NC0000272_Historic_File_1992thru2005_20210127

BLUE RIDGE Nov 2 6 20
PAPER PRODUCTS INC.
November 25, 2003 ATER OUALI(Y SECTION
FSVHEVILL REGIONAL DEEM
Mr. Forrest Westall
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Avenue
Asheville, NC 28801
RE: Pigeon River Foam Investigation
Blue Ridge Paper Products Inc.
Dear Forrest:
In mid-October, Blue Ridge Paper Products hic. learned of concerns about foam on the Pigeon River
in the area below Crabtree Creek. The initial concerns were communicated directly to mill personnel
from Mr. and Mrs. Mershon, residents who live on the river approximately 3/4 of a mile below
Ferguson Bridge, approximately 14 miles down stream from the mill. The Mershons' concern was
that the mill effluent may be causing the foam events. Subsequent to this community call, mill
personnel began visual inspections of the river in this vicinity and did verify foam on the river. This
report documents the efforts and conclusions to the investigation that followed.
• On October 17 and 20, 2003, foam samples were collected from the river at the Mershon
residence. These samples were sent to the Hercules labs for analysis. Hercules is a
wastewater treatment chemical supplier to the Canton Mill. The foam samples were
compared against wastewater taken from the mill effluent. These results did not directly
indicate a source for the foam.
• On October 21, 2003, water samples were collected from several locations on the river, and
analyzed for BOD5, to evaluate organic loading on the river. These samples indicated a
significant increase in BOD5 at or below the Ferguson Bridge. Organic loading can
sometimes contribute to potential foam issues.
• On October 22"a, the Canton Mill took steps to increase the defoamer application rate by
66% at the wastewater treatment plant. This action was taken to see whether this would
materially effect down stream foam. Reconnaissance of the river did not see a change in
foam at the problem areas.
175 Main Street o P.O. Box 4000
Canton, North Carolina 28716• Phone:[phone]
Raising Your Expectations

Mr. Forrest Westall
November 25, 2003
Paget of
• On October 29 h, water samples were collected from 11 locations in the river, and also from
tributary streams below Crabtree Creek. These samples were analyzed for BOD5, organics,
inorganics, and were also subjected to a bench "foaming test."
• On October 31", Blue Ridge employees began making daily trips down the river to watch for
foam and to observe any variations in foam conditions. These observations continued
weekdays through November 12ei.These observations identified multiple tributaries along
the river that were generating varying amounts of foam to the Pigeon River. It was also
observed throughout this period that corn fields along the river had recently been harvested
and were being fertilized and plowed under and husks and other plant materials were floating
in the water.
CONCLUSIONS
The analytical results from foam testing and water testing did not directly indicate a source of the
foam. The results of foam analyses indicated that ether/polyols, esters, and polyamides are present
in both samples from the mill and from the river at the state line. These compounds can come from
both synthetic and natural sources. Organic esters are associated with naturally occurring wood
pitch or resin. Some of the natural sources of polyamides include the proteins of corn, soybeans, and
peanuts and casein. Organic esters were either the predominant or a major component of the organic
species present in the samples, including in samples from above the mill and from tributary streams
below the mill. Therefore, the analytical results did not provide a direct indication of a specific
source of foam. These results also indicate that if organic esters, which are naturally occurring
materials from wood, are the cause of the foam, then this could be a natural phenomenon occurring
each fall when significant amounts of leaves are decomposing in the watershed.
The analytical results from water samples also did not provide any direct evidence as to the source of
foam on the river. BOD5 analyses on October 21st indicated that there may have been a source of
organic material entering the river between Crabtree Creek and Ferguson Bridge,but that source
could not be identified with subsequent sampling on October 29a'.
Bench-scale foaming tests conducted on the water samples collected on October 29 h indicated that
all of the samples collected, whether upsteam of the mill, from the river below the mill, or from
tributaries below the mill, all had the potential to produce at least some bubbles and foaming. The
sample collected directly below the Waynesville WWTP generated the most resilient foam, while the
samples from Crabtree Creek(a tributary) and from the river at Ferguson Bridge, and above the
Mershon house all generated a foamy residue.
The most conclusive evidence of foam sources on the river came from the daily observations, taken
as early as possible in the morning. During the period of observation, foam was seen on the river on
most days that rain had not either dissipated it or washed out the collecting areas. While small,
"quarter-size" patches of foam can be seen on the river at some times, most of the foam, especially

Mr. Forrest Westall
kovember 25, 2003
Page 3 of 3
larger "rafts" of foam are typically only observed below Crabtree Creek. During the period of
observations, foam was seen on the river on at least 8 days. However, foam was also observed on
Mingus Branch above the mill once, Richland Creek twice, Crabtree Creek four times, and Fines
Creek six times.
As for the use of defoamer at the mill,there was no observed effect as a result of increasing the
defoamer application rate. Based on the Canton Mill reconnaissance of the river, significant foaming
on the main stem of the Pigeon River subsided by November 14. Defoamer application was returned
to normal application rates on November 17. River observations for the following week continued to
show no significant foam on the Pigeon River. However during this period, tributaries, particularly
Richland Creek and Jonathan Creek, had significant foam.
Based on this analysis we conclude that the foam event is most likely associated with seasonal
effects from falling leaves, corn materials, and other plant sources washing into the river.
If you have any further questions or comments, please feel free to contact me. I can be reached by
phone at [phone] or by e-mail at [e-mail].
Sincerely,
Z?y5eitt, P.E.
Acting Environmental Manager
Blue Ridge Paper Products Inc.
cc: Bob Williams
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Bob Kimzey October 10, 2003
Concern for the Pigeon River...
Purpose in discussing the Blue Ridge Paper Mill...
My purpose is to stop the excess discharge (excess pollution!)
that is causing bubbles and foam, and at times excess odor, on
the Pigeon River.
I do not want to hurt the workers or the mill itself. I feel that when
the paper mill closes, it will collapse "of its own weight" and I do
not want to add to this. I only want the mill to live up to its
agreements and obligations and at least get the river back to
the way it was when Champion International turned the
operation over to Blue Ridge. I want the river to be no worse
than it was in the years of 1999 and 2000.
Bob Kimzey
700 Walnut Ridge Drive
Clyde, NC 28721
[phone]

Anne C. Phillips _ n �� R
3919 Kingston Pike
Knoxville, TN 37919
865-523-6346
pq
July 3, 2002 Q r� V
Forest Westall JUL - 5 2002 D
Water Quality Supervisor
NC Division of Water Quality WATERQUA LITYSECTION
Asheville Regional Office ASHEVILLEREGIONALOFFlCe"
Interchange Bldg
59 Woodfin Place
Asheville, NC 28801
RE: Pigeon River below Champion Paper Mill - Water Quality
Dear Mr. Westall:
You have doubtless already been informed that paddlers and
others on the Pigeon River below the Canton mill have
noticed very dark discoloration. At the pipe discharging
the plant' s water back into the river, the water is almost
black.
We hope you .will enforce the court' s requirements as to
water pollution by Champion, and that you will do this
right away. It seems unlikely to many of us that this is
merely cosmetic - such bad color is very apt to indicate
the presence of poisonous materials in the water. We
wouldn' t want to drink it, and we assume the people who
live along the river wouldn' t want to either. I am a
paddler, but am more interested in health issues than
recreational ones in this case.
Thank you for your early attention to this.
Anne C. Phillips

DEHNR PUBLIC AFFAIRS Fax:[phone]P97 Rug 3 101 11:34 P.01J02
C� IV
ss jr
VVilham>i.
Michael F. Easley, Governor d , .
Secretary N ENR
Nw"T,C.nCLIN,o:aurt�nnr ar
Grv✓lOrvMwl.wn NN'lMI+ Ruuul.�...
N.C. Department of Environment and Natural Resources
Release: Immediate Contact: Ernie Seneca, [phone] ext. 208
Date: August 3, 2001
Distribution:-Targeted
J)WQ seeking wastewater color reduction at Blue Ridge Paper will in Canton;
public hearing set September 6
RALEIGH—A proposed wastewater permit and associated color reduction plan for Blue Ridge Paper
lnc.'s plant in Haywood County will be discussed Sept. 6 at a public hearing in Waynesville.
The N.C. Division of Water Quality is recommending that a 19 to 29 percent color reduction be achieved
over the next five years along with tighter permit limits at the pulp and paper mill in Canton.
"Substantial improvements have been seen in the facility's wastewater discharge over the past decade,
and that has translated into a healthier Pigeon River," said Forrest Westall, water quality supervisor of DWQ's
Asheville Regional Office. "We.want to continue on that track and see even more improvement and color
reduction"
The hearing is scheduled at 7 p.m. in the Tuscola High School auditorium, 564 Tuscola School Road.
Built in 1908, the mill is currently permitted to discharge 29.9 million gallons of treated wastewater daily
into the Pigeon River in the French Broad River Basin. Champion International Corp. of Stamford, Conn. owned
and operated the plant until 1999,when employees purchased and renamed it.
Blue Ridge Paper is seeking renewal of its National Pollutant Discharge Elimination System permit and
two'variances for color and temperature. Previously renewed in December 1997, the permit and variances are set
to expire Nov_30, 2001, DWQ has been working with the U.S. Environmental Protection Agency and the
Tennessee Department of Environment and Conservation on the requests.
"We are committed to seeking what is most technically and economically feasible,"Westall said.
The mill has achieved about a 50 percent reduction in color—a byproduct of the pulping process—since
an agreement was reached in 1997. That agreement was between North Carolina, Tennessee,the EPA, City of
Newport,Tenn.; Cooke County,Tenn.;American Canoe Association,Tennessee Environmental Council and the
company.
(more)
Don Reuter,Director
Office of Public Affairs FAX[phone]
Phone[phone] n a to n ainet
1601 Mail Service Center,Raleigh,NC��7�69O�P 6�Ty J A�mat vc Action L•mpluyer

DEHNR PUBLIC AFFAIRS Fax:[phone] Aug 3 '01 11 :35 P. 02/02
2-2-2
The reduction in permitted color loading has been from 99,168 to 48,000 pounds per day. The company
spent more than $330 million to upgrade facilities and treatment levels.
At the Sept. 6 hearing,DWQ staff will explain the draft NPDES permit and the variances. Blue Ridge is
seeking renewed variances because it is unable tamcet state standards for color and temperature.
DWQ is also proposing a 12.5 percent reduction in the permit's daily maximum load for biochemical
oxygen demand.
The sign-up period for comments begins at 6:30 p.m. on the night of the hearing. Individual speaking
times could be limited depending on the number of people who register to comment_
DWQ will consider the comments and any additional information gathered. A decision on whether to
reissue the permit and'grant the variances is to be made within 90 days of the hearing,unless the comment period
is extended.
Written comments should be sent to Mr.Michael Myers,Division of Water Quality/NPDES Unit, 1617
Mail Service Center,Raleigh,NC 27699-1617.
Copies of the draft permit and proposed variances are available for public viewing during normal
business hours at the DWQ central office at 512 N. Salisbury St. in Raleigh, [phone] extension 508;
Asheville Regional Office at 59 Woodfin Place, [phone].
Don Reuter, Director
Office ofPublic Affairs FAX [phone]
Phone [phone] don cute alncmail.net
1601 Mail Service Center,Raleigh,NC Equal opp rtuumry/Afrumadve Acdon Employer

Health Services, NC Dept. of Human
Resources issued advisory against eating
fish from Pigeon River as per studies
showing a presence of dioxin in fish and

May 2, 1986 - Motion by EPA to dismiss Champion
suit denied.

Page 3
sediment downstream of the mill; albeit
not in Champion' s effluent. Dioxin not
regulated to date in the proposed NPDES
Permit .
July 13, 1988 - EMC issues water quality variance from
North Carolina color standard allowing
NPDES Permit for 85 True Color Units to be
placed in proposed NPDES Permit.
August 18-19, 1988- Tennessee color variance hearing in
Newport, Tennessee.
December 23, 1988 - Tennessee denies Champion' s color variance
request from standard, preventing
agreement reached 3/9/88 from being
formally enacted.
March 15, 1989 - EPA Issued a draft Discharge Permit for a
reconfigured Canton Mill, allowing it to
operate during reconfiguration.
July 12, 1989 - Second draft NPDES Permit (public notice)
for Champion with color limit consistent
with EMC variance and Tennessee
limit of 50 units at State Line. Permit
also including additional requirement for
chloroform and dioxin. Permit provided
for reduction in flow from 48 . 5 MGD
to 29 MGD and three (3) year schedule for
compliance (down from 5 year schedule in
initial draft) .
August 17, 1989 - Newport, Tennessee public hearing on EPA
NPDES Draft Permit .
August 24, 1989 - Asheville public hearing on permit .
September 8, 1989 - DEM issues Section 401 Water Quality
Certification for proposed Champion Permit.

September 25, 1989- Champion NPDES Permit issued by EPA.

Page 4
October 14, 1989 - Permit appealed first by Environmental
groups and then by Champion. EPA
administrative law judge grants hearing.
Hearing to be scheduled.
March 27, 1990 - Champion announces implementation of
modernization project despite pending legal
issues . Estimated cost of project is $250
million.
1990 - 1991 - Legal issues continue to be fought before
EPA Administrative Law Judge. Champion
continues modernization project.
April, 1991 - EPA Administrative Hearing held in Atlanta,
Georgia.
Early 1992 - Administrative Law Judge issues final
decision essentially leaving permit as is .
No appeal requested.
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�pF W A rFgq Michael F Easley,Governor
William Ross Jr,Secretary
r North Carolina Department of Enviramem and Natural Resources
O - - -- Y Alan W Klimek,P E Director
Division of Water Quality
December 1, 2004
198
Mr. John J. Pryately
Blue Ridge Paper Products Inc.WTP
P.O. Box 4000
Canton, NC 28716
SUBJECT: Wastewater/Groundwater Laboratory Certification Renewal
Dear Mr. Pryately:
The Department of Environment and Natural Resources, in accordance with the provisions of NC GS 143-215-
.3 (a) (10), 15 NCAC 2H .0800, is pleased to renew certification for your laboratory to perform specified
environmental analyses required by EMC monitoring and reporting regulations 15 NCAC 2B .0500, 2H .0900 and
2L.0100, .0200, .0300, and 2N .0100 through .0800.
Enclosed for your use is a certificate describing the requirements and limits of your certification. Please review
this certificate to insure that your laboratory is certified for all parameters required to properly meet your
certification needs.
Please contact us at 919-733-3908 if you have questions or need additional information.
Sincerely,
JJamers W. Meyeraboatory Section
Enclosure
cc: Gary Francies
p
I
- -i
ASH, it r?[IfiQt =Il fl)��11C[
NOnrIhCarolina
,�ntrrra//�
Lnhornlury Scclion 1623 Mail Service Center,Ralcigh,NC 27699-1623
4405 Reedy Creek Road;Raleigh,NC 27607
Phone[phone]/FAX [phone] Internet, wav d,vglab mg
An Equal Opportunity AWartative Action Employer-50%Recycled/10%Post Consumer Paper

Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Lab Name: Blue Ridge Paper Products Inc WFP Certificate Number: 198
Address: P O Box 4000 Effective Date: 0 1/0 112 0 0 5
Canton,NC 28716 Expiration Dale: 12/31/2005
Dale of Last Amendment:
The above named laboratory,having duly met the requirements of iSA NCAC 2H 0800,is hereby cenifed for the measurement of the parameters listed below
.. CERTIFIED PARAMETERS —'
INORGANICS
BOD
Sid Method 5210B
COLOR PC
NCASI Method 7101 (P1Co)
NCASI Method 253(PICo)
CONDUCTIVITY
Std Method 2510E
DISSOLVED OXYGEN
Sid Method 4500 O G
AMMONIA NITROGEN
Sid Method 4500 NH3 F
pH
Sid Method 4500 H B
RESIDUE SUSPENDED
Sld'Method 2540❑
TEMPERATURE
Sld Method 2550E
This cedificallon requires mainlance of an acceptable quality assurance program,use of approved methodology,and satisfactory performance on evaluation samples Laboratories are
subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H 0007

BLUE RIDGE � � � 0 � �
PAPER PRODUCTS INC. D
DEC - 2W
November 30, 2004
WATER QUALITY SECTION
Mr. Keith Haynes ASHEVILLE REGIONAL OFFICE
North Carolina Department of Environment
And Natural Resources
Division of Water Quality
2090 US Highway 70
Swannanoa,North Carolina 28778
Re: Release Notification,Number 6 Fuel Oil Leak, November 25, 2004
Dear Mr. Haynes:
Blue Ridge Paper Products Inc, is providing written notification as a follow-up to Daryl
Whitt's telephone call to you on November 25, 2004, concerning a Number 6 low sulfur
fuel oil release at the Canton Mill fuel oil unloading station.
At approximately 5:30 AM on Thursday,November 25, 2004, contract personnel
unloading a tractor trailer tanker of Number 6 fuel oil noticed oil on the ground adjacent
to the pump station. Upon investigation, it was found that there was a leak in the
underground low sulfur oil line, approximately three feet outside the containment area.
The area was excavated and a vacuum truck was used to clean up the release area,
including all oil-contacted soil and debris. Based upon vacuum truck volume and the oil
contained in the soil and debris, it is estimated that less than 750 gallons of oil was
released.
The pipeline was repaired and the cleanup was completed by the afternoon of November
26, 2004. No oil was released to the Pigeon River or to the Blue Ridge Paper wastewater
treatment plant. All oil was contained adjacent to the fuel oil unloading station.
If you have questions regarding this incident,please call Jim Giauque at 828-646-2028.
Sincerely,
im Giauque
i
Copy: Paul Dickens
Bob Williams
file:haynesl 12904
c.file:Spills/Releases
c.file:Water
175 Main Street• P.O.Box 4000 • Canton,North Carolina 28716
Phone:[phone]
Raising Your Expectations

William G.Ross Jr.,Secretary
G North Carolina Department of Environment and Natural Reswrces
ran .K' ek, E."D,ado
O visit of Later aTi
WWWW Asheville Regional Office
SURFACE WATER PROTECTION
November 4, 2004
Paul Dickens
Blue Ridge Paper Products Inc
PO Box 4000
Canton NC 28716
SUBJECT: Compliance Bioassay Compliance
Inspection
Blue Ridge Paper Products Inc
Canton Mill
Permit No: NC0000272
Haywood County
Dear Mr. Dickens:
Enclosed please find a copy of the Compliance Bioassay Compliance Inspection
Report for the inspection, which I conducted on October 19, 2004.
As noted in the Report, the test result and measured water quality parameters
indicated that the effluent would not be predicted to have chronic water quality impacts on
the receiving. The test result was recorded as a `Pass".
Please refer to the enclosed inspection report for additional observations and
comments. The assistance provided Mr. Harold Sweitzer and John Pryately in the
collection of the sample was greatly appreciated. If you have any questions, please do
not hesitate to call me at 828-296-4500.
Sincerely,
D. Keith Hayne
Environmental Specialist
Enclosure
cc: John Pryately, ORC
Central Files
,wAsfLeuillejFiles
No
�nhCarolina
lurn/!y
2090 U.S.Highway 70,Swannanoa,NC 28778 Telephone: [phone] Fax:[phone] Customer Service 1 877 623-6748

United States Environmental Protection Agency
Washington,D.C.20460 Form Approved.
EPA oryle No.2040-0057
Water Compliance Inspection Report Approval expires831-98
Section A: National Data System Coding(i.e.,PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fan Type
1 IMI 2 I`I 31 NC0000272 111 121 ,04/10/19 117 181g1 19 u u
20I
IUJ Remarks LUJ u
211 1IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII166
Inspection Work Days Facility Self-Monitoring Evaluation Rating Bit L] CA -----------------Reserved--------------
67 169 70 U 71 72 U1 73 W 74 75I I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected(For Industrial Users discharging to POND,also Include Entry Time/Date Permit Effective Date
POND name and NPDES permit Number) 02/09/01
Canton Mill 10:45 AM C4/10/19
175' Main St Exit Time/Date Permit Expiration Date
Canton MC 28716 11:30 AM 04/10/19 06/11/30
Name(s)of Onsite Representative(s)Ttles(s)/Phone and Fax Number(s) Other Facility Data
Harold L Sweitser/ORC/828-.646-2376/
Philip Lyme Teague/ORC/828-646-2301/
Jolin J .Pryately;ORC/828-646-.6720/
Name,Address of Responsible OfficiallTitle/Phone and Fax Number
Contacted
Paul Dickens, /// No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Effuent/ReceivingWaters
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Keith Ha e ARO" WQ'1/828-296-4500/828-299-7042
11046 f
Signs 71nag ent Q A iewer Agency/Office/Phone and Fax Numbers ate
A Ale
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.

NPDES yr/mo/day Inspection Type (cont.) 1
3 14O0000272 11 12L 04/10/19 17 18 U
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
On October 20, 2004, Division Aquatic Toxicology personnel initiated a. 3-brood Cer-iodaphnia dubia pass/fail
toxicity test using 24-hour composite samples of the subject facility's whole effluent. The samples were
collected on October 18-19 and 21-22, 2004 by the facility and were split by Asheville Regional Office staff.
The result of the test indicated that the subject discharge met criteria set forth in established standards.
At the instream waste concentration of i1laC=>::oi)., predicted by the low stream flow 7Q10 of 52 cfs and the
permitted discharge volume of 29.9 mgd, the control exhibited 100€ survival with 26.0 neonates per control
organism while the test treatment survival. was 1002 with treatment mean reproduction being 24.81. At the the
test concentration of 90`„ the test was recorded as a 'Bass". Results of additional water quality parameter
measurements, follow: First Sample; pH - 7.91su, Conductivity 2430 mieromhos/cm, Second Sample; 'pH - 7,92 SU,
Conductivity - 2110 micromhos/cm.
The result of the test :indicates that the effluent would not be predicted to have impacts on the receiving
stream.

�oF W ATERQ Michael F Easley,Governor
WillinmG Ross It,Secretary
rNorth Carolina Department or Environment and Natural Resources
Alan W Klimck,PC Director
Division of Water Quality
�j November 29, 2004
5180
Mr. John A. Gentry
Blue Ridge Parkway/Mt. Pisgah
199 Hemphill Knob Road
Asheville, NO 28803-
SUBJECT:Wastewater/Groundwater Laboratory Certification Renewal
FIELD PARAMETERS ONLY
Dear Mr Gentry:
The Department of Environment and Natural Resources, in accordance with the provisions of NO GS 143-215-
.3 (a) (10), 15 NCAC 2H .0800, is pleased to renew certification for your laboratory to perform specified
environmental analyses required by EMC monitoring and reporting regulations 15 NCAC 2B 0500. 2H .0900 and
2L .0100, .0200, .0300, and 2N .0100 through .0800.
Enclosed for your use is a certificate describing the requirements and limits of your certification. Please review
this certificate to insure that your laboratory is certified for all parameters required to properly meet your
certification needs.
Please contact us at 919-733-3908 if you have questions or need additional information.
Sincerely,
James W. Meyer
Laboratory Section
Enclosure
cc: Gary Francies
��0I/ 2 g t.*T
LABORATORY SECTION
ASHEVILLE REGIONAL OFFICE
Nar`thCarolimr
,/ly!ltlll7f/lIf
Labarntory Section 1623Mail Service Ccnter;Rnlcigh,NC27699-1623
4405 Reedy Creek Road;Raleigh,NC 27607
Phonc(919)733-3908/FAX [phone]/lnlemel: mavdwglaborg
An Equal OppodunilylAlfiimalive Action Employer-50%Recycled110%Post Consumer Paper

Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
FIELD PARAMETERS ONLY
Lab Name: Blue Ridge Parkway/Mt Pisgah Certificate Number: 5180
Address: 199 Hemphill Knob Road Effective Dale: 01/0 112 0 0 5
Asheville,NC 28803- Expiration Dale: 12/31/2005
Date of Last Amendment:
The above named laboratory,having duly met the requirements of 15A NCAC 2H 0800.is hereby certified for the measurement of the parameters listed below
r �J CERTIFIED PARAMETERS
INORGANICS
RESIDUAL CHLORINE
Sid Method 4500 CIO
Sid Method 4500 Cl G
CONDUCTIVITY
Sid Method 2510E
DISSOLVED OXYGEN
Sid Method 4500 O G
pH
Sid Method 4500 H B
TEMPERATURE
Sid Method 2550E
This certification requires malnlance of an acceptable quality assurance program,use of approved methodology.and satisfactory performance on evaluation samples Laboratories are
subject to civil penalties and/or decertification for Infractions as set forth in 15A NCAC 2H 0807

BLUE RIDGE C E � V ED
PAPER PRODUCTS INL MAR 4 2005
3 March 2005 WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
Michelle M. Raquet
Environmental Specialist
Planning Section
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Comments on 2005 Draft French Broad River
Basinwide Water Quality Plan, Pigeon River Subbasin
Dear Ms. Raquet—
Blue Ridge Paper Products Inc. (BRPP)respectfully submits the following comments on the
Draft 2005 French Broad River Basinwide Water Quality Plan. Our comments concern the
Pigeon River, Subbasin 04-03-05 of the French Broad River in North Carolina. Some of these
comments are fairly general in nature and others are quite specific.
General Comments
(1) Only three Pigeon River mainstem locations were sampled for biological assessment
during the five-year period. As a result, spatial resolution is not adequate to identify
causes of impairment. Richland Creek and Jonathan Creek, two streams with
considerably smaller watersheds,had the same number of sampling stations as the
mainstem Pigeon River. The problem of assessing conditions correctly,and
establishing causation is further complicated because only one organism group
(macroinvertebrates) was sampled in the Pigeon, rather than the two groups sampled
in smaller streams.
(2) The draft basin plan frequently mentions the low flow conditions that persisted during
a good portion of the study period. Water quality standards do not apply below
specific stream flows (typically7Q10 flows). Because NC biological results are, in
effect, serving as biological criteria, the same cautions and restraints should be
applied to the use and interpretation of biological results collected during low flow
periods. If anything, biological results are even more subject to low flow based
effects because not only is the biological community potentially affected by water
quality that is reflective of the low flow conditions,but in addition, low stream flows
directly affect physical conditions within the stream. For example, riffles are
dewatered, velocities are reduced, sediment buildup increases, pools become
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BRPP Comments on 2005 Draft French Broad River Basin Plan
3 March 2005, Page 2
shallower, etc. Furthermore, the conditions under which the biological methods and
metrics were calibrated do not necessarily include extreme low flows. Thus, it is
possible that the biological community is responding not to changes in water quality,
but merely to changes in the physical habitat due to low flow.
(3) During the period in question,Blue Ridge Paper Products sponsored an intensive
biological study in 2000. The draft report properly refers to that study. As part of
that study, benthic data were collected at numerous Pigeon River mainstem locations
and several tributary locations. As far as we can tell, these data were not incorporated
into this assessment. NC specifically solicits outside WQ data (App X,p. 15). The
BRPP-sponsored study collected benthic data consistent with the protocols
established by the state and utilized highly experienced biologists for the study. The
data generated in the BRPP biological study should be used.
Specific Comments
1) p 60/61 —In the Section titled Current Status on the bottom of p. 60, the report states that the
"Pigeon River, from 0.15 miles downstream of West Park Street in Canton to SR 1642 (Main
Street in Clyde) (6.4 miles), is currently Impaired in the aquatic life category due to a Poor
bioclassification at site B-4." Given that Site B-4 is located 5 miles downstream of the BRPP
discharge, we do not understand how the state has concluded with such precision where the
point of impairment begins. The report goes on to state that "Unfortunately, this portion of
Pigeon River has decreased its bioclassification from Good-Fair in 1997 to Fair in 1999 to
Poor in 2002." The report properly notes that this decrease in bioclassification may be
attributable to agricultural land use(i.e., tomato farming) and an increase in residential
development. However, the report goes on to state that "there was also an indication of toxic
impacts at this site during the time of sampling based on the presence of pollution tolerant
macroinvertebrates." Although it is true that"pollution tolerant macroinvertebrates" often
predominate at sites with toxic condition, they are not diagnostic of this condition. Many of
these pollution tolerant macroinvertebrates are tolerant to a wide range of environmental
insults besides toxics including habitat degradation and sedimentation. As the report notes
"this stretch of Pigeon River was severely impacted by low flow likely associated with
drought conditions... No pools were observed, riffles were minimum, and aquatic weeds
were abundant." The poor macroinvertebrate fauna and the abundance of pollution tolerant
macroinvertebrates could be a response to the low flow conditions and resultant poor habitat,
rather than to "toxic conditions". This reference to "toxic conditions" should either be
substantiated or removed.
2) n. 61 —In the last paragraph, the report states `clearly there are still impacts from BRPP".
Given the confounding effects of the drought, this statement is overly specific. A more
proper statement would be that there still appear to be impacts or that the impacts noted may
be the result of BRPP inputs.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BRPP Comments on 2005 Draft French Broad River Basin Plan
3 March 2005, Page 3
3) p. 63 —In the second paragraph, it is stated that "there are still concerns regarding nutrients in
(Waterville) lake". On page 62, the previous nutrient"problem" was attributed to BRPP, so
it is likely that readers of the report will deduce that the nutrient"problem" in the lake,
indeed if such a problem exists, is attributable to BRPP. However, the report provides no
data to establish such a link. In fact, nutrient levels in the BRPP effluent are low- the mill
has to add trace quantities of nutrients for effective activated sludge treatment of its
wastewater. Elsewhere in this document, DWQ acknowledges that nutrient concentrations
are high in Richland Creek, Jonathan Creek, and Fines Creek, and that nonpoint source
runoff is a problem throughout the watershed. Given these known and acknowledged
nutrient sources, the report should not imply that any nutrient problems in the lake arise from
BRPP inputs without a detailed analysis of loadings from the various documented sources.
4) p. 63 - In the third paragraph, the report says there is "evidence" of eutrophication yet at the
end of the same paragraph it acknowledges that "DWQ did not have enough samples to
Impair the lake for the aquatic life category according to use support methodology." This
type of speculation should be removed from the report, especially since the report
acknowledges that"The elevated levels of chlorophyll a, conductivity, and dissolved gasses
seem to be attributed to drought conditions."
5) p. 64 and 65 —As support for our previous comments, we note that on these pages DWQ
acknowledges nutrient problems in the following streams:
• Richland Creek... "DWQ monitoring data indicates that there are long-term water
quality impacts from nonpoint source pollution associated with urbanization,
sedimentation, and erosion. Richland Creek is located in one of the most heavily
developed areas of Haywood County and the Pigeon River watershed,"
• Lake Junaluska... "Lake Junaluska (200.0 acres)has had chronic problems with
sediment inputs from the surrounding watershed and is considered Impaired in the
aquatic life category due to eutrophication," and,
• Fines Creek... "Fines Creek drains primarily agricultural land, much of which is used
for pasture, and exhibits nutrient enrichment and high conductivity."
All of the above waterbodies drain into the Pigeon River downstream of BRPP and all are
more likely sources of nutrients for Waterville Lake than BRPP. In addition, there are other
known nutrient sources (e.g., WWTPs for Waynesville and Maggie Valley, as well as various
nonpoint source inputs).
6) p. 99—The report notes that"One of the most commonly noted types of habitat degradation
in the French Broad River basin was as a result of sediment entering streams from adjacent
land uses." Given the clear link between sedimentation and poor biological communities as
well as the nutrients associated with the sediment that is washed in, it is not appropriate to
suggest that all the biological and nutrient"problems"noted downstream of BRPP are the
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BRPP Comments on 2005 Draft French Broad River Basin Plan
3 March 2005, Page 4
result of the BRPP wastewater discharge.
7) Appendix VI, p. A-VI-6—Receiving stream information for NCS000105, Blue Ridge Paper
Products Inc. in the list of NPDES individual stormwater permits in the French Broad River
Basin contains an error. The current stormwater permit for BRPP covers stormwater
discharges to the Pigeon River and Bowen Branch. Discharges to Beaverdam Creek were
removed from the stormwater permit when this permit was reissued in April 2000.
Sincerely, I
'F-e S.
Paul S. Dickens Robert V. Williams
Manager,Environmental Affairs Director, Regulatory Affairs
828-646-6141 828-646-2033
cc: Greg Seegert, EA Engineering
John Crutchfield,Progress Energy
geithT aynes, NC DNER ARO
Forrest Westall , McGill Engrs
Larry Wilson, UTK
Glen Rogers
Derric Brown
C. File—Water
Engr File—Basin Plans
Environmental Group
175 Main Street • PC Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

SEC EIVED
BLUE RIDGE JUL 2 6 2005
PAPER PRODUCTS INC.
WATER QUALITY SECTION
July 25, 2005 ASHEVILLE REGIONAL OFFICE
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5580
Mr. Keith Haynes
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
Division of Water Quality
2090 US Highway 70
Swannanoa, North Carolina 28778
Subject: Release of Calcium Carbonate with Residual Sodium Hydroxide (Lime Mud)
Dear Mr. Haynes:
Blue Ridge Paper Products, hic. is providing written notification of a release of an estimated
volume of 2.5 gallons of calcium carbonate containing residual sodium hydroxide. The release
was to the mill stormwater system and the Pigeon River via Stormwater Outfall#1 and occurred
on 21 July 2005 between 7:00 and 7:05am.
This letter follows my telephone call to you on 21 July 2005.
The release occurred due to an open drain valve during a purge of the lime mud transfer line
running to the waste treatment plant. The mud was being transferred in order to aid settling in
the secondary containment system. The discharge was immediately discovered by waste
treatment personnel and the valve was shut. In addition to the corrective actions in the attached
report, the Pigeon River was visually inspected downstream of the release. No adverse impact
was observed. The pH of the river 100 feet downstream of the release was 6.5 and the pH above
the release was 6.7 at 8:00am.
Please call me at 828-646-2874 if you have any questions or need additional information.
Sincerely,
J. Glenn Rogers ames A. Giauque
Water Compliance Coordinator Principal Environmental Engineer
Blue Ridge Paper Products - Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Keith Haynes, NC-DENR
25 July 2005
cc: Greg Shuping
Haywood County LEPC
215 N. Main Street
Waynesville, NC 28786
C-File Water
Enviro Release File
L. Justus
J. Giauque
B. Williams
Blue Ridge Paper Products Inc. - Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 0 828-646-2000
Raising Your Expectations

NOTIFICATION REPORT FOR SPILL/RELEASE
Canton Mill - 175 Main Street/P.O. Box 4000
Canton,NC 28716
Name of Chemical: Calcium Carbonate containing residual Sodium Hydroxide(Lime Mud)
Is Substance an Extremely Hazardous Substance ❑ YES X NO
Caller's Name & Position: Glenn Rogers —Water Compliance Coordinator
Media into which release occurred: ❑ Air X Water X Land
Material was released to the ground (via an open valve) and splashed into Stormwater outfall#1
catch basin.
Quantity Released: (give reasonable estimate if known or that RQ may have exceeded, and will
call back as soon as possible- - do not delay reporting ). —Approximately 10 gallons to the
ground, 3-4 gallons to the catch basin, and 2 '/2 gallons to the river
Date, start and stop of release : 7/21/05 7:OOam-7:05am (EHS became aware of spill at 7:30am)
Cause and source of release : A drain valve was left open during a purge of the lime mud
transfer line to the WTP.
Action taken to respond to release and status of actions : Drain valve was immediately closed.
NEO emergency response team was dispatched to clean up the residual material on the ground
and the material in the catch basin. Remediation was complete by 12:OOpm.
Other Notification: National Response Center
Date: N/A Time: Report No.
Petty Officer Name :
NCDEHNR - Asheville or NC Emergency Response- Raleigh
Date: 7/21/05 Time: 8:15am/ 8:23am
Contact: Keith Haynes/NC Emergency Response
Page 1 of 2
Revised 7/25/2005

Notification Report For Spill/Release - continued
Local Emergency Planning Committee
Date: 7/21/05 Time: 2:20pm
Contact: Greg Shupin—Haywood County Emergency Management
Western North Carolina Regional Air Pollution Control Agency
Date: N/A Time :
Contact:
Whether any injuries occurred: ❑ YES X NO
If yes, provide detail: N/A
Name and telephone number of person to contact for further information:
Glenn Rogers 828-646-2874
Action taken for clean-up: NEO dispatched for clean up. Soil remediated and catch basin cleaned
out by 12:OOpm. Estimated loss of 2 �/2 gallons to the river although no material was observed
entering the river via stormwater outfall#3 and no adverse impacts were observed on the river.
The pH of the river was tested at approximately 8:OOam above and immediately below the
outfall. Results revealed no impact to the river.
Does release require written notification under Section 204 of Emergency Planning and
Community Right to Know Act (Title III SARA): ❑ YES X NO
Page 2 of 2
Revised 7/25/2005

�& WAIF Michael F.Easley,Governor
'Qp State of North Carolina
G William G.Ross,Jr.,Secretary
1 r Department of Environment and Natural Resources
Alan W.Klimek,P.E.,Director
Division of Water Quality
May 17, 2004
Mr. Robert Shanahan,
Vice President and Operations Manger
Blue Ridge Paper Products
P.O. Box 4000
Canton,North Carolina 28716
Subject: NPDES Permit Modification
Permit Number: NC0000272
Blue Ridge Paper Products
Canton Mill
Haywood County
Dear Mr. Shanahan:
Based on EPA comments dated April 21,2004, the Division of Water Quality has modified the Blue Ridge
Paper permit. The standard condition"There shall be no discharge of floating solids or visible foam in
other than trace amounts." that was inadvertently omitted from this permit has been added to the effluent
pages.
Please find enclosed the revised permit pages.The revised pages should be inserted into your permit.The
old pages may then be discarded. All other terms and conditions contained in the original permits remain
unchanged and in full effect.This permit modification is issued under the requirements of North Carolina
General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency.
If any parts,measurement frequencies or sampling requirements contained in this permit modification are
unacceptable to you,you have the right to an adjudicatory hearing upon written request within thirty(30) days
following receipt of this letter. This request must be in the form of a written petition, conform ng to Chapter
150B of the North Carolina General Statutes,and filed with the Office of Administrative Hearings (6714 Mail
Service Center, Raleigh,North Carolina 27699-6714). Unless such demand is made, this decision shall be
Final and binding.
If you have any questions concerning this permit modification, contact Sergei Chernilcov at the telephone
number 919-733-5083, extension 594.
Sincerely,
art Klimek PE I C E
cc Central Files D D
NPDES Unit
�i\ahevulle Regiorial Office%F,orrest.�bestalll MAY 26 =
J. Scott Gordon/ EPA Region IV
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
I
North Carolina Division of Water Quality [phone] ,
1617 Mail Service Center FAX[phone]
Raleigh,North Carolina 27699-1617 On the Internet at http://h2o.enr.state.nc.us/

A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge treated industrial,municipal,stormwater and landfill wastewater through
outfall(s) 001. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics Effluent Limits Monitoring Requirements
Monthly Daily Measurement Sample Type Sample
Average Maximum Frequency Location]
Flow 29.9 MGD Continuous Recording I or Et
BOD,5-day,20°C 3205 lb/day 10897 lb/day Daily Composite I,El
Total Suspended Residue 12549 lb/day 49560 lb/day Daily Composite I,Ei
NH3-N Daily Composite El
AOX1 1556.9 lb/day 2822.2 lb/day Daily Composite Ei
Color Daily Composite El
Dissolved Oxygen Daily Grab El
Temperature' Daily Grab Ei
pH 6 Daily Grab Et
Conductivity Daily Grab El
Fecal Coliform 200/ 100 ml 400/ 100 ml Weekly Grab Et
COD Weekly Composite Et
Silver Quarterly Composite Et
Zinc Quarterly Composite Et
Total Nitrogen Monthly Composite Et
(NO,-N+NO3-N+TKN)
Total Phosphorus Monthly Composite El
Chronic Toxicity Quarterly Composite E,
Cadmium Quarterly Composite E,
Trichloro henol 3.0 o Quarterly Composite E,
nol Pentachloro he 8.9 Quarterly Composite Et
Selenium 10.6 µg/L Quarterly Composite El
2,3,7,8 Tetrachloro-dibenzo- 0.014 pg/L Quarterly Composite I,Ei
dioxin10
Conductivity Daily Grab Pigeon River
Flow Daily Grab Pigeon River
Fecal Coliform Weekly Grab Pigeon River
Color Variable Grab Pigeon River
Tem erature Variable Grab Pigeon River
lve Dissod Ox en Variable Grab Pigeon River
Footnotes:
1. Sample Location: I-Influent,Et—Effluent,Pigeon River-Instream sampling as specified in A. (5.) Instream
Monitoring Special Condition.
2. AOX monitoring shall be in accordance with the Sampling Plan for Cluster Rule Parameters (dated March 19,
2001)or subsequent modifications approved by the Division. AOX data shall be submitted on a quarterly basis
along with other Effluent Guideline chemical data;refer to A. (7.) Effluent Guideline Sampling Plan Special
Condition.
3. See A. (8.) Color Analysis and Compliance Special Condition.
4. The daily average effluent dissolved oxygen concentration shall not be less than 6.0 mg/L. See A. (10.)
Dissolved Oxygen Special Condition.
5. See A. (13.) Temperature Variance Review Special Condition.
6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0(on the standard units scale).

