intensive survey ranged
from 330C at the outfall to about 250C at the downstream stations. Therefore,
0
three design temperatures were employed: 310C for miles 21.0 to 17.9+ 26 C
for miles 17.9 to 15.9 and 250C for miles 15.9 to 0.
Decay rates for organic nitrogen, ammonia nitrogen and CBOD (Rl) were
developed using average chemical concentrations measured at each station
(Table 2). Dissolved oxygen concentrations were corrected to the design
temperatures using an analysis based on percent saturation. The decay of all
modeled constituents was assumed follow first order kinetics. Rate constants
were determined by applying the X goodness of fit test. Chemical concentrations
measured at the river stations were compared to concentrations predicted by the
Quall 11 model with various reaction rates. The rate of organic nitrogen decay
was determined first, since its decay produces ammonia and thus directly affects
the ammonia decay rate. The best fit organic nitrogen rate was then incorporated
into the model and a best fit rate for ammonia decay was determined. Finally; a
decay rate for CBOD was found by fitting the rate to the dissolved oxygen data.
r
1
-4-
MOD concentrations in the stream are affected by numerous reactions. The
11 rate theoretically reflects CBOD oxidation rates. However, settling and
resuspension of bottom sediments also remove and replace CBOD in the Qverlying
water and influence the oxygen demand of CBOD. A rate fitted to dissolved
oxygen data incorporates these complex interactioW and models the stream
system as r wbvle.
Calibration of the Pigeon River model produced the following rate
constants:
.? Kl - 0.17 day 1
K2 - 2.01 day -1
Korg-N - 0.0 day 1 •
XNH3 • 0.8 day 1
The results of the ealibra?sd model se `illustrated in Figures 1-5?- The
solid line shows the constituent concentrations predicted by the model. The
three crosses correspond to the measured maximum, average and minimum
concentration at-each station. The scatter in the organic nitrogen data
(Figure 1) made accurate fitting difficult. The pictured calibration shores
the decrease in organic nitrogen concentration caused solely by dilution.
Ammonia nitrogen (Figure 2) decayed smoothy with travel down the Pigeon River.
A decay rate of 0.8 day 1 fit the data well. Although high for most systems,
this rate seems reasonable for the Pigeon River. The warm, turbulent, riffled
reaches of the river provide an excellent environment for nitrifying bacteria.
The metabolisn of these organisms is primarily responsible for the decay
ammonia in aquatic systems. Oxidised nitrogen (N02 + N03) is produced from
the oxidation of ammonia. The calibrated model (Figure 3) underestimated
the measured concentrations of nitrite and nitrate for most of the river. This
is probably due to additional runoff input to the river not accounted for in
the model. Although the CBOD oxidation was fitted to dissolved oxygen data,
the resulting predictions (Figures 4 i S) fit the measured data well.
C. Allocation
The calibrated model was adjusted to 7/10 flows for the allocation
determinations. USCS data was used to calculate 7/10 flows on the Pigeon and
all the major tributaries. Design waste flown were used for the Champion,

i
V

Clyde and Waynesville Wastewater Treatment Plants. Allocation flows are
Included in Table 1.
Wasteload allocation calculations aze routinely made at a calculated
de:igo'cE?pa azure. The design temperature calculated for Champion Papers
was 220C (71.6oF). However. the elevated temperature measured in the-Pigeon
below the Champion outfall are produced by the planp!a heated discbarge. It
seemed unreasonable to adjust the model to a calculated temperature never
seen in the river. The calibration model temperatures were therefore used
for the allocation detersiinations.
Othter boundary conditions were established as .follows:
Upstream temp. ...71.6°F
Upstream D.O. 7.9 mg/l (90% saturation)
him - Upstream CBOD • 3.0 mg/1 ?
Upstream NH3 - 0.05
Champion waste D.O. • 6 mg/1
A standard allocation procedure is employed for all Level C models.
With all boundary conditions set, the NH3-N in the waste is set equal to
zero and the CBOD concentration is varied until the resulting D.00.In the
simulated stream 'each does not drop below 5 mg/1. The CBOD is than set
to zero and the NH3-Nis varied until a D.O. -'5 mg/1 minimum is maintained.
The CBOD is then converted to BOD5 using the CBOD/BOD5 ratio determined for
the waste (3.65). These two points then define the allocation graph shown in
Figure 6. Any combination of NH3-N and BOD5 on or below this line respresents
an acceptable allocation for Champion Paper.
1

I-

Table 1. Measured Point-Source Flows for Calibration i Allocation Models ••
?
Calibration Allocation
Source Flow (cfs) Flow _Lc f S)
Pi=eon River upstream of Champion Paper .81.E+6 7S.1
Champion Influent 71.66 76.0
Champion Effluent 67.17 75.17
Beaverdam Creek 2.73 1.39
. Thichety {reek 0.70 0.36
Clyde WWTP 0.21 .198
Richland Creek 36.60 20.8
Waynesville WWTP 4.43- 9.3
Crabtree Creek 6.3:g 3.0
Jonathans Creek 36.01 29.6
Fines Creek 6.34 5.20
0

Pigeon River
Water Quality Data
August 26 and 27, 1980
Avg. D. 0.
@
Design Design
River temp Temp CBOD Org-N NH3-N 1N02+NO3
Station Mile C m211

