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North Carolina Depart~ent of Com

James B. H\lllt Jr., GovexnQr

Rick Carlisle. Secretary

Bu.$i1I.essllndustry Developm.ent Division
Phone: [phone]
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R:E: DCLIENTVISIT OFOR YOUR INFORMATION
ClOAT.A REQUt::ST DATTACHED DATA SHEETS

o PROJECT UPDATE
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Number of pages including cover: :;
301 Nortll Wllmlng1uD Street. P. O. BO;ll: 29S71, Ra.leigb, NC 2762b-0571
4th Floor. Education Building

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FACT SHEET

Mill Design, Construction, and Operation
Proposed Wisconsin Tissue Mill, Weldon; North Carolina

.

The proposed MILL SITE is located on Mush Island in Halifax County near the Town of
Weldon and occupies an area of approximately 500 acres. The site selection process involved
the evaluation of 67 sites in six southeastern states.
Proposed MILL CONSTRUCTION will take place in four phases with each phase
representing the addition of one paper machine. Full build-out of the mill (four paper
machines) is projected to be complete in 15-20 years with the addition of a new paper
machine projected to occur at approximately 5-year intervals dependent upon economic and
market conditions and the financial position of Wisconsin Tissue.
PROJECT COST for Phase 1 of the new mill will be approximately $180M and total project
cost is expected to be approximately $700M.
Proposed FACILITIES at the mill include: raw water intake, raw water treatment,
manufacturing, parking, process wastewater treatment (aerated stabilization and settling
basins), industrial solid waste landfill, treated wastewater discharge outfall, and
sediment/storm water ponds. Road, rail, and utility access to the site will be constructed
and/or upgraded. Facility layout was designed to avoid impact to on-site wetlands.
FURNISH for the mill will be virtually 100% recycle waste paper, post consumer waste,
newsprint, and corrugate. No timber harvesting or logging activities will be associated with
the proposed mill. The furnish will be re-pulped and processed by screening, cleaning,
washing, and bleaching through a deinking facility to supply both white and brown stack to
the paper machine. The process will not include the pulping or bleaching of wood chip pulp.
Mill PRODUCTION will include both bleached and unbleached (brown/naturallkraft grades
and some tissue paper) products. The white paper will be bleached in a single stage using
sodium hypochlorite. The bleaching method was selected by a task force after the evaluation
of current recycling and bleaching technologies. The selected bleaching process is the same
bleaching process used at an existing Wisconsin Tissue mill in Menasha, Wisconsin where no
dioxin (2,3,7,8-TCDD) has been detected in the wastewater discharge from the mill at
detection levels of 3.2 ppq. [For further information on dioxin, contact Mr. Bill Albright,
NCDENR, at 919-733-1236]. Average total production levels in TPD (tons/day) are
projected to be: Phase 1-274; Phase 2-438; Phase 3-685; Phase 4-849.
Mill PROCESS WATER will be supplied from the Roanoke River. Water usage at full
build-out is projected to be 10 MGD (15.5 CFS). The raw water intake structure will be
designed to exclude entrainment of fish eggs and larvae.
W ASTEW A TER will be treated in on-site aerated stabilization basins (ASB) and discharged
to the Roanoke River. Treated wastewater discharge volume is projected to be 10 MGD
(15.5 CFS) at full mill build-out. Average discharge flow for Phase I of the mill (3 MGD or
4.65 CFS) will be only 0.44% and 0.06% of the 7Q1O flow (1,050 CFS) and the average
annual flow (8,085 CFS) of the river, respectively. The discharge for the full build-out of the
mill (10 MGD or 15.5 CFS) is only 1.5% and 0.19% of the 7Q 1 0 flow and the average annual
flow of the river, respectively. Sanitary wastewater will be disposed through the Weldon
POTW.