7. Chronic Toxicity(Ceriodaphnia) at 90%Effluent Concentration: March,June, September, December(see A.
(4.) Chronic Toxicity Permit Limit(Quarterly)).
S. Trichlorophenol and Pentachlorophenol limits and monitoring are provisionally waived since the facility has
certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include
chlorophenolic biocide,the Permittee shall notified the Division prior to use and the limits and monitoring
requirements shall become immediately effective.
9. If after 18 months selenium has not been detected,the facility may request that the Division review selenium
data for possible removal of the limitation.
10. See A. (9.) Dioxin Monitoring Special Condition.
11. See A. (5.) Instream Monitoring Special Condition.
See A.(6.) Best Management Practices (BMP)Special Condition.
See A. (11.) Town of Canton Inflow and Infiltration Special Condition.
Definitions:
MGD—Million gallons per day lb/day—Pounds per day
ml—Milliliter BOD—Biochemical Oxygen Demand
1tg/l.-Micrograms per liter AOX-Adsorbable Organic Halides
COD-Chemical oxygen demand pg/L-picograms per liter
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A.(2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration, the
discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
outfall(s) 002 (Ea),shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
Effluent Characteristics Limits Monitoring Requirements'
Monthly Daily Measurement Sample Type3 Sample
Average Maximum Frequency Location'
Flow 2 Weekly Calculated E2
Chloroform 5.15lb/day 8.60lb/day Weekly Grab E,
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E,
dioxin(TCDD)
2,3,7,8 Tetrachloro-dibenzo- 31.9 pg/L Monthly Composite Ez
p-furan(TCDF)
Trichlorosyringol < 2.5 µw Monthly Composite E,
3,4,5-Trichlorocatechol < 5.0 µg/L' Monthly Composite E,
3,4,6-Trichlorocatechol < 5.0 µg/L' Monthly Composite Ez
3,4,5-Trichloroguaiacol < 2.5 µg/L 5 Monthly Composite EZ
3,44-Trichloroguaiacol < 2.5 µg/L' Monthly Composite E,
4,54-Trichloroguaiacol < 2.5 µW Monthly Composite E,
2,4,5-Trichlorophenol < 2.5 µgV Monthly Composite E,
2,4,6-Trichlorophenol < 2.5 µg/L' Monthly Composite EZ
Tetrachlorocatechol < 5.0 µg/L' Monthly Composite E,
Tetrachloroguaiacol < 5.0 µgV Monthly Composite Ez
2,3,4,6-Tetrachlorophenol < 2.5 µg/L' Monthly Composite EZ
Pentachlorophenol < 5.0 µg/I° Monthly Composite EZ
Footnotes:
I. Sample Location: EZ—Effluent is composed of Bleach Plant Effluent-acid (acid sewer collected from tap
installed on filtrate pump from CIO,bleaching stage D-100 and from tap installed on Filtrate pump from CIO'
bleaching stage D-2) and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E.). See A. (7.) Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters as prepared by the permittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001) shall be reported on a quarterly basis or more frequently; refer to A. (7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or flow
meters,and report total bleach plant flow(acid+alkaline wastestreams) in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams, which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.
4. For compliance purposes, the permittee must report the total chloroform mass loading based on addition of
separate acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels (ML)specified in 40 CFR 430.01.
Definitions:
lb/day—Pounds per day µg/L—Micrograms per liter
pg/L—Pico.-rams per liter
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration, the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
outfall(s) 003 (E31), shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
Effluent Characteristics Limits Monitoring Requirements'
Monthly Daily Average Measurement Sample Type3 Sample
Average Frequency Location'
Flow- Weekly Calculated E3
Chloroform 7.14lb/day 11.93lb/day Weekly Grab E3
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E3
dioxin(TCDD)
2,3,7,8 Tetrachloro-dibenzo- 31.9 pg/L Monthly Composite E3
furan(TCDF)
Trichlorosyringol < 2.5 µW Monthly Composite E3
3,4,5-Trichlorocatechol < 5.0 jig/L.' Monthly Composite E3
3,4,6-Trichlorocatechol < 5.0 µg/L° Monthly Composite E3
3,4,5-Trichloroguaiacol < 2.5 µg/L' Monthly Composite E3
3,4,6-Trichloroguaiacol < 2.5 µg/L Monthly Composite E3
4,5,6-Trichloroguaiacol < 2.5 µg/L' Monthly Composite E3
2,4,5-Trichlorophenol < 2.5 µg/L Monthly Composite E3
2,4,6-Trichlorophenol < 2.5 µg/L' Monthly Composite E3 '
Tetrachlorocatechol < 5.0 µg/L.' Monthly Composite E3
Tetrachloroguaiacol < 5.0 jigIL5 Monthly Composite E3
2,3,4,6-Tetrachlorophenol < 2.5 µg/L' Monthly Composite E3
Pentachlorophenol < 5.0 µg/L3 Monthly Composite E3
Footnotes:
1. Sample Location: E3—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from CIO,bleaching stage D-100) and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage E.). See A. (7.) Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters,as prepared by the permittee(Internal Outfall 002 parameters+ internal Outfall 003
parameters+ AOX from Outfall 001)shall be reported on a quarterly basis or more frequently; refer to A. (7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or by flow
meter,and report total bleach plant flow(acid+alkaline wastestreams) in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams, which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.
4. For compliance purposes,the permittee must report the total chloroform mass loading based on addition of
separate acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels(ML) specified in 40 CFR 430.01.
Definitions:
lb/day—Pounds per day µg/L.—Micrograms per liter
pg/L—Picograms per liter
There shall be no discharge of floating solids or visible foam in other than trace amounts.

BLUE RIDGE
PAPER PRODUCTS INC.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 4064
26 Oct 2004 Electronic Copy
Forrest R. Westall, PE
Water Quality Regional Supervisor
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
2090 US Highway 70
Swannanoa,NC 28778
Subject: NPDES NC 0000272 I
September 2004 Discharge Monitoring Report
Blue Ridge Paper Products, Inc.
Canton,NC -
Dear Forrest:
This letter accompanies the September 2004 discharge monitoring report (DMR) and documents -
flood impacts on permit-required monitoring.
As you are aware, the Blue Ridge Paper Products mill in Canton,NC was hit by the remnants of
three hurricanes (Frances, Ivan and Jeanne) and by back-to-back historic floods during the month
of September 2004. Our wastewater plant and significant parts of the mill were flooded twice.
Wastewater treatment operations resumed on 9/11 after the 9/8 Frances flood and on 9/21 after
the 9/17 Ivan flood. Compliance monitoring after the two floods resumed on 9/12 and 9/22,
respectively. Mill operations were disrupted for several weeks, and all of our resources since
Hurricane Frances on 9/8 have been devoted to flood repairs, additional flood preparations and
recovery. We are only now getting back to normal operation of our process and wastewater
treatment systems. The floods destroyed our wastewater lab, and we have not yet restored all the
lab capability that we need to do compliance monitoring in-house. We contracted with PACE
Lab to analyze wastewater process control,and compliance samples during the flood recovery
period.
Samples and Compliance Data Lost to Flooding
The-following September 2004 wastewater samples and monitoring data were lost to floodwaters
and are not reported:
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
26 Oct 2004, Page 2
• BOD-5 influent and effluent samples for 9/3 thru 9/7. These samples were in the BOD
incubator and were lost when the wastewater lab flooded on the morning of 9/8.
• September 2004 bleach plant effluent samples for dioxin. These samples were collected
on 9/6 and were in the sample refrigerator waiting for packaging and shipment to an off-
site lab. The sample refrigerator and contents were lost to floodwaters on 9/8. Bleach
plant operations did not resume until 9/30. There was not an opportunity during
September to replace the dioxin samples lost to the Frances flood.
• Bleach plant effluent chloroform samples for 9/13, 9/20 and 9/27. Bleach plant
operations were down from 9/8 until 9/30 due to flooding. Weekly bleach plant effluent
sampling resumed in October 2004 after the pulp mill restart.
• The September 2004 quarterly effluent chronic toxicity test. Two composite effluent
samples are required for this test, one collected on Monday and one collected on
Thursday. The first sample was collected on 9/6 and taken to PACE Lab on 9/7. The
Frances flood hit on 9/8, and the second sample to complete the test could not be
collected. The lost September toxicity test was discussed with Keith Haynes of the
DENR ARO after the Ivan flood. Ivan destroyed the automatic wastewater samplers
salvaged from Frances that are needed to collect samples for toxicity testing. Keith
agreed to postpone the toxicity test until October after new samplers are delivered and
normal mill operations resume. The substitute toxicity test samples were collected during
the week of 10/18, and a sample split was shared with DENR.
• All wastewater data and river data for 9/8 through 9/11 while mill and wastewater
operations were down from the Frances flood. This includes daily river samples for
Canton, Fiberville and Clyde and the weekly river samples for HEPCO,Big Creek and I-
40. Due to flood conditions, it was not safe to collect river samples. Several of the river
sample locations were inaccessible due to floodwater. In addition, field meters and lab
equipment for the river run were lost in the Frances flood and were not replaced until
9/12 when the river run resumed.
• AOX sample from 9/13. The AOX sampler(glass collection bottle) salvaged from the
Frances flood had a damaged temperature controller. The 9/13 AOX sample froze solid.
The sample was discarded as invalid because of freezing.
• Effluent and river fecal coliform samples for week of 9/13 were not collected. Tuesday
9/14 was the scheduled sample day for fecal coliform samples. Each week when fecal
samples are delivered to PACE Lab, a cooler with sample bottles for the next week is
picked up and stored in the wastewater lab. The cooler with sample bottles for 9/14 was
lost to Frances floodwaters on 9/8. A replacement cooler and sample bottles were picked
up on 9/16 with intention of collecting the fecal coliform samples on 9/17. The Ivan
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
26 Oct 2004, Page 3
flood occurred on 9/17.
• Influent and effluent laboratory analysis data for TSS,BOD-5, NH3-N and AOX for
9/16. These samples were in the sample refrigerator on the morning of the Ivan flood on
9/17. The samples were lost when the sample refrigerator was moved to high ground to
save it from flooding.
• All wastewater data and river data for 9/17 through 9/21 while mill and wastewater
operations were down from the Ivan flood. This includes daily river samples from
Canton, Fiberville and Clyde. Due to flood conditions, it was not safe to collect river
samples. Several of the river sample locations were inaccessible due to floodwater.
• Effluent and river fecal coliform samples for weeks of 9/20 and 9/27 were not collected.
The cooler and bottles for fecal coliform samples are picked up each week from PACE
Lab, and the bottles are labeled and prepared for the next week's fecal sample run. After
the Ivan flood, the normal weekly sampling routine was disrupted and replacement
coolers and sample bottles for fecal coliform were not prepared. The river runner -who
is responsible for weekly fecal coliform samples - assumed that since there were no
bottles prepared, the samples were not required. Blue Ridge Paper did not realize that
fecal coliform samples for the last two weeks of September had been missed until 10/11
when reviewing data for the DMR. Keith Haynes of the DENR ARO was notified on the
afternoon of 10/11 concerning missed fecal coliform samples for the weeks of 9/20 and
9/27.
• Influent and effluent apparent color data for 9/12 through 9/16 and for 9/22 &23.
Apparent color is reported but is not a permit-limited parameter. A temporary lab and
bench sheet for color were set up following the Frances flood. True (filtered) color is a
permit-limited parameter and process control parameter for Blue Ridge Paper. Apparent
color testing was a lower priority during flood recovery and did not resume until 9/24.
September 2004 Color Performance
There were two days of elevated effluent color at the end of September 2004 associated with
pulp mill restart. Keith Haynes of the DENR ARO was notified about September color results
on 10/3. The Blue Ridge Paper wastewater treatment plant operated 21 days during September.
During the 9 days that the Blue Ridge Paper wastewater treatment plant was down for flood
repairs, Town of Canton wastewater was discharged to the river. There was no mill operation or
industrial wastewater generation during 9-day treatment outage. On 10/14, Blue Ridge Paper
took samples of Town of Canton wastewater and analyzed this water for true (filtered) color.
The average of two grab samples taken 4 hours apart was 106 ppm true color. The normal Town
of Canton wastewater flow is 0.650 mgd. Assuming a town wastewater flow of 0.900 mgd
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
26 Oct 2004, Page 4
during the outage period, the daily color discharge from the town wastewater was 796 lbs per
day. The town flow estimate of 0.900 mgd accounts for some floodwater and is consistent with
town wastewater flows that we have observed during wet weather periods.
The monthly average color based on 21 days of wastewater treatment plant operation and
monitoring data during September 2004 is 57,497 lbs/day. The average color discharge during
September 2004 accounting for color from Town of Canton wastewater during 9 treatment
outage days is as follows:
( 9 days X 796 lbs/day) + (21 days X 57,4971bs/day)
----------------------------------------------------------------- = 40,4871bs/day.
30 days
Blue Ridge Paper Products believes that 40,487 lbs/day is a conservative estimate of
monthly average color discharge during the full 30 days of September 2004.
September 2004 Wastewater Excursions
Fecal coliform sample results for 9/7 for both secondary effluent and the river were elevated.
The effluent result was 1050 MPN/100 ml and the river result was 1300 MPN/100 ml. The
effluent fecal coliform permit limits are 400 MPN/100ml daily max and 200 MPN/100 ml
monthly average geometric mean. The river sample is not a permit-limited parameter.
The 9/7 sample day was the start of the Hurricane Frances flood. The Town of Canton
wastewater flow was elevated, and detention time in the Town's chlorine disinfection contact
chamber was limited. River flow was starting to rise with the first rainfall from Frances. We
believe the 9/7 fecal coliform results represent a"first flush" effect associated with heavy rains at
the beginning of Frances. The 9/7 fecal coliform results were discussed with Keith Haynes of
the DENR ARO on 9/22 when the PACE Lab report with these results was received. A follow-
up e-mail report was provided on 9/23.
There was a secondary effluent pH excursion on the morning of 9/30. There was a 6-hour period
of pH above 9.0 (maximum of 9.5)that resulted when a scheduled delivery of acid for
wastewater neutralization failed to arrive when expected. River run samples and downstream
inspection after the pH excursion show no impact to the river. Keith Haynes of the DENR ARO
was notified about the pH excursion on 9/30. A follow-up written report was provided on 10/1.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
26 Oct 2004, Page 5
Summary
Blue Ridge Paper is making good progress on recovery from the September 2004 floods. Our
mill operations and wastewater treatment performance are returning to normal. We truly
appreciate your help and that of Keith Haynes with flood recovery efforts.
Sincerely-
Paul S. Dickens John J.Pryately
Manager, Environmental Affairs Waste Treatment and Lab Supervisor
828-646-6141 Operator in Responsible Charge
dickep a,bluerideepaper.com 828-646-2480
pryatina blueridgepaper.com
Enclosure: September 2004 Discharge Monitoring Report
Distribution—copy attached to each DMR
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
26 Oct 2004, Page 6
Internal Distribution
C. File—Water
S. Single
B. Williams
B. Shanahan
J. Pryately
L. Cooper
D. Brown
A. Apostolopoulos
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
5 January 2005 CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 1759
D. Keith Haynes
Environmental Specialist
North Carolina Department of Environment
And Natural Resources
Division of Water Quality
2090 US Highway 70
Swannanoa, NC 28778
Subject: NPDES NC0000272
2004 Annual Average Color
Blue Ridge Paper Products, Inc.
Canton, NC
Dear Mr. Haynes -
This letter and attachment document the 2004 average annual color discharge from the Blue
Ridge Paper Products, Inc. mill in Canton, North Carolina. The average secondary effluent
color discharge for the calendar period 1 Jan 2004 through 31 Dec 2004 was 41,463 lbs/day.
The attachment provides daily wastewater discharge flows and color from the mill during 2004.
Sincerely, a
Paul S. Dickens Robert V. Williams
Manager, Environmental Affairs Director, Regulatory Affairs
828-646-6141 828-646-2033
[e-mail] [e-mail]
PSD/RVW/s
Attachment: Daily flow and color discharge for 2004 D D
JAN - 7 2005
WATER QUALITY SECTION
175 Main Street • PO Box 4000 ASHEVILLE REGIONAL OFFICE
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

2004 Discharge Color Data
NPDES Permit No.N00000272
Blue Ridge Paper Products,Inc.
Canton, NC
Date Flow Color Date Flow Color Date Flow Color
mg d-lbs/day mod Ibs/da an d Ibs/da
1/1/2004 25.51 34.039 3/1/2004 24.63 34,092 5/1/2004 24.54 42,161
112/2004 25.26 43,812 3/2/2004 25.13 43,171 5/2/2004 24.91 42,372
1/3/2004 25.07 44,324 3/3/2004 25.15 57,048 5/3/2004 24.58 37,713
1/4/2004 25.14 34,588 3/4/2004 25.92 58,376 5/4/2004 25.56 38,366
1/5/2004 25.87 31,934 3/5/2004 24.17 47,966 5/5/2004 24.18 36,702
1/6/2004 25.37 29,836 3/6/2004 25.28 41,322 5/6/2004 24.78 39,263
1/7/2004 25.33 33,803 3/7/2004 23.99 38,207 5/7/2004 23.29 39,630
1/8/2004 25.42 33,070 3/8/2004 23.40 32,197 5/8/2004 24.67 48,970
1/9/2004 24.92 34,701 3/9/2004 25.53 29,808 5/9/2004 24.70 45,108
1/10/2004 24.97 29,984 3/10/2004 25.29 33,747 5/10/2004 25.11 42,725
1/11/2004 25.14 35,859 3/11/2004 25.09 29,082 5/11/2004 27.81 45,223
1/12/2004 24.76 38,199 3/12/2004 25.93 43,256 5/12/2004 25.31 41,589
1/13/2004 24.37 39,433 3/13/2004 25.96 42,647 5/13/2004 25.42 45,793
1/14/2004 23.20 40,251 3/14/2004 23.83 52,870 5/14/2004 25.59 51,213
1/15/2004 24.84 38,115 3/15/2004 25.40 59,731 6/15/2004 24.54 40,728
1/16/2004 25.09 36,821 3/16/2004 26.69 50,314 5/16/2004 25.51 52,133
1/17/2004 24.64 42,952 3/17/2004 27.40 76,096 5/17/2004 25.62 72,434
1/18/2004 23.49 37,606 3/18/2004 27.11 57,883 5/18/2004 24.30 52,895
1/19/2004 23.27 34,928 3/19/2004 26.43 47,836 5/19/2004 21.51 34,083
1/20/2004 24.72 37,517 3/20/2004 26.15 41,649 5/20/2004 21.02 23.842
1/21/2004 24.70 35,845 3/21/2004 26.99 50,862 5/21/2004 22.55 21,065
1/22/2004 25.01 36,082 3/22/2004 24.95 47,235 5/22/2004 24.44 25,681
1/23/2004 25.54 37,279 3/23/2004 23.23 60,253 5/23/2004 25.13 25,360
1/24/2004 24.46 36,713 3/24/2004 26.30 63,597 5/24/2004 25.22 19,978
1/25/2004 25.85 36,001 3/25/2004 26.07 59,137 5/25/2004 26.67 25,356
1/26/2004 26.64 32,887 3/26/2004 26.19 39,309 5/26/2004 29.11 46,128
1/27/2004 25.18 27,303 3/27/2004 26.64 35,548 5/27/2004 27.34 49,016
1/28/2004 24.38 30,698 3/28/2004 25.40 41,099 5/28/2004 26.21 50.284
1/29/2004 24.59 29,533 3/29/2004 25.05 21,932 5/29/2004 27.21 42,658
1/30/2004 23.23 27,128 3/30/2004 27.23 40.423 5/30/2004 27.25 38,179
1/31/2004 23.97 27.987 3/31/2004 25.37 37,451 5/31/2004 27.34 36,032
2/l/2004 24.59 27,066 4/l/2004 24.90 39,661 6/l/2004 26.91 35,007
2/2/2004 24.46 28,542 4/2/2004 23.83 42,137 6/2/2004 24.46 30,603
2/3/2004 25.19 23,107 4/3/2004 24.58 42,636 6/3/2004 23.29 26,605
2/4/2004 24.56 35,229 4/4/2004 23.94 35,146 6/4/2004 23.40 27.518
2/5/2004 24.62 48,458 4/5/2004 26.17 48,677 6/5/2004 22.96 29.485
2/6/2004 25.05 45.342 4/6/2004 23.93 32,335 6/6/2004 23.30 28,370
2/7/2004 25.42 49,179 4/7/2004 20.02 26,882 6/7/2004 25.32 31,255
2/8/2004 25.44 39,886 4/8/2004 23.44 31,669 6/8/2004 24.07 37,343
2/9/2004 24.17 37,892 4/9/2004 25.22 41,640 6/9/2004 24.47 35,911
2/10/2004 25.49 48,035 4/10/2004 24.97 30,196 6/10/2004 22.92 33,649
2/11/2004 25.36 43,999 4/11/2004 24.47 33,470 6/11/2004 23.77 38,459
2/12/2004 24.49 53,706 4/12/2004 24.62 35,733 6/12/2004 24.95 40,568
2/13/2004 24.31 43,190 4/13/2004 26.81 44,272 6/13/2004 26.21 38,028
2/14/2004 25.26 37,499 4/14/2004 25.01 32,325 6/14/2004 24.36 31,495
2/15/2004 25.31 46,442 4/15/2004 24.33 29,020 6/15/2004 24.94 28,291
2/16/2004 24.75 42,318 4/16/2004 24.69 28.208 6/16/2004 25.67 32,546
2/17/2004 21.07 29,516 4/17/2004 24.20 30,675 6/17/2004 29.81 33,314
2/18/2004 25.24 48,626 4/18/2004 25.41 33,059 6/18/2004 24.47 34,280
2/19/2004 24.56 40,959 4/19/2004 23.18 32,674 6/19/2004 24.47 32,653
2/20/2004 25.75 42,300 4/20/2004 24.08 38,960 6/20/2004 25.08 33,884
2/21/2004 24.57 35,039 4/21/2004 25.75 47,668 6/21/2004 25.21 38,691
2/22/2004 24.76 35,718 4/22/2004 24.47 37,756 6/22/2004 23.93 37.124
2/23/2004 26.00 38,384 4/23/2004 24.22 37,571 6/23/2004 24.44 39,540
2/24/2004 26.19 41,719 4/24/2004 24.35 41,834 6/24/2004 24.73 42,284
2/25/2004 25.08 30,960 4/25/2004 25.09 45,622 6/25/2004 24.49 39,222
2/26/2004 25.48 35,056 4/26/2004 27.20 44,465 6/26/2004 25.62 46,156
2/27/2004 24.78 27,283 4/27/2004 24.83 36,038 6/27/2004 25.90 41,692
2/28/2004 24.54 27,010 4/28/2004 25.04 40,931 6/28/2004 26.30 44,751
2/29/2004 24.59 27,072 4/29/2004 25.85 45.270 6/29/2004 25.33 38,873
4/30/2004 24.16 42,316 6/30/2004 25.73 39,917
Subtotal Ibs 2,196 766 Subtotal Ibs 2,54 993 Subtotal Ibs 2 320 195
2004colorcalc.xls,2004 Daily Color data Paget of 2 Printed 1/5/2005

2004 Discharge Color Data,continued
NPDES Permit No.NC0000272
Date Flow Color Date Flow Color Date Flow Color
an d lbs/day an d Ibs/da an d Ibs/da
7/1/2004 25.08 43,082 9/1/2004 24.51 47,835 11/1/2004 23.63 31,729
7/2/2004 28.63 45,366 9/2/2004 24.27 43,107 11/2/2004 25.51 40.210
7/3/2004 27.66 38,291 9/3/2004 23.74 39,004 11/3/2004 25.91 41,489
7/4/2004 26.00 36,859 9/4/2004 22.74 35,086 11/4/2004 24.99 49,812
7/5/2004 25.70 37,938 9/5/2004 23.70 41,699 11/5/2004 21.51 36,237
7/6/2004 25.06 29,466 9/6/2004 24.62 42,086 11/6/2004 21.47 36,707
7/7/2004 28.06 42,590 977/2004 33.21 72,017 11/7/2004 22.41 28,783
7/8/2004 25.36 45,267 9/8/2004 0.9 796" 11/8/2004 22.73 38,861
7/9/2004 26.72 86,228 9/9/2004 0.9 796' 11/9/2004 22.20 39,251
7/10/2004 27.43 57,429 9/10/2004 0.9 796' 11/10/2004 21.65 36,834
7/11/2004 26.41 52,414 9/11/2004 0.9 796' 11/11/2004 23.41 48,419
7/12/2004 26.96 69,702 9/12/2004 12.00 19,015 11/12/2004 25.54 26,412
7/13/2004 25.65 44,073 9/13/2004 13.60 16,673 11/13/2004 23.78 40,062
7/14/2004 26.84 42,982 9/14/2004 16.40 25,167 11/14/2004 22.91 32,100
7/15/2004 24.37 41,466 9/15/2004 16.86 32,481 11/15/2004 24.01 40,649
7/16/2004 24.57 34,424 9/16/2004 21.09 51,536 11/16/2004 23.92 37,904
7/17/2004 23.53 32,579 9/17/2004 0.9 796 11/17/2004 24.20 42,384
7/18/2004 22.05 29,791 9/18/2004 0.9 796' 11/18/2004 24.26 33,991
7/19/2004 23.36 34,290 9/19/2004 0.9 796" 11/19/2004 26.63 44,197
7/20/2004 23.64 43,185 9/20/2004 0.9 796' 11/20/2004 22.44 36,307
7/21/2004 23.50 38,806 9/21/2004 0.9 796' 11/21/2004 23.74 35.440
7/22/2004 23.79 39,288 9/22/2004 10.17 15,776 11/22/2004 22.81 21,306
7/23/2004 23.68 37,121 9/23/2004 14.63 13,300 11/23/2004 25.03 33,400
7/24/2004 25.10 38,521 9/24/2004 15.40 83,483 11/24/2004 26.84 29,100
7/25/2004 25.59 38,628 9/25/2004 16.91 25,385 11/25/2004 22.98 30,665
7/26/2004 25.40 48,081 9/26/2004 15.45 10,953 11/26/2004 22.44 39,489
7/27/2004 26.87 46,615 9/27/2004 25.60 32,026 11/27/2004 22.29 39,596
7/28/2004 25.92 41,713 9/28/2004 25.42 25,652 11/28/2004 22.04 41,174
7/29/2004 26.83 43,415 9/29/2004 26.82 231,284 11/29/2004 22.79 36,303
7/30/2004 27.05 41,053 9/30/2004 25.86 303,882 11/30/2004 24.70 37,492
7/31/2004 26.75 46,845 10/1/2004 27.55 520,652 12/1/2004 24.92 32,006
8/1/2004 29.30 51,070 10/2/2004 26.92 139,647 12/2/2004 24.56 29,905
8/2/2004 27.69 53,115 10/3/2004 27.03 67,404 12/3/2004 24.34 34,509
8/3/2004 26.77 43,543 10/4/2004 25.11 58,637 12/4/2004 25.46 41,618
8/4/2004 27.04 42,619 10/5/2004 23.54 37,301 12/5/2004 26.50 48,401
8/5/2004 25.40 33,899 10/6/2004 22.46 26,974 12/6/2004 26.77 42,196
8/6/2004 27.31 34,848 10/7/2004 23.80 35,729 12/7/2004 29.13 48,589
8/7/2004 25.05 36,766 10/8/2004 23.88 35,849 12/8/2004 25.74 34,562
8/8/2004 24.78 36,990 10/9/2004 24.53 25,368 12/9/2004 27.08 37,491
8/9/2004 25.56 39,647 10/10/2004 25.91 45,163 12/10/2004 26.84 46.336
8/10/2004 25.50 39,988 10/11/2004 26.94 56,619 12/11/2004 25.67 43,888
8/11/2004 25.03 48,855 10/12/2004 27.10 37,744 12112t2004 25.22 40,595
8/12/2004 26.06 46,502 10/13/2004 25.39 39,174 12/13/2004 23.12 39,716
8/13/2004 23.72 34,222 10/14/2004 25.69 40,708 12/14/2004 22.93 36,909
8/14/2004 22.69 30,655 10/15/2004 24.69 35,211 12/15/2004 23.50 44,294
8/15/2004 24.59 29,943 10/16/2004 24.57 42,007 12/16/2004 27.64 51,175
8/16/2004 24.76 33,453 10/17/2004 25.37 40,413 12/17/2004 28.01 47,421
8/17/2004 24.05 34,299 10/18/2004 25.40 44,697 12/18/2004 26.21 39,784
8/18/2004 23.28 39,809 10/19/2004 26.65 40,452 12/19/2004 26.19 41,938
8/19/2004 24.45 45,684 10/20/2004 24.88 51,045 12/20/2004 26.18 43,450
8/20/2004 24.98 47,087 10/21/2004 25.56 45,832 12/21/2004 25.47 40,360
8/21/2004 25.12 48,821 10/22/2004 23.90 35,281 12/22/2004 25.31 38,418
8/22/2004 25.46 42,248 10/23/2004 25.14 42,772 12/23/2004 25.51 55,529
8/23/2004 25.52 44,274 10/24/2004 24.52 32,310 12/24/2004 24.30 45,194
8/24/2004 26.47 44,149 10/25/2004 23.00 39,899 12/25/2004 24.62 47,431
8/25/2004 23.57 42,065 10/26/2004 22.85 42,878 12/26/2004 24.66 51,827
8/26/2004 23.62 39,400 10/27/2004 24.03 48,700 12/27/2004 24.94 50,128
8/27/2004 22.63 35,097 10/28/2004 25.11 41,465 12/28/2004 25.06 42,218
8/28/2004 23.10 37,763 10/29/2004 23.93 31,733 12/29/2004 25.61 35,456
8/29/2004 25.11 54,446 10/30/2004 25.04 31,534 12/30/2004 25.28 31,204
8/30/2004 25.01 48,393 10/31/2004 25.00 32,526 12/31/2004 25.11 50,260
8/31/2004 22.70 46,768
' mill and wtp outage due to floods, Town of Canton wastewater discharge,
see 10/26/04 letter accompanying Sep 04 DMR
Subtotal Ibs 2.633 921 1 Subtotal Ibs 3 O60 333 Subtotal Ibs 2,41 111
Total color discharge,Ibs 15,175,319 Days in 2004 366 Annual Average Color, Ibs/day 41,463
2004colorcalc.xls,2004 Daily Color data Paget of 2 Printed 1/5/2005

Keith Haynes, NC DENR DWQ
5 Jan 2005, Page 2
Enclosure: One copy of report (for DENR ARO)
Distribution with enclosures:
N. C.Division of Water Quality Certified Mail Receipt 7099 3220 0007 0371 1773
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
Coleen Sullins
Chief Water Quality Section
Division of Water Quality
NC Department of Environment and
Natural Resources
1617 Mail Service Center
Raleigh NC 27699-1617
Mr.Marshall Hyatt
Water Management Branch
EPA Region IV
61 Forsyth Street SW
Atlanta, GA 30303-8960
John Cruchfield
Progress Energy
Harris Energy&Environmental Ctr.
P.O. Box 327
3932 New Hill-Holleman Rd.
New Hill,NC 27562-0327
Mr. Paul Davis
TDEC-Water Pollution Control
401 Church Street
6'"Floor Annex
Nashville,TN 37243
Mr.Jonathan Burr
TDEC—Water Pollution Control
Knoxville EAC
2700 Middlebrook Pike,
State Plaza Building, Suite 220,
Knoxville,TN 37921
Ms.Luanne K. Williams
N.C.Department of Health and Human Services
Epidemiology Section
1902 Mail Service Center
Raleigh, NC 27699-1902
175 Main Street PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
5 January 2005 CERTIFIED MAIL
Return Receipt Requested
7099 3220 0007 0371 1766
D. Keith Haynes
Environmental Specialist
North Carolina Department of Environment
And Natural Resources
Division of Water Quality
2090 US Highway 70
Swannanoa, NC 28778
Subject: NPDES NC0000272
2004 Dioxin Monitoring in Fish Tissue
Waterville Reservoir Special Water Quality Sample Results
Blue Ridge Paper Products, hie.
Canton, NC
Dear Mr. Haynes -
Enclosed is the final report documenting results from Blue Ridge Paper Products 15`h annual
Fish Tissue Study. This study, required by our NPDES permit, consists of annual sampling of
fish at specific sites in the Pigeon River and analysis of those fish for dioxin. Fish collection for
2004 took place in August.
EA Engineering Science and Technology completed fish collection and the report. Fish
collection followed the December 2001 monitoring plan approved by DENR. Severn Trent
Laboratories completed the dioxin analyses. The 2004 fieldwork included biannual water
quality samples collected from the Waterville reservoir in accordance with Condition A.12 of the
NPDES permit. The Waterville sample results are included in Appendix C of the report. Pace
Labs completed the water quality sample analyses.
Sincerely,
Paul S. Dickens
Manager, Environmental Affairs FASHEVILLE
D
828-646-6141
[e-mail] 2005
PSD/s
SECTION
NAL OFFICE
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

2004 Waterville Reservior Water Quality Sampling Elevation for DO calibration=2280 ft MSL
31-Aug-04
Samples Collected by EA Engineering Conductivity meter constant= /oocr zs
Field Crew: c<-� S C4w-� pM cal Buffer? buffer 10
before sampling -Qa la-©E)
Field Notes& Parameters for WQ Samples after sampling
Location #1 #2 #37
Sample ID Prior Laurel Branch Near Wilkins Creek Near Dam
Upper 113 of lake Middle 113 of lake Lower 113 of lake
Collection Depth 0.10 meters 0.10 meters 0.10 meters ao
Time ORf{D O9 YS jd z
4 e,.,,or' W, /�
Temperature, Deg C ZS, Z
Dissolved Oxygen,mglL 5� /y
Conductivity, amhos Ze �i 4'+a?P Z67
PH, std units
Secchi Depth, meters Scams/; w+
-rq- _y V�l rj�r