P-1 63.31 31' 6.75 2.20 0.1 0.05 0.16
P-2 63.21 31 4.5 35.40 1.1 1.40 .05
.P-4 62.91 31 4.55 23.73 0.88 1.12 0.06
P-5 61.41 31 3.63 21.37 •1.06 0.94 0.37*
P-6 39.51 28 3.67 22.40 0.74 0.66 0.59
P-7 57.91 25 4.23 ' 21.48 0.77 0.53 0.70
P-8 55-091 Z5 - 5.24 1&11:- -0.8:9 0.41 0.78
P-10 54.11 25 6.11 17.30 0.57 0.33 0.71
P-11 52.81 25 5.99 19.39 0.82 0.28 0.74
P-11A 50.55 25 6.28 13.82 0.72 0.21 0.78
P-12 49.11 25 6.37 13.39 0.61 0.17 0.79
P-13 43.71 25 7.36 7.20 0.57 0.13 0.57

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Rio! 140-11,1-41

1•

s

IN THE DISTRICT COURT OF THE UNITED S':ATSS
FOR THE WESTERN DISTRICT OF NDR:H CAROLINA
ASHEVILLE DIVISION

L S. pEyn 1 ? 1yr?
? DSrai^t ?? C
STR??t Gf Rt
Plaintiff, C.
CIVIL NC. A-C-86-26
CHAMPION INTERNATIONAL CORPORATION,
and
Intervenor-Plaintiff,
FTATE OF NOR'T'H CAROLINA, ex rel.
DE?A:cT::ENT OF NATURAL RESOURCES AND
COMMUNITY DEVELOPMENT,
vorsus
Defendants,
UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY; LEE M. THOMAS, Administrator,
U. S. Environmental Protection Agency;
and JACK E. RAVAN, Regional
Administrator, Region IV, U. S.
Environmental Protection Agency,
and
Intervenor-Defendant,
STATE OF TENNESSEE, on behalf of the
Tennessee Department of Health and
Environment and the Tennessee
Wildlife Resources Agency,
and
Intervenor-Defendants.
PIGEON RIVER ACTION GROUP; and
the LEGAL ENVIRONMENTAL ASSISTANCE
FOUNDATION,

-G-

JUDGMEN,
TH:S MATTER having cache before the court on cross-=lions
for summary judgment, and the issues having been determined, as
shown by a Memorandum of Decision aaterec? :y `.:10 -t
contemporaneously herewith;
IT IS ORDERED, ADJUDGED, AND DECREED that plaintiffs'
motions for summary judgment are denied and defendants' motions
for summary judgment are granted.
IT -IS FURT1E-R--ORDERED .,that. .plaintif s' motion to supplement
the record is allowed.
The Clerk is directed to send copies of the Memorandun of
Decision and this Judgment to counsel for the plaintiffs and
counsel for the defendants.
This day of Decemberp 1986.

AVID 8.-SENTELLE
UNITED STATES DISTRICT JUDGE
IN THE DISTRICT COURT OF THE UN:TSD STATES
FOR THE WESTERN DISTRICT OF NORT:i CARCLIN?,
• ASHEVILLE DIVISION
CIVIL NO. A-C-86-25
CHAMPION INTERNATIONAL. CORPORATION,
and
STATE OF NORTH CAROLINA, ex rel.
DEPARTMENT n" NATjnii. RES71JR , 7 AND
...COMMUNITY DEVELOPMENT,
versus
UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY; LEE M. THOMAS, Administrator,
U. S. Environmental Protection Agency;
and JACK E. RAVAN, Regional
Administrator, Region IV, U. S.
Environmental Protection Agency,
and
STATE OF TENNESSEE, on behalf of the
Tennessee Department of Health and
Environment and the Tennessee
Wildlife Resources Agency,
and
PIGEON RIVER ACTION GROUP; and
the LEGAL ENVIRONMENTAL ASSISTANCE
FOUNDATION,
? fL
?40
` w -
?L
V f ` ?

v?

Plaintiff,
Intervenor-Plaintiff,
Defendants,
Intervenor-Defendant,
Intervenor-Defendants.

MEMOPANDUM OF DECIS I _''??
THIS MATTER 13 before the court on cross-motions for sumMary
judgment. For the following reasons, it appears to the court
that the defendants' motions are well taken.
FACTUAL BACKGROUND
Plaintiff Champion owns a pulp and paper mill located in
Haywood County, North Carolina, on the Pigeon River,
approximately 26 miles upstream from the North Carolina/Tennessee
border. The Pigeon River is S small river with a relatively low
annual average stream flow of 48 million gallons per day (MOD).
The North Carolina segment of the river is classified as suitable
for trout fishing from the source to the Canton water supply
intake for the Champion Mill. From the Canton water supply
intake to the state line, the river is classified as Class C
(secondary recreation and fish propagation). The river below the
mill is characterized as a fishery, supporting species that are
leas sensitive to pollution than trout, such as carp and
goldfish.