The on-site industrial solid waste landfill will be constructed in phases and used exclusively
for the disposal of non-hazardous, non-putrescible, solid wastes. Projected SOLID WASTE
GENERATION rates in TPY (tons/year) are: Phase 1-60,000; Phase 2-36,000; Phase 3-
60,000; Phase 4-36,000. At full build-out, the mill is anticipated to have a 192,000 TPY
solid waste generation rate. The landfill will contain composite liner and leachate collection

.

.

.

.

.

.

.

.

L: \ W ork\life\33973\FactSheets\millfact.doc

03/23/99

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systems. Depending upon the timing of future mill phase expansions, the landfill is estimated
to meet the disposal needs of the mill for 20 years.
. EMPLOYMENT for Phase 1 is projected to be 250 persons. Approximately 600 new
ancillary jobs in the local economy are expected to result from the 250 new manufacturing
jobs. Mill employment at full build-out is expected to be 800-950 persons.
. ANNUAL PAYROLL for the proposed mill is expected to be $lOM at the end of Phase 1.
Economic impact on the community resulting from those wages is projected to be an
additional $17M added to the area economy.

L: \ W ork\1ife\3 3973\FactSheets\millfact.doc

03/23/99

FACT SHEET

Wastewater Treatment and Discharge
Proposed Wisconsin Tissue Mill, Weldon, North Carolina

. A Ni'DES PERMIT APPLICATION for discharge of treated process wastewater was submitted to
NCDENR on February 15, 1999.

. The proposed ON-SITE WASTEWATER TREATMENT facility will receive and treat process
wastewater, utility wastewater, landfill leachate, and some storm water runoff and discharge to the Roanoke
River in accordance with the NPDES Permit.

. Sanitary wastewater from the proposed facility will be discharged to the Town of Weldon publicly owned
treatment works (POTW).

. The treated PROCESS W ASTEW A TER DISCHARGE FLOWS projected for the Phase I and full build-
out of facility operations are 3 MGD and 10 MGD respectively. The full build~out of facility operations is
proposed to be achieved in four phases over a span of fifteen years to twenty years.

. The AVERAGE DISCHARGE FLOW for Phase I of the mill (3 MGD or 4.65 CFS) will be only 0.44%
and 0.06% of the 7QlO flow (1,050 CFS) and the average annual flow (8,085 CFS) of the river,
respectively. The discharge for the full build-out of the mill (10 MGD or 15.5 CFS) is only 1.5% and
0.19% of the 7Q 1 0 flow and the average annual flow of the river, respectively.

. W ASTEW A TER CONSTITUENTS projected to be present in the NPDES discharge to Roanoke River:

BOD: Prior to discharge the wastewater will be treated to comply with the EP A Categorical Effluent
Limitations Guidelines and Standards for the Pulp and Paper Point Source Category. More specifically, the
existing New Source Performance Standards (NSPS) for the Subpart I Subcategory (Secondary Fiber
Deink). The projected discharge limits for BOD for Phase I and full build-out flows are as follows.

Construction Total Flow 30-d Average 30-d Average
Phase BOD (lb/day) BOD (mg/l)
Phase I 3MGD 2,849 109
Full Build-Out 10 MGD 8,833 106

Actual BOD in the treated wastewater discharge will be less than the above limits.

TEMPERATURE: Projected discharge water temperatures are 30 oC and 15 oC for summer and winter,
respectively.

DIOXINS: No 2,3,7,8 TCDD or 2,3,7,8 TCDF has been detected (detection limit::;; 3.6 pg/l) in the outfall
from the Menasha Mill where a similar bleaching process (sodium hypochlorite) has been used.

CHLOROFORM: Based on Menasha Mill discharge data, chloroform concentration in the discharge is
estimated to be 80 ug/l.

OTHER CONSTITUENTS: The estimated concentrations of other constituents projected to be present in
the discharge are presented in the NPDES Permit application which is currently under NCDENR review.