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Drinking Wotor ID. 37715
W..t...ter ID: 10
ID#: 1111
PACE ANALYTICAL SERVICES, INC.
2225 RIVERSIDE DRIVE
AS11EVILLE ,NC 28804 DATE COLLECTED: 08/31/04
DATE REPORTED 09/17/04
REVIEWED BY:
Sample Sample Sample Analysis Method
PARAMETERS #1 N2 N3 Date Analyst Code
Chlorophyll-A, ug/l 3.07 11.79 2.54 09/17/04 TRB SM10200H
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. .r°t'liri t':YaIYlilr�' .. . to a�,'Y S

Discharges from Blue Ridge Paper Products, Canton,NC
Subject: Discharges from Blue Ridge Paper Products, Canton,NC
From: "Neil McCubbin" <[e-mail]>
Date: Tue, 5 Jul 2005 16:00:18 -0400
To: "'Susan massengale"' <[e-mail]>, "'Roger Edwards"'
<[e-mail]>
Susan,
Thanks for the information. It turns out that OTIS is available only to
government agencies, but your link led me to PCS, where I found the data I
wanted.
When I had looked on PCs before contacting you, the facility was listed, but
there was not data. The link you gave me seems to have activated something.
Although the Canton mill is routinely under the gun for color discharges, it
is actually one of the lower pulp and paper industry dischargers in the
country, so is a good reference for a well operated activated sludge system
in a paper mill. I know of only a few better mills.
I worked for EPA in relation to the Canton mill in the late 1990-s, so know
the mill configuration quite well. This makes their treated effluent data
all the more useful to me
I will contact Roger if I need more detail, but not at the moment.
Neil McCubbin
140 Fisher's Point, Foster, Quebec, CANADA JOE 1R0
Tel: +1 (450) 242 3333 Cell: +1 (450) 330 0133
Email: [e-mail] FAX +1 (413) 803 7514
-----Original Message-----
From: Susan massengale [mailto:[e-mail]
Sent: Monday, June 27, 2005 10:24 AM
To: nmccubbinomccubbin.ca; Roger Edwards
Subject: [Fwd: Blue Ridge Paper Products, Canton, NCI
Hello Mr. McCubbin,
By way of this e-mail I am forwarding your information request to Roger
Edwards, who is the current Surface Water Protection Supervisor in our
Asheville Regional Office.
I also encourage you to go to:
http://www.epa.gov/idea/otis/compliance report.html
Scroll down to the 2nd yellow box, Permit/ID search, and enter NC0000272.
Click the Get Detailed Facility Report button and you will get a
boatload of information on water quality and other permits.
By clicking on the fourth entry under Facility Permits and Identifiers
you will get access to info on the NPDES permit.
Please let Mr. Edwards and me know if there is additional information
you need or anything else we can help you with.
Susan Massengale
Public Information Office
N.C. Division of Water Quality
1 of 1 7/15/2005 8:32 AM

_art to 316a Study Field Sampling for Blue Ridge Paper
Subject: River Flow and Start to 316a Study Field Sampling for Blue Ridge Paper
Date: Tue, 5 Jul 2005 15:29:39 -0400
From: [e-mail]
To:[e-mail],[e-mail]
CC: [e-mail], [e-mail], [e-mail],
[e-mail], [e-mail], [e-mail],
[e-mail]
5 July 2005
Larry Wilson and Joyce Coombs, UTK Fisheries-
We had targeted next week for starting the Blue Ridge Paper 316a study field work if river conditions allowed. It
has been a extra wet June, and Pigeon River flow remains elevated above seasonal norms.
Questions:
• Were you able to do the practice run in Jonathan Creek last week or were stream conditions too high ?
• Does it look practical to start field work next week or do we delay until a period of better river flow and weather
conditions ?
I discussed past 316a study river flows with Greg Seegert of EA Engineering. His advice is as follows:
• The cutoff for efficient and safe field sampling in the Pigeon River System is a river flow of 2.0 feet at HEPCO.
Above 2.0 feet, you will be very limited in the sampling stations that you can access for collection.
• Previous 316a studies occurred when HEPCO river stage was between —0.7 and 1.5 feet.
• Greg recommends delaying 316a field work until HEPCO river stage is at 2.0 feet and falling. A stage of 1.7
to 1.8 feet and falling at the start of the field data period is optimum.
• If at all possible, sampling of all the field stations should occur within a 3 week period to avoid significant
temporal variations between upstream and downstream stream conditions. Target 2 stations or more per day
for fish and benthic sampling.
The annual dioxin fish sampling is not as sensitive to stream flow as the 316a study work. The dioxin fishing targets
collection of specific species. The 316a field work targets consistent sampling methodologies under similar stream
flow conditions.
Greg Seegert and his benthic expert will audit the first week of field sampling when we decide if river conditions are
suitable to start. Purpose of audit is consistency with previous study methods. He would like to observe sampling of
the upstream and nearest downstream stations. ,
We have time to wait for better river flow conditions. Hopefully no more than a delay of one to two weeks. Tropical
storms in late August and September remain a concern. Field crew available due to the start of UT fall semester is
also a constraint. Please keep me updated on when you think field work will start.
Thanks-
Paul Dickens
Manager, Environmental Affairs
Blue Ridge Paper Products, Inc.
[e-mail]
828-646-6141 FAX [phone]
1 of 2 7/15/2005 8:35 AM

BLUE RIDGE
PAPER PRODUCTS INC.
February 3,2005
NCDENR
Division of Water Quality
2090 US HWY. 70
Swannanoa, NC 28778
Att: Mr. Keith Haynes
Blue Ridge Paper Products Inc.
175 Main Street, PO Box 4000
Canton,NC 28716
Dear Mr. Haynes
On Saturday, January 29, 2005 Blue Ridge Paper Inc. had a release of oil product to the
mill's sewer system, which exceeded the 25 gallon reportable limit. This was not a
release to public waters. Attached is a written report as required within five working days
If you need further information please contact me at 828-646-2372.
Sincerely,
Louie Ju s/Agent TBRPP1
CC; Paul Dickens- Manager, Environmental Affairs NJ,
f�6 D
Bob Williams-Director, Regulatory Affairs u
Bob Shanahan—VP, Operations and Mill Management
File- Misc. Spills FEB — 4 2005
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
175 Main Street• P.O.Box 4000 • Canton,North Carolina 28716
Phone:[phone]
Raising Your Expectations

PASHEVILLE
ECEIVE
NOTIFICATION REPORT FOR SPILL/RELEAS
FEB - 4 2005 D
Blue Ridge Paper Products Inc.
Canton Mill- 175 Main Street/P.O. Box 4000WATER QUALITY SECTION
Canton, NC 28716 REGIONAL OFFICE
Name of Chemical: Hydraulic Fluid(Mobile 629 Gear Oil)
Is Substance an Extremely Hazardous Substance ❑ YES X NO
Caller's Name &Position: Louie Justus- Sr. Environmental Engineer
Media into which release occurred: ❑ Air X Water ❑ Land
Loss was to Mill sewer,which is treated by the Mill's wastewater treatment plant and has oil
removal equipment. No loss to public waters.
Quantity Released: (give reasonable estimate if known or that RQ may have exceeded, and will
call back as soon as possible- - do not delay reporting) Call-in report was approximately 75
gallons to sewer, final evaluation was approximately 100 gallons total loss with 50 gallons to the
sewer.
Date, start and stop of release: 1/29/05- approximately 6: 30PM- 7:OOPM
Cause and source of release: Split in metal line
Action taken to respond to release and status of actions : Shut equipment down, dispatched on-
site haz-mat team, oil dry applied to contain loss, wood fines added to absorb residual. Expedited
repair of split hydraulic line. Equipment down 4-hours for repair.
Other Notification: National Response Center
Date: NO Time: Report No.
Petty Officer Name :
NCDEHNR- Asheville or NC Emergency Response - Raleigh
Date: 1/29/05 Raleigh Time: 7:42 PM
Contact: Mary Young
Page I of 2
Revised 1/31/2005

Notification Report For Spill/Release- continued
Local Emergency Planning Committee
Date: No Time:
Contact:
Whether any injuries occurred: ❑ YES X NO
If yes, provide detail:
Name and telephone number of person to contact for further information:
Louie Justus 828-667-4994
Action taken for up: Oil dry and wood fines used to stop loss and absorb residual oil.
Oil in absorbent, collected and burned in Bark Boiler. No oil sheen observed
from wastewater treatment plant.
Does release require written notification under Section 204 of Emergency Planning and
Community Right to Know Act(Title III SARA): ❑ YES X NO
Page 2 of 2
Revised 1/31/2005

ICE
State of North Carolina
Department of Environment
and Natural Resources
Michael F.Easley, Governor .... .... �
Alan W.Klimek,P.E.,Director N C D EN R
Coleen H. Sullins,Deputy Director NORTH CAROLINA DEPARTMENT OF
Division of Water Quality ENVIRONMENT AND NATURAL RESOURCES
Asheville Regional Office
Water Quality Section
June 16, 2004
Paul Dickens
Blue Ridge Paper Products Inc
PO Box 4000
Canton NC 28716
SUBJECT: Compliance Evaluation Inspection Blue Ridge
Paper Products Inc
Canton Mill
Permit No: NC0000272
Haywood County
Dear Mr.Dickens:
Enclosed please find a copy of the Compliance Evaluation Inspection Report from the inspection that I
conducted at your facility on June 2, 2004. The facility was found to be in Compliance with permit
NC0000272.
Please refer to the enclosed inspection report for additional observations and comments. If you or your
staff have any questions, please do not hesitate to call me at 296-4500.
*Haynes
Environmental Specialist
Enclosure
cc: John J Pryately, ORC
Central Files
Asheville Regional Office,2090 U.S.70 Highway,Swannanoa,North Carolina 28778 Phone: [phone] Fax: [phone]
An Equal Opportunity/Af mative Action Employer—50%Recycled\l10%Post Consumer Paper

United States Environmental Protection AgencyFofm Approved.
EPA Washington,D.C.20480
OMB No.2040-0057
Water Compliance Inspection Report
Approval expires 8-31.98
Section A: National Data System Coding (i.e.,PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fat Type
1 u 2 u 31 NC0000272 111 121 04/06/02 117 18 CJ 19 L'J 20 U
Remarks
21IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII66
Inspection Work Days Facility Self-Monitoring Evaluation Rating 81 Q��JA��� ---------------Reserved---•--------------
67I 169 70 L'J 71 U �L
72 73 W 74 75I I I I I I 1180
Section B: Facility Data
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number)
Canton Mill 01:00 Pig 04/06/02 02/09/01
175 Main Street Exit Time/Date Permit Expiration Date
Canton NC 28716 03:00 PM 04/06/02 06/11/30
Name(s)of Onsite Representative(s)/Ttles(s)/Phone and Fax Number(s) Other Facility Data
John J Pryately/ORC/828-646-6720/
Name,Address of Responsible Officiallritle/Phone and Fax Number
Derric Brotm,PO Box 4000 Canton NC 28716//828-646-2318/ Contacted
No
Section C: Areas Evaluated During Inspection(Check only those areas evaluated)
Flow Measurement Operations&Maintenance 0 Facility Site Review Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Names)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Keith Hayne ARO WQ;/828-296-4500/828-299-7043
� r /�o�
Sign 0 nagem t Q A Rev er Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3(Rev 9.94)Previous editions are obsolete.

NPDES yr/mo/day Inspection Type 1
3I NC0000272 I11 121 04/06/02 I17 18 LCJ
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
The facility appeared to be well operated and adequately maintained. Influent and effluent ISCO sampler
temperatures were at or below the acceptable reading. Flow during the inspection was about 25 mCID.

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a

Permit: NC0000272 Owner-Facility: Blue Ridge Paper Products Inc-Canton Mill
Inspection Date: 06/02/04 Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NF
Is the sludge blanket level acceptable? ❑ ❑ ❑
Is the return rate acceptable(low turbulence)? ❑ ❑ ❑
Is the overflow clear of excessive solids/pin floc? ❑ ❑ ❑
Is Ure surface free of bulking? ❑ ❑ ❑
Comment:Some grass was growing in the#5 weir trough. This will be removed when the clarifier is taken down for
maintenance. Clarifier#6 was not in operation as it is not needed at this time. Maintenance on the clarifier will Include
painting metal parts and changing the the"box side"weir plate to a solid plate.
Aeration Basins Yes No NA NF
Mode of operation Ext.Air
Type of aeration system Surface
Is the basin free of dead spots? 0 ❑ ❑ ❑
Are surface aerators and mixers operational? N ❑ ❑ ❑
Are the diffusers operational? ❑ ❑ N ❑
Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑
Does the foam cover less than 25%of the basin's surface? N ❑ ❑ ❑
Is the DO level acceptable? N ❑ ❑ ❑
Are setUeometer results acceptable? ❑ ❑ ❑
Comment:

o��F WATF�QG Michael F. Easley,Governor
Stale of North Carolina
William G. Ross,Jr.,Secretary
co r Department of Environment and Natural Resources
O • ,� Alan W.Klimek,P.E.,Director
Division of Water Quality
February 27,2004
Mr. Robert Shanahan,
Vice President and Operations Manger
Blue Ridge Paper Products
P.O.Box 4000
Canton,North Carolina 28716
Subject: NPDESPermitModification
Color Limitations
Permit Number: NC0000272
Blue Ridge Paper Products
Canton Mill
Haywood County
Dear Mr. Shanahan:
Blue Ridge Paper's NPDES permit was reissued on November 15,2001. That permit included
several special conditions concerning effluent color discharges from the mill. Section A. (8.) of the
permit in part 5.required that Blue Ridge Paper submit"a report including a statistical analysis of
the permittee's monthly average color discharge,mill performance as related to color, [and] all
available data necessary to derive the lowest achievable annual average and monthly average color
loading limits"by October 1,2003. Blue Ridge Paper provided the required report in accordance
with that condition.
The 2001 NPDES Permit also required that the Division review the October 1 report in consultation
with the Technology Review Workgroup (TRW),Chaired by the Environmental Protection Agency
and with members from both North Carolina and Tennessee, and determine appropriate color
loading limitations for this permit. The TRW provided to DWQ its final recommendation on what it
believes is the most appropriate interim color limitations for the mill for annual average color
discharged and for monthly average color discharge on February 4,2004. The Division has
reviewed that recommendation and is providing this written notification to Blue Ridge Paper that its
annual average and monthly average limitations for effluent color are being revised.
Therefore, and in accordance with condition A. ( 8. ) 6. of your permit and the TRW
recommendation,I am revising your annual average color limitation to the following:
Effective January 1,2004, the average antral discharge of true color for each calendar year shall not
exceed 42,000 pounds per day. Pounds of effluent color shall be determined in accordance with the
existing conditions and monitoring requirements of Permit Number NC0000272,issued on
November 15,2001.
In addition,I am making an administrative change to your permit to reduce your monthly average
color limitation from the current level of 55,000 pounds per day to 52,000 pounds per day. This
change is effective March 1,2004 and reflects the recommendation of the TRW. As indicated above,
pounds of effluent color shall be determined in accordance with the existing conditions and
monitoring requirements of Permit Number NC0000272,issued on November 15,2001. This change
reflects a more restrictive limitation for monthly average color discharge and a monthly average
North Carolina Division of Water Quality [phone]
1617 Mail service Center FAX[phone]
Raleigh,North Carolina 27699-1617 On the Internet at http://h2o.enr.state.nc.us/

Blue Ridge Paper Products
Permit No. NC000272
Page 2
limitation in line with the reduction of the annual average color limitation. This change provides a
more effective regulatory control requirement for monthly average color and provides better
protection of the water quality of the Pigeon River.
The described changes affect only the limitations for annual and monthly average color discharge
limitations in the NPDES permit in section A. (8.)2. All other conditions in this permit remain in
effect as issued on November 15,2001 and effective December 1,2001. Please include a copy of this
letter with all copies of the plant's permit filed with the company and used for reference at the mill
site.
If any parts,or requirements of this permit modification are unacceptable to you,you have the right
to an adjudicatory hearing upon written request within thirty (30) days following receipt of this
letter. This request must be in the form of a written petition,conforming to Chapter 150B of the
North Carolina General Statutes,and filed with the Office of Administrative Hearings (6714 Mail
Service Center,Raleigh,NC 27699-6714). Unless such demand is made, this decision shall be final
and binding.
The Division appreciates the continued progress of Blue Ridge Paper in improving the quality of
your treated effluent and the Pigeon River. We anticipate continued improvement and progress
toward the overall goal of this process: removal of the color variance for Blue Ridge Paper by the
expiration date of the NPDES Permit. If you have any questions concerning this permit
modification,please call Forrest Westall at 828/251-6208.
Sincerely,
Alan Klimek,PE
cc Central Files
Forrest Westall
Sergei Chernikov
tKeith , aynes
Don Anderson
Paul Davis
David McKinney
Karrie-Jo Shell

o�o� WATF,QQG Michael F. Easley,Governor
State of North Carolina
William G.Ross,Jr.,Secretary
(!) Department of Environment and Natural Resources
Alan W. Klimek,P.E.,Director
Y Division of Water Quality
February 27,2004
Mr. Robert Shanahan,
Vice President and Operations Manger
Blue Ridge Paper Products
P.O.Box 4000
Canton,North Carolina 28716
Subject: NPDESPermitModification
Color Limitations
Permit Number:NC0000272
Blue Ridge Paper Products
Canton Mill
Haywood County
Dear Mr.Shanahan:
Blue Ridge Paper's NPDES permit was reissued on November 15,2001. That permit included
several special conditions concerning effluent color discharges from the mill. Section A. (8.) of the
permit in part 5.required that Blue Ridge Paper submit"a report including a statistical analysis of
the permittee's monthly average color discharge,mill performance as related to color, [and] all
available data necessary to derive the lowest achievable annual average and monthly average color
loading limits"by October 1,2003. Blue Ridge Paper provided the required report in accordance
with that condition.
The 2001 NPDES Permit also required that the Division review the October 1 report in consultation
with the Technology Review Workgroup(TRW),Chaired by the Environmental Protection Agency
and with members from both North Carolina and Tennessee,and determine appropriate color
loading limitations for this permit. The TRW provided to DWQ its final recommendation on what it
believes is the most appropriate interim color limitations for the mill for annual average color
discharged and for monthly average color discharge on February 4,2004. The Division has
reviewed that recommendation and is providing this written notification to Blue Ridge Paper that its
annual average and monthly average limitations for effluent color are being revised.
Therefore,and in accordance with condition A. ( 8. ) 6. of your permit and,the TRW
recommendation, I am revising your annual average color limitation to the following:
Effective January 1,2004, the average annual discharge of true color for each calendar year shall not
exceed 42,000 pounds per day. Pounds of effluent color shall be determined in accordance with the
existing conditions and monitoring requirements of Permit Number NC0000272,issued on
November 15,2001.
In addition,I am making an administrative change to your permit to reduce your monthly average
color limitation from the current level of 55,000 pounds per day to 52,000 pounds per day. This
change is effective March 1,2004 and reflects the recommendation of the TRW. As indicated above,
pounds of effluent color shall be determined in accordance with the existing conditions and
monitoring requirements of Permit Number NC0000272,issued on November 15,2001. This change
reflects a more restrictive limitation for monthly average color discharge and a monthly average
North Carolina Division of Water Quality [phone]
1617 Mail service Center FAX[phone]
Raleigh,North Carolina 27699-1617 On the Internet at http://h2o.enr.state.nc.us/

Blue Ridge Paper Products
Permit No. NC000272
Page 2
limitation in line with the reduction of the annual average color limitation. This change provides a
more effective regulatory control requirement for monthly average color and provides better
protection of the water quality of the Pigeon River.
The described changes affect only the limitations for annual and monthly average color discharge
limitations in the NPDES permit in section A. (8.) 2. All other conditions in this permit remain in
effect as issued on November 15,2001 and effective December 1,2001. Please include a copy of this
letter with all copies of the plant's permit filed with the company and used for reference at the mill
site.
If any parts, or requirements of this permit modification are unacceptable to you,you have the right
to an adjudicatory hearing upon written request within thirty (30) days following receipt of this
letter. This request must be in the form of a written petition,conforming to Chapter 150B of the
North Carolina General Statutes,and filed with the Office of Administrative Hearings (6714 Mail
Service Center,Raleigh,NC 27699-6714). Unless such demand is made, this decision shall be final
and binding.
The Division appreciates the continued progress of Blue Ridge Paper in improving the quality of
your treated effluent and the Pigeon River. We anticipate continued improvement and progress
toward the overall goal of this process: removal of the color variance for Blue Ridge Paper by the
expiration date of the NPDES Permit. If you have any questions concerning this permit
modification,please call Forrest Westall at 828/251-6208.
Sincerely,
Alan Klimek,PE
cc Central Files
oxresP t' W a1Ll
Sergei Chernikov
Keith Haynes
Don Anderson
Paul Davis
David McKinney
Karrie-Jo Shell

BLUE RIDGE SUN 1 7 2004
PAPER PRODUCTS INC.
WATER QUALITY SECTION
16 June 2004 ASHEVILLE REGIONAL OFFICE CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5160
Mr. D. Keith Haynes
Environmental Specialist
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
Division of Water Quality
2090 US Highway 70
Swannanoa, North Carolina 28778
Subject: NPDES NC0000272
Release of Stormwater Normally Managed as Wastewater
Blue Ridge Paper Products, Inc.
Canton Mill
Dear Mr. Haynes -
This follows our telephone call and e-mail to you on 14 June 2004 and reports an unintentional
bypass of stormwater normally managed as wastewater. The release was to the mill stormwater
system and the Pigeon River via Mingus Branch. The estimated discharge volume was 15,000
gallons and occurred between 0600 and 0730 on 14 June.
This letter meets the 5-day written report requirement of our permit.
Specific information:
Stormwater from the hardwood chip pile is collected for treatment in the hardwood chip sump
and pump station. From this sump, the hardwood chip pile water is pumped to pine chip
stormwater holding basin and then into the headworks of our NPDES-permitted wastewater
facility. Our wastewater operators responded to a high level alarm for the hardwood chip sump
at 0600 on the morning of 14 June. They found that the hardwood chip pumps and intake screen
were plugged and not moving their full capacity of water. Thompson Industrial Services was
immediately contacted and arrived on site at 0715 to pump out and clean the hardwood sump.
The sump was cleaned and normal pump flow was restored. Wood chips were observed in the
sump overflow to stormdrain outfall#3 tributary to Min.-Us Branch. Based on this observation,
we believe that some water did overflow and escape the hardwood sump. Our estimated release
volume is based on influent flow rate at the time the sump was cleaned (— 165 gpm) and the time
between discovery and restoration of full pump capacity.

Mr. D. Keith Haynes, NC DENR ARO DWQ
16 June 2004, Page 2
A flash food occurred in Canton at about 2100 on the evening of 12 June and sent water and
debris into our hardwood chip area when Mingus Branch overflowed its banks and onto our
property. The stormwater sumps for both our pine and hardwood chip piles were inspected after
the flood event at 2300 on 12 June. These stormwater pumps were keeping up with flow at the
time. The sumps were again inspected at 0300 on 13 June and throughout the day on 13 June
and the morning of 14 June. We believe that our wastewater operators caught the start of the
hardwood sump overflow event when they responded to the sump's high water level alarm. The
hardwood chip sump is on a routine cleaning schedule to remove accumulations of chips and
debris. We believe the clogging of the hardwood chip pumps and screen that occurred on the
morning of 14 June was result of the unusually large volume of water and handled by these
pumps since the storm and flood on 12 June. We responded immediately to the overflow when
discovered.
Please advise if additional information or follow-up is required.
Very truly yours—
Paul S. Dickens
Manager, Environmental Affairs
828-646-6141
[e-mail]
cc: Michael Koerschner
C-File Water
Enviro Release file
B. Williams
L. Justus
J. Giauque
Environmental Group
175 Main Street PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
September 29, 2003
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No. NC0000272,Blue Ridge Paper Products, Inc.
October 1, 2003 Required Report
Dear Mr. Westall:
Attached is the October I, 2003 Report. This report is submitted to fulfill the
requirements stated in Section A(8.),Paragraph 5 of the 2001 NPDES Permit. Blue
Ridge Paper Products is submitting this report to you in your capacity as Regional Water
Quality Supervisor for the Division of Water Quality and as a member of the Technology
Review Workgroup.
Please call me at(828) 646-2033 or Melanie Gardner at [phone] if you have any
questions or concerns regarding this report.
Sincerely,
&611 IIJ�
Bob Williams AS6
Director- Environmental,Health and Safety
Attachment
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone: [phone] • Fax: [phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
Bxc:
Billy Clarke
Melanie ardner
FAIT as
o an an
Steve Single
Daryl Whitt
Bob Williams

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
I. Introduction
The following report details the Canton Mill's ability to attain the lowest achievable
annual average and monthly average color loading limits based on the Mill's performance
from December 2001 —August 2003. Section A(8.), Paragraph 5 of the 2001 NPDES
Permit provides in part, as follows:
"...By October 1, 2003, the permittee shall submit to the North Carolina
Division of Water Quality a report including a statistical analysis of the
permittee's monthly average color discharge, mill performance as related
to color, all available data necessary to derive the lowest achievable
annual average and monthly average color loading limits... "
This report is submitted to fulfill the requirements of Section A(8.), Paragraph 5. Based
on the Mill's performance from December 2001 —August 2003 and the Mill's continued
commitment to color improvement,Blue Ridge Paper Products believes an annual
average color limit of 42,000 pounds per day and a monthly average color limit of 52,000
pounds per day are feasible.
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` October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
II. Color Performance
Set forth below is a summary of the actions implemented and planned for further color
improvement at the Canton Mill. These actions satisfy the `Highest Certainty' items
recommended by the Division of Water Quality and the Technology Review Workgroup.
2.1 Process Optimizations Items
The sixteen Process Optimization Items recommended in the Bleach Environmental
Process Evaluation and Report prepared by Liebergott& Associates Consulting Inc. and
GL&V Pulp Group Inc. have all been evaluated and implemented where appropriate.
2.2 Improved Black Liquor Leak and Spill Collection and Control
This recommendation consists of four elements including:
1) Continuous improvement of operating practices so more leaks and spills are recovered
rather than discharged to the sewer;
2) Improvement in preparation for planned outages to maximize capture of tank clean-out
waste and routing to recovery;
3)Reduction of clean water that continuously runs into sewers to prevent dilution of
smaller spills and facilitate recovery of highly colored wastewaters; and
4) Improvement in the equipment used for the handling of knot rejects to prevent black
liquor leaks into the recovery sumps.
The following is a discussion of actions relating to each element.
2.2.1 Continuous Improvement of Operating Practices etc.
A number of Best Management Practices (BMPs)have been implemented to improve the
recovery of colored discharges within the mill. These include: A) Color testing on the
2

` October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
Primary Influent every 2 hours; B) The use of the off-line, spare clarifier for process
losses and intentional diversions; C)Piping the Hardwood Brown Spill tank to the Pine
Blow Tower for additional spill collection capability and Hardwood Fiberline outage
management; and D) Implementation of control logic in the Pine Brownstock area to
minimize tank overflows during shutdowns.
The Mill began 24-hour color testing in 2-hour increments on the primary influent in
2001. The purpose of this increased color testing is to improve the mill's ability to
respond to process upsets on an immediate, real-time basis. If high 2-hour color results
are detected, the Wastewater Treatment Plant (WWTP) operators communicate the
information to mill operations and in-mill investigations begin. If necessary, diversion of
the primary influent to the off-line, spare clarifier is initiated. The high color material
that is captured in the off-line clarifier is later discharged into the system at a rate that has
a minimum impact on color and is not disruptive to the WWTP system. The off-line
spare clarifier is also used during outage situations when high color material cannot be
recovered by the in-mill spill control systems due to upset conditions, lack of recycle or
evaporator capacity or intentional diversions.
In order to increase the Hardwood Fiberline's ability to recycle recovered brownstock
material, piping was installed from the Hardwood Brown Spill tank to the Pine Blow
Tower. Prior to installation of this piping, there was no outlet for recycled hardwood
brownstock material when that system was shut down. This design allows for the
Hardwood Brown Spill tank to be recycled into the Pine Blow Tower and is especially
useful in hardwood outage situations when the recycle of additional recovered material is
required. Color savings from this 2001 project are reflected in the improvements seen
around the hardwood brownstock or 2B sewer area as well as improved color
performance.
3

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
During the first quarter of 2003, additional control logic was developed and implemented
on the pine brownstock system to prevent high colored filtrate tanks (15` 2"d, and P stage
Pre-02 filtrate tanks) from overflowing and potentially reaching the sewer. The control
logic is designed to alert the operator when the brownstock filtrate tank(s) reach 85%
with audible and visual alarms. If the tank level(s) continues to rise to 90%, the pine
brownstock operators receive a"high-high"level alarm and warning text on their
monitors. The control logic then automatically interlocks (i.e., shuts down) the washer
stock feed pump that is associated with the high-level filtrate tank. Further, additional
controls have been built into the logic for the Pine Brown Spill tank. The alarm logic for
this tank checks the tank level at various times each day. If the tank level is greater than
50% at either time period, the Pine Brownstock Operator will receive an audible alarm as
well as a text message stating that the"Pine Brown Spill tank level is high." The control
logic will then check the level three hours later and if the level is still above 50%, the
operator will receive another alarm stating that the "Pine Brown Spill tank level is still
too high." In addition, if the Brown Spill tank level exceeds 80%, the operator receives a
high level alarm on his/her Digital Control System (DCS) graphic. All of these control
system improvements have enhanced the operator's ability to monitor the system and
prevent spills and losses from these processes.
2.2.2 Improvement in Preparation for Planned Outages
Color management of planned outages has improved significantly as a result of the
following practices:
• Increasing color testing from 2 hours to one hour before outages, during outages
and upon start-up;
• Improved communication between the Wastewater Treatment Plant and mill
operations;
• Utilization of the off-line, spare clarifier;
4

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
• Developing tank draining schedules where only the necessary vessels are emptied
for inspection and scheduled maintenance;
• Reducing tank levels to the lowest level possible prior to shutdown.
To effectively monitor color performance during maintenance outages, the WWTP
operators begin hourly color testing on the primary influent when the Recovery operation
initiates its shutdown procedure. The hourly color data is posted on the mill's Plant
Information (PI) System where it is widely available to operations and support personnel.
If a result is greater than 300 color units, it is immediately communicated to the Recovery
and Pulp Mill foremen via the mill radio system and they institute investigative action to
pinpoint the source. The appropriate corrective action is then taken. The Pulp Mill and
Recovery foremen also communicate their investigative findings with one another to
ensure effective troubleshooting is in place.
If an hourly color result is elevated and mill operations communicates that there has been
a process loss, the WWTP operators will divert the primary influent flow to the 1 million
gallon off-line, spare clarifier for temporary storage. There have also been instances
when the WWTP operators diverted the primary influent flow without direct
communication of a spill. The WWTP operators are trained to take action and route high
colored primary influent to the off-line, spare clarifier when necessary. The high color
material is later fed into the WWTP system at a slow, non-disruptive rate. Such a slow
feed rate minimizes the material's impact on secondary effluent color and does not
disrupt the WWTP process. For very high colored material captured in the off-line
clarifier, polyamine may be added in small amounts. Small amounts of polyamine aid in
the color removal of the concentrated material captured in the clarifier without negatively
affecting the sludge quality as larger amounts of polyamine have been demonstrated to
do. During normal mill operations, full-scale application of polyamine was not proven to
be effective and it created unmanageable sludge conditions; however,polyamine has
been effective on these higher color concentration events captured in the off-line clarifier.
5

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
Also, if at any time high colored material is seen in the primary influent, or if mill
operations communicates a process loss/intentional diversion, the WWTP operators can
immediately divert the primary influent flow into the off-line, spare clarifier. Improved
communications between the WWTP and mill operations have allowed for optimal use of
the off-line clarifier, especially in outage situations when overall spill system capacity is
in demand.
Tank draining schedules are developed in preparation for planned maintenance outages.
Increased attention has been given to draining only the tanks and lines requiring
inspection and/or maintenance rather than draining entire sequences. Draining the entire
sequence was a routine approach in the past so that vessels would be empty and available
for maintenance if problems were detected. The schedule has been optimized so that
inspections are rotated between outages, thereby ensuring that all tanks are inspected
while reducing the frequency that individual tanks must be emptied. However, issues
may arise where more frequent maintenance is required on certain vessels and
appurtenances and in these cases, the tanks must be drained before a scheduled inspection
is due. In preparation for all scheduled outages, it is standard practice to focus on
reducing tank levels to minimize the amount of material to be drained. This practice also
reduces potential losses in the event of an upset process condition during shutdown,
outage, or start-up periods.
These practices have measurably improved outage color performance. Specifically,
reductions in the color losses are demonstrated by the 2002 semi-annual shutdowns
(outages performed twice per year, lasting approximately one week with each outage
involving half of the mill operations).In a comparison of semi-annual outage primary
influent color data, the 2002 data showed an average 3 8% reduction in the maximum
daily primary influent color from historical performance (1996—2001). These
improvements are significant given that the majority of the spill recovery systems were
implemented in 1997 and 1998.
6

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
2.2.3 Reduction of Clean Water that Continuously Runs into Sewers
There has been a greater than 90,000 gallon per day reduction in the amount of clean
water being sewered, primarily in the mill's digester courtyard. This reduction in flow
was achieved by implementing customized Double Mechanical Seals and Water
Management Systems on the 18 digester re-circulation pumps. This project has involved
extensive trialing of different types and combinations of specially designed mechanical
seals over the past several years. The decrease in flow from the mechanical seals is at
least 3 to 4 gallons per minute per pump, which equates to a daily flow savings greater
than 90,000 gallons. The removal of non-mechanical seal pump packing water from the
digester sewers has also contributed to improved color performance for the area. Since
complete implementation of the mechanical seals, measured color in the area has been
reduced by approximately 60%. This is due in part to the removal of seal water that
could be contaminated by black liquor leaks on the non-mechanical seal packing and
from the recovery sumps operating more efficiently. With less clean water dilution in the
sewers leading to the recovery sumps, the effective conductivity of the material increases
and can be captured for re-use in the process at a greater efficiency. Customized Double
Mechanical Seals and Water Management Systems have also been installed on the
Knotter feed pumps for both the Pine and Hardwood Fiberlines, to further reduce water
infiltration to the sewer.
2.2.4 Improvement in Equipment used for Handling Knot Rejects
Two projects have been completed to improve the equipment used for handling knot
rejects. Black liquor from the Knot Rejects Collection bins is routed to a dedicated U-
drain, which flows to a dedicated knot bin sump pump for each Fiberline. The flow from
the knot bin areas is collected and pumped to the Brown Spill tank for each respective
Fiberline. Recovery of this material has contributed to improved color performance, as
7

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
demonstrated by Figure 1 below. The Hardwood Fiberline Brownstock sewer color has
shown the most dramatic reduction in color,which results from:
• Having the flexibility to send contents from the Hardwood Brown Spill tank to
the Pine Blow Tower during shutdown and start-up from an outage;
• Reducing the amount of clean water dilution by installing the Double Mechanical
Seals and Water Management Systems;
• Capturing the black liquor from the knot rejects system and;
• Improved communication and color monitoring.
Monthly Average Hardwood Brownstock and Digester Area Color
Since Installation of Double Mechanical Seals and
Water Management Systems
12000
10000
n 8000
a
N
a 6000
0
�j 4000
2000
0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
m > > Q y O
Hardwood Brownstock and Digester Area Color
Figure 1
8

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
III. Improvements in BFRTM Reliability
Approximately$1.5 Million has been spent on Bleach Filtrate Recycle process
improvements for 2002—2003. This has resulted in improved BFRTM closure rates over
the past year and operational variability is also showing improvement in the Metals
Removal Process (MRP). In August 2003, the monthly average closure rate reached
targeted levels with improved MRP uptime and equipment reliability matching Fiberline
reliability. To improve process variability, a new media filter and a new ion exchange
softener were installed in the MU. Due to accelerated degradation of the original three
media filters over recent months, they will also be replaced by the end of 2003. With this
additional equipment,metallurgy changes and other process improvements, MRP
downtime is expected to be reduced significantly. Having four media filters and three ion
exchange softeners will provide enough capacity for the MRP to remain online while
repairs are made to an individual media filter or softener. These projects are beginning to
demonstrate improved closure rates, reduced operational variability of the MRP, and
increased mechanical reliability of the MRP, all of which should aid in reducing both
measured and unaccounted color. As was expected, a recent statistical evaluation
demonstrated that lower closure rates are a major contributor to elevated secondary
effluent color and unaccounted color,individually as a main effect and also combined
with other factors as an interaction effect. These effects will be discussed in a later
section.
9

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
IV. Color Challenges in 2002—2003
As a result of many years of color reduction activities and those discussed herein, the
monthly average secondary effluent color for the period December 2001 through October
2002 was 39,833 lbs/day. However,due to unforeseen and complex issues discussed in
this report, secondary effluent color increased in late 2002.
In November 2002, secondary effluent color variability began to increase. The
contributing source(s) were not readily evident. Out of the 15 sewer and process areas
measured daily, there were no measured sources that were statistically out of control
except for the Pine Eo filtrate, and that influent contribution was less than 5,000 lbs/day
over the in-control average. Two major sewer areas, the Bleach Plant Filtrate Acid Sewer
and the Hardwood BrownstocloDigester Area Sewer were actually operating below their
average level of performance. The unaccounted color averaged about 23,000 lbs/day for
the month (compared to a 2002 YTD average of approximately 10,000 lbs/day). A
thorough review of all sewered, color-contributing sources revealed that the hardwood
screen rejects were not being quantified in the daily in-mill color analysis. Data has been
collected and the average color contribution from the hardwood screen rejects is 3,000
lbs/day. This source has been a small portion of the mill's unaccounted color since 1996;
therefore, it is not a significant contribution to the elevated unaccounted color seen during
this period. Further, the Wastewater Treatment Plant Color removal effect was dropping.
Elevated unaccounted color and reduced WWTP color removal are indicators that
support the presence of Sewer Generated Color(SGC), yet closure was averaging 77%
and the color contribution from the Bleach Plant Filtrates, the historical pre-cursors of
SGC, were running below average as illustrated in Figure 2 below.
10

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
Monthly Average Color in the Bleach Plant Acid Sewer
Jan-02 through Jan-03
16000
4000
2000
10000
U 8000
6000
4000
t Color 6A
Figure 2
As the Canton Mill has reduced releases of brown colored material, a greater percentage
of the primary influent color has became unaccounted color. Color is a pH dependent
parameter and Blue Ridge is in un-charted territory with such low brown color effluents
and the BFRTm technology. The result of increasing the pH of an acidic bleach plant
filtrate in the laboratory shows a visually significant increase in color. The Sewer
Generated Color phenomenon has been duplicated on the bench in multiple studies and
the National Council on Air and Stream Improvement(NCASI) supports that color is a
pH dependent phenomenon. Sewer Generated Color does not disappear when the pH is
adjusted from alkaline back to neutral conditions.
Duke University graduate level internship and thesis studies performed at the Canton Mill
in 19941 and 19952 showed, on average, Sewer Generated Color for Pine D1 filtrate was
an increase of 32-47% above the original sample color and Sewer Generated Color for
Hardwood DI filtrate was 64-88%. Regarding WWTP color removal, data suggested
I `A Laboratory Analysis of Color Removal Across a Pulp and Paper Mill Wastewater Treatment Facility"
by Aimee Winter McCord
2 `A Laboratory Analysis ofthe Color Removal Mechanism Occurring Across the Wastewater Treatment
Plan"by Chad Salisbury
11

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
some hardwood Sewer Generated Color may be removable across the WWTP (3%
reduction in color after WWTP process), but pine filtrates showed an average increase in
color of 21% in the simulated WWTP process. Data from this study show brown source
color removal up to 70% and the long-term average color removal across the WWTP
from primary influent to secondary effluent is 25%. The annual Color Pies showing the
breakdown of mill sewers compared to primary influent color support the presence of
Sewer Generated Color as unaccounted color has averaged 25% (19,081 lbs/day) since
1996. Of this 25%, the hardwood screen rejects contribute a small amount (currently
about 2,7001bs/day).. The period from November 2002 through April 2003 is evidence
that specific interactions and operational conditions can significantly intensify the Sewer
Generated Color effect. Bench scale studies are planned to better understand the various
types and magnitudes of the major interaction effects pinpointed during the period of
elevated color. It is recognized that these conditions may change and new effects may
need to be studied in the future.
Figure 3 below shows the trend of increasing unaccounted color and decreasing WWTP
color removal that began in November 2002.
12

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
Unaccounted Color and WWTP Color Removal %
30000 Monthly Averages: Jan-02 through Feb-03 35.00%
T
25000 30.00%
a n
25.00%0
c 20000
C 20.00%;o
9 15000 3
15.00%c
0 10000 01
V 10.00°i°o
a
5000 5.00%
0 0.00%
0 0 0 0 0 0 0 0 0 0 0 0 0 0
Q O d d
IO N N 7 7 7 -T N
Go 0 Z O � LL
—�—Unaccounted Color 0 WWTP Color Removal
Figure 3
The trend of increasing unaccounted color and simultaneous decreasing WWTP color
removal continued in December and a Color Team was formed including representatives
from Operations, Environmental and the Technical Manufacturing Support group. This
team initially audited the color measurement system as well as monitored sewer areas and
related instrumentation for accuracy as well as potential unmeasured sources of color.
When there were no anomalies discovered, the team focused on analyzing process
parameters for shifts and deviations that could contribute to elevated color. Processes in
the Fiberlines and Recovery area were reviewed in most detail while deviations from the
Paper Machines were also considered. The Pine Eo filtrate was consistently the only
color source that was running above its upper control limit but the causes were unknown.
Multiple statistical analyses were performed including CUSUMs or Cumulative Sum
charts to identify if, in fact, statistically significant shifts were occurring. While there
13 .