it
-3-
The intake for the Champion Mill diverts 46.4 mill-ion
gallons a day and returns a,,proximately 4_5 million gallons a d27-
During low flow conditions, the trill diverts virtua_ly all the
flow of the Pigeon River.
Or. June 3e, 1981, Champion's state-:slued National Pollutant
Discharge Elimination System (NPDES) permit for the Mill at
Canton expired. That permit did not contain any color
limitations.
North Carolina took no action on the renewal of Champion's
permit until Tennessee and a local citizens' group, Pigeon Raver
Action Group {PAAG), began to lobby North Carolina for action to
abate the pollution of the river. In January 1983, Tennessee
provided North Carolina with information indicating that
discharges from the Champion Mill were violating Tennessee's
water quality standards for each designated use. Tennessee
requested relssuance or modification of Champion's 1981 permit to
address its water quality concerns, noting that the 1.981 permit
was issued without prior notification of Tennessee pursuant to
Section 402(b)(3) of the Clean Water Act.
In February 1983, Tennessee and North Carolina met to
discuss appropriate terms for the renewal permit. Subsequent to
that meeting, Tennessee developed a model permit for the Champion
f ,
-4-
Mill reflecting the conditions that Tennessee would impose if it
were the permitting authority. That permit proposed a limit on
increase of apparent in-stream color of 40 color units at the
state line. The 40 color unit limit on increased apparent color
was ostensibly based on observations of laboratory samples and
norms: ranges of colt e in mr:.a xiterioaw4- Taiinessre's color
standard is in narrative form and contains no numerical limits.
In May 1983, Tennessee requested that North Carolina adopt
the model permit. Tennessee renewed this request in June 1983,
and in July, requested that the Environmental Protection Agency
f-EPA) -investigate and sasst an aoly-ng the Gh:ar?p on.-prob.len
Also in July, PRAG requested that EPA exercise careful oversight
of the renewal of the Champion permit.
At the prompting of Tennessee, representatives of North
Carolinas Tennessee and EPA met at EPA regional headquarters
during July of 19830 At that meetings the parties agreed to:
(1) develop permit limitations for the mill that would meet the
existing water quality standards of the Pigeon River; (2) consult
with the company in assessing the technical achievability of t!:e
limits; and (3) develop a technically acceptable solution.
To aid in developing the permit limitations, EPA reviewed
the general water quality criteria contained in the 1968 water

-5-
quality criteria book and the 1976 water quality criteria b,--.k,
as well as specific studies on Pigeon, Paver po:lition, to
determine what permit conditions would satisfy the color
standards of the two states. On the basis of the information
available concerning effects of color on fish and aquatic wife,
and aesthetic quality in the Pigeon River, EPA concluded that an
in-stream 50 color unit limit should be reflected in the
perm it.I
North Carolina and the EPA both conducted modeling analyses
to determine the actual color removal necessary to meet a 50
color unit in-stream limit at the state line. These modeling
aha.yses ultiMate'ly reaal'ted in substantially"dif-ferent color
removal figure3.2
On October 26, 1984, North Carolina gave public notice of a
draft permit. Tennessee requested a public hearing on the draft
permit to air its objections. The public hearing was held on
January 29, 1985. The draft permit conditions on color provided:
1Tennessee had earlier reached approximately the same
conclusion. S_ee, page 3.
2The data from EPA's analysis indicated a need for color
removal of up to 89%. North Carolina concluded that color
removal of up to 35% was necessary. Tennessee's analysis
resulted in a recommendation of up to 80% color removal.
* -6-
On or before April 91, 1985, the company will
construct, operate, and maintain a 0.100 MGD
ultrafiltration color removal demonstration facility.
:'he company will make all reasonable efforts to
achieve successful operation of the demonstration
facility with color removal efficiency of 75% based
on total effluent flow, if technically feasible.
On or before April 119 19869 the Environmental
Management Commission shall review the operation of
the demonstration facility, both in terms of :?mo???1
efficiency and cost. If the Environmental
Management Commission determines the demonstration
facility has been reasonably successful in achieving
color reduction, the company shall on or before
October 11, 1987, construct, operate, and maintain
permanent color removal facilities for the treatment
of approximately 2.0 MGD of processed waste water.
Company shall snake all reasonable efforts to remove
at least 75% of total mill effluent color, subject
to technical feasibility.
At the hearing, Tennessee presented two major objections to
the draft permit. First, it contended that Champion must be
required to meet a 75% removal requirement by October 11, 1987.
Tennessee argued that North Carolina should not qualify
champion's obligation by requiring 75% removal only if
technically and economically feasible through ultrafiltration.
Instead, the permit must impose an absolute requirement,
requiring Champion to apply for a variance if it determined
ultrafiltration was not feasible. Tennessee believed that the
variance process would then al-ow the state to require
alternative control techniques.
w
it
.7_
Second, Tennessee argued that the permit should li:ni.
Influent color level during low flow. While stating general
agreement with the 751 removal target contained in the permit,
Tennessee explained that, when the influent contains higher color
loadings than usual, 75% might not achieve a 50 color unit level
at the state border during 1.1..vt f;.?.)w cvnd l?tpo?.s. ien«ds. ee
recommended specific language defining the flow conditions during
which a limit on influent level would apply. In addition to
appearing at the public hearing, Tennessee presented detailed
recommendations in writing to North Carolina.
IO €ebruaryPA submitted adver_se.comments on the pereo_i_t.
Like Tennessee, EPA was concerned that 75S removal would not
achieve a 50 color unit level at the state line unless influent
levels remained at 700 to 800 color units.3 Additionally, EPA
requested a permit provision requiring that, if ultrafiltration
was not feasible, other color removal techniques be tested until
one is found that will meet the 751 removal requirement.
In the interim, North Carolina's water standard was changed
to include an aesthetic criterion for the first time. The EPA
requested that North Carolina submit a permit provision to meet
3The color concentration of effluent discharged by the mill
averages 700-900 color units on an annual basis, with variable
concentration that may exceed 1200 color units on some days. '