. W ASTEW A TER TREATMENT will include biological treatment in a series of aerated stabilization
basins, addition of nitrogen and phosphorus as nutrients to enhance biological treatment, settling of solids
in a settling basin, flow monitoring, and discharge to Roanoke River in accordance with the requirements of
the NPDES Permit.

. REUSEIRECYCLING OF WASTEWATER as process water for production operations will be used. Up
to 70% reuse will occur.

L:\ Work\life\33973\FactSheets\wstwtrfact,doc

03/23/99, 3:33 PM

..

systems. Depending upon the timing of future mill phase expansions, the landfill is estimated
to meet the disposal needs of the mill for 20 years.
. EMPLOYMENT for Phase 1 is projected to be 250 persons. Approximately 600 new
ancillary jobs in the local economy are expected to result from the 250 new manufacturing
jobs. Mill employment at full build-out is expected to be 800-950 persons.
. ANNUAL PAYROLL for the proposed mill is expected to be $lOM at the end of Phase 1.
Economic impact on the community resulting from those wages is projected to be an
additional $17M added to the area economy.

L:\ W ork\life\33973\FactSheets\millfact.doc

03/23/99

FACT SHEET

Wastewater Treatment and Discharge
Proposed Wisconsin Tissue Mill, Weldon, North Carolina

. A NPDES PERMIT APPLICATION for discharge of treated process wastewater was submitted to
NCDENR on February 15, 1999.

. The proposed ON-SITE W ASTEW A TER TREATMENT facility will receive and treat process
wastewater, utility wastewater, landfill leachate, and some storm water runoff and discharge to the Roanoke
River in accordance with the NPDES Permit.

. Sanitary wastewater from the proposed facility will be discharged to the Town of Weldon publicly owned
treatment works (POTW).

. The treated PROCESS W ASTEW A TER DISCHARGE FLOWS projected for the Phase I and full build-
out of facility operations are 3 MGD and 10 MGD respectively. The full build~out of facility operations is
proposed to be achieved in four phases over a span of fifteen years to twenty years.

. The AVERAGE DISCHARGE FLOW for Phase I of the mill (3 MGD or 4.65 CFS) will be only 0.44%
and 0.06% of the 7Q 10 flow (1,050 CFS) and the average annual flow (8,085 CFS) of the river,
respectively. The discharge for the full build-out of the mill (10 MGD or 15.5 CFS) is only 1.5% and
0.19% of the 7Q1O flow and the average annual flow of the river, respectively.

. WASTEWATER CONSTITUENTS projected to be present in the NPDES discharge to Roanoke River:

BOD: Prior to discharge the wastewater will be treated to comply with the EP A Categorical Effluent
Limitations Guidelines and Standards for the Pulp and Paper Point Source Category. More specifically, the
existing New Source Performance Standards (NSPS) for the Subpart I Subcategory (Secondary Fiber
Deink). The projected discharge limits for BOD for Phase I and full build-out flows are as follows.

Construction Total Flow 30-d Average 30-d Average
Phase BOD (lb/day) BOD (mg/l)
Phase I 3MGD 2,849 109
Full Build-Out 10 MGD 8,833 106

Actual BOD in the treated wastewater discharge will be less than the above limits.

TEMPERATURE: Projected discharge water temperatures are 30 oC and 15 oC for summer and winter,
respectively.

DIOXINS: No 2,3,7,8 TCDD or 2,3,7,8 TCDF has been detected (detection limit ~ 3.6 pg/l) in the outfall
from the Menasha Mill where a similar bleaching process (sodium hypochlorite) has been used.

CHLOROFORM: Based on Menasha Mill discharge data, chloroform concentration in the discharge is
estimated to be 80 ug/l.

OTHER CONSTITUENTS: The estimated concentrations of other constituents projected to be present in
the discharge are presented in the NPDES Permit application which is currently under NCDENR review.

. W ASTEW A TER TREATMENT will include biological treatment in a series of aerated stabilization
basins, addition of nitrogen and phosphorus as nutrients to enhance biological treatment, settling of solids
in a settling basin, flow monitoring, and discharge to Roanoke River in accordance with the requirements of
the NPDES Permit.