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
were several process parameters that were discovered to be operating outside their normal
ranges of variability,the most notable shifts were seen in the Fiberlines. Specifically, the
Pine Fiberline Bleach Plant and the Hardwood Fiberline Pre-Bleach and D1 (first D)
stages. Additional statistical studies were performed and targets were established for the
above parameters as well as others, based on early 2002 when the color performance was
in the 36,000—39,000 lbs/day range. As the Fiberlines began reaching the established
targets, the unaccounted color remained elevated.
During the latter part of 2002, the variability in the White Liquor strength and solids
increased. This change was believed to be negatively impacting the Fiberline operations
by causing increased carryover into the bleach plants. These issues corresponded to the
decreased color performance seen beginning in November 2002. Elevated White Liquor
solids were then identified as an interaction effect contributing to elevated secondary
effluent and unaccounted color and this parameter was added to the Daily Color
Monitoring list. Also during late 2002, the quality of purchased lime for the Causticizing
operation was compromised due to flooding and other issues with the Mill's normal lime
supplier. Negotiations with additional lime suppliers are ongoing to improve the quality
of purchased lime.
Upon startup from the Cold Mill Outage in April 2003, unaccounted color increased even
further to the 35,000—40,000 lbs/day range from pre-Cold Mill levels in the 20,000
lbs/day range. Pine Eo filtrate color was back below the in-control average yet
unaccounted color was still high. Detailed Analysis of Variance (ANOVA) Factorials
were performed in an effort to determine which factors and combinations of factors were
affecting secondary effluent color and unaccounted color significantly. For these
analyses, an alpha of.05 was used. The results of the ANOVAs proved that there were
multiple statistically significant main effects and interaction effects "responsible" for the
elevated secondary effluent color and unaccounted color. This means that the effect
impacting the dependent variables (secondary effluent and unaccounted color)was not
14

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
doing so by chance. The interaction effects involve relationships between certain
parameters that significantly affect color. Subtle operational changes made in late 2002
had triggered a major Sewer Generated color problem and greater than 30 effects,
including main and interaction effects, were pinpointed. The most significant main
effects were BFRTm Closure, Pulp Mill Flow and Hardwood Pre-Bleach Conductivity.
There were numerous significant interaction effects, some including up to four interacting
factors, which is evidence of the problem's complex nature. To determine if the effects
had been present during periods of"good" color performance, ANOVAs were performed
on those periods as well. The only main effect that was statistically significant in
impacting secondary effluent color from January 2002—July 2002 was Closure and there
were no main effects nor interaction effects that were statistically significant for
unaccounted color during the period of good color performance. As a result of the
ANOVA studies, a daily color monitoring information report was created which tracks
the color-impacting parameters via targets and 30-day trends. Closure was the most
significant main effect contributing to elevated secondary effluent color. Given the
increase in bleach plant filtrate that reaches the mill sewer when closure rates are low,
there is a larger volume of low pH material available to undergo the Sewer Generated
Color effect. Because it has been shown that Sewer Generated Color is not removed
across the Wastewater Treatment Plant, lower closure rates translate into a measurable
increase in secondary effluent color. In addition to being a main effect, closure was a
statistically significant color-impacting variable in 13 different interaction effects as well.
Pulp Mill flow was the second most significant main effect contributing to elevated
secondary effluent color. Similar to closure, elevated flow from the Pulp Mill is likely to
be low pH material,which is a pre-cursor for Sewer Generated Color.
Hardwood Pre-Bleach Conductivity is the measure of conductivity from a pulp filtrate
sample taken off of the Pre-Bleach washer. Elevated conductivity indicates increased
carryover into that stage. Increased carryover from the pre-bleach stage can affect the
15

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
first stage of bleaching(D1), potentially requiring elevated acid usage on the D1 stage.
This was observed during the period of elevated color and was also a statistically
significant main effect and interaction effect in the ANOVA analyses. Elevated acid use
in the bleach plant could intensify the Sewer Generated Color effect by further reducing
pH.
Also, it was believed that start-up of the entire mill from the Cold Mill outage required
adequate time to reach stable operation. This stable operation was not achieved until
mid-May. Challenges from the Cold Mill start-up had to be managed before the targets
from the ANOVA Factorial analyses could properly be incorporated into the daily
operation. At this point unaccounted color and secondary effluent color finally began
reaching normal ranges.
Incorporation of the results from the ANOVA studies into the Daily Color Monitoring
Information report has proven to be a useful tool for color management at the Canton
Mill. It is recognized that the conditions causing these effects may change in the future
and new effects may need to be studied/evaluated. Since the Daily Color Monitoring
Information report has been in use, the average secondary effluent color has dropped
from 49,024 lbs/day(average during November 2002 through April 2003 period of
elevated color) to 42,669 lbs/day. The Canton Mill is utilizing this new tool and will
continue to use and develop innovative tools for troubleshooting color in the future.
16

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
V. Statistical Analysis of Data
The average secondary effluent color from December 2001 through August 2003,
excluding the period of elevated secondary effluent and unaccounted color, is 39,833
lbs/day. Based on a statistical evaluation of the mill's monthly average color
performance, for the same period, the achievable secondary effluent color using a 95"'
percentile distribution is 43,189 lbs/day. The 2002 annual average secondary effluent
color was 41,171 lbs/day. Blue Ridge is committed to continued color performance
improvements and recommends an annual average secondary effluent limit of 42,000
lbs/day. '
Blue Ridge recommends a monthly average effluent limit of 52,000 lbs/day based on the
color challenges encountered in the past year. Data for the December 2001 through
August 2003 period is attached to this report.
17

Blue Ridge Paper Products Inc.
Monthly Average Secondary Effluent Color: Dec-02 through Aug-03
Attachment 1: October 1, 2003 Report
Monthly Average Ibs/day
Month Secondary Effluent Color
Dec-01 36,821
Jan-02 39,040
Feb-02 39,870
Mar-02 37,886
Apr-02 42,477 Monthly Average Ibs/day
May-02 42,458 Secondary Effluent Color Excluding Nov-02 -Apr-03
Jun-02 41,312 Dec-01 36821
Jul-02 41,686 Jan-02 39,040
Aug-02 40,750 Feb-02 39,870
Sep-02 39,480 Mar-02 37,886
Oct-02 36,382 Apr-02 42,477
Nov-02 48,014 May-02 42,458
Dec-02 44,701 Jun-02 41,312
Jan-03 51,269 Jul-02 41,686
Feb-03 48,324 Aug-02 40,750
Mar-03 50,412 Sep-02 39,480
Apr-03 51,423 Oct-02 36,382
May-03 40,955 May-03 40,955
Jun-03 42,458 Jun-03 42,458
Jul-03 44,734 Jul-03 44,734
Aug-03 42,527 Aug-03 42,527
2002 average 41,174 95th percentile 43,189
2003 ytd average 46,513 period average 40,591
95th percentile for 2003 51,369

E V
DEC - 1 2005
BLUE RIDGE WATERQUPLITVSECTION
PAPER PRODUCTS INC.
ASHY=yil LF PEG'CNAL OFf-ICE
Certified Mail
Return Receipt Requested
30 November 2005 7099 3220 0007 0371 5900
Mr. Alan W. Klimek, P.E.
Director
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Effluent Color Performance Following Highest Certainty and Reasonable
Certainty Actions
NPDES Permit No. NC0000272
Blue Ridge Paper Products Inc.
Canton, North Carolina
Dear Mr. Klimek:
Enclosed are two (2) copies of the subject report in accordance with Part I, Condition A.(8.),
Paragraph 8 of the December 2001 NPDES permit. With this report Blue Ridge Paper has
completed Highest Certainty, Reasonable Certainty, and Lowest Certainty actions for color
reduction identified in the NPDES permit. The report also documents on-going mill-identified
colot reduction initiatives. ' I
The Blue Ridge Paper Canton Mill is committed to continued color performance improvement
and recommends an annual average secondary effluent true color limit of 39,000 pounds per day
and a monthly average true color effluent limit of 52,000 pounds per day. Based on recent color
performance and color-related projects underway, we believe that these limits are technically,
economically and operationally feasible.
Please contact us if you have any questions.
Sincerely,
V6
Paul S. Dickens Robert V. Williams
Manager, Environmental Affairs Director,Regulatory Affairs
828-646-6141 828-646-2033
[e-mail] [e-mail]
Environmental Group
175 Main Street o PO Box 4000
Canton, North Carolina 28716 o 828-646-2000
Raising Your Expectations

,, V
Mr. Alan W. Klimek, NC DENR DWQ
30 November 2005, Page 2
Enclosure: Effluent Color Performance Following Highest Certainty and Reasonable
Certainty Actions
cc: (w/encl): Dave A. Goodrich
Environmental Supervisor
Point Source Branch
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Roger Edwards
Surface Water Protection Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
er yne as
Environmental Specialist
Division of Water Quality
North Carolina Department of Environment
' and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Don Anderson
US Environmental Protection Agency
Office of Water
Office of Science and Technology (4301 T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Sergei Chernikov
Environmental Engineer I
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Alan W. Klimek, NC DENR DWQ
30 November 2005, Page 3
Internal Distribution:
C. File Water
Engr File—NPDES Color Reports
B. Shanahan
J. Clary
M. Ferguson
K. Hennessy
D. Brown
R. Medford
C. Dowdle
D. Cherry
J. Pryately
L. Cooper
Environmental Group
175 Main Street o PO Box 4000
Canton, North Carolina 28716 a 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
Blue Ridge Paper Products Inc.
Canton Mill, Canton, North Carolina
NPDES No. NC 0000272
Effluent Color Performance Following
Highest Certainty and Reasonable Certainty
Actions
Update on Mill-Identified Color Reduction Initiatives
December 2005

December 2005 Effluent Color Report, BRPP Canton Mill
Page i
Executive Summary
This report documents the ability of the Blue Ridge Paper Products Inc., Canton Mill to attain
annual average and monthly average color limits following Highest Certainty and Reasonable
Certainty actions identified in the December 2001 NPDES permit. The report is submitted to
satisfy requirements of Part I, Section A.(8.), Paragraph 8 of the permit.
"...By December 1, 2005, the permittee shall submit, as related to implementation of the
process improvements evaluated according to Paragraph 7, a statistical analysis of Blue
Ridge Paper's effluent quality performance. This report shall include a statistical
analysis of the Blue Ridge Paper's monthly average and annual average color discharge,
mill performance as related to color, and all available data necessary to derive the
lowest achievable annual average and monthly average color loading limits. ..."
Based on the Canton Mill's performance from December 2003 through September 2005 and the
mill's continued commitment to color improvement, Blue Ridge Paper believes that an annual
average secondary effluent true color limit of 39,000 pounds per day and a monthly average
secondary effluent true color limit of 52,000 pounds per day are technically, economically and
operationally feasible.
Dec 2005 Color Report Final.doc

December 2005 Effluent Color Report, BRPP Canton Mill
Page ii
Fable of Contents
ExecutiveSummary......................................................................................................................... i
Introduction..................................................................................................................................... 1
Purpose........................................................................................................................................ 1
PermitRequirement.................................................................................................................... 1
Previous Color Limits, Evaluations and Reports........................................................................ 1
Blue Ridge Paper Color Reduction Initiatives................................................................................ 2
Hardwood Fiberline Six Sigma Team.........................................................................................2
Pine Brown Recovery Transfer Line.......................................................................................... 3
Milkof Lime............................................................................................................................... 3
Pine and Hardwood Quaternary Screen Rejects Press................................................................3
GreenLiquor Sump.....................................................................................................................4
AcidSewer Rerouting.................................................................................................................4
Color Process Improvement Six Sigma Team............................................................................ 5
ColorReliability Projects............................................................................................................ 5
Statistical Analysis of Color Data................................................................................................... 5
Summaryand Recommendation..................................................................................................... 6
Attachment I: Color Reduction Initiatives Under 2001 NPDES Permit, December 2005
Dec 2005 Color Report Final.doc

December 2005 Effluent Color Report, BRPP Canton Mill
Page I
Introduction
Purpose
This report documents the ability of the Blue Ridge Paper Products Inc., Canton Mill to attain
annual average and monthly average color limits following Highest Certainty and Reasonable
Certainty actions identified in the December 2001 NPDES permit. The report also documents
recent mill-identified color reduction initiatives.
Permit Requirement
The requirement of the 2001 NPDES permit for this report is specified in Section A.(8.),
Paragraph 8:
"By December 1, 2005, the permittee shall submit, as related to implementation of the
process improvements evaluated according to Paragraph 7, a statistical analysis of Blue
Ridge Paper's effluent quality performance. This report shall include a statistical
analysis of the Blue Ridge Paper's monthly average and annual average color discharge,
mill performance as related to color, and all available data necessary to derive the
lowest achievable annual average and monthly average color loading limits.
By February 1, 2006, the Division of Water Quality (in consultation with the Technology
Review Workgroup) shall recommend to the NPDES Committee, considering the
statistical analysis report submitted by the permtttee and the demonstrated performance
of the mill, the lowest achievable average and monthly average color loading effluent
limitations. If the limits determined to be achievable are within or below the range of
32,000 to 39,000 lbs per day as an annual average, the limits shall become effective
March 1, 2006, by written notification from the Director. If the limits determined to be
achievable by the Division of Water Quality(in consultation with the Technology Review
Workgroup) are above the target range, the Permit shall be modified in accordance with
North Carolina's permitting process to reflect those limits."
Previous Color Limits,Evaluations and Reports
Effluent color limits in Part I, Section A(8.),Paragraph 2 of the December 2001 NDPES are as
follows:
"The average annual discharge of true color for each calendar month shall not exceed
48,000 pounds per day. The monthly average effluent true color loading shall not exceed
55,000 pounds per day. For the purpose of this permit/variance only, 'pounds of true
color' is calculated by the following equation:
Effluent flow (mgd)x Effluent Trite Color((ppm, sic)Platinum Cobalt Units)x 8.34"
The 2001 NPDES permit also established a series of actions and reports related to color
reduction at the Blue Ridge Paper Canton Mill. "Highest Certainty" actions were projects
Dec 2005 Color Report Final.doc

r
December 2005 Effluent Color Report, BRPP Canton Mill
Page 2
identified by Blue Ridge Paper and the Technology Review Workgroup (TRW) as technically,
economically and operationally feasible. These projects were implemented during 2002 and
2003. Canton Mill effluent color performance following implementation of the Highest
Certainty projects was documented in the October 2003 Color Report required under Part I,
Section A (8), Paragraph 5 of the NPDES permit.
"Reasonable Certainty" actions were projects identified by the TRW with possible application to
the Canton Mill. Blue Ridge Paper completed evaluation of the technical, economic and
operational feasibility of Reasonable Certainty actions during 2002 and 2003. Results were
documented in the December 2003 Color Report required under Part I, Section A (8), Paragraph
7 of the NPDES permit. None of the Reasonable Certainty actions were deemed feasible.
However, based on mill performance with Highest Certainty actions and other initiatives, Blue
Ridge Paper recommended an annual average color limit of 42,000 pounds per day. In addition,
the Mill voluntarily accepted a reduced monthly average color limit of 52,000 pounds per day.
The Division of Water Quality (DWQ) revised the NPDES permit for these limits on February
27, 2004.
"Lowest Certainty" actions involve possible technologies to treat or eliminate the Chloride
Removal Process (CRP) wastestream. Part I, Section A (8.), Paragraph 9 of the NPDES permit
specified several specific technologies for evaluation including land application, commercial
incineration, coagulation/precipitation and solidification for land disposal. Blue Ridge Paper
identified and evaluated several other possible technologies including ozone and chlorine dioxide
bleaching. However, based on engineering evaluation and/or bench and pilot scale testing, no
feasible Lowest Certainty actions were found. These results were reported in the March 2005
CRP Color Reduction Technology Assessment Report. The CRP Report was originally due in
December 2004, but the DWQ granted a 3-month extension following floods that affected the
Qanton Mill in September 2004. 1 4 0 0
Blue Ridge Paper Color Reduction Initiatives
Attachment I outlines major color reduction initiatives at the Blue Ridge Paper Canton Mill
under the 2001 NPDES permit. As of December 2005, Blue Ridge Paper has completed
NPDES requirements related to Highest Certainty, Reasonable Certainty and Lowest Certainty
actions for color reduction. The Canton Mill has undertaken other color initiatives beyond those
specified in the NPDES permit. These are included in Attachment I. Mill-identified color
projects not included in previous permit-required color reports are documented in sections
below.
Hardwood Fiberline Six Sigma Team
The October and December 2003 Color Reports identified hardwood fiberline washing as a
statistically significant contributor to secondary effluent color. A Six Sigma team was chartered
in spring of 2004 to evaluate opportunities to decrease hardwood color through improved
hardwood brownstock washing and process control. The team looked at process procedures,
Dec 2005 Color Report Final.doc

Y
December 2005 Effluent Color Report, BRPP Canton Mill
Page 3
operating practices and process control parameters to understand their effect on process
reliability and color. A new operating strategy was implemented including new performance
metrics and tracking. The team also identified opportunities to improve brown stock washing
through shower bar adjustments and replacements. New design shower bars were recently
installed on the Number 1 Hardwood Brownstock Washer. A performance evaluation of the new
shower bar design is underway. Shower bar replacements on additional fiberline washers may
be considered during 2006.
Pine Brown Recovery Transfer Line
This project was introduced in the December 2003 Color Report. The Pine Brown Recovery
Transfer Line was completed during the Spring 2004 semi-annual outage. The project provided
a transfer pipeline between the Pine Brown Spill Tank and the Hardwood Blow Tower. The
transfer pipeline increases the effective recovery volume of the Pine Brown Spill System by
allowing excess color materials from the pine fiberline to be pumped into the hardwood fiberline
for recovery. This extra recovery volume is used during maintenance outages and other events to
improve overall capture and recovery of color materials that otherwise would not be reclaimed.
The estimated annual average secondary effluent color reduction from the Pine Brown Recovery
Transfer line is 500 pounds per day.
Milk of Lime
This project was included in the May 2004 Supplement to the December 2003 Color Report.
During Spring of 2004, Blue Ridge Paper conducted a full-scale trial on the color reduction
effect of,adding a continuous slurry of hydrated lime to the mill osewer system prior to
wastewater treatment. This "milk of lime"provides calcium, which in bench scale studies was
effective in removing brown color. Milk of lime addition produced a reduction in primary
influent color. However, there was no statistically significant reduction in secondary effluent
color associated with milk of lime. In addition, milk of lime addition has adverse effects on
sludge dewatering and wastewater sludge volume. Based on the dose rate and cost, milk of lime
is not an economically or operationally feasible technology for color reduction.
Pine and Hardwood Quaternary Screen Rejects Press
This project was introduced in the December 2003 Color Report and was implemented during
2004. The Pine and Hardwood Screening Systems follow brownstock washing and remove
shives and undigested pulp from brownstock fiber before bleaching. The screen reject flow
includes a sizable volume of filtrate that contains dissolved color materials. The Quaternary
Screen Reject Presses allow separation of the rejects and filtrate so that color materials in the
filtrate can be reclaimed. During summer of 2004, Blue Ridge Paper worked with a specialty
equipment vendor to fabricate, install and test prototype mechanical screw presses on the reject
drains for the hardwood and pine quaternary screens. After pressing, the reject filtrates are
returned to brownstock filtrate tanks. The dewatered rejects are burned in the Canton Mill bark
Dec 2005 Color Report Final.doc

11
December 2005 Effluent Color Report, BRPP Canton Mill
Page 4
boiler. The prototype screw presses were successful, and permanent units were purchased and
installed in the fall of 2004.
Based on monitoring during trials of the Quaternary Screen Reject Presses, color reduction is
approximately 1000 pounds per day. Blue Ridge Paper is working with the equipment
manufacturer to improve reliability and uptime for the Quaternary Screen Reject Presses. The
Blue Ridge Paper installation on the quaternary screen rejects is the first application of its kind
for screw press equipment.
Green Liquor Sump
This Green Liquor Sump project was introduced in the May 2004 Supplement to the December
2003 Color Report. The project was completed in August 2005. The Green Liquor sump allows
segregation of green liquor from black liquor recovery sumps in the recovery furnace area. This
segregation is important to in-mill color control because green liquor contamination of black
liquor materials prevents their capture and recovery. The green liquor is corrosive to evaporators
and other chemical recovery cycle equipment.
The estimated annual average secondary effluent color reduction from the Green Liquor Sump is
500 pounds per day.
Acid Sewer Rerouting
As documented in the October 2003 Color Report, unaccounted color has become a larger
percentage of mill sewer color as Blue Ridge Paper has successfully reduced brown color
discharges to wastewater treatment. Unaccounted color is calculated as the difference between
measured primary influent color in pounds per day and the sum of color measured in mill sewers
upstream of wastewater treatment. Unaccounted color is primarily the result of sewer-generated
color that occurs when acid bleach plant filtrates are exposed to alkaline conditions in the mill
sewer and primary clarifiers. Sewer generated color consists of dissolved color materials and is
not effectively removed by filtration and conventional coagulation and precipitation technology.
The current acid sewer at the Blue Ridge Paper Canton Mill mixes with the alkaline mill sewer at
the 4A manhole upstream of primary treatment. This configuration creates conditions that may
contribute to sewer generated color. To minimize the creation of sewer generated color, it is
desirable to keep acid bleach plant filtrates away from alkaline pH conditions.
A project was engineered during early 2005 to reroute acid bleach filtrates directly to the primary
clarifiers downstream of initial pH adjustment for the alkaline mill sewer. With rerouting, the
acid filtrates will see a neutral pH range of 6 to 9 when mixed with other mill wastewaters for
treatment. The design allows the bleach plant filtrates to mix with either primary influent or
primary effluent wastewater prior to secondary treatment. The Acid Sewer Project,was
constructed during summer and fall of 2005 and will go into full operation in early 2006. Startup
testing is scheduled for December 2005.
Dec 2005 Color Report Final.doc

e
December 2005 Effluent Color Report, BRPP Canton Mill
Page 5
Blue Ridge Paper believes the Acid Sewer Project will achieve reduction in sewer generated
color. The reduction in secondary effluent color, however, is difficult to predict. The Acid
Sewer Project is a full-scale trial in terms of secondary effluent color reduction.
Color Process Improvement Six Sigma Team
As a result of color reduction projects implemented under the 2001 NPDES permit, secondary
effluent color from the Blue Ridge Paper Canton Mill for the period January through September
2005 averaged 39,465 pounds per day. This average includes several months of color
performance in the range of 32,000 to 38,000 pounds per day and several months of color
performance in the range of 41,000 to 46,000 pounds per day. This variability in monthly color
performance is a result of maintenance outages and normal process variability. Reducing the
variability of color performance is the next color reduction challenge for the Blue Ridge Paper.
A Six Sigma Team was chartered in September 2005 to examine the primary operating
conditions associated with periods of lowest color performance.
Color Reliability Projects
In addition to the Color Process Improvement Team, Blue Ridge Paper will dedicate capital in
2006 to improve the reliability of processes that have a demonstrated impact on color
performance. These capital projects will focus on pulp washing efficiency, engineering controls
to improve early detection of process upsets that may release color, and further mechanical
reliability improvements to the Bleach Filtrate RecyclingTM (BFR)process. Engineering design
of the Color Reliability Projects is underway with implementation planned during the first half of
2006. The 2006 ColorlReliability Projects are included in Attachment I.
Statistical Analysis of Color Data
The average daily secondary effluent true color from the Blue Ridge Paper Canton Mill for the
period December 2003 through September 2005 - excluding the period of mill outage and restart
in September and October 2004 due to Hurricanes Frances and Ivan—is 39,548 pounds per day.
The upper 95 percent confidence interval for the average of this period is 40,280 pounds per day.
The average monthly secondary effluent color for the period December 2003 through September
2005—excluding the flood-affected months - is 39,545 pounds per day. The upper 95 percent
confidence interval for monthly average color is 41,350 pounds per day. The maximum monthly
average color during this period occurred in August 2005 at 45,842 pounds per day. If the
flood-affected months of September and October 2004 are included, the maximum monthly
average color occurred in October 2004 at 59,539 pounds per day.
Dec 2005 Color Report Final.doc

December 2005 Effluent Color Report, BRPP Canton Mill
Page 6
Summary and Recommendation
Blue Ridge Paper Products Inc. has completed Highest Certainty, Reasonable Certainty and
Lowest Certainty actions for color reduction identified in the December 2001 NPDES permit.
The mill has also identified, evaluated and implemented other initiatives for color reduction.
Several of these mill-identified projects are underway and will be completed during 2006.
The Blue Ridge Paper Canton Mill is committed to continued color performance improvement
and recommends an annual average secondary effluent true color limit of 39,000 pounds per day
and a monthly average true color effluent limit of 52,000 pounds per day. Based on recent color
performance and color-related projects underway, we believe that these limits are technically,
economically and operationally feasible.
Dec 2005 Color Report Final.doc

Attachment I - Color Reduction Initiatives Under 2001 NPDES Permit,December 2005 Update
Blue Ridge Paper Products Inc. - Canton Mill
Color Reduction Measure 2001 2002 JJJFNQ0_3= 2004 200- 2006
1 2-Hour Color Testing -
2 Liebervott Recommendations Implemented ---"""-"►
3 Use of Off-line Clarifier for Spill Diversion • - • • • - - ••
4 Hwd Brown Recovery Tank Line to Pine Blow Tower ------------
5 1-Hour color testing before and during maintenance outages
6 Installation of Mechanical Seals(clean water segregation) -----------► -•• - -
7 Improvement of equipment used for handling Pine and Hardwood Knot Rejects ------------► "-
8 $1.5MM spent on Bleach Filtrate Recycle Improvements -------------► •- -
9 Installed Pine Brownstock Control Logic improvements ------------► - - -- • -
l0 Determined multiple contributors and interaction effects causing Sewer Generated Color -----------� •• -
I1 Bench-scale sewer-generated color work ------------- ------------
12 Hardwood Fiberline Six Sigma Team for process optimization and color improvements --------- --- -------------
13 Improvements made to Pine Brownstock sumps for better recovery ------------- ------------ « -
14 White Rot Fungus Trial-growth efforts unsuccessful,may re-visit in future ------------- -------------
10
15 Pine Brown Recovery Tank Line to Hwd Blow Tower -------------- -------------- ------------► _
16 Milk of Lime Trial(not successful,no statistically significant SE color reduction) ------------- -------------- -------------- ►_
17 Pine and Hardwood Quaternary Screen Rejects Press(eliminate quaternary screen rejects
dischar a to sewer,recover filtrate and shives)
Trial to confirm and size system for C102 de-colorization of CRP/evaluate full-scale
18 application(trials completed after Sep 04 floods,not economically,technically or
operationally feasible
19 Green Liquor Sump at recovery furnaces(implementation delayed by Sep 2004 floods, i
-------------- ------'------- ---'-'-'------ ---'------
corn leted Aug 2005)
................................... ............................_......................................................................................._.......................... .......................-..........
20 Acid Sewer Rerouting-improved segregation of bleach plant filtrates from akaline -
wastewaters to reduce sewer generated color
2I Color Process Improvement Six Sigma Team to examine operating conditions associated
-------------- ------------- --'----'----- ------------- ---------
with good color performance '
22 2006 Color Reliability Projects-Pulp Washing Improvements(shower replacements and ►
re-bleach internal recycle pump)
23 2006 Color Reliability Projects-BRF Mechanical Improvements(MRP fiber detection and ► '^^°°^7
revention
-'-------'--- -'------------ --------i__
--'--'---- -
24 2006 Color Reliability Projects-Recovery Process Improvements(piping changes and
instrumentation)
-'--'----'--' '-----'------ -'------
25 2006Color Reliability Projects-Color Monitoring Improvement(relocated and redtmdant _____________ ______________ ________ ____________i
instrumentation)
- Completed Process Change/Evaluation 'Process Evaluation or Change
Continued Performance Improvement Expected Performance Improvement

FAS-HEV-ILLE
0M4VEBLUE RIDGE
DPIIPER PROOIICTS INC.
LITY SECTIONGIONAL OFFICE
May 18, 2004
Mr. Forrest Westall
Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Hwy 70
Swannanoa, North Carolina 28778
Subject: Supplement to December 2003 Color Report & Schedule Revision
NPDES No. NC0000272
Blue Ridge Paper Products Inc.
Canton, North Carolina
Dear Mr. Westall:
This letter is a supplement to the December 2003 report on "Reasonable Certainty" actions for
color reduction as specified in the November 2001 NPDES permit for Blue Ridge Paper
Products, Inc. The letter outlines current ongoing and additional color reduction activities in
preparation for the CRP color reduction report due in December 2004 [Permit Condition A.(8.)9]
and the statistical evaluation report for second tier color reductions due in December 2005
[Permit Condition A.(8.)8].
The Blue Ridge technology analysis documented in the December 2003 report identified three
most feasible areas for additional color reduction:
1. Contain color associated with the de-watering/disposal of Pine and Hardwood
Quaternary Screen Rejects.
2. Provide an additional capacity and outlet for color associated with the Pine Brown
Recovery tank.
3. Improve process control around Hardwood washing through process optimization efforts.
Blue Ridge also proposed a pilot test of ozone destruction of color associated with CRP and
Hardwood Eo filtrate streams.
This supplement communicates Blue Ridge's intent to update and revise the schedule around
certain color reduction initiatives. Blue Ridge will be accelerating and adding certain initiatives
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Forest Westall, NC DENR DWQ
May 18, 2004, Page 2
that are expected to benefit overall reductions. While evaluating these initiatives Blue Ridge
intends to modify the timeline for any ozone pilot test pending this evaluation. Significant
engineering work has already been completed for the ozone pilot test.
The status of these color reduction activities follows. Our first priority for color reductions
continues to be pollution prevention; color minimization through even tighter process operations
as opposed to end-of-pipe color treatment.
Current Color Reduction Activities
A. Hardwood and pine quaternary screen rejects —implementation accelerated
This project was defined in the December 2003 report and will pipe the quaternary screen
rejects from both pine and hardwood fiber lines to the Pine Rejects Press and recover the
filtrate for reuse in the process. For process operability reasons related to purging "dirt" and
other pulp contaminates, the quaternary screen reject flows are currently sewered
contributing an estimated 1500 to 2000 lbs per day to secondary effluent color.
Preliminary engineering for rejects transfer piping is underway. Evaluation of alternative
equipment for rejects dewatering is also underway.
B. Pine brown recovery spill line to hardwood blow tower—complete, 2"d Qtr. 2004
This is the project defined in December 2003 to provide additional process collection and
reclaim capability for black liquor and colored filtrates by connecting the pine brown
recovery tank to the hardwood blow tower. The piping work for the project was completed
during 151 Quarter 2004. The final phase of piping system changes will become active and
available at the end the May 2004 scheduled fiber line outage for annual maintenance.
The reduction in annual average secondary effluent color from the pine brown recovery spill
line is less than 500 lbs/day. However, this additional process collection and reclaim
capability can potentially avoid 1500 to 3000 lbs/day of monthly average color related to
outages and unplanned maintenance events.
C. Green liquor sump in Recovery Furnace area—additional initiative
Green liquor spills, leaks and maintenance diversions in the recovery furnace area are
sewered. Black liquor spills or leaks in the recovery furnace area that are contaminated with
green liquor are also sewered. This sewering of highly color materials is due to operational
problems that occur when green liquor is recovered and mixed with black liquor in recovery
furnace sumps. The recovery furnace spill sumps reclaim liquor materials by returning them
to the black liquor evaporator system. Green liquor causes corrosion and fouling of the
evaporators and is therefore segregated from black liquor whenever possible.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Forest Westall, NC DENR DWQ
May 18, 2004, Page 3
Preliminary engineering for a separate green liquor spill sump system at the recovery
furnaces is underway. The sump will segregate green liquor and black liquor handling areas
at the recovery furnaces. It will allow recovery of green liquor chemicals from process leaks,
operational purges and maintenance diversions and should improve color performance by
reducing sewering of green liquor materials and black liquor that is contaminated with green
liquor. These colored process loses will be recovered.
The reduction in annual average secondary effluent color from the green liquor sump is less
than 500 lbs/day. The additional process collection and reclaim capability provided by the
sump can potentially avoid 1500 to 3000 lbs/day of monthly average color related to outages
and unplanned maintenance events.
D. Chlorine dioxide treatment of the CRP waste stream—additional initiative
Blue Ridge will substitute a trial of chloride dioxide (002) treatment of the chloride
removal process (CRP) waste stream in place of the ozone treatment pilot test described in
the December 2003 report. We are prepared to proceed with the ozone pilot test if the C102
trial is not successful. However, based on bench and pilot scale work for combined C102
and ozone treatment of CRP completed during 2003, we believe that C102 treatment alone is
viable and worth further study. The advantage over ozone treatment is that Blue Ridge has
an existing C102 generation system with associated safety and air emission controls. These
existing facilities make C102 treatment potentially much more cost effective.
Preliminary engineering is underway for transfer piping and supporting utilities to treat CRP
along with pine D2 filtrate with C102 in a surplus process bleach tank. The D2 filtrate
contains residual C102 from the pulp bleaching process and will dilute the CRP color stream
to prevent salt precipitation during color treatment. Blue Ridge will retain an outside
chlorine dioxide expert to conduct additional CRP color treatment trials to verify the sizing
of equipment and C102 dose rates for a full-scale system.
The potential reduction in annual average secondary effluent color from CRP treatment with
chlorine dioxide is estimated to be 2000 lbs/day.
E. Milk of lime to sewer— additional initiative
Blue Ridge is conducting a trial on the color reduction effect of adding continuous slurry of
hydrated lime to the mill sewer system prior to wastewater treatment. This "milk of lime"
slurry provides calcium, which in bench scale studies was effective in reducing brown color
from bleaching filtrates. As Blue Ridge has tightened controls on black liquor-related dark
color, brown color has become a large portion of the mill's remaining color discharge.
The milk of lime trial will conclude in May. Blue Ridge will prepare a statistical analysis of
primary influent and secondary effluent color data to determine if the "milk of lime" effect
on color is significant. We will also evaluate the potential color reduction benefit, the effect
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