the amended North Carolina color standard. North Carolina fa::ed
to do so; instead, it issued a final permit one morph later.
The color limitations in the fins: permit were identica: to
those in the draft permit with the exception of the fol:ow!r.g new
paragraph at the end:
If the Commission determines that the demonstration
b raRsona'aly successful in
achieving targeted color reductions, it may order
Champion to undertake such additional action as it
deems necessary to achieve appropriate color removal
within a permit as determined by the Commission.
Appropriate color removal is currently considered to
be 75% removal of total mill effluent color under
present operational practices; however, the degree
of appropriate color removal may be subsequently
modified by the Environmental Management Commission.
Such _add tional measure.a_may include _pther Pozor
rez=ova1- proovs-s ss,- m-eth*ds or technlgu-es which the
Commission determines to be technologically and
economically feasible. Additional measures may be
ordered either singly or in combination. Any order
pursuant to this section shall entitle Champion to a
hearing in accordance with the procedural
requirements specified in G.S. 143-215.4 to contest
such order.
North Carolina, however, had failed to notify Tennessee of
North Carolina's decision to reject Tennessee's recommendations
on the Champion permit as required by Section 402(b)(5) of the
Clean Water Act. The state also failed to provide EPA With an
opportunity to comment on the final permit prior to issuance as
required by 40 C.F.R. 1123.44(a)(b)(j).

« _9-
On July 18, 1985, EPA notified North Carolina that issuance
of the Champion permit despite the objections of EPA violated the
NPDEE regulations and thus could not be considered a valid perm=t.
Therefore, EPA deemed the May 14, 1985, permit to be a proposed
permit as described in the regulations.
On August 6, 1985, EPA formally objected to the May 1't,
1985, permit because
(1) The permit did not assure compliance with the
North Carolina water quality standards in that
it provides no basis for how Korth Carolina
interprets, applies or enforces its narrative
color standards (aesthetic quality);
(2) The permit did not require Champion to
unequivocally comply with either Tennessee's or
North Carolina's standard. If the
ultrafiltration demonstration project is
unsuccessful, the permit does not require any
further color removal and only provides that
additional color removal "may" be required;
(3) The permit did not assure compliance with the
Tennessee color standard since it does not
assure the 50 color unit ifn-stream limit at the

W.

state line will be met when. influent values
exceed 800 color units at low flows. EPA also
noted that it had found North Carolina's
reasons for rejecting Tennessee's
recommendations to be inadequate pursuant to 40
C.F.R. S 123.44(c)(2), thereby invoking an
objection under 3 402(d)(2)(A).
Neither North Carolina nor Champion requested the public
hearing provided for in 40 C.F.R. S 123.44(e), and North Carolina
failed to modify the permit in accordance with EPA's objections
pursuant to 40 C.F.A. 5 123.44(h)(1). On November 139 1985, EPA
notified Champion that it had assuMed permitting authority. This
lawsuit ensued.
ANALYSIS
The issue before this court is whether EPA properly and
lawfully objected to the North Carolina issued permit, and assumed
jurisdiction over the permitting process. The EPA's 'August 6
objection letter included three separate grounds for objection.
If even one of those grounds is proper, then the defendants are
entitled to summary judgment.
Ak -11-
North Carolina's Color Standard
Shortly before issuance of the Champion permit, North
Carolina adopted and the EPA approved a revised narrative water
quality standard for color pursuant to Section 303 of the Clean
Water Act:
Colored . . . Wastes: Only such amounts as will not
render the water injurious to public health,
secondary recreation or to aquatic life and wildlife
or adversely affect the palatability of fish,
aasthetica.l quality or impair the waters for
designated uses.
15 IN.C.AC. ::28.,021t(b)(3),(f) (1985)•,. Prior.Lo this Lme,_the
North Carolina standard did not contain an aesthetic requirement.
EPA objected to the Champion permit in part because it failed to
assure compliance with North Carolina's revised color standard.
See Item 7, Administrative Record.
The EPA bases this objection on Section 402(d)(2)(b) of the
Clean Water Act, 33 U.S.C. S 1342(d)(2)(B), which allows the
Administrator to object to any permit proposed by a state that is
outside the guidelines and requirements of the Clean Water Act.
EPA v. State Water Resources Control Board, 426 U.S. 200, 206
(1976). An NPDES permit that does not contain conditions
adequate to achieve state water quality standards approved under
-12.
Section 303 of the Clean Water Act is outside the requirements of
both the Clean Water Act and regulations issued under the Act.
33 U.S.C. § 1342(5)(1)(9); 33 U.S.C. § 1311(b)(1)(c); Trustees
for Alaska v. EPA, 749 F.2d 549, 556-57 (9th Cir. 1984). The
NPDES regulations issued under the Clean Water Act also
.pecificAlly require that each V.PDES permit contain "any
requirements . . . necessary to: (1) achieve water quality
standards established under Section 303 of the Act." 40 C.F.R. §
122.44(d)(1). Thus, any permit that fails to contain conditions
necessary to achieve water quality standards violates both the
AcL and 40 C.F.R. § 122.44(4)(1). The Champion permit did not
contain or reference North Carolina's color standard. Item 18,
Administrative Record. Based on this omission, the EPA has
determined that the Champion permit fails to assure compliance
with North Carolina's Water standard and is therefore outside the
guidelines and requirements of the Clean Water Act. This
determination is to be given substantial deference an.d will be
disturbed only if it is arbitrary and capricious. Cleveland
Electric.Illuminatina Co. v. EPA, 603 F.2d it 5-6 (6th Cir. 1979).
Under the arbitrary and capricious standard, the Supreme Court,
in Citizens to Preserve Overton Park v. Volpe, 401 U.S. 402, 416
(1971)9 stated:

-13-
1T?he Court mist consider whether the decision was
based on a consideration of the relevant :actors and
whether there has been a clear error of judgment
. Although this inquiry into the facts is to
be searching and careful, the ultimate standard of
review is a narrow one. The Court is not empowered
to substitute its judgment for that of the agency.
(Citations omitted.]
Under this standard, the EPA's decision was not lkrbi"rary
and capricious. The objection was based on a properly
promulgated state water standard. 15 N.C.A.C. 28.0211(b)(3)(f).
In its objection letter of August 5, 19859 the EPA carefully

outlined the perceived deficiencies in the permit as applied to
the R.o,rth Carolina color standard. In addition, it told North
Carolina exactly what additions to the permit would resolve EPA's
concerns. Specifically, the EPA objected to the permit because
it failed to include the factors to be considered and the
methodology to be used by the Environmental Management Commission
to judge compliance with the color standard in the permit. Item
7, Administrative Record.
The EPA's objection to a proposed permit must be'based on
one of several enumerated grounds. 40 C.F.R. J 123.44(c). One
of the grounds listed is that "Etahe permit fails . . . to ensure
compliance with any applicable requirement of this part . . . ."
40 C.F.R. S 123.44(e)(1). (Emphasis"added.) A review of the
color removal section of the permit demonstrates that EPA's
It

•14-
concern with ensuring compliance is not addressed. Clearly,
Unless there is some method for measuring eortpl!ance, there is no
way to ensure compliance. The EPA reasonab:y reached this
conclusion. It considered the relevant factors, I.e., North
Carolina's water standard, the terms of the Champion permit and
the requirements of tha Clean Va:.er A%;i,. Thei't has been no clear
error of judgment. Volpe. _s_u, pra. Therefore, EPA's objection was
not arbitrary and capricious. Based on this objection, the EPA
properly assumed jurisdiction over the permitting process.
After the EPA objects, the permitting state (or other
interested party) may either request a public hearing,,or submit a
revised permit that meets EPA's objection within 90 days of
receipt of the objection. 40 C.F.R. S 123.44(e); 40 C.F.R. S
123.44(h)(1); 33 U.S.C. S 1342(d)(4). North Carolina's4 only
response to the objection came 92 days after the date of EPA's
objection letter. It is not clear whether the response was
within 90 days of receipt of the objection. Id_ However, even
if it was within the 90 days, it still does not meet the
requirements of 40 C.F.R. S 123.44. That section requires either
a request for a public hearing or submission of a revised permit.
See also 33 U.S.C. S 1342(d)(4)0 North Carolina's response was
4Champion did not respond at all.

-15-
simply a letter, not even styled as a revised permit. Item 4,
Administrative Record. Therefore, at the expiration of the 910
days, permitting authority passed to the EPA by operation of law.
.40 C.F.R. J 123.44(h)(1); 33 U.S.C. S 1342(d)(4). Because EPA's
actions with regard to this objection were not arbitrary or
capricious, E?' ?.s ant;t'_ad :o summary judgment based on this
single objection. However, this court will address the other two
objections as well.
UneQuivocal Compliance
The second ground for EPA's objection to the ChampSon
permit was that it did not require Champion to unequivocally
comply with either Tennessee's or North Carolina's water standard.
By the terms of the permit, Champion is required only "to make
all reasonable efforts to remove at least 75% of total mill
effluent color, subject to technical feasibility." Item 18,
Administrative Record. This requirement is subject to a finding
by the North Carolina Environmental Management Commission that
the demonstration facility has been reasonably successful, both
in terms of removal efficiency and oust. If the demonstration
facility is found unsuccessful, the Commission "may" in the
1 11