. REUSEIRECYCLING OF W ASTEW A TER as process water for production operations will be used. Up
to 70% reuse will occur.

L:\ Work\life\33973\FactSheets\wstwtrfact.doc

03/23/99.3:33 PM

BASIS FOR PROJECTED WASTEWATER ANALYTICAL DATA

Treated wastewater effluent characteristics for the discharge to the Roanoke River (Outfall 001)
(for which analytical data are requested on the NCDENR Standard Fonn C and EP A Fonn 2 C)
were projected from various data sources. These sources included the following:

Effluent data for BOD and TSS are based on the EP A Categorical New Source Perfonnance
Standards as applied to all four phases of mill construction (full build-out).

For all other effluent constituents, the discharge characteristics were projected based on analytical
data of the effluent discharge from Wisconsin Tissue's secondary wastewater treatment facility at
the similar Menasha, Wisconsin mill. The concentration-based characteristics of the wastewater
generated from the Menasha Mill should be similar to those characteristics for all four
phases/production levels for the proposed mill.

Actual laboratory reports for these analytical data for the Menasha mill effluent are provided in
the Appendix to the NPDES Permit application.

Acute and chronic toxicity testing data of the Menasha mill effluent using Ceriodaphnia dubia
and Pimephales promelas also are included in the appendix of the NPDES Permit application.
The toxicity testing data indicate that the discharge from the proposed mill should exhibit no
acute toxicity or chronic toxicity at the instream waste concentration for the proposed mill
discharge.

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FACT SHEET

Industrial Solid Waste Landfill
Proposed Wisconsin Tissue Mill, Weldon, North Carolina

· An ON-SITE INDUSTRIAL SOLID WASTE LANDFILL will be constructed in phases
and used exclusively for disposal of non-hazardous solid wastes generated at the mill.
. NON-HAZARDOUS SOLID WASTES to be disposed on-site within the landfill include:

--water and wastewater treatment sludge,
--pulper rejects,
--solids from de-inking process operations, and
--non-putrescible general mill trash.

[For information on waste characterization, contact Mr. Bill Albright, NCDENR, at 919-733-
1236]
PUTRESCIBLE WASTES, such as food waste, will be disposed off-site at a permitted
municipal solid waste landfill.
Small quantities of a HAZARDOUS WASTE (cleaning solution from parts washing) will be
shipped to an off-site recycling facility.
· Projected WASTE GENERATION RATES for the 4 phases of mill construction are:
Phase I - 60,000 tons/year, Phase II - 36,000 tons/year, Phase III - 60,000 tons/year, and
Phase IV - 36,000 tons/year. At full build-out, the mill is anticipated to have a 192,000
tons/year non-hazardous solid waste generation rate.
· Landfill CONFIGURATION AND SIZE ultimately will consist of six cells and occupy an
area of approximately 50 acres at full build-out. The initial cell of the landfill will occupy
approximately 8 acres.
. LANDFILL LOCATION is within the easternmost portion of the property.
· Depending on the timing of future mill phase expansions, the landfill is estimated to meet the
disposal needs of the facility over an EFFECTIVE LIFETIME of 20 years. The initial cell
of the landfill will be designed to contain waste generated during the first 5 years of mill
operation.
. COMPOSITE LINER AND LEACHATE COLLECTION SYSTEMS will be constructed
within the landfill cells. Landfill design will meet or exceed NCDENR industrial solid waste
landfill requirements. The liner system will consist of 2 feet of compacted clay with a
permeability requirement of Ix 1 0-7 em/see or less overlain by a 60 mil layer of High Density
Polyethylene geomembrane. The leachate collection system will consist of sand or a
geosynthetic drainage net that will direct leachate toward a leachate collection trench.
Leachate removed from the system will either be pumped to a holding tank or piped directly
to the mill's wastewater treatment system.
. WASTE CONTAINMENT will be provided by 30-ft high berms. Waste placed above the
berms will have a maximum anticipated slope of 10 percent.
. A FINAL COVER will be constructed as waste within portions of the landfill reaches design
grades. The final cover will consist of a 40 mil geomembrane liner overlain by 2 feet of
protective soil cover. Vegetation will be established over the cover to minimize erosion.
. STORMWATER CONTROL within the landfill area will be designed for the 25 year, 24
hour storm. Any stormwater that contacts waste will be considered as leachate and will be
transported to the mill's wastewater treatment plant.