,4
Mr. Forest Westall, NC DENR DWQ
May 18, 2004, Page 4
on wastewater treatment operations and operating cost. Preliminary data suggest that milk of
line addition can potentially reduce 500 to 20001bs/day of secondary effluent color.
Summary
Implementation of `Highest Certainty' actions identified in the NPDES permit fully met the
expectations for first tier color reductions. Blue Ridge Paper Products believes that projects
identified in the December 2003 report and in this letter will meet the second tier color
reductions. This mix of initiatives will be evaluated to achieve compliance with the next color
reduction range of 39,000 to 32,000 lbs/day. We will also evaluate whether these initiatives
might achieve reductions that will allow the color variance to be lifted.
Blue Ridge is internally preparing full project descriptions with cost and color benefit analysis to
determine technical, economic and operational feasibility.
Sincerely, t
s.
Paul S. Dickens Robert V. Williams
Manager, Environmental Affairs Director, Regulatory Affairs
dickep@blueridgepal)er.com willib@blueridgepaT)er.com
828-646-6141 828-646-2033
PSD/s
Attachment I: Updated Color Reduction Initiatives Schedule
cc: EPA TRW
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Attachment I
Color Reduction Initiatives Under 2001 NPDES Permit - May 2004 Update
Blue Ridge Paper Products, Inc. - Canton Mill C
Color Reduction Measure 2001- 200Z 2003 2004 20115 2006 ,
I 2-Hour Color Testing I W XZK=�'<
2 Lieber ott Recommendations Implemented
3 Use of Off-line Clarifier
4 Hwd Brown Recovery Tank Line to Pine Blow Tower =��a"a" F'�"�'S • -
5 1-Hour color testing before and during maintenance outages � �"•.. xmsua µ �«
6 Installation of Mechanical Seals •'""•"" "? :`°w.`""" «", - ss�urF� ••<.wm a=
7 Improvement of equipment used for handling Pine and .. .�. „
Hardwood Knot Rejects
8 $1.5MM spent on Bleach Filtrate Recycle Irtt rovements ` -�" "` `t:& £",."m`" `""" 3:_s" •% `�#AR»,
9 Installed Pine Brownstock Control Logic improvements
10 Determined multiple contributers and interaction effects causing
Sewer Generated Color
1 I Bench-scale sewer-generated color work
12 Process Optimization/Six Sigma Team designated for Hardwood .,•„ :�
Fiberline color improvements
13 Improvements made to Pine Brownstock sumps for better .,. .•..� � dP £ £= £
recovery
14 White Rot Fungus Trial-growth efforts unsuccessful,may re-
visit in future.
15 Pine Brown Recovery Tank Line to Hwd Blow Tower
16 De-Waterin /Dis osal of Pine and Hwd Screen Rejects "'v"k ER '"m"== "
17 Trial to confirm and size system for C102 de-colorization of
CRP/evaluate full-scale application
18 Green liquor sump at recovery furnances
19 Milk of Lime Trial
20 Pilot Scale Plant for Ozone De-Colorization(may drop if C102
dechlorization is successful)
- Past Process Change Implementation Process Evaluation or Change
Continued Performance Improvement fwm, £ Expected Performance Improvement
Colorprojschd, Initiatives Page 1 of 1 Printed 5/17/04

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to attain the lowest achievable
annual average and monthly average color loading limits based on the Mill's performance
from December 2001 —August 2003. Section A (8.),Paragraph 5 of the 2001 NPDES
Permit provides in part, as follows:
"...By October 1, 2003, the permittee shall submit to the North Carolina
Division of Water Quality a report including a statistical analysis of the
permittee's monthly average color discharge, mill performance as related
to color, all available data necessary to derive the lowest achievable
annual average and monthly average color loading limits... "
This report is submitted to fulfill the requirements of Section A(8.), Paragraph 5. Based
on the Mill's performance from December 2001 —August 2003 and the Mill's continued
commitment to color improvement,Blue Ridge Paper Products believes an annual
average color limit of 42,000 pounds per day and a monthly average color limit of 52,000
pounds per day are feasible.
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October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
II. Color Performance
Set forth below is a summary of the actions implemented and planned for further color
improvement at the Canton Mill. These actions satisfy the `Highest Certainty' items
recommended by the Division of Water Quality and the Technology Review Workgroup.
2.1 Process Optimizations Items
The sixteen Process Optimization Items recommended in the Bleach Environmental
Process Evaluation and Report prepared by Liebergott&Associates Consulting Inc. and
GL&V Pulp Group Inc. have all been evaluated and implemented where appropriate.
2.2 Improved Black Liquor Leak and Spill Collection and Control
This recommendation consists of four elements including:
1) Continuous improvement of operating practices so more leaks and spills are recovered
rather than discharged to the sewer;
2) Improvement in preparation for planned outages to maximize capture of tank clean-out
waste and routing to recovery;
3) Reduction of clean water that continuously runs into sewers to prevent dilution of
smaller spills and facilitate recovery of highly colored wastewaters; and
4) Improvement in the equipment used for the handling of knot rejects to prevent black
liquor leaks into the recovery sumps.
The following is a discussion of actions relating to each element.
2.2.1 Continuous Improvement of Operating Practices etc.
A number of Best Management Practices (BMPs)have been implemented to improve the
recovery of colored discharges within the mill. These include: A) Color testing on the
2

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
Primary Influent every 2 hours; B) The use of the off-line, spare clarifier for process
losses and intentional diversions; C)Piping the Hardwood Brown Spill tank to the Pine
Blow Tower for additional spill collection capability and Hardwood Fiberline outage
management; and D) Implementation of control logic in the Pine Brownstock area to
minimize tank overflows during shutdowns.
The Mill began 24-hour color testing in 2-hour increments on the primary influent in
2001. The purpose of this increased color testing is to improve the mill's ability to
respond to process upsets on an immediate, real-time basis. If high 2-hour color results
are detected, the Wastewater Treatment Plant(W WTP) operators communicate the
information to mill operations and in-mill investigations begin. If necessary, diversion of
the primary influent to the off-line, spare clarifier is initiated. The high color material
that is captured in the off-line clarifier is later discharged into the system at a rate that has
a minimum impact on color and is not disruptive to the WWTP system. The off-line
spare clarifier is also used during outage situations when high color material cannot be
recovered by the in-mill spill control systems due to upset conditions, lack of recycle or
evaporator capacity or intentional diversions.
In order to increase the Hardwood Fiberline's ability to recycle recovered brownstock
material, piping was installed from the Hardwood Brown Spill tank to the Pine Blow
Tower. Prior to installation of this piping, there was no outlet for recycled hardwood
brownstock material when that system was shut down. This design allows for the
Hardwood Brown Spill tank to be recycled into the Pine Blow Tower and is especially
useful in hardwood outage situations when the recycle of additional recovered material is
required. Color savings from this 2001 project are reflected in the improvements seen
around the hardwood brownstock or 2B sewer area as well as improved color
performance.
3

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
During the first quarter of 2003, additional control logic was developed and implemented
on the pine brownstock system to prevent high colored filtrate tanks (ls` 2"1, and 3rd stage
Pre-Oz filtrate tanks) from overflowing and potentially reaching the sewer. The control
logic is designed to alert the operator when the brownstock filtrate tank(s) reach 85%
with audible and visual alarms. If the tank level(s) continues to rise to 90%, the pine
brownstock operators receive a"high-high" level alarm and warning text on their
monitors. The control logic then automatically interlocks (i.e., shuts down) the washer
stock feed pump that is associated with the high-level filtrate tank. Further, additional
controls have been built into the logic for the Pine Brown Spill tank. The alarm logic for
this tank checks the tank level at various times each day. If the tank level is greater than
50% at either time period, the Pine Brownstock Operator will receive an audible alarm as
well as a text message stating that the"Pine Brown Spill tank level is high." The control
logic will then check the level three hours later and if the level is still above 50%, the
operator will receive another alarm stating that the "Pine Brown Spill tank level is still
too high." In addition, if the Brown Spill tank level exceeds 80%, the operator receives a
high level alarm on his/her Digital Control System (DCS) graphic. All of these control
system improvements have enhanced the operator's ability to monitor the system and
prevent spills and losses from these processes.
2.2.2 Improvement in Preparation for Planned Outages
Color management of planned outages has improved significantly as a result of the
following practices:
• Increasing color testing from 2 hours to one hour before outages, during outages
and upon start-up;
• Improved communication between the Wastewater Treatment Plant and mill
operations;
• Utilization of the off-line, spare clarifier;
4

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
• Developing tank draining schedules where only the necessary vessels are emptied
for inspection and scheduled maintenance;
• Reducing tank levels to the lowest level possible prior to shutdown.
To effectively monitor color performance during maintenance outages, the WWTP
operators begin hourly color testing on the primary influent when the Recovery operation
initiates its shutdown procedure. The hourly color data is posted on the mill's Plant
Information (PI) System where it is widely available to operations and support personnel.
If a result is greater than 300 color units, it is immediately communicated to the Recovery
and Pulp Mill foremen via the mill radio system and they institute investigative action to
pinpoint the source. The appropriate corrective action is then taken. The Pulp Mill and
Recovery foremen also communicate their investigative findings with one another to
ensure effective troubleshooting is in place.
If an hourly color result is elevated and mill operations communicates that there has been
a process loss, the WWTP operators will divert the primary influent flow to the 1 million
gallon off-line, spare clarifier for temporary storage. There have also been instances
when the WWTP operators diverted the primary influent flow without direct
communication of a spill. The WWTP operators are trained to take action and route high
colored primary influent to the off-line, spare clarifier when necessary. The high color
material is later fed into the WWTP system at a slow, non-disruptive rate. Such a slow
feed rate minimizes the material's impact on secondary effluent color and does not
disrupt the WWTP process. For very high colored material captured in the off-line
clarifier,polyamine may be added in small amounts. Small amounts of polyamine aid in
the color removal of the concentrated material captured in the clarifier without negatively
affecting the sludge quality as larger amounts of polyamine have been demonstrated to
do. During normal mill operations, full-scale application of polyamine was not proven to
be effective and it created unmanageable sludge conditions; however,polyamine has
been effective on these higher color concentration events captured in the off-line clarifier.
5

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
Also, if at any time high colored material is seen in the primary influent, or if mill
operations communicates a process loss/intentional diversion, the WWTP operators can
immediately divert the primary influent flow into the off-line, spare clarifier. Improved
communications between the WWTP and mill operations have allowed for optimal use of
the off-line clarifier, especially in outage situations when overall spill system capacity is
in demand.
Tank draining schedules are developed in preparation for planned maintenance outages.
Increased attention has been given to draining only the tanks and lines requiring
inspection and/or maintenance rather than draining entire sequences. Draining the entire
sequence was a routine approach in the past so that vessels would be empty and available
for maintenance if problems were detected. The schedule has been optimized so that
inspections are rotated between outages, thereby ensuring that all tanks are inspected
while reducing the frequency that individual tanks must be emptied. However, issues
may arise where more frequent maintenance is required on certain vessels and
appurtenances and in these cases, the tanks must be drained before a scheduled inspection
is due. In preparation for all scheduled outages, it is standard practice to focus on
reducing tank levels to minimize the amount of material to be drained. This practice also
reduces potential losses in the event of an upset process condition during shutdown,
outage, or start-up periods.
These practices have measurably improved outage color performance. Specifically,
reductions in the color losses are demonstrated by the 2002 semi-annual shutdowns
(outages performed twice per year, lasting approximately one week with each outage
involving half of the mill operations). In a comparison of semi-annual outage primary
influent color data, the 2002 data showed an average 38% reduction in the maximum
daily primary influent color from historical performance (1996—2001). These
improvements are significant given that the majority of the spill recovery systems were
implemented in 1997 and 1998.
6

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
2.2.3 Reduction of Clean Water that Continuously Runs into Sewers
There has been a greater than 90,000 gallon per day reduction in the amount of clean
water being sewered, primarily in the mill's digester courtyard. This reduction in flow
was achieved by implementing customized Double Mechanical Seals and Water
Management Systems on the 18 digester re-circulation pumps. This project has involved
extensive trialing of different types and combinations of specially designed mechanical
seals over the past several years. The decrease in flow from the mechanical seals is at
least 3 to 4 gallons per minute per pump, which equates to a daily flow savings greater
than 90,000 gallons. The removal of non-mechanical seal pump packing water from the
digester sewers has also contributed to improved color performance for the area. Since
complete implementation of the mechanical seals, measured color in the area has been
reduced by approximately 60%. This is due in part to the removal of seal water that
could be contaminated by black liquor leaks on the non-mechanical seal packing and
from the recovery sumps operating more efficiently. With less clean water dilution in the
sewers leading to the recovery sumps, the effective conductivity of the material increases
and can be captured for re-use in the process at a greater efficiency. Customized Double
Mechanical Seals and Water Management Systems have also been installed on the
Knotter feed pumps for both the Pine and Hardwood Fiberlines, to further reduce water
infiltration to the sewer.
2.2.4 Improvement in Equipment used for Handling Knot Rejects
Two projects have been completed to improve the equipment used for handling knot
rejects. Black liquor from the Knot Rejects Collection bins is routed to a dedicated U-
drain, which flows to a dedicated knot bin sump pump for each Fiberline. The flow from
the knot bin areas is collected and pumped to the Brown Spill tank for each respective
Fiberline. Recovery of this material has contributed to improved color performance, as
7

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
demonstrated by Figure 1 below. The Hardwood Fiberline Brownstock sewer color has
shown the most dramatic reduction in color, which results from:
• Having the flexibility to send contents from the Hardwood Brown Spill tank to
the Pine Blow Tower during shutdown and start-up from an outage;
• Reducing the amount of clean water dilution by installing the Double Mechanical
Seals and Water Management Systems;
• Capturing the black liquor from the knot rejects system and;
• Improved communication and color monitoring.
Monthly Average Hardwood Brownstock and Digester Area Color
Since Installation of Double Mechanical Seals and
Water Management Systems
12000
10000
m 8000
a
n 6000
`o
4000
2000
0
N O N O O
N N N N N N N M M N N N N M
o O O o O o O O 4 O 4 O O
+Hardwood Brownstock and Digester Area Color
Figure 1
8

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
III. Improvements in BFRTM Reliability
Approximately$1.5 Million has been spent on Bleach Filtrate RecycleTM process
improvements for 2002—2003. This has resulted in improved BFRTM closure rates over
the past year and operational variability is also showing improvement in the Metals
Removal Process (MRP). In August 2003, the monthly average closure rate reached
targeted levels with improved MRP uptime and equipment reliability matching Fiberline
reliability. To improve process variability, a new media filter and a new ion exchange
softener were installed in the MRP. Due to accelerated degradation of the original three
media filters over recent months, they will also be replaced by the end of 2003. With this
additional equipment,metallurgy changes and other process improvements,MRP
downtime is expected to be reduced significantly. Having four media filters and three ion
exchange softeners will provide enough capacity for the MRP to remain online while
repairs are made to an individual media filter or softener. These projects are beginning to
demonstrate improved closure rates, reduced operational variability of the MRP, and
increased mechanical reliability of the MRP, all of which should aid in reducing both
measured and unaccounted color. As was expected, a recent statistical evaluation
demonstrated that lower closure rates are a major contributor to elevated secondary
effluent color and unaccounted color, individually as a main effect and also combined
with other factors as an interaction effect. These effects will be discussed in a later
section.
9

Ic October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
N. Color Challenges in 2002—2003
As a result of many years of color reduction activities and those discussed herein, the
monthly average secondary effluent color for the period December 2001 through October
2002 was 39,833 lbs/day. However, due to unforeseen and complex issues discussed in
this report, secondary effluent color increased in late 2002.
In November 2002, secondary effluent color variability began to increase. The
contributing source(s) were not readily evident. Out of the 15 sewer and process areas
measured daily, there were no measured sources that were statistically out of control
except for the Pine Eo filtrate, and that influent contribution was less than 5,000 lbs/day
over the in-control average. Two major sewer areas, the Bleach Plant Filtrate Acid Sewer
and the Hardwood Brownstock/Digester Area Sewer were actually operating below their
average level of performance. The unaccounted color averaged about 23,000 lbs/day for
the month (compared to a 2002 YTD average of approximately 10,000 lbs/day). A
thorough review of all sewered, color-contributing sources revealed that the hardwood
screen rejects were not being quantified in the daily in-mill color analysis. Data has been
collected and the average color contribution from the hardwood screen rejects is 3,000
lbs/day. This source has been a small portion of the mill's unaccounted color since 1996;
therefore, it is not a significant contribution to the elevated unaccounted color seen during
this period. Further, the Wastewater Treatment Plant Color removal effect was dropping.
Elevated unaccounted color and reduced WWTP color removal are indicators that
support the presence of Sewer Generated Color(SGC), yet closure was averaging 77%
and the color contribution from the Bleach Plant Filtrates, the historical pre-cursors of
SGC, were running below average as illustrated in Figure 2 below.
10

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
Monthly Average Color In the Bleach Plant Acid Sewer
Jan-a2 through Jan-03
16000
aoao
t2oao
n" 10000
0
s
u e000
cooa
4000
4�
4
t Color 6A
Figure 2
As the Canton Mill has reduced releases of brown colored material, a greater percentage
of the primary influent color has become unaccounted color. Color is a pH dependent
parameter and Blue Ridge is in un-charted territory with such low brown color effluents
and the BFRrm technology. The result of increasing the pH of an acidic bleach plant
filtrate in the laboratory shows a visually significant increase in color. The Sewer
Generated Color phenomenon has been duplicated on the bench in multiple studies and
the National Council on Air and Stream Improvement (NCASI) supports that color is a
pH dependent phenomenon. Sewer Generated Color does not disappear when the pH is
adjusted from allcaline back to neutral conditions.
Duke University graduate level internship and thesis studies performed at the Canton Mill
in 19941 and 19952 showed, on average, Sewer Generated Color for Pine D 1 filtrate was
an increase of 32-47% above the original sample color and Sewer Generated Color for
Hardwood D1 filtrate was 64-88%. Regarding WWTP color removal, data suggested
1 "A Laboratory Analysis of Color Removal Across a Pulp and Paper Mill Wastewater Treatment Facility"
by Aimee Winter McCord
2 "A Laboratory Analysis of the Color Removal Mechanism Occurring Across the Wastewater Treatment
Plan"by Chad Salisbury
11

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
some hardwood Sewer Generated Color may be removable across the WWTP (3%
reduction in color after WWTP process), but pine filtrates showed an average increase in
color of 21% in the simulated WWTP process. Data from this study show brown source
color removal up to 70% and the long-term average color removal across the WWTP
from primary influent to secondary effluent is 25%. The annual Color Pies showing the
breakdown of mill sewers compared to primary influent color support the presence of
Sewer Generated Color as unaccounted color has averaged 25% (19,081 lbs/day) since
1996. Of this 25%, the hardwood screen rejects contribute a small amount (currently
about 2,700 Ibs/day). The period from November 2002 through April 2003 is evidence
that specific interactions and operational conditions can significantly intensify the Sewer
Generated Color effect. Bench scale studies are planned to better understand the various
types and magnitudes of the major interaction effects pinpointed during the period of
elevated color. It is recognized that these conditions may change and new effects may
need to be studied in the future.
Figure 3 below shows the trend of increasing unaccounted color and decreasing WWTP
color removal that began in November 2002.
12

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
Unaccounted Color and WWTP Color Removal %
30000 Monthly Averages: Jan-02 through Feb-03 35.00%
T
25000 30.00%
0
c 20000 25.00%0
6 20.00%A
a 15000 3
15.00%0
10000 °
0 10.00-1
U
5000 5.00%
M
0 0.00%
O O O O O O O O C O O O O O
N Ul N Q (Q 7 7 01 U O N (a N
tL Q g 5 Q co O Z o u
-*-unaccounted Color 0 WWTP Color Removal
Figure 3
The trend of increasing unaccounted color and simultaneous decreasing WWTP color
removal continued in December and a Color Team was formed including representatives
from Operations, Environmental and the Technical Manufacturing Support group. This
team initially audited the color measurement system as well as monitored sewer areas and
related instrumentation for accuracy as well as potential unmeasured sources of color.
When there were no anomalies discovered, the team focused on analyzing process
parameters for shifts and deviations that could contribute to elevated color. Processes in
the Fiberlines and Recovery area were reviewed in most detail while deviations from the
Paper Machines were also considered. The Pine Eo filtrate was consistently the only
color source that was running above its upper control limit but the causes were unlrnown.
Multiple statistical analyses were performed including CUSUMs or Cumulative Sum
charts to identify if, in fact, statistically significant shifts were occurring. While there
13 .

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
were several process parameters that were discovered to be operating outside their normal
ranges of variability, the most notable shifts were seen in the Fiberlines. Specifically, the
Pine Fiberline Bleach Plant and the Hardwood Fiberline Pre-Bleach and D1 (first D)
stages. Additional statistical studies were performed and targets were established for the
above parameters as well as others,based on early 2002 when the color performance was
in the 36,000—39,000 lbs/day range. As the Fiberlines began reaching the established
targets, the unaccounted color remained elevated.
During the latter part of 2002, the variability in the White Liquor strength and solids
increased. This change was believed to be negatively impacting the Fiberline operations
by causing increased carryover into the bleach plants. These issues corresponded to the
decreased color performance seen beginning in November 2002. Elevated White Liquor
solids were then identified as an interaction effect contributing to elevated secondary
effluent and unaccounted color and this parameter was added to the Daily Color
Monitoring list. Also during late 2002, the quality of purchased lime for the Causticizing
operation was compromised due to flooding and other issues with the Mill's normal lime
supplier. Negotiations with additional lime suppliers are ongoing to improve the quality
of purchased lime.
Upon startup from the Cold Mill Outage in April 2003, unaccounted color increased even
further to the 35,000—40,000 lbs/day range from pre-Cold Mill levels in the 20,000
lbs/day range. Pine Eo filtrate color was back below the in-control average yet
unaccounted color was still high. Detailed Analysis of Variance (ANOVA) Factorials
were performed in an effort to determine which factors and combinations of factors were
affecting secondary effluent color and unaccounted color significantly. For these
analyses, an alpha of.05 was used. The results of the ANOVAs proved that there were
multiple statistically significant main effects and interaction effects "responsible" for the
elevated secondary effluent color and unaccounted color. This means that the effect
impacting the dependent variables (secondary effluent and unaccounted color)was not
14

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
doing so by chance. The interaction effects involve relationships between certain
parameters that significantly affect color. Subtle operational changes made in late 2002
had triggered a major Sewer Generated color problem and greater than 30 effects,
including main and interaction effects, were pinpointed. The most significant main
effects were BFRTm Closure, Pulp Mill Flow and Hardwood Pre-Bleach Conductivity.
There were numerous significant interaction effects, some including up to four interacting
factors, which is evidence of the problem's complex nature. To determine if the effects
had been present during periods of"good" color performance, ANOVAs were performed
on those periods as well. The only main effect that was statistically significant in
impacting secondary effluent color from January 2002—July 2002 was Closure and there
were no main effects nor interaction effects that were statistically significant for
unaccounted color during the period of good color performance. As a result of the
ANOVA studies, a daily color monitoring information report was created which tracks
the color-impacting parameters via targets and 30-day trends. Closure was the most
significant main effect contributing to elevated secondary effluent color. Given the
increase in bleach plant filtrate that reaches the mill sewer when closure rates are low,
there is a larger volume of low pH material available to undergo the Sewer Generated
Color effect. Because it has been shown that Sewer Generated Color is not removed
across the Wastewater Treatment Plant, lower closure rates translate into a measurable
increase in secondary effluent color. In addition to being a main effect, closure was a
statistically significant color-impacting variable in 13 different interaction effects as well.
Pulp Mill flow was the second most significant main effect contributing to elevated
secondary effluent color. Similar to closure, elevated flow from the Pulp Mill is likely to
be low pH material,which is a pre-cursor for Sewer Generated Color.
Hardwood Pre-Bleach Conductivity is the measure of conductivity from a pulp filtrate
sample taken off of the Pre-Bleach washer. Elevated conductivity indicates increased
carryover into that stage. Increased carryover from the pre-bleach stage can affect the
15

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
first stage of bleaching (D1),potentially requiring elevated acid usage on the D1 stage.
This was observed during the period of elevated color and was also a statistically
significant main effect and interaction effect in the ANOVA analyses. Elevated acid use
in the bleach plant could intensify the Sewer Generated Color effect by further reducing
pH.
Also, it was believed that start-up of the entire mill from the Cold Mill outage required
adequate time to reach stable operation. This stable operation was not achieved until
mid-May. Challenges from the Cold Mill start-up had to be managed before the targets
from the ANOVA Factorial analyses could properly be incorporated into the daily
operation. At this point unaccounted color and secondary effluent color finally began
reaching normal ranges.
Incorporation of the results from the ANOVA studies into the Daily Color Monitoring
Information report has proven to be a useful tool for color management at the Canton
Mill. It is recognized that the conditions causing these effects may change in the future
and new effects may need to be studied/evaluated. Since the Daily Color Monitoring
Information report has been in use, the average secondary effluent color has dropped
from 49,024 lbs/day (average during November 2002 through April 2003 period of
elevated color) to 42,669 lbs/day. The Canton Mill is utilizing this new tool and will
continue to use and develop innovative tools for troubleshooting color in the future.
16

October 1, 2003 Report
Blue Ridge Paper Products Inc.
Canton,North Carolina
V. Statistical Analysis of Data
The average secondary effluent color from December 2001 through August 2003,
excluding the period of elevated secondary effluent and unaccounted color, is 39,833
lbs/day. Based on a statistical evaluation of the mill's monthly average color
performance, for the same period, the achievable secondary effluent color using a 95`h
percentile distribution is 43,189 lbs/day. The 2002 annual average secondary effluent
color was 41,171 lbs/day. Blue Ridge is committed to continued color performance
improvements and recommends an annual average secondary effluent limit of 42,000
lbs/day.
Blue Ridge recommends a monthly average effluent limit of 52,000 lbs/day based on the
color challenges encountered in the past year. Data for the December 2001 through
August 2003 period is attached to this report.
17

.. r
Blue Ridge Paper Products Inc.
Monthly Average Secondary Effluent Color: Dec-02 through Aug-03
Attachment 1: October 1, 2003 Report
Monthly Average Ibs/day
Month Secondary Effluent Color
Dec-01 36,821
Jan-02 39,040
Feb-02 39,870
Mar-02 37,886
Apr-02 42,477 Monthly Average Ibs/day
May-02 42,458 Secondary Effluent Color Excluding Nov-02-Apr-03
Jun-02 41,312 Dec-01 36821
Jul-02 41,686 Jan-02 39,040
Aug-02 40,750 Feb-02 39,870
Sep-02 39,480 Mar-02 37,886
Oct-02 36,382 Apr-02 42,477
Nov-02 48,014 May-02 42,458
Dec-02 44,701 Jun-02 41,312
Jan-03 51,269 Jul-02 41,686
Feb-03 48,324 Aug-02 40,750
Mar-03 50,412 Sep-02 39,480
Apr-03 51,423 Oct-02 36,382
May-03 40,955 May-03 40,955
Jun-03 42,458 Jun-03 42,458
Jul-03 44,734 Jul-03 44,734
Aug-03 42,527 Aug-03 42,527
2002 average 41,174 95th percentile 43,189
2003 ytd average 46,513 period average 40,591
95th percentile for 2003 51,369

BLUE RIDGE
PAPER PRODUCTS INC-
25 August 2005
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5733
Mr. Keith Haynes
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office 11 h (J
Division of Water Quality
2090 US Highway 70 I�5
Swannanoa, North Carolina 28778 G AUG 2 6 2005 .
WATER OUP iTY SECTIr`l�
Subject: Unanticipated Partial Bypass of Untreated Wastewater AS_NLL_L r'E`- C
Effluent pH Excursion
Blue Ridge Paper Canton Mill
NPDES Permit#NC0000272
Dear Mr. Haynes:
This letter is the required written report for events occurring on 8/20/05 and 8/21/05. This letter
follows telephone notifications to DENR on 8/20 and 8/22/05 and e-mail notifications of 8/21
and 8/22/05.
Unanticipated Partial Bypass of Untreated Wastewater
The Blue Ridge Paper Products mill in Canton, North Carolina experienced a total power failure
on the evening of Saturday 8/20/05. At approximately 1725 on 8/20,Progress Energy had a
transformer explosion and fire on one of the transmission lines serving the Blue Ridge Paper
Canton Mill. The mill lost both the mill side and wastewater treatment Progress Energy power
feeds at approximately 1738. The dual feed power transfer switch at the wastewater treatment
plant (WTP) worked as designed and put the WTP and low lift pumps on mill-generated power
when Progress Energy power was disrupted. The low lift pumps are the influent wastewater
pumps for both the mill and Town of Canton wastewater. At approximately 1754, the mill-
generated power system failed, and the low lift pumps went down. The particular circumstances
of the Progress Energy power disruption damaged the mill's emergency load shed system. The
mill's generators remained connected to non-critical loads, overloaded and tripped on low
voltage.
Blue Ridge Paper Products -Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 o 828-646-2000
Raising Your Expectations

Mr. Keith Haynes, NC-DENR
25 August 2005
The Progress Energy power feed to the WTP was restored by 1810, and the low lift pumps were
manually transferred from mill power back to Progress Energy power. There was a period of 16
minutes where there was no power available for the low lift pumps. Wastewater flow rate at the
time of the power failure was 25 mgd.
Immediately after restoring power to the low lift pumps, Blue Ridge Paper personnel inspected
the 4A manhole on the mill sewer. Based on high water marks in the 4A manhole, there was
some mill wastewater overflow to the Pigeon River during the 16-minute period of no power.
The exact volume of overflow is undermined. Based on the rate of level rise at the low lift sump,
the period of overflow was less than 10 minutes. This event is an unanticipated, partial bypass of
treatment under the NPDES permit for the Blue Ridge Paper Canton Mill. No Town of Canton
wastewater was involved as it was completely contained in the low lift sump. The partial bypass
of treatment was mill wastewater that backed up into the mill sewer system during the time that
the low lift pumps had no power. Because the mill sewer system was filling and storing water,
the rate of overflow was much less than the influent flow rate at the time of the power failure.
At 1840, Blue Ridge Paper dispatched personnel to take downstream river samples for DO and
pH and to check for foam and signs of aquatic stress. Monitoring of the river continued until
2200. There were no foam and no signs of ecological damage to the Pigeon River.
The power failure on 8/20 resulted in an unplanned total mill outage. The Blue Ridge Paper
wastewater treatment plant continued in continuous operation after power was restored.
Manufacturing production of paper and pulp remained down for 36 hours after the Progress
Energy power failure.
Blue Ridge Paper issued the legally-required "notice of discharge of untreated wastewater" on
8/22/05. With this letter, all reporting requirements to the state and public for the 8/20/05 power
failure are complete.
Power Failure Details
Investigation of the power failure determined that when Progress Energy took down their
transmission lines to isolate the transformer that failed, the transmission lines were shorted to
ground. The mill's power generators back fed electricity into the Progress Energy transmission
lines. This back feed of power overloaded and damaged the mill's power tie switch to Progress
Energy. The power tie switch was not designed to carry the large current that occurred because
of grounded Progress Energy transmission lines. The power tie switch melted. When Progress
Energy power returned, the mill power system was no longer physically connected to outside
power. The emergency load shed system- which monitors the Progress Energy transmission
lines for power- did not activate. The mill generators carried the full mill load, but overloaded
and tripped out on low voltage. The entire mill then lost power and shut down.
Blue Ridge Paper Products Inc. -Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Keith Haynes, NC-DENR
25 August 2005
The dual feed power transfer switch at wastewater treatment correctly switched from primary to
emergency power when Progress Energy took down their transmission lines. The switch is not
designed to automatically transfer from emergency power back to primary power after a primary
power failure. This is a standard equipment and personnel safety feature of power transfer
switches. The switch automatically transfers from primary to emergency power, but then must
be manually reset. When the mill-generated emergency power system failed, the mill
electricians had to manually reset and restore the Progress Energy power feed to the wastewater
treatment plant.
Effluent pH Excursion
The power surge following the power failure on 8/20/05 damaged wiring for automatic valves on
the primary influent pH control system at the Blue Ridge Paper wastewater treatment plant. The
influent pH control system uses carbon dioxide to control wastewater pH. There is a backup
primary effluent pH control system that uses sulfuric acid.
After the 8/20 power outage, the influent pH control system was placed on a manual fixed feed
rate. The primary effluent pH control system was used to trim pH to secondary treatment. The
mill made arrangements for extra sulfuric acid deliveries to compensate for increased sulfuric
acid use until the automatic influent pH controls could be repaired. Extra deliveries were
scheduled for noon on 8/21 and for the morning of 8/22. Unfortunately, the sulfuric acid
delivery scheduled for noon on 8/21 was delayed until midnight. The scheduled delivery tanker
broke down, and a replacement truck and driver had to be found. The mill ran out of sulfuric
acid early on the afternoon of 8/21/05.
Between 1500 and 2230 on 8/21/05, secondary effluent pH from the Blue Ridge Paper Canton
mill exceeded the pH limit of 9.0. The maximum pH value was 9.3 at 1600.
Additional sulfuric acid deliveries were received on schedule on 8/22/05. The electrical problem
with the influent pH control system was repaired.
Lost Data
The 8/20/05 power failure also disrupted our wastewater data recording system for effluent flow
and pH. Some of the electronic data from 8/20 and 8/21 were corrupted. We reconstructed
flow and pH data manually using hourly values from electronic display trend records and from
wastewater operator logs. The data recording problems were corrected on 8/24/05. We lost an
additional 6 hours of secondary effluent flow data during these repairs.
Summary
The Blue Ridge Paper Canton mill was down with no manufacturing production for 36 hours
following the 8/20/05 power failure. The dual power feed to the wastewater treatment plant
Blue Ridge Paper Products Inc. -Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Keith Haynes, NC-DENR
25 August 2005
worked as designed. The particular circumstances of the Progress Energy power disruption
(transmission line short to ground) caused the mill power system to fail. Power to the
wastewater treatment plant then had to be manually reset and restored. Our mill electricians and
wastewater operators did an outstanding job in an emergency situation. They limited the period
of no power to our wastewater low lift pumps to 16 minutes and the period of partial mill sewer
overflow to less than 10 minutes.
The effluent pH excursion on 8/21/05 was a result of control system damage from the 8/20/05
power failure and a scheduled acid delivery that did not arrive when planned. We also lost
some electronically recorded wastewater trend data for 8/21, 8/22 and 8/24/05.
Sincerely,
J. Glenn Rogers Paul S. Dickens
Water Compliance Coordinator Environmental Manager
828-646-2874 828-646-6141
[e-mail] [e-mail]
cc: C-File Water
Environ Release File
L. Justus
J. Giauque
B. Williams
J. Clary
J. Pryately
B. Shanahan
L. Cooper
Blue Ridge Paper Products Inc. - Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
19 August 2005
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 5702
Mr. Keith Haynes
North Carolina Department of Environment
and Natural Resources D �/
Asheville Regional Office '
Division of Water Quality
2090 US Highway 70 AUG 2 3 2005
Swannanoa, North Carolina 28778
WATER QUALITY SECTION
VL ASHEVILLE REGIONAL OFFICE
Subject: Release of Stormwater Normally Managed as Wastewater
Blue Ridge Paper Canton Mill
Dear Mr. Haynes:
Blue Ridge Paper Products, Inc. is providing written notification of a release of an estimated
volume of 257,000 gallons of stormwater normally managed as wastewater from the hardwood
chip storage area. The release was to the mill stormwater system and the Pigeon River via
Stormwater Outfall#3 and occurred on between -- 2300 on 8/17/05 and 0830 on 8/18/05.
This letter follows our telephone call to you on 8/18/05.
The release occurred due to a flash flood in Canton (2.52 inches of rain in 1 hour), which caused
Mingus Branch to overflow into the hardwood chip storage area. Stormwater and debris from
this event overwhelmed the hardwood chip stormwater sump where chip pile stormwater is
normally pumped back into our wastewater plant for treatment.
Wastewater treatment personnel discovered the discharge when inspecting pumps at the
hardwood chip stormwater sump. The pumps were running, but had become clogged with
debris. Appropriate corrective actions were taken to clear debris and restore pumping (see
attached report). No adverse impact was observed in the Pigeon River from the release.
Stormwwater runoff onto Blue Ridge Paper property from the Radio Hill area of Canton
combined with flood damage to the Mingus Branch storm drain system have become a problem.
There have been three flash floods on Mingus Branch since June 2005, each resulting in release
Blue Ridge Paper Products - Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Keith Haynes, NC-DENR
19 August 2005
of chip pile stormwater to the river. As you are aware, the mill is spending a considerable
amount of time and effort to prevent future flooding of the hardwood chip storage area. Repair
and reconstruction of the Mingus Branch storm drain inlet adjacent to our distribution warehouse
have been completed. Excavation and repair of the Mingus Branch storm drain beneath our
hardwood chip pile will start the week of 8/22/05. Until this work is complete, we remain
vulnerable to flash flooding of our chip pile storage area from runoff from Radio Hill.
Please call us if you have any questions or need additional information.
Sincerely,
J. Glenn Rogers Paul S. Dickens
Water Compliance Coordinator Environmental Manager
828-646-2874 828-646-6141
cc: C-File Water
Environ Release File
L. Justus
J. Giauque
B. Williams
J. Clary
J. Pryately
Blue Ridge Paper Products Inc. -Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