.
- 46-
future require some unspecified "additional action" to achieve
"appropriate" color removal, which is currently considered 755,
but may be changed on the basis of unspecified factors. See Item
18, Administrative Record. The EPA contends that, in the absence
of a definite obligation to achieve a certain level of color
removal that will ensure compliance with both Tennessee's and
North Carolina's color standards, the permit fails to satisfy
Section 301(b)(1)(c) of the Clean Water Act, 33 U.S.C. 4
13t1(b)(1)?e).
Again, this court must examine EPA's objection in light of
Lhe arba,trary. and capric ous standard. C1 eye-la
Illuminating Co. v. EPA, supra, at 5-6. This court must not
attempt to substitute its judgment for that of the EPA. Rather,
it "'must consider whether the decision was based on a
consideration of the relevant factors and whether there has been
a clear error of judgment.'" Id., at 6, -quoting Citizens to
Preserve Overton Park y. Volpe, su ra, at 416 (1971)'.
The EPA did not act arbitrarily and capriciously in
objecting to the permit based on its failure to unequivocally
require compliance with either North Carolina's or Tennessee's
color standards. The EPA is authorized to object to a proposed
permit if it does not en_sure_ compliance with the requirements of

w
-17-
the Clean Water Act, 40 C.F.R. 4 123.44(c)(1). Even without
going beyond the narrative -3tandards set out by both states, the
EPA could reasonably conclude that the permit fails to ensure
compliance. The language of the permit is clearly permissive.
If the demonstration project is deemed ur.zuec-:;z: ul, %, the
permit does not require any further efforts to achieve color
removal sufficient to meet the color standards. In objecting on
this basin, the EPA considered the narrative color standards of
both Tennessee and North Carolina, the terms of the permit and
the requirements of the Clean Water Act. Those were the relevant
fac,Lors, s.nd Lhe.re hasr .;been..-no :.=clear error of ??dgme=n t:
Therefore, the EPA did not act in an arbitrary and capricious
manner and is entitled to summary judgment on this ba313.5
The 50 Color Unit Standard
The third basis of EPA's objection was that the Champion
permit failed to require compliance with Tennessee's color
5 "
After EPA's objection, North Carolina and Champion had 90
days to respond either by requesting public hearing or by
submitting a revised permit. They did neither, responding only
by letter, clearly insufficient under 40 C.F.R. 3 123.44(h)(1)
and 40 C.F.R. S 123.44(e).

ti
standard ,. during per:cd9 of h_Z:: i.^.i j•_e::_
.. ._ve_3 and ;ou
The E?A and Tennessee concluded that, to com,;?y ;pit:^ ':'ennes ,;
narrative color standard, the Champ!on permit must contain
effluent limitations sufficient to -assure that the color of the
Pigeon River will not exceed 50 color units at the state line.
The EPA further concluded t:at the conditions in the Champion
..permit do nct ass%;r3 :::ri.,7_1.:nce t*ith the 50 color unit level
during low flow conditions when Influent levels exceed 800
unit3.6 The E?A, therefore, concluded that the per=it does
not contain effluent limits necessary to comply with Tennessee's
narrative color standard and objected to the permit as being
outside the guidelines and requirements of the Clean 'Water Act as
well as under the _Interstate dispute provision.
North Carolina and Champion contend that Tennessee has not
adopted, pursuant to Tennessee law, a water quality standard for
color of 50 color units and that Tennessee has not adopted,
pursuant to Tennessee law, an interpretation of its Vater quality
criteria for color to mean a color limitation of 50 color units.
North Carolina's objection was based on the fact that the
numerical interpretation of the narrative color standard had not
been formally adopted nor subjected to established public hearing
6See footnote 3, supra.

process and subsequent review and approval by the EPA as
prescribed by Section 303 of the Clean Water Act.
Once again, the standard of review is whether the EPA or
Tennessee acted in an arbitrary or capricious manner. Cleveland
Electric, suvra. Using this standard, this court will examine
the EPA's (and Tennessee's) decision to apply a numerical
ia:..ry:=tQt:on of the narrative standard to the Pigeon River an6
the EPA's (and Tennessee's) selection of 50 color units as that
numerical standard.
North Carolina contends that t- he EPA acted in an arbitrary
and capricious wanner by applying a numerical color standard to
the Pigeon liver when Tennessee has enacted only a narrative
standard. Clearly, Tenn-essee'a standard is a narrative standard
and contains no numerical requirements. However, that fact alone
does not establish that the EPA acted in an arbitrary and
capricious manner.
In 1974, the EPA identified color as a pollutant of national
concern in the pulp and paper industry because of the highly
colored effluent resulting from the pulp washing process.
Consequently, the EPA promulgated national technology based color
effluent limitations, for certain segments of the industry. 39
Fed. Reg. 18742 (May 29, 1974). These regulations were upheld In
t