L:\W ork\life\33973\Fact Sheets\landfact.doc

03/23/99,3:35 PM

FACT SHEET

Water Resources
Proposed Wisconsin Tissue Mill, Weldon, North Carolina

AFFECTED ENVIRONMENT

· ROANOKE RIVER FLOW in the area of the proposed mill is controlled by the Roanoke
Rapids dam.
· MEAN MONTHLY FLOWS range from approximately 5,300 cfs in August to
approximately 11,200 cfs in April. From April 1 to June 15 of each year, the discharge from
the Roanoke Rapids dam is targeted at specific daily flows to provide a minimum and
maximum flow for striped bass spawning.
· The Roanoke River below the dam is considered to fully support DESIGNATED USES.
· There are no significant WATER QUALITY problems in the area of the river adjacent to the
proposed mill site. This area also is rated as good based on BIOLOGICAL CONDITION.
. There are no restrictions on FISH CONSUMPTION in this area of the river.
· There are several other MAJOR NPDES DISCHARGES immediately upstream from the
proposed mill site.

DESIGN/OPERA TIONAL FACTORS THAT MAY AFFECT WATER RESOURCES

· TREA TED PROCESS W ASTEW A TER DISCHARGE to the Roanoke River at full mill
build-out is projected to be approximately 10 MGD (or) 15.5 CFS. The average wastewater
discharge flow at full mill build-out represents only 1.5% of the 7Q 10 flow of the river and
only 0.19% of the average annual river flow.
BOD LEVEL: After on-site secondary treatment, the 30-day average BOD is projected to be
::;8,833 lb/day or 106 mgll.
W ASTEW A TER TEMPERATURE: Projected wastewater discharge temperatures are
300C for summer and 150C for winter conditions.
W ASTEW A TER CONSTITUENTS: Based upon wastewater characteristics from a similar
mill, 2,3,7,8-TCDD and -TCDF should not be present (at detection limits::; 3.6 pgll) and
other wastewater constituents will be at or below state NPDES permit limits. [For further
information on dioxin, contact Mr. Bill Albright, NCDENR, 919-733-1236].

MITIGATING FACTORS

. A NPDES permit application for discharge of treated process wastewater was submitted to
NCDENR on February 15, 1999. Treated wastewater discharge will comply with the
specified NPDES PERMIT LIMITS.

· QUAL2E-UNCAS modeling of the Roanoke River main stem between Roanoke Rapids and
Hamilton, conducted by NCDENR, predicts that the river has the ASSIMILATIVE
CAPACITY to receive the projected additional 8,833Ibs/day BOD loading from the
proposed mill without depressing instream dissolved oxygen concentrations below the
minimum of 4.9 mgll

· THERMAL MODELING will be used to assess potential effects that discharge water
temperature may have on ambient river water temperature below the proposed mill discharge.

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. No whole effluent toxicity is expected in the wastewater effluent at the instream waste
concentration for the proposed mill discharge based on ACUTE AND CHRONIC
TOXICITY TESTING of effluent from the Menasha mill.