NOTIFICATION REPORT FOR SPILI/RELEASE
- CANTON MILL —
175 MAIN STREET/P.O.BOX 4000 -
CANTON,NC 28716
Name of Chemical 5/0em 1476?
Is Substance an Extremely Hazardous Substance ❑ YES NO
Caller's Name &Position:
Media into which release occurred: ❑ Air Water ❑ Land
VX
* GEON RIVE-fC 7116-CuGy 5'7'o Ri19 aoz;e,? ©w7-rye *3
Quantity Released: (give reasonable estimate if known or that RQ may have exceeded, and will
call back as soon as possible-- do not delay reporting) Zar7�Co e7 G,?&l AI-5-
Date, start and stop of release : 811745 AV — 8I18Io5@ 84M /?Pjqft/*w;Q7
Cause and source of release : -{jA54 7)
R4;Al -0 5 WANOJ! C440QYi vG WM r7`J -sea uG I�JCCFS S r
9/10c000-b 0- P 57641 G6
Action taken to respond to release and status of actions : Ajr:6 V✓)C ZWiiCk 4WD l?WWRS
762 10 CLOW, 11/h 020,52 CIO 57,MGE Sinn-P AND
Ncr/zq L tRIMPI;G CAG'✓ �%` 'e �XPE`1�,7�J (9 �� GarL� �uMQ 5ys7�"t �a� I
OWL'o 74f IN.0.
Other Notification:
National Response Center
Date: IM Time: Report No.
Petty Officer Name :
NCDEHNR-Asheville or NC Emergency Response-Raleigh
Date: 8110h05 / Time: 9,qm
Contact: Kai rJr yg w S

Local Emergency Planning Committee
Date: Wll Time
Contact:
Western North Carolina Regional Air Pollution Control Agency
Date: AIA Time
Contact:
Whether any injuries occurred: ❑ YES NO
If yes,provide detail:
Name and telephone number of person to contact for further information:
L6t1/Z �SuS�S 828-65F(�-Z37Z GZ�iVnJ 4QGS $2{�-(NSF(- 2874/
Action taken for clean-up: A10N6 /OC-Q U t/ i' L
Does release require written notification under Section 204 of Emergency Planning and
Community Right to Know Act(Title III SARA): ❑ YES NO

Blue Ridge Paper Products Canton,NC 60-Meter Tower Page 1
Blue Ridge Paper Products Canton, NC 60-Meter Tower
DATE TIME WSP WDR SD WD WSP WDR SD WD TEMP TEMP TEMP DEL T SLR BAT PREC BP
2005 END 10 M 10 M 10 M 60 M 60 M 60 M 2 M 10 M 60 M DEG F WM2 VOLTS IN INHG
ST MPH DEG DEG MPH DEG DEG DEG F DEG F DEG F
8 17 2005 100 1.6 189 23.4 1.7 233 31.8 68.9 68.9 68.8 0.01 0.0 13 .37 0.00 27.45
8 17 2005 200 1.8 201 24.0 1.8 267 24.4 68.2 68.3 68.0 0.02 0.0 13.36 0.00 27.44
8 17 2005 300 1.8 208 37.0 2.5 285 23 .0 68.3 68.2 67.8 -0.09 0.0 13 .29 0.00 27.42
8 17 2005 400 2.5 222 21.6 3 .6 244 18.1 67.7 67.6 67.1 -0.13 0.0 13 .37 0.00 27.42
8 17 2005 500 1.8 164 16.0 1.3 288 41.3 67.5 67 .3 67.1 -0.20 0.0 13 .36 0.00 27.42
8 17 2005 600 2.0 174 17.0 1.8 207 24.5 67.5 67 .4 67.0 -0.13 0.9 13 .36 0.00 27.42
8 17 2005 700 2.3 244 24.5 3 .2 255 15.3 67.7 67.5 67.0 -0.16 34.7 13.36 0.00 27.43
8 17 2005 800 1.8 224 33 .8 1.8 272 30.7 69.4 68.9 67.8 -0.49 164.1 13.38 0.00 27.43
8 17 2005 900 2.5 323 36.9 2.8 314 32.1 73 .0 71.7 70.3 -1.26 382.8 13.34 0.00 27.42
8 17 2005 1000 2.7 358 51.4 3.1 339 43.8 78.5 76.6 75.1 -1.85 599.8 13.40 0.00 27.42
8 17 2005 1100 2.7 313 43.9 3.1 315 47.3 80.7 79.2 77.8 -1.47 523.2 13.39 0.00 27.42
8 17 2005 1200 4.1 303 42.5 5.2 309 20.2 82.1 80.6 79.1 -1.54 490.1 13 .37 0.00 27.42
8 17 2005 1300 4.4 300 30.6 5.2 305 17.0 82.3 80.8 79.5 -1.51 598.2 13 .36 0.00 27.40
8 17 2005 1400 5.9 283 21.1 8.7 274 15.2 77.9 77.1 75.9 -0.73 286.8 13.32 0.02 27.39
8 17 2005 1500 5.0 93 29.6 5.9 100 21.3 78.5 78.0 76.8 -0.52 783.0 13.36 0.01 27.39
8 17 2005 1600 3.1 226 35.0 3 .8 221 25.9 80.2 78.9 77.8 -1.33 348.9 13.36 0.00 27.36
8 17 2005 1700 3.1 235 50.6 4.1 294 33.6 80.8 79.6 78.3 -1.22 345.9 13 .35 0.00 27.36
8 17 2005 1800 6.4 98 15.2 8.3 96 11.4 78.6 78.0 76.9 -0.62 192.8 13.36 0.00 27.36
8 17 2005 1900 4.1 115 19.3 5.8 108 13.2 75.9 75.7 74.8 -0.16 27.2 13 .39 0.00 27.37
8 17 2005 2000 3.3 96 38.5 6.1 67 24.3 72.9 72.9 72.3 0.01 0.6 13.42 0 4 27.38
8 17 2005q 216- 7.6 62 18.8 11.8 56 10.7 69.3 69.3 69.2 0.03 0.0 13.40 rt�7.42 Y
200S 2200 2.7 117 40.9 5.5 82 13 .7 68.2 68.0 67.8 -0.09 0.0 13.37 0.25 27.43
8 17 2005 2300 1.4 205 34.4 1.8 113 38.2 67 .7 67 .6 67.4 -0.04 0.0 13.37 0.02 27.42
8 17 2005 2400 1.8 250 18.5 1.9 303 26.5 67.3 67.1 67.2 -0.16 0.0 13.36 0.00 27.43
http://www.blueridgeweather.com/2005/CHAH229.HTM 8/18/2005

r
� n �I 2
BLUE RIDGE
PAPER PRODUCTS INC. ��Ij 15 2005
12 August 2005 Certified Mail WATER OLJACITY SECTION
Return Receipt Reguesteds"evi� E REciotiA OFFICE
7099 3220 0007 5696
D. Keith Haynes
NCDENR Division of Water Quality
2090 US Highway 70
Swannanoa, North Carolina 28778
Subject: Stormwater Discharge 8/10/05
NCS 000105
Blue Ridge Paper Products Inc.
Canton Mill
Dear Keith—
This follows our telephone conversation on Aug 11, 2005 at 4:00pm. This letter provides
information regarding the stormwater discharge to the Pigeon River on Aug 10, 2005.
As you are aware, there was a flash flood in Canton, NC on 7/19/05 that resulted in localized
flooding along Mingus Branch. Stormwater from Mingus Branch flooded our chip pile system
and also filled the secondary containment pit in our heavy equipment maintenance shop. We
previously reported chip pile stormwater releases to the river that occurred during and after the
7/19 flash flood. The chip pile stormwater is normally managed as a process wastewater and
treated in our wastewater plant.
As a follow-up to the 7/19/05 storm, a vacuum truck contractor was retained to pump chip pile
stormwater out of the containment pit at the heavy equipment shop. However, rather than using
the vacuum truck, the contractor pumped this water to the ground outside the maintenance shop.
A small portion reached the Mingus Branch storm drain system before the pumping activity was
found by Blue Ridge Paper personnel and stopped. No adverse impact was observed in the river.
This incident was reported to your office at 12:33 pm on 8/10. We have discussed the incident
with both the owner and site coordinator of the contract company involved. The contractor's site
coordinator will be re-trained on the mill's stormwater and mill reporting procedures.
If you have any questions concerning this incident or need further information, please call.
M.Q. 415i&
Matt Upton Paul Dickens
Environmental Monitoring Engineer Manager, Environmental Affairs
828-646-6814 828-646-6141
[e-mail] [e-mail]
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Keith Haynes, NC DENR ARO DWQ
8/12/05, Page 2
cc: C. File Water
Jim Giauque
Louie Justus
Bob Shanahan
Jim Haynes
Robert Munford
Bob Williams
Blue Ridge Paper Products Inc. - Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

p E
BLUE RIDGE AUG 1 0 2005 D
PAPER PRODUCTS INC.
WATER QUALITY SECTION
August 8, 2005 ASHEVILLE REGIONAL OFFICE
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5665
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Mr. Sergei Chernikov
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES NO. NC0000272
Request for Certification in Lieu of Monitoring for Chloroform
Blue Ridge Paper Products, Inc.
Canton, NC
As requested in your site visit on July 28, 2005 Blue Ridge is providing an updated list of
fiberline data to be included in its request for certification in lieu of monitoring for chloroform. As
you will note the maximum value for the kappa factor on the hardwood fiberline has changed
from 0.29 to 0.42. All other daily maximum values remained unchanged.
Blue Ridge requests a revised permit limit with regard to the hardwood kappa factor to reflect
this change. In addition, Blue Ridge requests the option to demonstrate compliance by either
sampling each fiberline for chloroform or by monitoring process parameters.
Finally, in accordance with 40 CFR 430.02(f)(6)(i)(B), once a value is exceeded, Blue Ridge
proposes to demonstrate compliance with the applicable chloroform standard by taking one
sample to monitor the bleach plant effluent for chloroform within 7 days of exceeding the value.
After one sample demonstrates compliance, process monitoring will resume in lieu of monitoring
for chloroform.
Blue Ridge has remained well below permitted limits for daily maximum and monthly average
chloroform limitations required by NPDES permit No. NC0000272 and remains committed to
continuous improvement in effluent quality. If you have any questions please don't hesitate to
call me at 828-646-2874.
Sincerely,
Glenn Rogers Paul Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2874 828-646-6141
rogerq@blueridgel)aper.com [e-mail]
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

4 August 2005, Page 2
Attachment: Demonstration period - Chloroform monitoring and process data
cc:
Mr. D. Keith Haynes (w/attachments)
Environmental Specialist
North Carolina Department of Environment
& Natural Resources
2090 U.S. Highway 70
Swannanoa, NC 28778
Internal Distribution:
C. File—Water
B. Williams
B. Shanahan
J. Clary
J. Pryately
D. Brown
C. Dowdle
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

Attachment 1
Pine Chloroform and Parameter Maximums
Daily Averages(Pine)
Pine Chloroform 1st Pine C102 Stage Pine Total Clot
Date Ob/day) pH Kappa Factor Ob/ADT)
12/3/2001 0.40 2.45 0.23 65.77
12/10/2001 1.35 2.48 0.26 75.52
12/17/2001 0.23 2.51 0.24 51.17
12/24/2001 0.37
12/31/2001 0.48 `
1/7/2002 1.02 2.55 0.25 65.21
1/15/2002 1.34 2.74 0.24 61.67
1/21/2002 0.96 2.39 0.25 71.65
1/28/2002 0.87 2.63 0.24 55.98
2/4/2002 0.97 2.29 0.25 65.55
2/11/2002 0.67 2.34 0.23 54.63
2/18/2002 0.59 2.50 0.24 54.28
2/25/2002 0.41 2.49 0.22 52.75
3/4/2002 0.52 2.61 0.26 72.17
3/11/2002 0.59 2.53 0.24 70.32
3/18/2002 0.45 2.53 0.23 63.45 -
3/25/2002 0.35 2.45 0.23 56.13
4/1/2002 0.23 2.19 0.24 55.37
4/8/2002 0.31 2.43 0.23 54.21
4/19/2002 0.23 2.51 0.23 54.72
4/22/2002 0.29 2.77 0.25 55.46
4/29/2002 0.12 2.55 0.23 54.34
5/6/2002 0.12 2.02 0.22 45.61
5/13/2002 0.40 2.50 0.22 54.36
5/20/2002 0.57 2.02 0.24 56.40
5/31/2002 0.37 2.75 0.25 51.71
6/3/2002 0.35 3.04 0.26 66.38
6/10/2002 0.52 2.05 0.22 48.75
6/21/2002 0.66 2.57 0.28 61.25
6/24/2002 0.48 2.35 0.28 55.56
7/1/2002 0.72 2.73 0.24 55.54
7/8/2002 0.92 2.24 0.25 66.41
7/15/2002 0.82 2.43 0.24 60.09
7/22/2002 0.82 2.26 0.24 55.92
7/29/2002 0.51 2.12 0.25 56.06
8/5/2002 0.16 2.29 0.24 53.44
8/12/2002 0.08 2.24 0.25 62.63
8/19/2002 0.53 2.37 0.23 52.45
8/26/2002 0.72 2.55 0.23 53.87
9/2/2002 0.74 2.57 0.26 67.83
9/15/2002 1.15 2.39 0.24 48.69
9/16/2002 0.88 2.38 0.23 53.96
9/23/2002 0.23 2.43 0.23 57.09
9/30/2002 0.68 2.27 0.24 47.71
Pi Data Archive system doom/unavailable
Fiberline down/abnormal operations
Mill flooded/operations down

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Attachment I
Pine Chloroform and Parameter Maximums
Daily Averages(Pine)
Pine Chloroform 'St Pine C102 Stage Pine Total C102
Date (lb/day) pH Kappa Factor Ob/ADT)
7/28/2003 0.88 2.25 0.29 61.88
8/4/2003 0.72 2.57 0.24 62.14
8/15/2003 0.55 2.45 0.23 60.02
8/18/2003 0.69 2.43 0.24 57.92
8/25/2003 0.50 2.47 0.27 62.47
9/2/2003 0.31 2.38 0.26 61.56
9/8/2003 0.45 2.53 0.24 58.91
9/15/2003 0.42 2.78 0.28 65.65
9/22/2003 0.40 2.15 0.33 65.63
9/29/2003
10/3/2003 0.73 2.35 0.27 52.93
10/6/2003 0.59 2.38 0.27 56.17
10/13/2003 0.33 2.43 0.25 55.46
10/20/2003 0.83 2.49 0.24 57.57
10/27/2003 0.36 2.58 0.25 63.80
11/3/2003 0.35 2.35 0.24 52.24
11/10/2003 0.35 2.50 0.25 53.82
11/17/2003 0.40 2.56 0.23 54.91
11/24/2003 0.41 2.59 0.26 54.87
12/1/2003 0.72 2.75 0.21 49.95
12/8/2003 0.31 2.42 0.23 44.78
12/15/2003 0.41 2.52 0.24 52.14
12/22/2003 0.33 2.38 0.25 51.44
12/29/2003 0.34 2.49 0.27 55.88
1/5/2004 0.19 2.45 0.24 52.64
1/12/2004 0.27 2.58 0.23 52.20
1/19/2004 0.18 2.44 0.23 52.36
1/26/2004 0.21 2.47 0.23 54.62
2/2/2004 0.19 2.75 0.24 57.06
2/9/2004 0.19 2.61 0.23 58.00
2/16/2004 0.21 2.60 0.22 48.69
2/23/2004 0.17 2.35 0.25 60.05
3/l/2004 0.19 2.35 0.25 56.49
3/8/2004 0.13 2.72 0.24 58.85
3/15/2004 1.27 2.57 0.31 62.52
3/22/2004 0.19 2.65 0.27 43.15
3/26/2004 0.34 2.60 0.23 56.00
3/29/2004 0.20 2.50 0.25 59.42
4/5/2004 0.26 2.37 0.27 57.42
4/12/2004 0.39 2.32 0.26 60.95
4/23/2004 1.26 2.53 0.23 56.97
4/26/2004 0.30 2.41 0.25 57.18
5/3/2004 0.27 2.53 0.25 52.91
Pi Data Archive system doom/unavailable
Flberline doom/abnormal operations
"Mill flooded/operations down 3

Attachment I
Pine Chloroform and Parameter Maximums
Daily Averages(Pine)
Pine Chloroform 1st Pine C102 Stage Pine Total C102
Date pb/day) pH Kappa Factor pb/ADT)
6/10/2004 0.11 2.38 0.24 55.84
5/17/2004 2.41 0.16 38.15
6/28/2004 0.18 2.46 0.25 53.66
5/31/2004 0.48 2.42 0.24 54.08
6/7/2004 0.33 2.26 0.26 58.59
6/14/2004 0.76 2.41 0.26 56.87
6/21/2004 0.40 2.37 0.24 56.08
6/28/2004 0.37 2.39 0.24 56.17
7/5/2004 0.46 2.31 0.26 66.23
7/12/2004 0.48 2.35 0.28 69.46
7/19/2004 0.49 2.36 0.26 64.13
7/26/2004 0.82 2.34 0.25 58.06
8/2/2004 0.38 2.21 0.26 58.98
8/9/2004 0.55 2.34 0.26 63.14
8/16/2004 0.35 2.24 0.25 58.62
8/23/2004 0.48 2.11 0.27 62.17
8/30/2004 0.84 2.16 0.28 69.89
9/6/2004 0.32 2.18 0.24 61.96
9/13/2004 "'
9/20/2004 '"'
9/27/2004 - -
10/6/2004 0.13 2.51 0.21 50.76
10/11/2004 0.19 2.50 0.29 60.21
10/18/2004 0.18 2.14 0.27 59.73
10/25/2004 0.24 2.28 0.30 61.57
11/1/2004 0.19 2.68 0.25 57.00
11/8/2004 0.40 2.61 0.25 57.59
11/15/2004 0.42 2.40 0.29 61.88
11/22/2004 0.35 2.35 0.28 61.58
11/29/2004 0.52 2.36 0.27 63.05
12/6/2004 0.30 2.36 0.24 57.07
12/13/2004 0.37 2.49 0.28 62.17
12/20/2004 0.36 2.22 0.29 56.26
12/27/2004 0.48 2.39 0.27 57.96
1/3/2005 0.51 2.34 0.29 62.59
1/10/2005 0.53 2.36 0.29 64.59
1/17/2005 0.33 2.37 0.29 63.15
1/24/2005 0.32 2.47 0.31 64.29
1/31/2005 0.31 2.42 0.28 59.49
2(7/2005 0.57 2.37 0.30 63.61
2/14/2005 0.55 2.40 0.28 58.78
2/21/2005 0.45 2.48 0.28 63.17
2/28/2005 0.44 2.32 0.26 62.77
Pi Data Archive system down/unavailable
Fiberline dawn/abnormal operations
Mill flooded/operations down 4

Attachment I
Pine Chloroform and Parameter Maximums
Daily Averages(Pine)
Pine Chloroform 1st Pine CIO,Stage Pine Total CIO,
Date (Ib/day) pH Kappa Factor pb/ADT)
3/7/2005 0.39 2.24 0.28 60.08
3/14/2005 0.53 2.35 0.21 54.13
3/21/2005 0.40 2.45 0.23 53.86
3/28/2005 0.40 2.36 0.23 52.65
4/4/2005 2.58 0.32 61.66
4/11/2005 0.57 2.25 0.24 49.34
4/18/2005 0.40 2.59 0.22 49.34
4/25/2005 0.33 2.47 0.23 52.61
5/2/2005 0.15 2.30 0.25 54.63
5/9/2005 0.36 2.38 0.22 51.36
5/16/2005 0.43 2.50 0.25 58.11
5/23/2005 0.25 2.25 0.24 52.87
5/30/2005 0.22 2.74 0.23 50.95
6/6/2005 0.29 2.30 0.31 68.84
6/13/2005 0.20 2.75 0.27 60.67
6/20/2005 0.27 2.58 0.26 56.41
6/27/2005 0.21 2.42 0.25 59.81
Maximum Process Values 3.19 0.33 75.52
Table 1
Pine Fiberiine Chloroform Data December 2001 -July 2005
Chloroform Data Standard %Standard
Chloroform Maximum Monthly
Average 1.05 5.15 20.36%
Chloroform Maximum
Daily 1.35 8.60 15.66%
'Pi Data Archive system down/unavailable
"Flberline down/abnormal operations
Mill flooded/operations down 5

Attachment I
Hardwood Chloroform and Parameter Maximums
Daily Averages(Hardwood)
Hardwood 1st Hardwood CIO, Hardwood Total
Date Chloroform(lb/day) Stage pH Kappa Factor CIO,(Ib/ADT)
12/3/2001 0.39 3.32 0.19 37.57
12/10/2001 0.41 3.11 0.26 42.18
12/17/2001 0.20 2.64 0.25 38.57
12/24/2001 0.19 `
12/31/2001 0.29 `
1/7/2002 0.23 2.79 0.22 33.43
1/15/2002 0.22 2.83 0.20 35.63
1/21/2002 0.17 2.81 0.19 35.86
1/28/2002 0.24 2.77 0.26 42.63
2/4/2002 0.22 2.65 0.29 41.07
2/11/2002 0.24 2.73 0.27 41.67
2/18/2002 0.45 3.08 0.28 39.77
2/25/2002 0.51 3.02 0.22 39.05
3/4/2002 0.40 3.06 0.19 35.89
3/11/2002 0.91 3.12 0.22 37.06
3/18/2002 0.41 3.20 0.21 35.57
3/25/2002 1.29 3.47 0.22 34.60
4/1/2002 0.76 3.49 0.18 32.67
4/8/2002 0.60 3.37 0.19 32.22
4/19/2002 0.56 3.30 0.23 38.46
4/22/2002 0.89 3.61 0.22 35.86
4/29/2002 0.55 3.29 0.24 36.62
5/6/2002 0.52 3.32 0.20 29.56
5/13/2002 0.57 3.43 0.23 36.68
5/20/2002 1.01 2.28 0.01 4.57
5/31/2002 0.54 3.30 0.19 31.68
6/3/2002 0.52 3.49 0.18 33.72
6/10/2002 0.28 3.41 0.16 32.49
6/21/2002 0.33 3.44 0.15 36.21
6/24/2002 0.25 3.12 0.12 27.57
7/l/2002 0.34 3.51 0.16 33.24
7/8/2002 0.15 2.98 0.21 34.45
7/15/2002 0.50 3.36 0.23 35.48
7/22/2002 0.67 3.56 0.19 34.71
7/29/2002 0.74 3.51 0.17 33.13
8/5/2002 0.31 3.30 0.19 29.54
8/12/2002 0.38 3.34 0.19 33.36
8/19/2002 0.69 3.47 0.22 36.58
8/26/2002 0.15 3.33 0.22 36.03
9/2/2002 0.60 3.21 0.23 38.71
9/15/2002 0.39 3.29 0.13 19.67
9/16/2002 0.39 3.18 0.17 32.10
9/23/2002 0.45 3.20 0.22 36.54
9/30/2002 0.41 3.20 0.18 33.81
Pi Data Archive system down/unavailable
Fiberline down/abnormal operations
'"Mill flooded/operations down 6

Attachment I
Hardwood Chloroform and Parameter Maximums
Daily Averages(Hardwood)
Hardwood 1st Hardwood C1O2 Hardwood Total
Date Chloroform(hb/day) Stage pH Kappa Factor CIO,(lb/ADT)
10/7/2002 0.37 3.12 0.21 34.15
10/14/2002 0.52 3.06 0.19 35.29
10/21/2002 0.42 2.76 0.22 36.99
10/28/2002 0.29 3.29 0.18 36.01
11/4/2002 0.31 3.19 0.24 37.46
11/11/2002 0.23 3.19 0.23 39.25
11/18/2002 0.17 3.39 0.20 32.32
11/25/2002 0.28 3.27 0.22 39.46
1202002 0.24 0.00 0.00 0.00
12/9/2002 0.24 0.00 0.00 0.00
12/16/2002 0.28 0.00 0.00 0.00
12/23/2002 0.59 0.00 0.00 0.00
12/30/2002 0.23 0.00 0.00 0.00
1/6/2003 0.22 3.03 0.23 39.58
1/13/2003 0.28 3.12 0.26 42.34
1/20/2003 0.30 3.09 0.26 42.39
1/27/2003 0.16 3.09 0.22 34.49
2/6/2003 0.16 3.06 0.21 36.29
2/10/2003 0.27 3.07 0.25 39.69
2/17/2003 0.47 3.26 0.25 41.16
2/24/2003 0.30 3.26 0.23 32.13
3/3/2003 0.24 3.26 0.26 35.12
3/10/2003 0.28 3.28 0.18 32.78
3/17/2003 0.55 3.79 0.29 43.93
3/24/2003 0.42 3.62 0.22 39.40
4/1/2003 0.33 3.53 0.22 35.35
4/7/2003 '• ••
4/15/2003 0.22 3.50 0.19 32.76
4/21/2003 0.18 3.28 0.21 33.58
4/28/2003 0.21 3.10 0.26 36.36
5/2/2003 - 3.43 0.17 35.51
5/5/2003 0.23 3.24 0.18 31.91
5/12/2003 0.18 3.15 0.22 32.55
5/19/2003 0.23 3.19 0.18 34.45
5/26/2003 0.18 3.24 0.19 34.41
6/2/2003 0.24 3.18 0.22 33.75
6/9/2003 0.20 3.12 0.20 33.59
6/16/2003 0.34 3.30 0.23 37.10
6/23/2003 0.23 3.30 0.20 33.64
6/30/2003 0.25 3.13 0.23 35.73
7/7/2003 0.43 3.40 0.19 32.45
7/14/2003 0.22 3.60 0.16 30.20
7/21/2003 0.22 3.38 0.19 39.74
Pi Data Archive system down/unavailable
Fiberline doom/abnormal operations
Mill flooded/operations down 7

Attachment I
Hardwood Chloroform and Parameter Maximums
Daily Averages(Hardwood)
Hardwood 1st Hardwood CIO, Hardwood Total
Date Chloroform(Ib/day) Stage pH Kappa Factor CIOipb/ADT)
7/28/2003 0.36 3.43 0.20 .36.29
8/4/2003 0.56 3.52 0.18 33.02
8/15/2003 0.25 3.02 0.19 32.23
8/18/2003 0.36 3.18 0.21 32.21
8/25/2003 0.66 3.44 0.22 35.26
9/2/2003 0.24 3.37 0.20 35.14
9/8/2003 0.41 3.24 0.18 34.04
9/15/2003 0.33 3.41 0.20 36.26
9/22/2003 0.28 3.51 0.17 31.31
9/29/2003 •• '•
10/3/2003 0.20 3.30 0.00 0.00
10/6/2003 0.18 3.39 0.03 4.83
10/13/2003 0.23 3.18 0.21 37.13
10/20/2003 0.43 3.11 0.14 29.33
10/27/2003 •' 3.45 0.24 39.68
11/3/2003 0.19 3.34 0.20 37.94
11/10/2003 0.72 3.17 0.20 39.34
11/17/2003 0.23 3.34 0.20 36.27
11/24/2003 0.56 3.36 0.15 33.34
12/1/2003 0.20 3.16 0.20 33.48
12/8/2003 0.42 3.17 0.21 40.47
12/15/2003 0.49 3.42 0.21 34.34
12/22/2003 0.28 3.60 0.22 34.88
12/29/2003 0.56 3.32 0.23 35.53
1/5/2004 0.20 3.24 0.22 37.87
1/12/2004 0.27 3.35 0.21 35.79
1/19/2004 0.13 3.13 0.24 34.31
1/26/2004 0.15 3.17 0.22 32.84
2/2/2004 0.39 3.24 0.24 33.39
2/9/2004 0.35 2.94 0.27 35.98
2/16/2004 0.20 3.24 0.26 34.72
2/23/2004 0.25 3.50 0.25 37.15
3/1/2004 0.36 3.16 0.23 34.82
3/8/2004 0.33 3.25 0.23 36.54
3/15/2004 0.15 3.14 0.21 34.14
3/22/2004 0.35 3.14 0.21 39.15
3/26/2004 0.21 3.09 0.19 33.03
3/29/2004 " 3.13 0.26 37.12
4/5/2004 0.28 3.32 0.26 37.49
4/12/2004 0.33 3.30 0.26 35.67
4/23/2004 0.29 3.42 0.21 30.57
4/26/2004 0.59 3.50 0.18 31.51
5/3/2004 0.52 3.34 0.22 34.27
Pi Data Archive system down/unavailable
Fiberline down/abnormal operations
'•Mill flooded/operations down 8

Attachment I
Hardwood Chloroform and Parameter Maximums
Daily Averages(Hardwood)
Hardwood 1st Hardwood C102 Hardwood Total
Date Chloroform(lb/day) Stage pH Kappa ractor ClO,,pb/ADT)
5/10/2004 0.46 3.05 0.20 .32.43
5/17/2004 0.17 3.07 0.22 29.57
5/28/2004 0.22 3.33 0.22 29.21
5/31/2004 0.36 3.19 0.28 36.52
6/7/2004 0.27 3.27 0.21 32.95
6/14/2004 0.47 3.47 0.22 34.78
6/21/2004 0.32 3.02 0.25 29.92
6/28/2004 0.14 2.95 0.25 31.87
7/5/2004 0.16 3.21 0.20 27.47
7/12/2004 0.17 3.18 0.22 30.93
7/19/2004 0.23 3.18 0.24 29.69
7/26/2004 0.14 2.98 0.22 27.59
8/2/2004 0.22 3.43 0.16 29.20
8/9/2004 0.10 2.87 0.24 28.89
8/16/2004 0.08 3.01 0.23 29.38
8/23/2004 0.09 3.17 0.24 33.43
8/30/2004 0.11 3.24 0.24 33.46
9/6/2004 0.11 2.91 0.25 34.58
9/13/2004 "' •" •" "•
9/2 012 0 0 4 '•' "` "' "•
9/27/2004 '•' "' '•' "'
10/6/2004 0.06 3.15 0.21 30.37
10/11/2004 0.13 3.28 0.22 30.06
10/18/2004 0.12 3.36 0.23 35.24
10/25/2004 0.10 3.12 0.27 35.92
11/1/2004 0.27 3.44 0.28 37.38
11/8/2004 0.08 2.96 0.32 35.95
11/15/2004 0.15 3.37 0.32 35.64
11/22/2004 0.10 3.14 0.41 41.04
11/29/2004 0.14 3.49 0.38 42.58
12/6/2004 0.19 3.03 0.32 38.91
12/13/2004 0.06 2.99 0.41 43.84
12/20/2004 0.08 2.93 0.30 36.00
12/27/2004 0.07 3.12 0.16 28.09
1/3/2005 0.08 3.15 0.14 24.89
1/10/2005 0.10 3.20 0.13 21.85
1/17/2005 0.15 3.41 0.18 24.99
1/24/2005 0.11 3.45 0.21 29.45
1/31/2005 0.12 3.15 0.28 36.17
2/7/2005 0.08 2.96 0.26 34.14
2/14/2005 0.09 3.07 0.29 35.32
2/21/2005 0.11 3.18 0.30 36.98
2/28/2005 0.14 3.30 0.23 31.20
Pi Data Archive system down/unavailable
Fiberline down/abnormal operations
"Mill flooded/operations down 9

Attachment I
Hardwood Chloroform and Parameter Maximums
Daily Averages(Hardwood)
Hardwood 1st Hardwood CI02 Hardwood Total
Date Chloroform(lb/day) Stage pH Kappa Factor CIO,(Ib/ADT)
30/2005 0.27 3.25 0.21 31.40
3/14/2005 0.16 3.20 0.22 28.75
3/21/2005 0.13 3.21 0.25 32.21
3/28/2005 0.24 3.13 0.28 31.88
4/4/2005 0.13 3.62 0.32 34.06
4/11/2005 0.16 3.39 0.24 29.11
4/18/2005 0.18 3.56 0.29 31.07
4/25/2005 0.27 3.41 0.28 33.46
5/2/2005 0.22 3.49 0.27 30.12
5/9/2005 0.10 3.14 0.31 32.73
5/16/2005 0.18 3.22 0.30 31.42
5/23/2005 0.17 3.05 0.28 33.03
5/30/2005 0.22 3.38 0.31 30.51
6/6/2005 0.54 3.04 0.42 41.92
6/13/2005 0.23 3.41 0.25 36.65
6/20/2005 0.17 3.10 0.21 31.86
6/27/2005 0.16 3.02 0.19 30.44
Maximum Process Values 3.79 0.42 43.93
Table 2
Hardwood Fiberline Chloroform Data December 2001 -July 2005
Chloroform Data Standard %Standard
Chloroform Maximum Monthly
Average 0.75 7.14 10.53%
Chloroform Maximum
Daily 1.29 11.93 10.82%
'PI Data Archive system down/unavailable
Fiberline down/abnormal operations
"Mill flooded/operations dawn 10

Michael F.Easley,Governor
William G.Ross Jr.,Secretary
G North Carol na spa rtq ent f Envirorimegt and Natural Resources
y u f
r AIanfW.Klimek,P.E.Director
_ -=1 Division of Water Quality
_ __Asheville Regional-Office—
SURFACE WATER PROTECTION
June 2, 2005
Paul Dickens
Blue Ridge Paper Products Inc
PO Box 4000
Canton NC 28716
SUBJECT: Compliance Evaluation Inspection
Blue Ridge Paper Products Inc
Canton Mill
Permit No: NC0000272
Haywood County
Dear Mr. Dickens:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for
the inspection which Roger Edwards and I conducted on May 19, 2005. The facility was
found to be in Compliance with permit NC0000272.
Please refer to the inspection report for additional observations and comments. If
you, or your staff, have any questions, please do not hesitate to call me at 828-296-4500.
Sincerely,
Keith Hayn
Environmental Specialist
Enclosure
cc: John J Pryately, ORC
Central Files
NoithturallffCarolina
Ji a
2090 U.S.Highway 70,Swannanoa,NC 28778 Telephone:[phone] Fax:[phone] Customer Service 1 877 623-6748

7
United States Environmental Protection Agency
7A!—
Washington,D.C.20460 Form Approved.P- E OMB-N¢204�0057
Water Compliance Inspection Report-- Approval expires 8.31-98 `
Section A: National Data System Coding(i.e.,PCS)
Transaction Code NPDES ydmo/day Inspection Type Inspector Fac Type
1 pf 2 IJ 31 NC0000272 1 11 121 05/05t19 1 17 18 u 191_1 201J
Remarks u
211111111111111111111111111111111111111111111111166
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 CA ------Reserved-----------
671 169 701J 711J 72 U4 73W 74 751 I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also Include Entry Time/Date Permit Effective Dale
POTW name and NPDES permit Number)
Canton Mill 09:30 AM 05/05/19 02/09/01
175 Main St Exit Time/Date Permit Expiration Date
Canton MC 28716 02:00 PM 05/OS/19 06/11/30
Name(s)of Onsite Represenlative(s)fiitles(s)/Phone and Fax Number(s) Other Facility Data
John J Pryateiy/ORC/828-646-6720/
Name,Address of Responsible Officia[rFitle/Phone and Fax Number
Paul Dickens,PO Box 4000 Canton NC 2871G//828-646-6141/ Contacted
No
Section C: Areas Evaluated During Inspection(Check only those areas evaluated)
Permit E Flow Measurement Operations&Maintenance E Records/Reports
Self-Monitoring Program 0 Facility Site Review Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Names)and Signature(s)of Inspecter(s) Agency/Office/Phone and Fax Numbers Date
Roger C Edwards ARO WQ;/828-296-4500 Ext.46561
Keith Haynes ARO ElQ//828-296-4500 EXt.4660/
67S—
Signature of Management
Q AA Reviewer Agency/Office/Phone and Fax Numbers / Date
Roger C Edwards�C-(/ 828-296-4500 Ext.4656;
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.

NPDES yr/mo/day Inspection Type 1
3 I
NC0000272 11 12 17 18 I � 05i05119 I - U
Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
The facility is very well maintained and operated. Several equipment/control updates were made as a result
of the Septmeber 2004 flooding.