-20-
America.. Pacer :nst`t::te v. :'rain., 5;: • .2A_ 32?, 3249-5.4 ::.:.
Cir•).• a ..er:ednb1r7 n • M r • .?h. d
`. , cert. , ??? U.S. 9+ (1974W). h e . ... oy , ;';P
color l-z:ta:icns :a 1.992 because it :cnc:jded that color was r.ct
a problem of uas! .form national con-:ern in the ind;+stry and snc,11d
instead be regulated on a case-by-case ba2:s as d::ta:ed by water
quality requirements. 47 Fed. Reg. 52,C'j :'Jcv. le, '9°.2:
(emphasis added). Therefore, it is the EPA's stated po:iay tnat
color standards be determined on a case-by-case basis. The E?A's
selection of a color standard applicable only to the Pigeon. R.1ver
is right in line with that stated policy. There has bee. no
clear error in judgment. Therefore, FFA's cations were within
the scope or its authority and not arbitrary and capricious. The
fact that the EPA selected a numerical standard does no',,. change
this result.
Obviously, the c..^.ly way a permitee tin this case, Champ:on)
can, adequately comply with the colon standard is for the perm::
to contain explicit and unequivocal direction as to how the
company can comply. A numerical requirement accomplishes this
result, informing the permitee of exactly what must be done to
meet the narrative color standard. In addition, it allows the
regulating authority to readily determine if the permitee is
complying with the color standard. Thus, the application of a
-21-
numerical interpretation of Tennessee's narrative standard is not
arbitrary and capricious.
Further, the EPA did not act in an arbitrary and capricious
manner when it selected 50 color units as that numerical
interpretation. After carefully examining the administrat!ve
record, this court concludes that it contained an adequate basis
upon which the EPA could decide that 50 color units was the
appropriate limit. The record references a number'of reports
which support a 50 color unit limit.? There is also
information in the record which indicates that the National
Council on Pulp and Paper determined that a change at t0'eolor
7See Items 169 21 and 50 which reference the following:
Water Quality Criteria, National Technical .
Advisory Committee to the Secretary of the
Interior (1968).
"Report on the Pollution of the Interstate
Waters of the Pigeon River (Tennessee-Nora':
Carolina), Federal Water Pollution Control
Administration (Feb. 1968).
Water Quality Criteria, U.S. EPA (1976).
Churchill, M., "Natural Reduction of
Papermill Color in Streams," Sewage &
Industrial Wastes, 661 (Vol. 23, No. , May
1951 .
There are also references in these items to a 1973 EPA report and
a 1979 report prepared by the North Carolina Department of
Natural Resources.
-22-
t
units was perceived by 50% of the people, wn.1le a charge of 40
color units vaa perceived by 90% of the people. In addition.,
there was information in the record that South Carolina has used
a 40 color unit standard. Item 51, Administrative Record.
Finally, the State of North Carolina, during a meeting with
representatives of the EPA and Tennessee, agreed to meet a u0 to
50 color 4,it level at the state line. Item 49, Administrative
Record. The record clearly indicates that the EPA considered the
relevant factors. See Cleveland, supra. There has been no clear
error of judgment and this court will not substitute its judgment
for the informed, technical judgment of the EPA. Id. The EPA's
selection of a 50 color unit standard was not arbitrary and
caprieious, acrd It was jus-tified in objecting to the permit as
being outside the guidelines and requirements in that the
proposed permit failed to ensure compliance. 40 C.F.R. S
123.44(c)(1).
The State of Tennessee also selected 50 color units as the
numerical interpretation of its narrative standard. (North
Carolina contends that the numerical interpretation is invalid
because Tennessee has not formally adopted the interpretation
through rule-making procedure. The EPA's stated policy is to
handle color requirements on a case-by-case basis. 40 Fed. Reg.
A A

=2,014 (Nov. 18, 10082). The Fo::rLy Cir.-U:t court of Appea:9
recently observed:
When, EPA decides to forego general regulations in
favor of having limits set by individual permit
writers, the Agency has trade a considered decision.
to set particular limitations on a plan:-by-plant
basis. For this court to deal with the issue . . .
as if it were a genera ruse-making matter wound be
to flout the Agency•s approach to the prob:em.
Kennecott v. U.S. EPA, 780 F.2d 4481 457 (4th "':r. 1?8?.r).
In addition, Tennessee law clearly authorizes this sort of
permit limitation-8 Any permit granted by the Commissioner of
the Tennessee Department of Health and Environment is required to
include:
The Brost stringent effluent limitations and
schedules of compliance oithe'r promulgated by the
p:oaz?a, r eg. st.1red imt:ete?t "Xny aDg:'llo b :W _t! ..
Quality standards, necessary to comply with an
areaaide waste treatment plan or, necessary to comply
with other state or federal laws or regulations.
T.C.A. S 59-3-108(e)(1) (emphasis added).9
North Carolina erroneously contends that numerical color
limits are not inc:.:ded la ogler :'e nnecsee permits. In the
Bowater Souther Paper Company permit, effective May 19 1984,
Tennessee imposed a 33 color unit increase limit.
9See also Tenn. Gen. Reg. 1200-4-1-.05(4)(d):
In the application of effluent standards and
limitations, water quality standards, and other
legally applicable requirements, the Commissioner
may, for each issued permit, specify average and
maximum daily quantitative limitations for the level
-24-
7n :'er.nessee's re:pcnse. f::ed at the Nutt Carr:!na
Environmental Management Comm:SS:Jn,s rub1!c hearing, Tennessee
thcrouga:y sjbstan:!&ter' its reccmmendat!cn of a 50 co=or ^.:
Emit. Item 159 Adm!nistrative Reeor:. Tennessee clearly
ecn3idered the relevant fa-tars, just as t::e EPA did.
Tennessee's se:ection of a SC color unit limit was not artitr_r•i
and capricious. :here was no c1--:&r error of judgment.
Therefore, the EPA Was also Justified in ob?ecting under the
interstate dispute provision. 33 U.S.C. § 1342,d)(2)(a).
Neither the EPA nor Tennessee acted in an arbitrary and
capricious manner in selecting 53 color units as the limit
applicable to Ch.ampion's discharge into the Pigeon River.
There ore, EPA's obje-^ltion was proper under bosh the interstate
dispute provision, 33 U.S.C. § 1342(d)(2);3), and under the
provision 6f allowing objection when the permit is outside the
9 (continued)
of pollutants in the authorized discharge in terms
of weight (except pH temperature, radiation, and any
Oftthtr , cll,:? tte n2 awwr-:-riately expressed by
weight). The Comn!ssioner, may, in addition to the
specifications of daily quantitative limitations by
weight, specified daily average and daily maximum
concentration limits for those pollutants sub' Oect to
limitation. :n addition, lim!tations expressed In.
other terminoioey may be required when necessary to
protect water quality or to describe adequate
operation of the treatment facility.
(Emphasis added.)