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FACT SHEET

Aquatic Resources
Proposed Wisconsin Tissue Mill, Weldon, North Carolina

AFFECTED ENVIRONMENT

· At least 50 FISH SPECIES representing anadromous, catadromous, and resident species
inhabit the river near the proposed mill at some point in their life cycle.
· Several important stocks of ANADROMOUS FISH, such as striped bass, american shad,
and hickory shad utilize the upper reaches of the Roanoke river as a spawning area.
· In the Roanoke River, the PRIMARY SPAWNING AREA for striped bass is located near
Weldon (River mile 130), while the primary spawning area for American shad is from
Weldon to the Roanoke Rapids dam. Hickory shad spawn primarily in the lower reaches of
the river but may also spawn in the area of the proposed mill. Spawning occurs in the spring
at which time, striped bass and shad eggs are released into the water. These semi-buoyant
eggs drift downstream until hatching.
· No FEDERALLY THREATENED OR ENDANGERED AQUATIC SPECIES are
reported to occur in the vicinity of the proposed mill. However, several STATE LISTED
MUSSEL SPECIES are reported to be present immediately' upstream from the mill site and
could be present in the area of the proposed mill raw water intake and treated wastewater
discharge outfall. Thirteen freshwater mussel species have been documented to occur in the
lower Roanoke River.

DESIGN/OPERA TIONAL FACTORS THAT MAY AFFECT AOUA TIC RESOURCES

· RA W WATER WITHDRAWAL at full mill build-out is projected to be approximately 10
MGD (or) 15.5 cfs. Water will be withdrawn from the Roanoke River.
· TREATED PROCESS W ASTEW A TER DISCHARGE to the Roanoke River at full mill
build-out is projected to be approximately 10 MGD (or) 15.5 cfs. Water will be discharged to
the Roanoke River. The average wastewater discharge flow at full mill build-out represents
only 1.5% of the 7QI0 flow of the river and only 0.19% of the average annual river flow.
BOD LEVEL: After on-site secondary treatment, the 30-day average BOD is projected to be
:5:8,833Ib/dayor 106 mgll.
W ASTEW A TER TEMPERATURE: Projected wastewater discharge temperatures are
300C for summer and 150C for winter conditions.
W ASTEW A TER CONSTITUENTS: Based upon wastewater characteristics from a similar
mill, 2,3,7,8-TCDD and -TCDF are not expected to be present in the wastewater at detection
limits :5: 3.6 pgll and other wastewater constituents will be at or below state NPDES permit
limits. [For more information on dioxin, contact Mr. Bill Albright, NCDENR, at 919-733-
1236].

MITIGATING FACTORS

· A RAW WATER INTAKE SCREENING STRUCTURE will be designed to minimize
entrainment of the fish eggs that are released by anadromous fish species that spawn in the
area. [For further details on intake screen design, contact Mr. Bill Albright, NCDENR, at
919-733-1236].

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· QUAL2E-UNCAS modeling of the Roanoke River main stem between Roanoke Rapids and
Hamilton, conducted by NCDENR in 1996, predicts that the river has the ASSIMILATIVE
CAPACITY to receive the projected additional 8.833lbs/day BOD loading from the
proposed mill without depressing in stream dissolved oxygen concentrations below the
minimum of 4.9 mgll

· THERMAL MODELING will be used to assess potential effects that discharge water
temperature may have on migrating adult fish and eggs drifting down the river.

. CONSTRUCTION SCHEDULE for the intake and discharge structures in the river and any
other water-side construction activities will take into consideration the spawning window for
the anadromous fish species present.

. A MUSSEL SURVEY will be conducted in the river immediately adjacent to the proposed
site to identify the presence or absence of state listed freshwater mussel species. This survey
will be initiated as soon as acceptable river conditions permit.

· No toxicity to aquatic species is expected in the wastewater effluent at the instream waste
concentration for the proposed mill discharge based on ACUTE AND CHRONIC
TOXICITY TESTING of effluent from the Menasha mill.