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Seronrlary Clariflar Yes No NA NF
he s u ge wanket level acceptable?(Approximately Y,of the sidewall depth) 00 ❑ ❑
Comment:Some minor weir blockage was noted on the#5 clarifier due to vegetation that had not removed this year.
Aeration Basins
Vac No NA NF
Mode of operation Ext.Air
Type of aeration system Surface
Is the basin free of dead spots? N ❑ ❑ ❑
Are surface aerators and mixers operational? 0 ❑ ❑ ❑
Are the diffusers operational? ❑ ❑ 0 ❑
Is the foam the proper color for the treatment process? E ❑ ❑ ❑
Does the foam cover less than 251 of the basin's surface? N ❑ ❑ ❑
Is the DO level acceptable? ❑ ❑ ❑
Are set0eometer results acceptable? N ❑ ❑ ❑
Is the DO level acceptable?(1.0 to 3.0 mgfl) 0 ❑ ❑ ❑
Are settelometer results acceptable?(400 to 800 mill in 30 minutes) ❑ ❑ ❑
Comment:
Siandhy P� Vas No NA N
Is automatically activated standby power available? E ❑ ❑ ❑
Is the generator tested by interrupting primary power source? ❑ ❑ 0 ❑
Is the generator tested under load? ❑ ❑ E ❑
Was generator tested&operational during the inspection? ❑ ❑ N ❑
Do the generator(s)have adequate capacity to operate the entire wastewater site? 0 ❑ ❑ ❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power? 0 Cl ❑ ❑
Is the generator fuel level monitored? N ❑ ❑ ❑
Comment:Standby power is provided by mill bailers.
Fl=Waal vpmpnt-Fffluent Yes No NA N
Is Flow meter used for reporting? N ❑ Cl ❑
Is flow meter calibrated annually? ❑ ❑ ❑
Is the flow meter operational? ❑ ❑ ❑
(If units are separated)Does the chart recorder match the flow meter? N ❑ ❑ ❑
Comment:
Effluent Samnlinn Yes No NA NF
Is composite sampling flow proportional? W ❑ ❑
1-1
Is sample collected below all treatment units? N ❑ ❑ ❑
Is proper volume collected? 0 ❑ ❑ ❑
Is the tubing dean? ❑ ❑ ❑
Is proper temperature set for sample storage(kept at 1.0 to 4.4 degrees Celsius)? E ❑ ❑ ❑
Is the facility sampling performed as required by the permit(frequency,sampling type representative)? ❑ ❑ ❑
Comment:Samplers are new as the old ones had to be replaced due to the 9/04 floods.
Effluent Piop
Vas No NA NF
Is right of way to the outfall properly maintained? N ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? N ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? 0 ❑ ❑ ❑
Comment:

I �
BLUE RIDGE sEP - s 2co5
PAPER PRODUCTS INC. —J
WA7ER OJr. Iry ; 'GN
ASHCVIL L❑ +n Q,y-:4 C F
Certified Mail
Return Receipt Requested
7099 3220 0007 0371 5719
2 Sep 2005
Mr. Roger C. Edwards
Regional Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Subject: NPDES No. NC 0000272
Influent Monitoring Change for New Acid Sewer
Blue Ridge Paper Products Inc.
Canton, North Carolina
Dear Mr. Edwards—
Condition II.D.1 —Representative Sampling—of the subject NPDES permit requires your review
and approval of influent monitoring changes. The acid sewer project at the Blue Ridge Paper
Canton Mill will change the mill's method of sampling and reporting influent wastewater
concentrations. This letter outlines the proposed changes and requests your approval.
Acid Sewer Force Main
During the mill visit tour and permit discussion on 5/19/05, Blue Ridge Paper informed you
about the acid sewer replacement project. Our acid sewer system was damaged by the floods of
September 2004. Repairs were made following the floods, but the existing acid sewer requires
long-term replacement. Rather than construct a new below-ground acid sewer system, Blue
Ridge Paper is installing an above-ground acid sewer. The new acid sewer will cross the river in
double containment pipe and discharge to either our primary influent or primary effluent splitter
box. A process flow diagram of the Blue Ridge Paper wastewater treatment plant with the new
acid sewer routing is enclosed.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Roger Edwards, NC DENR DWQ -
9/2/05, Page 2
The existing acid sewer discharges into the main mill sewer at the 4A manhole and mixes with
alkaline wastewaters before primary treatment. The wastewaters handled by the acid sewer are
acid filtrates from pulp bleaching and chlorine dioxide generation. These wastewaters are low in
suspended solids and do not require primary settling before biological treatment. We know from
laboratory testing and mill sewer monitoring that mixing of acid bleach plant filtrates with
alkaline wastewater contributes to "sewer generated color". Sewer generated color is a well-
documented phenomena where bleach plant filtrates exposed to high pH develop additional color
that does not diminish when the filtrates are adjusted back to neutral pH. Bleach plant filtrates
that are exposed to sulfides under reducing conditions found in primary treatment may also
generate additional color. We believe the option to route acid bleach plant filtrates around
primary treatment may reduce sewer generated color. The acid sewer project will provide this
capability.
The new acid sewer is currently under construction and with startup planned in late November
2005. During your 5/19/05 mill visit, Blue Ridge Paper representatives asked if a construction
permit was necessary for this project. Since the new acid sewer replaces an existing mill sewer
system, you indicated that a construction permit was not required.
Change to Influent Monitoring
The new acid sewer will change the mill's method of sampling and reporting influent wastewater
concentrations. The NPDES permit requires daily sampling and reporting of influent wastewater
concentrations of BOD, TSS and color. We also collect a quarterly influent wastewater sample
for dioxin. The enclosed process flow diagram outlines compliance and process control
sampling and monitoring locations with the new acid sewer routing.
With the current acid sewer, the low lift wastewater sample represents the influent to wastewater
treatment. The new acid sewer by-passes the existing low lift wastewater sampler. A new
wastewater sampler will be provided on the acid sewer. Daily, 24-hr time composite samples of
both low lift and acid sewer wastewater will be collected and analyzed for BOD, TSS and color.
The low lift wastewater sampler will remain the mill's monitoring point for Cluster Rule Best
Management Practice (BMP) requirements. For permit monitoring and reporting, Blue Ridge
Paper will calculate"total influent concentrations" to the wastewater treatment plant.
Total influent concentrations are the flow-weighted average of low lift and acid sewer sample
concentrations. Calculations of low lift flow and total influent concentration are outlined on the
enclosed process flow diagram. The daily calculations will be done in our OPS-32 wastewater
database using lab data for the low lift and acid sewer samples and flow data from our mill plant
information system. There will be no change to the monthly discharge monitoring report. Total
influent concentrations will be reported on the influent wastewater page.
Blue Ridge Paper Products hic. - Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Roger Edwards, NC DENR DWQ-
9/2/05, Page 3
Summary
We request DENR approval of the influent monitoring changes outlined in this letter.
We are hopeful that the acid sewer project will reduce secondary effluent color by reducing
sewer-generated color in primary treatment. However, the mill has experienced several color
reduction projects where actual secondary effluent color performance does not reflect changes
predicted from individual sewer color reductions or lab-scale tests. The dynamic nature of color
generation and removal in wastewater treatment is difficult to predict. From the standpoint of
color reduction, the acid sewer project is a full-scale trial.
Please contact us if you have questions concerning monitoring and startup of the acid sewer
project.
_e �
Paul S. Dickens John J. Pryately
Manager, Environmental Affairs WWTP Supervisor, Operator in Charge
828-646-6141 828-646-6720
[e-mail] pryatj @blueridgepaper.com
Enclosure: Wastewater PFD with Compliance and Process Control Sample Notes
cc: C File—Water
Engr File—2005 Acid Sewer Project Monitoring
J. Clary
L. Cooper
WTP Operators
T. Simpson
G. Rogers
B. Shanahan
B. Williams
D. Brown
A. Apostolopoulos
M. Ferguson
B. Bosch
C. Dowdle
R. Medford
Blue Ridge Paper Products Inc. -Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

\O�()F W A r�9Q(r Michael F Easley,Governor
pj7Y William Ross Jr,Secretary
> r North Carolina Department arEnvironment and Natural Resources
y
O Y Alan W Klimek,P.E Direelor
Division or Water Quality
August 15, 2005
198
Mr. John J. Pryately AUG 15 500e
Blue Ridge Paper Products Inc. WTP
P.O. BOX 4000 SECTIONCanton, NC 28716 ILABORATORy,PJV RE�INAL OFFICE
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Mr.Pryately:
Enclosed is a report for the inspection performed on, August 2, 2005 by Mr. Gary Francies.
Where deficiencies are cited in this report, a response is required as well as for all lettered comments
and/or recommendations. Within thirty days of receipt, please supply this office with a written item for
item description of how these deficiencies, comments and/or recommendations were corrected. If the
deficiencies cited in the enclosed report are not corrected, enforcement actions will be recommended.
For certification maintenance, your laboratory must continue to carry out the requirements set forth in
15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from this office.
Thank you for your cooperation during the inspection. If you wish to obtain an electronic copy of this
report by email, or if you have questions or need additional Information please contact us at 919-733-
3908.
Sincerely,
James W. Meyer
Laboratory Section
Enclosure
Cc: Gary Francies
t�'o�`l,Carolina
Jvawra/!jl
Laboratory Section 1623 Mail Service Center,Raleigh,NC 27699.1623
4405 Reedy Crack Road;Raleigh,NC 27607
Phone[phone]/FAX [phone]/Internet wwwdwylaboig
An Equal Cppodunity/Af rmalive Actfon Employer—50%Recycledll 0%Post Consumer Paper

a
' On-Site Inspection Report
i
LABORATORY NAME: Blue Ridge Paper Products Inc. WWTP
l
ADDRESS: P.O. Box 4000
Canton, NC 28716
CERTIFICATE NO: 198
DATE OF INSPECTION: 812/05
TYPE OF INSPECTION: Maintenance
EVALUATOR: Gary Francies
LOCAL PERSON(S) CONTACTED: Mr John Pryately, Mr. Glenn Rogers, Ms Lori Cooper,
Mr. Harold Sweitzer
I. INTRODUCTION:
This laboratory was inspected to verity its compliance with the requirements of 15A NCAC 2H 0800 for the analysis
of environmental samples.
11. GENERAL COMMENTS:
In September 2004, the facility experienced unprecedented flooding from two consecutive tropical storms. The
entire laboratory was flooded with several feet of water:Records were either lost or severely damaged.The facility
attempted to salvage and restore the records but some have been lost. The staff is congratulated for doing an
outstanding job of starting the laboratory program up again after the floods. All instruments, meters, equipment,
lab benches, reagents, etc have been replaced.
Ill. DEFICIENCIES,REQUIREMENTS,COMMENTS,AND RECOMMENDATIONS:
A COMMENT: Extra nutrient, mineral, and buffer solutions are not added to the sample bottles containing more
than 67% sample.
NOTE: The Iaboratu has updated its referenced method to the 20" Edition Standard Methods, This Is a new
requirement of the 20 Edition that was not a part of previous approved methods.
REQUIREMENT: When a bottle contains more than 67% of the sample after dilution, nutrients may be limited in
the diluted sample and subsequently reduce biological activity. In such samples, add the nutrient, mineral, and
buffer solutions (3a through e) directly to individual BOD bottles at a rate of 1 mUL(0.33 mU300-mL bottle) or use
commercially prepared solutions designed to dose the appropriate bottle size. Ref: Standard Methods, 20th Edition
- Method 5210 B.4f.
RECOMMENDATION: It is recommended that a powder pillow for a 300-mL sample bottle be used. Dilution water
would be prepared as it currently is and for the bottles containing more than 67% sample, one powder pillow would
be added in addition to the dilution water containing the nutrient solutions.
IV. PAPER TRAIL INVESTIGATION:
No paper trail was performed.
V. CONCLUSIONS:
Correcting the above cited comment will help this lab to produce quality data and meet certification requirements.
Please respond to all lettered comments.
Report prepared by: Gary Francies Date: 8/8105

F WATF
O R Michael F.Easley
�4 QG �� Governor
(� r William G.Ross,Jr., Secretary
North Carolina Department of Environment and Natural Resources
O Y Alan W.Klimek,P.E.Director
Division of Water Quality
Asheville Regional Office
June 28, 2004
198
MR. JOHN PRYATELY
BLUE RIDGE PAPER PRODUCTS WWTP LAB
P.O. BOX 4000
CANTON, NC 28716
SUBJECT: Wastewater/Groundwater Laboratory Certification
Dear Mr. Pryately:
We have scheduled an on-site inspection of your laboratory for approximately 9:00 a.m., July 21,
2004. The scope of the inspection will include all methods marked on Attachment I of the laboratory's
current North Carolina Wastewater /Groundwater Certificate and /or marked on the application for NC
Wastewater/Groundwater Laboratory Certification. The purpose of the inspection will be to verify the
laboratory's documented quality control/quality assurance procedures and adequacy in meeting the
requirements of 15A NCAC 2H .0800.
Attached are inspection checklists for the upcoming inspection. Prior to the on-site inspection,
excluding the data review sections, please have your analysts complete each checklist. Any checklists that
your laboratory is unable to complete, or any specific items that you do not understand, will be completed
during the inspection. Completion of these checklists prior to the on-site audit, with comments by analysts
relating to specific procedural differences will help avoid any unnecessary interruption of the analyst's
schedule. Hold these checklists at your laboratory for use at the time of the inspection.
Please have available for review all DMR report sheets and bench data produced since the last on-site
inspection. These data sets will be used to assess the quality of your data during the inspection. If further
data or report sheets are required,we will notify you during the inspection.
Review your last inspection report (Inspection date: 5/6/03), to assure that all deficiencies have been
corrected. If any deficiencies cited in the 5/27/03 inspection report have not been corrected, enforcement
action will be recommended.
Thank you for your time and cooperation. I can be contacted at [phone] if you have
questions. Please notify me if any of the attached documents fail to open or will not print properly.
Sincerely,
Gary Francies
Laboratory Section
Enclosures
cc: James f- Me er
Water Quality Section,2090 US Highway 70,Swannanoa,NC 28778 Telephone: [phone] Customer Service
Fax: [phone] 1 800 623.7748

ArF9Michael F.Easley,Governor
P William G.Ross Jr.,Secretary
\Q G North Carolina Department of Environment and Natural Resources
rAlan Klimek,P.E.Director
> -1 Division of Water Quality
O Y
May 23, 2003
198
Mr. John J. Pryately
Blue Ridge Paper Products Inc. WTP D d
D
Canton, NC 28716
P.O. Box 4000
MAY 2 7 SOOZ
SUBJECT: Additional Parameter Certification LABORATORY SECTION
ASHEVILLE REGIONAL OFFICE
COLOR PC NCASI Method 71.01, (Ptco
COLOR PC NCASI Method 253 (PtCo)
Dear Mr. Pryately:
The Department of Environment and Natural Resources, in accordance with the
provisions of 15A NCAC 2H .0800, is pleased to certify your laboratory to perform
additional analytical parameter(s). This change to your certification is effective May
23, 2003.
Enclosed is an amended certificate that includes the new parameter(s). The same
requirements applying to your present certification are applicable to the new
parameter addition(s). Please review this certificate to insure that your laboratory is
certified for all parameters required to properly meet your certification needs.
Contact us at [phone] if you have questions or need additional information.
Sincerely,
James W. Meyer
Laboratory Section
JWM:jwm
Enclosure
cc Gary W. Francies
NCDENR
Laboratory Section N.C.Division of Water Quality 1623 Mail Service Center Raleigh,NC"27699-1623 [phone]
FAX: [phone] Internet: www.esb.enr.state.nc.us/lab

F WA Michael F.Easley,Governor
0 9 William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
Alan Klimek,P.E.Director
-i
Division of Water Quality -
O C
May 23, 2003
198
Mr. John J. Pryately
Blue Ridge Paper Products Inc. WTP
P.O. Box 4000
Canton, NC 28716
SUBJECT: Deleting Parameter(s) from Certificate
COLOR PC Std Method 2120B (PtCo)
Dear Mr. Pryately:
Per your request we are deleting the above parameters from your certificate.
Enclosed is an updated certificate reflecting this change which is effective on
May 23, 2003.
If you have questions or we can be of any further assistance, please contact us at
[phone].
Sincerely,
James W. Meryer
Laboratory Section
JWM:jwm
Enclosure
cc Gary W. Francies
ArA
NOD. R
Laboratory Section N.C.Division of Water Quality 1623 Mail Service Center Raleigh,NC27699-1623 [phone]
FAX: [phone] Internet: www.esb.enr.state.nc.us/lab

Attachment I
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Lab Name: Blue Ridge Paper Products Inc.WTP Certificate Number.. 198 .
Address: P.O.Box 4000 Effective Date: O1/O1/2003
Canton, NC 28716 Expiration Date: 12/31/2003
Dale of Last Amendment: 05/23/2003
The above named laboratory,having duly met the requirements of 15A NCAC 21-1.0900,is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANICS
BOD
Sid Method 5210B
COLOR PC
NCASI Method 71.01 (PtCo)
NCASI Method 253(PtCo)
CONDUCTIVITY
Sid Method 25106
DISSOLVED OXYGEN
Std Method 4500 O G
AMMONIA NITROGEN
Sid Method 4500 NH3 F
pH
Sid Method 4500 H B
RESIDUE SUSPENDED
Sid Method 2540D '
TEMPERATURE
Sid Method 2550B
This certification requires maintance of an acceptable quality assurance program,use of approved methodology,and satisfactory performance on evaluation samples. Laboratories are
subject to civil penalties and/or decertification for Infractions as set forth In 15A NCAC 2H.0807.

BLUE RIDGE
PAPER PRODUCTS INC.
January 13, 2004
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products Inc. Canton Mill
Dioxin Monitoring in Fish Tissue Report-2003
Dear Mr. Westall:
Attached is the final report detailing the results from Blue Ridge Paper Products' fourteenth
annual Fish Tissue Study. This study, as required by our NPDES permit, consists of annual
sampling of fish at specific sites in the Pigeon River and analysis of those fish for dioxin. The
actual fish collection took place in August 2003. All surveys were conducted by EA Engineering
Science and Technology and the analyses were conducted by Severn Trent Laboratories.
As you know, the Study Plan for the 2003 fish tissue monitoring was revised in response to the
fish consumption advisory on the Pigeon River being completely rescinded and the Walters Lake
advisory being partially rescinded. Carp in Walters Lake is the only fish species remaining under
advisory for both the North Carolina and Tennessee portions of the Pigeon River.
If you have any questions or comments,please call Bob Williams at(828) 646-2033 or Daryl
Whitt at(828) 646-6814.
Sincerely, ,n
1111A
Melanie Gardner
Advanced Environmental Engineer
Attachment
D � � � od � D ,
FjAN 16 t00a
1VATER OUALIN SECTIN
175 Main Street - P.O. Box 4000 ASUEVILL RE0101JAL OFFICE
Canton, North Carolina 28716 ® Phone: [phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
xc: Mr. Keith Haynes
Water Quality Section
Asheville Regional Office
59 Woodfin Place
Asheville,NC 28802
Attn: Central Files
Division of Environmental Management
and Natural Resources
NC Division of Environment and Natural Resources
P.O.Box 29535
Raleigh,NC 27626-0535
Mr.Marshall Hyatt
USEPA Region IV
345 Courtland Street,N.E.
Atlanta, GA 30365
Ms. Coleen Sullins
Chief,Water Quality Section
Division of Environmental Management
512 N Salisbury Street
P.O. Box 27687
Raleigh,NC 27611-7687
Mr. Paul Davis,Director
TN Dept. of Environment and Conservation
Division of Water Pollution Control
6'h Fl.L&C Annex
401 Church Street
Nashville,TN 37243-1534
Mr. David McKinney
TN Wildlife Resources Agencies
Ellington Agricultural Agency Center
P.O.Box 40747
Nashville,TN 37204

RESULTS OF 2003
DIOXIN MONITORING IN FISH TISSUE
Prepared for:
Blue Ridge Paper Products Inc.
Canton,Mill
Canton, North Carolina
Prepared by:
EA Engineering, Science, and Technology, Inc.
444 Lake Cook Road, Suite 18
Deerfield, IL 60015
January 2004 III
r
VOOZ 90 3
ITY SECTI"
GIOHAL OFFICE

TABLE OF CONTENTS
Page
Listof Tables.........................................................................................iii
Listof Figures ........................................................................................v
EXECUTIVE SUMMARY....................................................................... vii
1. INTRODUCTION................................................................................. 1-1
2. SAMPLING LOCATIONS...................................................................... 2-1
3. SAMPLING OBJECTIVES ..................................................................... 3-1
4. FISH COLLECTION TECHNIQUES AND LEVEL OF EFFORT..................... 4-1
5. SAMPLE PREPARATION...................................................................... 5-1
6. ANALYTICAL RESULTS...................................................................... 6-1
7. REFERENCES .................................................................................... 7-1
APPENDIX A: CHAIN OF CUSTODY FORMS
APPENDIX B: SEVERN TRENT LABORATORY-SACRAMENTO
ANALYTICAL REPORTS
i

LIST OF TABLES
Number Title Page
2-1 Pigeon River sampling station information .......................................... 2-2
4-1 Fish collection techniques and level of effort ....................................... 4-2
4-2 Summary of fish composites collected in the Pigeon River,
August2003 ............................................................................... 4-3
6-1 Summary of Pigeon River fish tissues analysis results--2003 .................... 6-2
6-2 Toxicity equivalence factors for CDD/F isomers................................... 6-3
6-3 Summary of CDD/F isomer analyses, toxicity equivalent
factors, and toxicity equivalent values for the 2003 Pigeon
River fish tissue composites ...........................................................: 6-5
6-4 Blue Ridge Paper Canton Mill fish fillet tissue analysis results
1990-2003.................................................................................. 6-8
iii

LIST OF FIGURES
Number Title Page
ES-1 TCDD concentrations in carp fillets collected from the Pigeon River,
..
2-1 Sampling station locations on the Pigeon River..................................... 2-3
2-2 Sampling Station No. 1 on the Pigeon River........................................ 2-4
2-3 Sampling Station No. 2 on the Pigeon River........................................ 2-5
2-4 Sampling Station No. 3 on the Pigeon River........................................ 2-6
2-5 Sampling Station No. 4A on the Pigeon River...................................... 2-7
2-6 Sampling Station No. 4B on the Pigeon River ...................................... 2-8
2-7 Sampling Station No. 5 on the Pigeon River........................................ 2-9
6-1 TCDD concentrations in carp fillets collected from the Pigeon River,
1990-2003.................................................................................6-15
6-2 TCDD concentrations in catfish fillets collected from Stations 4A and
4B in Waterville Lake, 1997-2003 ...................................................6-17
v

EXECUTIVE SOVIMARY
Bottom feeding species were collected in 2003 from six locations in the Pigeon River and
analyzed for 2,3,7,8-tetra6hlorodibenzo-p-dioxin (TCDD), 2,3,7,8-tetrachlorodibenzofuran
(TCDF), and other CDD and CDF isomers. TCDD and TCDF concentrations in fillet
composites from bottom feeders were very low (range=non-detected to 0.81 ppt) at the three
riverine locations downstream of the mill. Bottom feeders used at these locations were
common carp and black redhorse. TCDD concentrations in bottom feeder fillet composites at
the two Waterville Lake locations were 3.4 ppt and 12.0 ppt (Stations 4A and 4B,
respectively) for carp and non-detect for flathead catfish at Stations 4A and 4B. Since 1990,
TCDD concentrations in common carp fillets have declined dramatically (82-99 percent) at all
downstream stations (Figure ES-1).
vii

Figure ES-1. TCDD Concentrations in Carp Fillets Collected from
the Pigeon River, 1990-2003 (Stations 2 and 3).
2s
20 — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — —
—�— Station 2 - Station 3
c
o_
15 - - - - - - - - - - - - - - - - - - - - - - - - - -
- - - - - - - - - - - - - - - - -
L
Q.
C y
r:ca
Q
0 10 — —_—_— - -
- — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — —
U
F-
5 — t l— — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — —
*
a a
to �.,\ b c c c c
0 + - - +
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
YEAR
a) TCDD conentrations at Station 3 were not detected, therefore, the value plotted represents the detection limit for that sample.
b) TCDD concentrations at Station 2 were not detected, therefore, the value plotted represents the detection limit for that sample.
c) TCDD concentrations at Stations 2 and 3 were not detected, therefore, the values plotted represent the detection limits for those samples.

Figure ES-1 (Cont.). TCDD Concentrations in Carp Fillets Collected from
the Pigeon River, 1990-2003 (Stations 4A and 4B).
70
60 - -`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
\
50 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
a
O_ \ /
'L 40 - - - - -A'- - - - - - L - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
d \
R
Q30 - - - - - - - - - - - - -\- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -. / � \
IM *Q - -
U
20 - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
10 - - - - - - - - - - - - - - - \\- - -� - - - - - �`= - - - - - - - - - - - - - - - - - - - - -
Z I/
1990 1991 1992 1993 1994 1995 1996 1997 1996 1999 2000 2001 2002 2003
YEAR
—•— Station 4a — . — Station 4b

1. INTRODUCTION
This report details the results of a study conducted during 2003 to determine the
concentrations of 2,3,7,8,-TCDD (dioxin) and 2,3,7,8-TCDF (furan) in bottom-feeding fish
collected from the Pigeon River near Canton, North Carolina. The study described herein is
number 14 in a series of fish tissue surveys designed and conducted to be completely
responsive to the requirements of A.(9.) Dioxin Monitoring Special Condition in Blue Ridge
Paper's current NPDES permit for the Canton Mill (Permit No. NC0000272). Sampling
locations, selection of target species, sampling methods, and sample preparation/preservation
techniques are in accordance with the study plan (EA 2001a). The approved study methods
and scope detailed herein generally follow those used since 1990 (EA 1990, 1991, 1992,
1993a, 1993b, 1994, 1995, 1996, 1997, 1998, 2000, 2001b, 2001c, and 2003). However,
selected project details were modified to be responsive to the suggestions/recommendations of
the North Carolina Department of Environment and Natural Resources (NCDENR), the
Tennessee Wildlife Resources Agency, U.S. EPA Region IV, and the North Carolina
Department of Health and Human Services (NCDHHS). The principal change in the program
was that the collection and analysis of sportfish composite samples have not been required
since 2000.
The 2003 study was conducted during 26-28 August, during which time biologists from EA
collected and prepared fish tissue samples from six sampling locations on the Pigeon River.
Details relevant to the location of Pigeon River sampling stations and fish tissue sampling
objectives follow in Sections 2 and 3, respectively. Fish collection techniques and level of-
effort are detailed in Section 4; methods of sample preparation and shipment are presented in
Section 5. Analytical results are summarized in Section 6 and references are provided in
Section 7.
1-1

2. SAMPLING LOCATIONS
In accordance with the study plan (EA 2001 a), fish were collected from six locations on the
Pigeon River. Five monitoring stations were located downstream from the Canton Mill outfall
(four in North Carolina and one in Tennessee) and one control or background site was located
upstream of it. Detailed sampling station information is provided in Table 2-1 and Figure 2-1.
Station 1, the background site, is located at Pigeon River Mile (RM) 64.5, approximately 1.2 RM
upstream from the Canton Mill outfall (Figures 2-1 and 2-2). Fish were collected from the river
reach adjacent to the Canton Recreational Park(located upstream from the city of Canton).
Except under extremely high flows, the Canton Mill dam blocks the movement of fishes and
thereby prevents the interaction of control and downstream monitoring station fishes.
Monitoring Station 2 is located upstream from Clyde,North Carolina at RM 59.0, approximately
4.3 RM downstream from the Canton Mill outfall (Figures 2-1 and 2-3). Station 3 is 11.0 RM
downstream from the outfall (RM 52.3),in the vicinity of the old Rt. 209 bridge (Figures 2-1 and
2-4). Monitoring stations 4A and 4B are located in Waterville Lake at RM 41.5 and 39.0,
respectively (Figure 2-1). Station 4A is located approximately 21.8 RM downstream from the
Mill outfall, near the Messer Branch-Pigeon River confluence(Figure 2-5). Monitoring Station
4B is in the vicinity of the Wilkins Creek-Pigeon River confluence, approximately 24.3 RM
downstream from the Canton Mill outfall (Figure 2-6). Station 5 is located near Bluffton,
Tennessee at RM 19.0, approximately 44.3 RM downstream from the Mill outfall and about 6
miles downstream of the CP&L Hydro site(Figures 2-1 and 2-7). Sampling stations were
separated by at least 5.5 RM (with the exception of the Waterville Lake stations which are only
2.5 RM apart). Appropriate habitats were sampled within each study reach in an effort to collect
the desired complement of fishes.
Fish sampling was conducted in the vicinity of each location described above,however, the
distance or effort at each station depended on how difficult it was to collect fish at that station.
At Station 1, an approximate 0.2 RM reach was sampled which extended from just downstream
of the downstream most River Road (Rt. 215) Bridge to the bridge by the city park. The
Station 2 sample reach was approximately 0.2 RM in length and was adjacent to a sharp bend
along Old Thickety Road. The Station 3 sample reach extended approximately 0.2 RM,just
upstream of the old Rt. 209 Bridge. An approximate 0.4 RM reach of Waterville Lake was
sampled adjacent to and upstream of the Messer Branch-Pigeon River confluence. The
Station 4B study area consisted of a 1.0 RM reach of Waterville Lake located near the Wilkins
Creek-Pigeon River confluence. Sampling at Stations 4A and 4B included gillnetting near the
shore along both the left and right banks of Waterville Lake. A large pool just upstream of the I-
40 Bridge was sampled at Location 5.
2-1

Table 2-1. Pigeon River Sampling Stations.
Station River Station Location and
Number Mile Distance from Outfall Site Descriinion/Habitat Tyne Fish Community
1 64.5 Pigeon River upstream from Canton, Characterized by riffle,ran,and pool habitats. Maximum Relative abundance dominated by minnows and darters. River
NC,adjacent to Canton Recreational depth approximately 5 ft. Substrate primarily cobble and chub,greenfin darter and rock bass are dominant. Northern hog
Park(1.2 RM upstream from Canton boulders interspersed with gravel and sand. sucker,black redhorse,mirror shiner,central stoneroller,
Mill outfall). greenside darter,and mottled sculpin are common.
2 59.0 Pigeon River upstream from Clyde,NC Characterized by run and pool habitats with canopy Relative abundance dominated by redbreast sunfish,central
(4.3 RM downstream from the Canton cover. Maximum depth approximately 6 ft. Substrate stoneroller,and northern hog sucker.
Mill outfall). primarily cobble/gravellsand with some boulders and bedrock.
3 52.3 Pigeon River in the vicinity of the Rt. Characterized by run and pool habitats with some Redbreast sunfish,northern hog sucker,and common carp are
209 bridge(11.0 RM downstream canopy cover. Maximum depth approximately 5 ft. dominant. Central stoneroller is common.
N from the Canton Mill outfall) Substrate primarily bedrock and boulders with some
N cobble and sand/gravel/fines deposited in pool areas.
4A 41.5 Upper Waterville Lake(21.8 RM Characterized by deep-water lentic habitat with bedrock Relative abundance dominated by black crappie. Bluegill,
downstream from the Canton Mill covered by loose,unconsolidated bottom sediments. Maximum flathead catfish,channel catfish,and largemouth bass are
outfall) depth sampled approximately 15 ft. common. Common carp are present but not common.
4B 39.0 Lower Waterville Lake from the dam to Characterized by deep-water lentic habitat,bedrock, Relative abundance of catch dominated by black crappie.
confluence with Wilkins Creek(24.3 RM and soft bottom sediments. Maximum depth sampled Bluegill,channel catfish,and flathead catfish are common.
downstream from the Canton Mill approximately 40 ft. Very steep banks with little cover. Common carp are present but not common.
outfall)
5 19.0 Pigeon River near Bluffton,TN,just A single deep pool is sampled. Maximum depth Northern hog sucker is dominant. Smallmouth bass,rock bass,
upstream of 140(44.3 RM downstream approximately 8 ft. Substrate primarily boulder and cobble, black redhorse,whitetail shiner,and banded sculpin are
from the Canton Mill outfall) common. Except for smallmouth bass and rock bass,
centrarchids are uncommon. Freshwater drum,gizzard shad,
and buffalo are occasionally common. Common carp are
absent.

1-40
Station 5
RM 19.0 5
Bluffton,TN
(Hartford,TN
TENNESSEE N
NORTH
\\\ CAROLINA
K 11
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(26.0) �\
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Walters Dam 4B
Station 4B Station 4A
RM 39.0 RM 41.5
4A Waterville Lake
Fines Creek 1 f
New Hepco Bridge
FLOW Jonathan
Creek Old Rt.209
3 Station 3 Station 2 Mill Outfall
RM 52.3 RM 59.0 RM 63.3
Waynesville STP 2 Outfall c d Canton,NC
RM 54.7 Clyde Station 1 1
RM 64.5
(Control)
Figure 2-1. Fish tissue sampling station locations on the Pigeon River.
2-3

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Figure 2-2. Sampling Station No. 1 on the Pigeon River.
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2-4

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h k e
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Za Station 2
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Figure 2-3. Sampling Station No. 2 on the Pigeon River.
C
2-5

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f/'��_... f �J���•.�� $ Sao \� o �I � (� �;... I I I � / 1, �� '
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I ( Wp fw
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Figure 2-5. Sampling Station No. 4A on the Pigeon River.
2-7
Eno

•) ^, it >\ � /�'�,� \��`"'-,-��j�;, , �;��C�. .,
Go
C°II� -��``�7•\i; ( 'j Sillli /�J�y�h �\` \� ��r�ssYl ll , �
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Station 4B
IV
Figure 2-6. Sampling Station No. 4B on the Pigeon River.
�O
2-8

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1�
/fir Station_5
Iff16°O
� - S
1 )� �� 1��� V(r('✓IjjG
Figure 2-7. Sampling station No. 5 on the Pigeon River.
2-9

3. SAMPLING OBJECTIVES
In accordance with the study plan (EA 2001a), the goal of the fish collection effort was to
collect one composite bottom feeder fillet sample at each of the six sampling stations. Each
composite consisted of 5 similarly sized(shortest specimen within 75% of the length of the
longest) adult individuals of the target species. Common carp (Cyprinus carpio) was the target
species at Stations 2, 3,4A, and 4B. Common carp are absent at Stations 1 and 5, so at these
stations, black redhorse(Moxostoma duquesnei) was the target bottom feeder. In Waterville
Lake, one additional fillet composite sample using flathead catfish was collected at Stations 4A
and 4B.
In addition to the fillet composites, a whole body composite consisting of 5 similarly sized
common carp was collected at Station 4A in Waterville Lake.
In summary, fish were collected as follows:
• Bottom feeder fillet composite—one sample at all six stations
• Catfish fillet composite—one sample at Stations 4A and at 4B
• Common carp whole body composite—one sample from Station 4A
The study plan called for the collection of catfish fillet composite samples at Stations 2 and 3 if
specimens were encountered. However,no specimens were encountered at these locations in
2003.
Every reasonable effort was made to collect the desired size, species, and/or number of fish,
however, the outcome of the sampling effort each year is dependent on physical river
conditions and the natural diversity and abundance of target fishes at each sampling location.
The 2003 Pigeon River collections yielded the desired species at each sampling station. In
addition, the number of specimens collected made it possible to composite individuals of
similar weight and length (with larger/adult specimens preferred), and the 75 percent rule was
met for all samples.
3-1

4. FISH COLLECTION TECHNIQUES AND LEVEL OF EFFORT
Sampling was conducted on 26-28 of August 2003. Notes were recorded at each sampling
station with regard to the type of sampling gear, level of effort (time), and habitat (Table 4-1).
Surface water temperature measurements at each riverine location are summarized below:
Station RM Date Temp
1 64.5 8/27 23.6
2 59.0 8/26 25.7
3 52.3 8/26 24.1
5 19.0 8/28 22.8
All fish submitted for tissue analysis were measured to the nearest millimeter (total length) and
weighed to the nearest gram (wet weight). These data are summarized in Table 4-2.
The field investigators were equipped with an array of collecting gear which enabled sampling
of all habitats regardless of river conditions. U.S. EPA recommends active methods of fish
collection in their Sampling Guidance Manual (Versar 1984), such as electrofishing, trawling,
angling, or seining. These methods are preferred over passive methods (e.g., gill nets, trap
nets, trotlines) because the collection period is typically shorter (i.e., hours versus days--
thereby minimizing decomposition), and because samples are collected from more definable
areas (Versar 1984). Electrofishing was used at all stations, except 4A and 4B (Waterville'.
Lake), where gill nets were necessary because of water depth. A boat electrofishing unit
(pulsed direct current) was used to sample fish at Stations 3 and 5. The boat electrofisher was
equipped with a Smith Root Type VIA electrofisher, and powered by a 240-volt, 5000W
generator. A pram electrofisher, equipped with a Coffelt VVP-2C pulser and powered by a
120-volt, 1800W generator, was utilized at Stations 1 and 2. Electrofishing techniques
followed those described in the National Dioxin Study (Versar 1984).
Fish collection techniques and level of effort (time) expended at each of the six stations are
summarized in Table 4-1. Total study effort involved —3.3 electrofishing-hours and —229 net-
hours. Total electrofishing duration (energized time) was 45, 95, 30, and 30 minutes at
Stations 1, 2, 3, and 5, respectively.
4-1

Table 4-1. Fish Collection Techniques and Level of Effort.
Station Sampling Sampling
Number RM Dates Techniques Level of Effort Comments
1 64.5 27 AUG 03 Pram Electrofishing 45 nun An approximate 0.2 RM reach of river was sampled;water level moderate—visibility good;characterized
by riffles,urns,and pools with primarily cobblePooulder substrates interspersed with gravel and sand along
margins. The entire reach was sampled using the pram.
2 59.0 27 AUG 03 Pram Electrofiishing 1 In,35 min Less than 0.2 RM retch of river was sampled;water level modemte--visibility good;station characterized
by run and pool habitats with canopy cover,substrate primarily cobble/gravel with some boulders and
bedrock,and sand/gravel/fines deposited along margins. Sampling involved several electrofishing passes
near woody debris using the pram.
3 52.3 26 AUG 03 Boat Electrofishing 30 min An approximate 0.2 RM reach of river was sampled;water level modemte--visibility good;station
characterized by runs and pools with primarily bedrock and boulder substrates,with sand/gmveVfmm
deposited along margins. Sampling involved several electrofishing passes over the reach utilizing a boat-
mounted electrofishing unit.
N
4A 41.5 26-27 AUG 03 (5)Gill nets —94 net-hrs An approximate 0.4 RM reach of river was sampled;lake level was nonnal—visibility good,station
characterized by moderately deep-water lentic habitat with bedrock and soft,unconsolidated bottom
substrates. Sampling involved gill net sets just off the left and tight shores.
4B 39.0 26-27 AUG 03 (6)Gill nets —135 net-hrs An approximate 1.0 RM reach of river was sampled;lake level was normal--visibility good;station
characterized by deep-water lenlic habitats with bedrock and soft bottom substmtes. Sampling involved
gill nets. Effort was concentrated near the rock pile near the dam,in the small bay at the mouth of Wilkins
Creek,and in the I small bay upriver from Wilkins Creek but along the opposite bank.
5 19.0 28 AUG 03 Boat Electrofishing 30 min An approximate 0.1 RM reach of river was sampled;water was clear and moderately low--visibility good
to excellent;station was a large pool and associated shoal habitat;substrate boulder and cobble. Sampling
involved several electrofishing passes over the pool using a boat-mounted electrofishing unit.