w
-25-
guide'. ines and requirements of the Act, 33 U.S.C. S 1342;di;2)ibi•
Thus, the EPA is entitled to summary Judgment. on this basis as
well.
Scope of EPA Permitting Authority
is this court upholds EPA's
assumption of jurisdiction (which it does), that jurisdiction
should be limited only to the color standard and that the other
permit terms should not be changed. This contention is Without
merit.
When the EPA objects to a permit, the state has 90 days to
request a hearing,. or submit a xevi`ted permit. If it does
neither, the EPA may issue a permit pursuant to 33 U.S.C.
1342(2) in accordance with the guidelines and requirements of
the Clean Water Act. 33 U.S.C. S 1342(d)(4). See also 40 C.F.A.
S 123.44(c); 40 C.F.R. S 123.44(h)(1).
The permit issued under that section must meet all
applicable requirements. 33 U.S.C. SS 1342(a)(1) and (2). It
clearly contains no other limit on the EPA's permitting authority
once jurisdiction passes to the Agency pursuant to 33 U.S.C.
4 .25-

S 1342(a). The provision o° 33 U.S.C.. S 1342(d)(2) requiring the
EPA to include in the objection letter the limitations and
conditions which the permit would include if it were issued by
the EPA was obviously intended to instruct the state as to how to
resolve EPA's objections, not to require the EPA to construct a
model permit at this stage of the proceedings. In fact, the EPA:
would be acting improperly if it foreclosed all changes in the
permit even before it obtained permitting authority-10
Under 40 C.F.R. S 123.44(h)(3), exclusive permitting
authority passes to the EPA. "Exclusive" clearly contemplates
that EPA obtains complete control over the permitting process.
In addition, under 33 U.S.C. S 1342(d)(4)9 after permitting
a.uthority_has passed to the EPA,` it "may" issue a permit. "May"
is clearly permissive and the EPA, with proper justification,
could deny the permit application.
There is no provision in the Clean Water Act for partial
permits. Either the state or the EPA has authority to issue the
permit. Here, that authority has passed to the EPA and that
10The permit program under 33 U.S.C. S 1342(a) is subject to
the same requirements as a state permit program under 33 U.S.C.
S 1342(b). 33 U.S.C. S 1342(a)(3). That section requires that
the program " . . . provide an opportunity for public hearing
0 0 0 •" 33 U.S.C. 5 1342(b)(3).
-27-
authority is exclusive. The EPA is not lfm:ted to considerat:cn
of color requirements.
Snecific_Ob'ect!ons and Further Rev=ew
Nhi:e it is likely that plaintiffs, particularly Chsmrion,
may have Specific objections to t-hl;.-"..er ;; irni r? ."inally
produced, either encompassed Within the topics discussed above or
in addition thereto, these ob:ections are simply not ripe for
discussion nor is this court the proper forum. Section 509 of
the Clean Mater Act, 33 U.S.C. 6 1369, vests the courts of
appeals with exclusive jurisdiction to review the Administrator's
actions ,int pro ;? -t- ti-no-new source perfo? a^ce `star;0ards.,
effluent standards for toxic pollutants, and other similar
decisions and, most specifically, in making determinations about
the adequacy of state NPDES programs and in issuing or denying
NPDES permits. 33 U.S.C. 3 1369(b)(1). The legislative history
E S7

-28-
of the 1977 amendments to applicable statutes indicates that
Congress contemplated no review until Tina: agency action.lL
Moticr, to Suvn:e=ent the Record
The motion Se ALLOWED, and the item: were considered in
reaching +1,4,. d
CONCLUSION
Based on the foregoing, the EPA is entitled to summary
judgment, and a Judgment to that effect will be filed
a.:mu:tAneoualy b rewiLh..
• This / day of w.I I ?? •ff ???? 1986.
it"Judicial review arising out o: this provision would .e in
the sivne manner as judicial review o- any EPA issued 402 Fermit."
H.R. Rep. No. 95-830, 95th Cong., 1st Sess. (1977). T.'-.,e
Administrative Procedure Act cited by plaintiff as an alternate
basis for jurisdiction for this court likewise requires that an
agency action be ripe for judicial determination and a final
decision. Abbott Laboratories v. Gardner, 387 U.S. 136, 148
(1967). Therefore, should plaintif:s or either of then have
valid objections to EPA's final action once it has exercised its
permitting authority, those objections can be raised in the
appropriate circuit court o: appeals at that appropriate time.
UNITED STATES DISTRICT JUDG7..