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FACT SHEET

Wetlands and Terrestrial Resources
Proposed Wisconsin Tissue Mill, Weldon North Carolina

AFFECTED ENVIRONMENT

· PRESENT LAND USE of the property is for agriculture. The majority of the property
consists of cultivated fields (cotton, soybeans, and peanuts).
· There are approximately 15 acres of WETLANDS on the project property. These areas
primarily consist of approximately 12 acres of broadleaf, deciduous forested wetlands and 3
acres of a channelized stream/ditch.
. The treated wastewater OUTFALL PIPELINE CORRIDOR will cross bottomland
hardwood forest and crop fields between the northern property boundary and the Roanoke
River. This corridor will be approximately tOO-feet wide and cover approximately 3.5 acres.
· A WETLAND DELINEATION has been performed, and a USACE Section 404 and
Section 10 Permit applications will be submitted in May, 1999.
· NATIVE ECOLOGICAL HABITATS on the property are mainly limited to wetland areas.
· No PROTECTED OR SENSITIVE SPECIES have been identified on the proposed mill
property. Protected and sensitive ecological resources adjacent to the property have been
identified by the DENR Natural Heritage Program, and are shown in the attached figure.

DESIGN/OPERA TION FACTORS THAT MAY AFFECT WETLAND AND
TERRESTRIAL RESOURCES

· Areas of CONSTRUCTION impact to wetlands include: an entrance road crossing of a
tributary creek to the Roanoke River (- 0.5 acres), a river water intake structure (< O.1.acres),
and a wastewater outfall pipeline to the river (- 3.5 acres).
· OPERATION of the proposed mill will result in increased human activity on the site,
including noise and traffic associated with mill operations. Since 1918, Wisconsin Tissue has
operated, and even expanded, the Menasha, Wisconsin mill within a residential community.

MITIGA TING FACTORS

· The FACILITY LAYOUT has been designed to minimize disturbance to wetland areas on
and off the site.

· Mitigation requirements for construction impacts to wetlands will be determined through
consultation with the US ACE and NCDENR. Wetland MITIGATION PLANS will be
developed for the 404 Permit Application.

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03/23/99

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Sensitive Species

Weldon Quadrangle

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FACT SHEET

Air Quality
Proposed Wisconsin Tissue Mill, Weldon, North Carolina

AFFECTED ENVIRONMENT

· The Halifax County, North Carolina area is currently in attainment or unclassified for all CRITERIA
POLLUTANTS (S02, NOx, CO, VOC, Lead, PMI0).
· The mill site is 200 kilometers from the NEAREST FEDERALLY PROTECTED PSD CLASS I
AREA (Swanquarter Wildlife Refuge).
· NCDENR expects the area to be in attainment of the revised ozone and particulate matter standards
when they are implemented.
· NCDENR regulates TOXIC AIR POLLUTANTS as specified in the air quality rules at 2Q.0700.
The mill site emits two of these pollutants (chloroform and formaldehyde) above the threshold
emission rate that requires a permit.

DESIGN/OPERA TIONAL FACTORS THAT MAY AFFECT AIR RESOURCES

· An 80.4 MM BTU per hour capacity PACKAGE BOILER will be constructed to provide steam for
the mill site. The boiler will primarily fire natural gas but will have the ability to use No.2 or No.6
fuel oil as a backup fuel.
· A 330 TPD DEINK PLANT will also be part of the mill site. The mill will pulp, deink and bleach
recycle paper with sodium hypochlorite. The proposed will not use a bleached kraft pulping process.
Chloroform emissions will be generated from the bleaching process.
· A 390 TPD PAPER MACHINE, which includes a 53.7 MM BTU per hour air cap dryer to assist
with drying the paper, is also part of the proposed mill. The air cap dryer primarily fires natural gas,
but also is capable of burning propane as a backup fuel. Formaldehyde will be emitted from
combustion of natural gas in the air cap.
· A CONVERTING OPERATION converts the paper into product by cutting and folding into the
desired products.
· The maximum emissions expected from the mill site are 238.1 TPY particulate matter, 189.0 TPY
S02, 245.1 TPY NOx, 220.4 TPY CO, 240.8 TPY VOCs, 42.8 TPY chloroform, and 0.11 TPY
formaldehyde.
· An on-site natural gas-fired COGENERATION PLANT with a third party is under consideration as
part of the project. A final decision is expected in the next four to six weeks. If the decision is to
include a cogeneration plant on the site, appropriate air permit applications will be filed.

MITIGA TING FACTORS

· Based on projected annual emissions the proposed mill is not considered to be a major emission
source under the PSD regulations. A construction AIR PERMIT APPLICATION will be submitted
the week of April 2, 1999. .
· The package boiler will primarily be NATURAL GAS-FIRED. Natural gas is a cleaner burning fuel
than fuel oil.
· NSPS SUBPART Dc LIMITS VISmLE AND S02 EMISSIONS from the boiler. The NSPS limits
opacity to 20% and requires that the boiler burn no greater that 0.5 percent sulfur fuel oil.
· The deink plant is expected to produce up to 50% UNBLEACHED, 100% POST-CONSUMER
GRADE OF PULP, thereby reducing the annual chloroform emissions from the de ink plant.

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· The deink plant is conservatively designed to perform at ~O% OF THE ANNUAL AVERAGE
CHLOROFORM CONCENTRATION STANDARD set by NCDENR. The air dispersion
modeling of chloroform concentrations was conducted assuming that the mill site bleached] 00% of
the pulp produced in one year.
· Air dispersion modeling of formaldehyde emissions from the paper machine indicates that the off-site
ANNUAL AVERAGE CHLOROFORM CON CENTRA TION WILL BE $;1 % OF THE
STANDARD set by NCDENR.

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Facts About Dioxin From Six(6) DeInking Mills Using Sodium
Hypochlorite Bleaching in Northern Wisconsin Alone

1. No Detects(ND) of dioxin /furans (TCDDfTCDF) have been reported in effluents
from any ofthe six(6) deinking mills operating in Northern Wisconsin alone at
detection levels of less than 8 ppq (parts per quadrillion). These mill use sodium
hypochlorite bleaching.

2. Wisconsin Department of Natural Resources (WDNR) even DROPPED monitoring
requirements for dioxin in the WPDES permits issued in 1997 and 1998 for these
mills (including Wisconsin Tissue Mills). Following is a direct quote from the
September 1997 Fact Sheet prepared by WDNR for issuance of Wisconsin Tissue
Mills' WPDES permit: "Total phenol, aluminum, DIOXIN and zinc monitoring
required in the previous permit have NOT been retained based on results of an
updated evaluation of data which indicated that water quality limits and monitoring
are NOT necessary."

3. In reviewing the WPDES permit application of one of the deinking mills using
sodium hypochlorite, the WDNR wrote in its Permit Reissuance Briefing Memo (4th
March, 1995), " The elimination of dioxin and furan monitoring requirements is
WARRANTED based on [the mill's] pulping process and results of past monitoring.
Dioxin and furan are most likely generated at facilities that use Elemental Chlorine to
bleach chemically pulped wood. Since [the mill] does not pulp wood, the generation
of Dioxin and Furan is UNLIKELY."

4. WDNR has permitted one of the deinking mills using sodium hypochlorite bleaching
for the land application of sludge from deinking and bleaching processes. This soil
amendment has been applied to agriculture lands since 1987 without any
environmental problems. One other deinking mill using sodium hypochlorite is
conducting research on test plots in preparation for a commercial project to use land
application of the sludge to the benefit the soil.

5. The Lower Fox River (which has received the discharge from five of these Wisconsin
mills over the past years) has been studied extensively by the WDNR and the USEPA
for chemicals of concern in the past years. To date, the regulatory agencies have not
expressed any concern for dioxin, nor has any fish advisory been posted for dioxin in
the river.

Bharat Shah
Wisconsin Tissue
23rd March,1999