Table 4-2. Summary of fish composites collected at six stations in the Pigeon River, August 2003.
TOTAL TOTAL
LENGTH WHOLE BODY
DATE STATION SPECIES (mm) WEIGHT(g) SAMPLE TYPE COMPOSITE
27 AUG 03 1 BLACK REDHORSE 420 500 FILLET R
(RM 64.5) BLACK REDHORSE 373 425
BLACK REDHORSE 398 440
BLACK REDHORSE 343 350
BLACK REDHORSE 346 270
MEAN 376 397
27 AUG 03 2 COMMON CARP 584 2430 FILLET R
(RM 59.0) COMMON CARP 562 2350
COMMON CARP 553 1930
COMMON CARP 512 1700
COMMON CARP 552 2150
MEAN 553 2112
27 AUG 03 3 COMMON CARP 565 2330 FILLET R
(RM 52.3) COMMON CARP 605 2780
COMMON CARP 596 2770
COMMON CARP 555 2410
COMMON CARP 545 2130 '
MEAN 573 2484
26-27 AUG 03 4A FLATHEAD CATFISH 530 1830 FILLET R
(RM 41.5) FLATHEAD CATFISH 574 2430
FLATHEAD CATFISH 531 1990
FLATHEAD CATFISH 521 1750
FLATHEAD CATFISH 575 2220
+_3
MEAN 546 2044
26-27 AUG 03 4A COMMON CARP 717 5700 FILLET R
(RM 41.5) COMMON CARP 672 4150
COMMON CARP 680 3970
COMMON CARP 655 3500
COMMON CARP 672 4400
MEAN 679 4344
26-27 AUG 03 4A COMMON CARP 630 3300 WHOLE BODY WB
(RM 41.5) COMMON CARP 644 3180
COMMON CARP 594 2900
COMMON CARP 587 2680
COMMON CARP 578 2260
MEAN 607 2864
4-3

Table 4-2 (cont.).
TOTAL TOTAL
LENGTH WHOLE BODY
DATE STATION SPECIES (mm) WEIGHT(g) SAMPLE TYPE COMPOSITE
26-27 AUG 03 4B COMMON CARP 654 3430 FILLET R
(RM 39.0) COMMON CARP 713 5150
COMMON CARP 745 6800
COMMON CARP 702 5200
COMMON CARP 602 3170
MEAN 683 4750
26-27 AUG 03 4B FLATHEAD CATFISH 533 1700 FILLET R
(RM 39.0) FLATHEAD CATFISH 526 1660
FLATHEAD CATFISH 513 1630
FLATHEAD CATFISH 511 1720
FLATHEAD CATFISH 513 1750
MEAN 519 1692
28 AUG 03 5 BLACK REDHORSE 460 1160 FILLET R
(RM 19.3) BLACK REDHORSE 524 1420
BLACK REDHORSE 445 960
BLACK REDHORSE 484 1290
BLACK REDHORSE 458 1040
MEAN 474 1174
4-4

Target species were collected at all sampling stations in 2003. Common carp, the target
bottom feeder at stations 2, 3, 4A, and 4B, were collected (and prepared for fillet and/or
whole body analysis) at those stations. In addition, the preferred target bottom feeding species
(black redhorse) was collected from Stations 1 and 5. The physiography of the Waterville
Lake Stations 4A and 4B necessitated the use of gill nets for the collection of bottom feeding
species. All nets were pulled and examined on a regular basis to reduce stress or specimen
mortality. All specimens submitted for analysis appeared healthy and in good condition.
Lengths and weights for each fish making up each composite are provided in Table 4-2.
Bottom feeder fillet composites consisted of five black redhorse at Stations 1 and 5 and five
common carp at Stations 2, 3, 4A, and 4B. In addition, a second bottom feeder fillet
composite, consisting of five flathead catfish, was prepared for analysis from Stations 4A and
4B. A single bottom feeder whole body composite consisting of five common carp from
Station 4A was prepared for analysis (Table 4-2).
All nine composites submitted for analysis in 2003 met the US EPA Region IV
recommendation (Cunningham 1990) that the smallest specimen in each composite be equal to
or greater than 75 percent of the total length of the largest specimen in that composite (Tables
4-2 and 6-4).
4-5

5. SAMPLE PREPARATION
All fish tissue samples were prepared in accordance with U.S. EPA Region IV
recommendations (Cunningham 1990) as described in EA (2001a). To prevent
cross-contamination between sampling stations, all sampling equipment likely to come into
contact with the fish was rinsed extensively with site water between stations.
Specimens collected at each station were sorted by size and species, and target species were
identified. The objective was to obtain a 3 to 5-fish composite sample at each station (plus a
catfish composite for each station in Waterville Lake as well as a common carp whole body
composite from either station in Waterville Lake) which met the species and size objectives
discussed in Section 3. From the target fishes collected, specimens of similar length and
weight were selected for each composite sample. All specimens retained were immediately
placed on ice for later processing. For each fish retained, length and weight data were
collected and recorded on the appropriate fisheries data sheet.
Following identification of target organisms, selection of composite samples, and collection of
length/weight data, each specimen was prepared for shipment and analysis. Bottom feeder.
fillet samples consisted of epaxial muscle tissue and skin from one side of the fish. Bottom`
feeder whole body samples consisted of the entire fish. Fillet samples were prepared by
removing the scales (or removing skin from catfishes) and then making an incision behind the
opercula (on both sides of the fish) from the base of the spine (behind the skull) to just below
the pectoral fin. Care was taken to cut through the epaxial muscle without puncturing the rib
cage or gut lining. A second incision was made along the length of the spine to the caudal fin
on both sides of the fish. The epaxial muscle was then gently cut away from the rib cage to
obtain a fillet. In this fashion, all flesh and skin was obtained from head to tail on both sides
of the fish. Fillet knives were solvent rinsed (hexane and acetone) between fish from different
stations. Each composite sample was wrapped in aluminum foil (dull side toward sample),
labeled, and placed on dry ice. Right side fillets were sent to Severn Trent Laboratory for
analysis; left side fillets were retained by Blue Ridge personnel as back-up fillets.
All individual specimens (fillets or whole bodies) composing a single composite sample were
placed together in a water-tight plastic bag labeled with the station name, sample number, and
the number of specimens in that composite. All labels contained the following information:
• sample identification number,
w sample location and station identification,
• sampling team initials,
• date of sample collection,
O species name,
• sample type (i.e., fillet or whole body)
5-1

A chain-of-custody form was filled out for each cooler of samples submitted for analysis.
Each form included composite-specific information and instructions. Copies of all
chain-of-custody records are provided in Appendix A.
All samples were frozen solid prior to shipment to the analytical laboratory. The frozen
samples were packed on dry ice, shipped via overnight delivery on 2 September and were
received, still frozen, at Severn Trent Laboratory - Sacramento on 3 September 2003.
5-2

6. ANALYTICAL RESULTS
The fish tissue samples were received at Severn Trent Laboratory (STL) - Sacramento,
California_under chain-of-custody on 3 September 2003. Once received at the laboratory,
samples were compared to the chain-of-custody record to verify the contents of each shipping
container. Each individual fish or fillet within a composite was homogenized separately by
STL personnel, and equal aliquots of the homogenate from each fish were removed to
constitute the composite. Dioxin and furan analyses were performed using high resolution Gas
Chromatography/Mass Spectrometry (GS/MS) as required by the U.S. EPA. Laboratory
documentation of all chemical extractions and analyses are provided in Appendix B. All
chemical analyses of the samples were conducted using EPA Method 8290 (U.S. EPA 1994)
as specified in the Canton Mill NPDES permit.
The quality of the analytical results was assured through reproducible calibration and testing of
the extractions and GC/MS systems. A laboratory method blank was prepared along with
each batch of samples. The laboratory also used precision and recovery standards for
determination of initial and ongoing precision and accuracy.
Laboratory reports for all 2003 Pigeon River fish tissue dioxin, furan, and lipid content
analyses are provided in Appendix B. Each laboratory analysis report form lists the
concentration of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), 2,3,7,8-tetrachlorodibenzofuran
(TCDF), and all other CDD/CDF isomers. Results of the dioxin, furan, and lipid content
analyses are summarized in Table 6-1. Detection limits are reported parenthetically on a
sample-specific basis. Only fillet results are discussed below because NCDHHS considers
only fillet results when issuing health advisories.
Concentrations of 2,3,7,8-TCDD in bottom feeder composite fillet samples were below the
level of detection at Stations 1, 2, 3, 4A (flathead catfish), 4B (flathead catfish), and 5 (Table
6-1). Concentrations of 2,3,7,8-TCDD were detectable only in common carp composite fillet
samples from Stations 4A (3.4 ppt) and 4B (12.0 ppt). Furan isomer (2,3,7,8-TCDF) analysis
results indicated a concentration range from non-detect [Stations 1, 2, 4A (flathead catfish),
and 4B (flathead catfish)] to 3.5 ppt (common carp at Station 4B).
Examination of the data in Table 6-1 indicates that all fish collected during this study had body
burdens well below the FDA dioxin health advisory level (25 ppt) for fish tissue [as
established and presented in FDA (1981 and 1983) and Cordle (1983)].
NCDHHS has identified a dioxin evaluation level of 3 ppt in fillet samples, expressed as
average toxicity equivalent (TEQ) (NCDEHNR 1991). The TEQ of each chlorodibenzo
dioxin and furan (CDD/F) isomer is based on the toxicity equivalence factor (TEF) (WHO
1997 and Table 6-2) as described in the 2001 Study Plan (EA 2001b). The TEQ value is
calculated assuming additivity of effects from the individual congeners of dioxins and furans
and is expressed as an "equivalent amount of 2,3,7,8-TCDD" (NCDEHNR 1991). The
measured concentration of each CDD/F isomer, when multiplied by its appropriate TEF,
yields the TEQ
6-1

Table 6-1. Summary of Pigeon River Fish Tissue Analysis Results,2003.
Station Percent
Number Sample ID Species Composite/Sample Type 2,3,7,8-TCDDt'i 2,3,7,8-TCDFtai Lipid
1 LOC 1 BLACK RH. Black redhorse 5 fillet samples ND(DL=0.20) ND (DL=0.15) 2.2
2 LOC 2 CARP Common carp 5 fillet samples ND(DL=0.18) ND(DL=0.39)
3.2
3 LOC 3 CARP Common carp 5 fillet samples ND(DL=0.31) 0.81a1> 6.6
4A LOC 4A FH. CATFISH Flathead catfish 5 fillet samples ND(DL=0.35) ND (DL=0.98) 2.5
LOC 4A CARP Common carp 5 fillet samples 3.4 3.4 16.0
LOC 4A CARP-WB Common carp 5 whole body samples 1.9 1.5 11.0
4B LOC 4B FH.CATFISH Flathead catfish 5 fillet samples ND(DL=0.20) ND (DL=0.16) 3.4
LOC 4B CARP Common carp 5 fillet samples 12.0 3.5 22.0
t`' 5 LOC 5 BLACK RH. Black redhorse 5 fillet samples ND (DL=0.19) 0.66tbi 6.1
(a) Units=ppt(parts per trillion)or pg/g(picogram per gram)
(b) Estimated result. Result is less than the reporting limit

Table 6-2. Toxicity Equivalence Factors for CDD/F Isomers.
DIOXIN DIBENZOFI.IRAN
Isomer�a' TEF(b) Isomer(a) TEF(b)
2,3,7,8-TCDD I 2,3,7,8-TCDF 0.1
1,2,3,7,8-PeCDD 1 1,2,3,7,8-PeCDF 0.05
2,3,4,7,8-PeCDF 0.5
1,2,3,4,7,8-HxCDD 0.1 1,2,3,4,7,8-HxCDF 0.1
1,2,3,7,8,9-HxCDD 0.1 1,2,3,7,8,9-HxCDF 0.1
1,2,3,6,7,8-HxCDD 0.1 1,2,3,6,7,8-HxCDF 0.1
2,3,4,6,7,8-HxCDF 0.1
1,2,3,4,6,7,8-HpCDD 0.01 1,2,3,4,6,7,8-HpCDF 0.01
1,2,3,4,7,8,9-HpCDF 0.01
OCDD 0.0001 OCDF 0.0001
(a) In each homologous group, the relative toxicity factor for the isomers not listed is 1/100 of
the value listed for the other isomers in that homologous group.
(b) TEF=toxic equivalence factor=relative toxicity assigned.
6-3

of that isomer (the toxic concentration of that isomer relative to the toxicity of
2,3,7,8-TCDD). In cases where CDD/F concentrations were below the level of detection, a
value of zero was used in the TEQ calculation.
The TEQ calculation and summarization schemes presented in Table 6-3 followed methods
used by NCDHHS (NCDEHNR 1991). Bottom feeder fillet TEQ values were below the
NCDHHS limit of 3 ppt for all stations, except 4A and 4B in Waterville Lake. Although the
TEQ values for carp fillet composites at Stations 4A and 4B (8.6 and 20.0 ppt, respectively)
exceeded the level of concern, the TEQ value for flathead catfish fillets from the same
locations were < 0.01 and 0.0 ppt, respectively. In addition, the common carp whole body
composite at Station 4A was also below the NCDHHS limit of 3 ppt.
Table 6-4 illustrates the decline in 2,3,7,8 TCDD concentrations in carp fillet samples from
1990 through 2003. Since 1990, 2,3,7,8 TCDD concentrations in carp fillets declined
dramatically (82-99 percent) at all sampling stations (Table 6-4, Figure 6-1). The
concentrations of 2,3,7,8 TCDD in carp fillets from all stations in 2003 were similar to those
observed in 2002, except at Station 4B. Concentrations of 2,3,7,8 TCDD in carp fillets at
Station 4B appear to have increased slightly in recent years (Figure 6-1), with a similar, but
less pronounced trend at Station 4A. The increases in TCDD concentrations observed in carp
fillets since 1999 may be due in part to environmental conditions, specimen size, and/or dioxin
biouptake/depuration rates of individual carp submitted for analysis rather than representing a
real increase in dioxin concentrations in Waterville Lake. Regarding specimen size, on
average, the size of the carp submitted for fillet analysis from Waterville Lake has increased in
recent years, particularly at Station 4B. For example, during the period 1999-2003, the mean
weight of carp analyzed at Stations 4A and 4B was 3.193 kg and 5.042 kg, respectively,
compared to only 2.673 kg (Station 4A) and 3.207 kg (Station 4B) for the period 1994 through
1999 (EA 1994, 1995, 1996, 1997, 1998, 2000, 2001b, 2001c, and 2003). In addition, three
of the five fish submitted for analysis at Station 4B in 2003 were greater than 700mm, and one
fish was 745mm and weighed 6800 grams, the largest fish ever submitted for fillet analysis.
In contrast to carp fillets, TCDD concentrations in catfish fillets from Stations 4A and 4B have
declined since 1999 (Figure 6-2). Thus, despite modest increases in recent years that may be
an artifact associated with the size of the specimens collected, the concentration of 2, 3, 7, 8
TCDD in carp fillets from Waterville Lake has declined by 82-87 percent from 1990 through
2003 (Figure 6-1).
6-4

Table 6-3. Summary of CDD/F Isomer Analyses, Toxicity Equivalent Factors and Toxicity Equivalent Values for the 2003 Pigeon River Fish
Tissue Composites.
STATION 1 STATION 2 STATION 3
BLACK REDHORSE - Fillet COMMON CARP' - Fillet COMMON CARP - Fillet
CDD/F ISOMERS TEF(c) Results(a) TEQ(b) Results TEQ Results TEQ
Dibenzodioxin
t + ,
2,3,7,8-TCDD 1.0 0.20 * 0.000 0.18 * 0.000 0.31 * 0.000
1,2,3,7,8-PeCDD 1.0 0.48 * 0.000 0.48 * 0.000 0.56 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.34 * 0.000 0.40 * 0.000 0.42 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.26 * 0.000 0.59 * 0.000 0.69 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.29 * 0.000 0.35 * 0.000 0.36 * 0.000
1,2,3,4,,6,7,8-HpCDD 0.01 0.48 * 0.000 2.10 * 0.000 3.1(d) 0.031
OCDD 0.0001 1.60 * 0.000 11.00 0.001 10.0(d) 0.001
Dibenzofuran
2,3,7,8-TCDF 0.1 0.15 * 0.000 0.39 * 0.000 0.8.1(d) 0.081
1,2,.3,7,8-PeCDF 0.05 0.23 * 0.000 0.26 * 0.000 0.30 * 0.000
2,3,4,7,8-PeCDF 0.5 0.23 * 0.000 0.26 * 0.000 0.26 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.22 * 0.000 0.29 * 0.000 _ 0.22 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.18 * 0.000 0.25 * 0.000 0.19 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.22 * 0.000 , 0.30 * 0.000 0.23 * 0.000
1,2,3,7,8,9-HxCDF 0-.1 0.25 * 0.000 0.34 * 0.000 0.26 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.43 * 0.000 0.37 * 0.000 0.41 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.51 * 0.000 0.43 * 0.000 0.48 * 0.000
OCDF 0.0001 0.61 * 0.000 0.67 * 0.000 0.59 * 0.000
Total TEQ 0.00 0.00 0.11

Table 6-3 (cont.)
STATION 4A
FLATHEAD CATFISH - Fillet COMMON CARP - Fillet COMMON CARP - WB
CDD/F ISOMERS TEF(c) Results (a) TEQ(b) Results TEQ Results TEQ
Dibenzodioxin
2,3,7,E-TCDD 1.0 0.35 * 0.000 3.40 3.400 1.90 1.900
1,2,3,7,8-PeCDD 1.0 0.83 * 0.000 2.50 2.500 1.70 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.61 * 0.000 1.70 * 0.000 0.34 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.50 * 0.000 7.70 0.770 5.00 0.500
1,2,3,7,8,9-HxCDD 0.1 0.52 * 0.000 1.40 * 0.000 0.91 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 1.40 * 0.000 24.00 0.240 21.00 0.210
OCDD 0.0001 6.4 (d) 0.001 92.00 0.009 81.00 0.008
Dibenzo£uran
2,3,7,8-TCDF 0.1 0.98 * 0.000 3.40 0.340 1.50 0.150
1,2,3,7,8-PeCDF 0.05 0.48 * 0.000 1.90 * 0.000 0.69 * 0.000
2,3,4,7,8-PeCDF 0.5 0.48 * 0.000 2.6(d) 1.300 1.70 * 0.000
1,2,3,4,7,8-HxCDF 0.1 0.43 * 0.000 1.40 * 0.000 0.82 * 0.000'
1,2,3,6,7,8-HxCDF 0.1 0.36 * 0.000 1.20 * 0.000 0.73 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.44 * 0.000 0.71 * 0.000 0.26 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.50 * 0.000 0.30 * 0.000 0.29 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.67 * 0.000 2.30 * 0.000 1.40 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.79 * 0.000 0.69 * 0.000 0.71 * 0.000
OCDF 0.0001 1.00 * 0.000 0.50 * 0.000 0.51 * 0.000
Total TEQ 0.00 8.56 2.77

Table 6-3 (con[.)
STATION 4B STATION 5
FLATHEAD CATFISH - Fillet COMMON CARP - Fillet BLACK REMORSE - Fillet
CDD/F ISOMERS TEF(c) Results (a) TEQ(b) Results TEQ Results (a) TEQ(b)
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.20 * 0..000 12.00 12.000 0.19 * 0.000
1,2,3,7,8-PeCDD 1.0 0.50 *. 0.000 _ _ _ _ 3.7(d) 3.700 0.58 * 0.000
1,2,3,4,7,8-HxCDD 0.1 0.37 * 0.600 3.1(d) 0.310 0.35 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.38 * 0.000 11.00 1.100 0.29 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.32 * 0.000 1.80 * 0.000 0.30 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.54 * 0.000 30.00 0.300 0.55 * 0.000
OCDD 0.0001 0.96 * 0.000 76.00 0.008 0.74 * 0.000
Dibenzofuran
2,3,7,8-TCDF 0.1 0.16 * 0.000 3.50 0.350 0.66(d) 0.066
1,2,3,7,8-PeCDF 0.05 0.26 * 0.000 1.40 * 0.000 0.28 * 0.000
2,3,4,7,9-PeCDF 0.5 0.26 * 0.000 4.4(d) 2.200 0.28 * 0.000
1,2,3,4,7,8-HXCDF 0.1 0.26 * 0.000 1.60 *' 0.000 0.22 * 0.000
1,2,3,6,7,E-HxCDF 0.1 0.22 * 0.000 1.80 * 0.000 0.19 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.27 * 0.000 0.93 * 0.000 0.23 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.31 * 0.000 0.30 * 0.000 0.26 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.50 * 0.000 2.40 * 0.000 0.37 * 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.59 * 0,000 0.76 * 0.000 0.44 * 0.000
OCDF 0.0001 0.54 * 0.600 -' 0.30 * 0.000 0.63 * 0.000
Total TEQ 0.00 19.97 0.07
(a) Units = ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from World Health Organization (WHO 1997) .
(d) Estimated result. Result is less than reporting limit.
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.

Table 6-4. Blue Ridge Paper Canton Mill Fish Fillet Tissue Analysis Results, 1990-2003(a).
1990 Results0t 1991 Results(b)
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDD(0 Station Species Fish Range(mm) 2,3,7,8-TCDDI`l
1 Rock bass 5 151-197 ND(0.15) 1 Rock bass 10 151-190 ND(0.40)
RM 64.5 Rock bass 5 153-213 ND(0.15) RM 64.5 Redbreast sunfish 10 106-178 ND(0.33)
Black redhorse 2 380-383 ND(0.20) Black redhorse 5 358-471 ND(0.35)
2 Redbreast sunfish 5 185-196 1.4 2 Redbreast sunfish 8 154-189 0.87
RM 59.0 Redbreast sunfish 5 148-201 3.4 RM 59.0 Redbreast sunfish 8 154-202 0.93
Common carp 1 517 19.7 Common carp 10 491-570 9.7
3 Redbreast sunfish 5 188-203 0.79 3 Redbreast sunfish 10 176-209 ND(0.89)
RM 52.3 Redbreast sunfish 5 191-198 2.6 RM 52.3 Bluegill 6 164-197 ND(0.83)
Common carp 2 489-555 4.2 Common carp 10 408-463 2.4
4A Bluegill 5 178-192 ND(1.2) 4A Largemouth bass 7 313468 3.0
RM 41.5 Bluegill 5 153-174 ND(0.63) RM 41.5 Black crappie 10 173-216 ND(0.63)
Common carp I 574 27 Common carp 10 502-688 23
60 4B Bluegill 5 183-196 0.76 4B Bluegill 5 186-212 ND(0.34)
RM 39.0 Largemouth bass 2 279-400 ND(1.8) RM 39.0 Bluegill 5 190-208 ND(0.62)
Common carp 4 551-638 66 Common carp 10 532-605 40
5 Redbreast sunfish 10 143-223 0.98
RM 16.5 Spotted bass 2 266-369 ND(0.35)
Common carp 2 51 I-539 1.7
Total Fish Filleted 57 138

Table 6-4 (cont.).
1992 Resultsai 1993 Results(b)
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDDr°t Station Species Fish Range(mm) 2,3,7,8-TCDDt°t
1 Rock bass 10 147-194 ND(0.085) 1 Rock bass 10 185-208 ND(0.10)
RM 64.5 Redbreast sunfish 10 147-182 ND(0.075 RM 64.5 Redbreast sunfish 5 148-203 ND(0.12)
Black redhorse 6 365-441 1.4 - Black redhorse 10 365-410 ND(0.80)
2 Redbreast sunfish 10 180-220 0.72 2 Redbreast sunfish 10 168-206 ND(0.27)
RM 59.0 Redbreast sunfish 10 178-220 ND(0.38) RM 59.0 Redbreast sunfish 10 140-191 ND(0.15)
Common carp 10 486-581 9.3 Commou carp 10 462-620 3.1
3 Redbreast sunfish 10 175-200 ND(0.34) 3 Redbreast sunfish 10 155-210 ND(0.27)
RM 52.3 Redbreast sunfish 10 183-200 ND(0.29) RM 52.3 Redbreast sunfish 7 180-213 ND(0.36)
Common carp 10 438-600 4 Common carp 10 440-576 3.4
4A Black crappie 10 153-232 ND(0.094) 4A Black crappie 10 178-201 ND(0.15)
RM 41.5 Black crappie 10 177-224 ND(0.10) RM 41.5 Black crappie 10 182-204 ND(0.089)
Common carp 10 492-622 29 Common carp 10 525-611 19
i
4B Bluegill 10 182-212 ND(0.23) 4B Largemouth bass 10 190-310 ND(0.12)
RM 39.0 Largemouth bass 5 215-332 ND(0.19) RM 39.0 Bluegill 10 185-210 ND(0.20)
Common carp 10 558-640 51 Common carp 10 530-644 28
5 Redbreast sunfish 10 175-245 ND(0.38) 5 Redbreast sunfish 6 180-231 ND(0.17)
RM 19.0 Spotted bass 2 256-355 ND(0.30) RM 19.0 Smallmouth bass 9 212-281 ND(0.13)
Small nth buffalo 5 428-510 0.61 Smallmouth buffalo 5 450-550 ND(0.41)
Total Fish Filleted 158 162

Table 6-4 (cont.).
1994 Resultsol 1995 Results(c)
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDDt-t Station Species Fish Range(man) 2,3,7,8-TCDDr r
1 Rack bass 6 156-185 ND(0.083) 1 Rock bass 10 162-205 ND(0.10)
RM 64.5 Redbreast sunfish 10 155.197 ND(0.10) RM 64.5 Rock bass 10 150-220 ND(0.26)
Black redhorse 3 367-435 ND(0.096) Black redhorse 7 375-464 ND(0.21)
2 Redbreast sunfish 10 176-206 ND(0.073) 2 Redbreast sunfish 10 152-194 ND(0.20)
RM 59.0 Redbreast sunfish 10 160-210 ND(0.092) RM 59.0 Redbreast sunfish 10 161-188 ND(0.16)
Common carp 10 490-590 0.99 Comon carp 10 435-664 1.7
3 Redbreast sunfish 10 148-196 ND(0.15) 3 Redbreast sunfish 10 170-206 ND(0.18)
RM 52.3 Redbreast sunfish 10 158-210 ND(0.074) RM 52.3 Redbreast sunfish 10 154-202 ND(0.20)
Common carp 10 456-565 0.74 Common carp 10 391-571 1.2
4A Black crappie 10 203-231 ND(0.085) 4A Largemouth bass 5 281-439 2.0
RM 41.5 Bluegill 10 185-205 ND(0.084) RM 41.5 Bluegill 10 167-199 ND(0.26)
U Common carp 10 465-591 3.4 Common carp 10 520-615 5.8
O 4B Black crappie 10 200-215 ND(0.084) 4B Largemouth bass 9 248-391 0.68
RM 39.0 Black crappie 10 195-220 ND(0.062) RM 39.0 Bluegill 8 158-216 ND(0.34)
Common carp 10 520-635 6.6 Common carp 4 532-626 11.0
5 Redbreast sunfish 6 129-289 ND(0.075) 5 Smallmouth bass 9 280-423 ND(0.11)
RM 19.0 Smallmouth bass 9 234-442 ND(0.11) RM 19.0 Redbreast sunfish 7 163-192 ND(0.15)
Smallmouth buffalo 9 440-520 ND(0.089) Black redhorse. 7 440481 ND(0.45)
Total Fish Filleted 163 156

Table 6-4 (cont.).
1996 Resultsn) 1997 Results(")
Number of Length Number of Length
Station Species Fish Range(ram) 2,3,7,8-TCDD(`) Station Species Fish Range(mm) 2,3,7,8-TCDD(')
1 Redbreast sunfish 5 154-185 ND(0.13) 1 Redbreast sunfish 5 144-161 ND(0.11)
RM 64.5 Rock bass 5 160-208 ND(0.085) RM 64.5 Rock bass 5 162-194 ND(0.23)
Black redhorse 5 401-440 ND(0.089) Black redhorse 4 291-424 ND(0.22)
2 Redbreast sunfish 5 179-187 ND(0.10) 2 Redbreast sunfish 5 183-200 ND(0.26)
RM 59.0 Redbreast sunfish 5 183-191 ND(0.12) RM 59.0 Redbreast sunfish 5 160-181 ND(0.12)
Common carp 5 543-580 1.5 Common carp 5 506-615 1.4
3 Redbreast sunfish 5 184-190 ND(0.13) 3 Redbreast sunfish 5 187-202 ND(0.18)
RM 52.3 Redbreast sunfish 5 165-185 ND(0.13) RM 52.3 Redbreast sunfish 5 164-195 ND(0.18)
Common carp 5 516-630 0.87 Common carp 5 450-505 ND(0.33)
4A Black crappie 5 216-233 ND(0.15) 4A Black crapppie 5 215-231 ND(0.27)
RM 41.5 Black crappie 5 215-229 ND(0.18) RM 41.5 Black crappie 5 220-230 ND(0.10)
Common carp 5 562-632 4.2 Common carp 5 570-655 2.3
p� Channel catfish 5 418-482 2.0
i
.�-. 4B Black crappie 5 223-258 ND(0.11) 4B Black crappie 5 226-241 ND(0.17)
RM 39.0 Largemouth bass 5 278-310 ND(0.13) RM 39.0 Largemouth bass 5 270-360 ND(0.21)
Common carp 5 470-623 4.0 Common carp 5 605-690 11.0
Flathead catfish 5 430-540 0.62
5 Rock bass 4 169-186 ND(0.077) 5 Rock bass 5 143-214 ND(0.15)
RM 19.0 Smallmouth bass 5 315-454 ND(0.12) RM 19.0 Smallmouth bass 5 278-367 ND(0.27)
Smallmouth buffalo 5 451-555 ND(0.12) Smallmouth buffalo 5 406-525 ND(0.22)
Total Fish Filleted 89 Total Fish Filleted 99

Table 6-4 (cont.).
1998 Results[) 1999 Results(b)
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDD(`) Station Species Fish Range(mm) 2,3,7,8-TCDD(°)
1 Redbreast sunfish 5 145-176 ND(0.19) 1 Redbreast sunfish 5 141-177 ND(0.21)
RM 64.5 Rock bass 5 158-179 ND(0.29) RM 64.5 Rock bass 5 164-180 ND(0.37)
Black redhorse 5 340-396 ND(0.18) Black redhorse 5 352-427 ND(0.33)
2 Redbreast sunfish 5 164-177 ND(0.20) 2 Redbreast sunfish 5 167-190 ND(0.37)
RM 59.0 Redbreast sunfish 5 166-193 ND(0.28) RM 59.0 Redbreast sunfish 5 158-178 ND(0.29)
Common carp 5 551-661 1.3 Common carp 5 544-615 ND(0.27)
3 Redbreast sunfish 5 168-193 ND(0.34) 3 Redbreast sunfish 5 169-189 ND(0.36)
RM 52.3 Redbreast sunfish 5 167-200 ND(0.22) RM 52.3 Redbreast sunfish 5 162-176 ND(0.37)
Common carp 5 449-550 ND(0.38) Common carp 5 500-591 0.57
4A Black crappie 5 220-240 ND(0.49) 4A Black crappie 5 220-268 ND(0.18)
RM 41.5 Largemouth bass 5 227-330 ND(0.15) RM 41.5 Black crappie 5 219-244 ND(0.08)
Common carp 5 585-621 1.6 Common carp 5 574-645 0.58
Channel catfish 5 416458 ND(0.28) Channel catfish 5 425-482 0.83
N 4B Black crappie 5 233-252 ND(0.15) 4B Black crappie 5 233-244 ND(0.27)
RM 39.0 Largemouth bass 5 259-330 ND(0.17) RM 39.0 Largemouth bass 5 276-305 ND(0.32)
Common carp 5 563-686 9.1 Common carp 5 621-680 4.7
Flathead catfish 5 414-523 ND(0.20) Flathead catfish 5 372-513 ND(0.46)
5 Rock bass 4 155-190 ND(0.11) 5 Rock bass 5 170-203 ND(0.29)
RM 19.0 Smallmouth bass 5 295-365 ND(0.21) RM 19.0 Smallmouth bass 5 297430 ND(0.19)
Smallmouth buffalo 5 464-537 ND(0.31) Smallmouth buffalo 5 476-565 ND(0.31)
Total Fish Filleted 99 Total Fish Filleted 100

Table 6-4 (cont.).
2000 ResultsNl 2001 ResultsM
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDDt'1 Station Species Fish Range(min) 2,3,7,8-TCDDt`t
1 Redbreast sunfish 5 137-148 ND(0.48) 1 Black redhorse 5 312-407 ND(0.25)
RM 64.5 Rock bass 5 162-186 ND(0.45) RM 64.5
Black redhorse 5 357-396 ND(0.38)
2 Redbreast sunfish 5 169-176 ND(0.31) 2 Common carp 5 456-555 ND(0.27)
RM 59.0 Redbreast sunfish 5 164-181 ND(0.43) RM 59.0
Common carp 5 505-582 ND(0.42)
3 Redbreast sunfish 5 169-181 ND(0.43) 3 Common carp 5 504-615 ND(0.35)
RM 52.3 Redbreast sunfish 5 186-199 ND(0.32) RM 52.3
Common carp 5 514-569 ND(0.53)
4A Black crappie 5 212-241 ND(0.29) 4A Channel catfish 5 476-612 1.2
RM 41.5 Black crappie 5 220-241 ND(0.24) RM 41.5 Common carp 5 528-668 1.3
Common carp 4 559-604 1.1
Channel catfish 5 435-487 ND(0.70)
w
4B Black crappie 5 213-231 ND(0.41) 4B Flathead catfish 5 405-463 ND(0.29)
RM 39.0 Black crappie 5 220-230 ND(0.37) RM 39.0 Common carp 5 654-723 5.6
Common carp 4 593-712 4.4
Flathead catfish 5 407-450 ND(0.42)
5 Rock bass 5 171-198 ND(0.45) 5 Black redhorse 5 437-497 ND(0.26)
RM 19.0 Smallmouth bass 5 209-238 ND(0.31) RM 19.0
Black redhorse 5 427-476 ND(0.35)
Total Fish Filleted 98 Total Fish Filleted 40

Table 6-4 (cont.).
2002 Resultsttlt 2003 Results('[
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDDI`t Station Species Fish Range(mm) 2,3,7,8-TCDDtm
1 Black redhorse 5 372431 ND(0.14) 1 Black redhorse 5 343420 ND(0.20)
RM 64.5 RM 64.5
2 Common carp 5 517-548 ND(0.28) 2 Common carp 5 512-584 ND 0.18
RM 59.0 RM 59.0 (0.
)
3 Common carp 5 575-632 ND(0.22) 3 Common carp 5 545-605 ND(0.31)
RM 52.3 RM 52.3
4A Common carp 5 523-648 2.2 4A Common carp 5 655-717 3.4
RM 41.5 Channel catfish 5 425-475 ND(0.31) RM 41.5 Flathead catfish 5 521-575 ND(DL=0.35)
4B Common carp 5 647-670 6.6 4B Common carp 5 602-745 12.0
RM 39.0 Flathead catfish 5 418-505 ND(0.22) RM 39.0 Flathead catfish 5 511-533 ND(DL=0.20)
RM519.0 Black redhorse 5 430-489 ND(0.14) 5 Black redhorse 5 445-524 ND(DL=0.19)
RM 19.0
Total Fish Filleted 40 Total Fish Filleted 40
(a) Survey conducted by EA Engineering,Science,and Technology. Analyses conducted by ENSECO Laboratories 1990-1994,Quanterra Laboratories 1995-1999,Severn Trent Laboratories in 2000-2003.
(b) Survey conducted in August.
(c) Survey conducted in August and September.
(d) Survey conducted in September.
(e) Units =ppt(parts per trillion)or pgIg(picogram per gram)
ND = Non-detectable at the detection limit in parentheses.

Figure 6-1. TCDD Concentrations in Carp Fillets Collected from
the Pigeon River, 1990-2003 (Stations 2 and 3).
2s
20 — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — —
�— Station 2 - +- Station 3
c
0
. 15 — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — —
w
L
d
� (2
� to
tC
Q
❑ 10 — — — — — — —
— — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — —
U ■
F—
5 — — — — — — — — — — — — — — — — — — — — — — — — — — — —
— — — — — — — — — — -- — — —
'JZ ` a
a
_ c c
0 _ + — — + + -- •---�
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
YEAR `
a) TCDD conentrations at Station 3 were not detected, therefore, the value plotted represents the detection limit for that sample.
b) TCDD concentrations at Station 2 were not detected, therefore, the value plotted represents the detection limit for that sample.
c) TCDD concentrations at Stations 2 and 3 were not detected, therefore, the values plotted represent the detection limits for those samples.

Figure 6-1 (Cont.). TCDD Concentrations in Carp Fillets Collected from
the Pigeon River, 1990-2003 (Stations 4A and 4B).
70
60 - `\- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
i
- - - - - - - - - - -
c
o \ /
40 - - - - -o - - - - - ` - - - - - - - - - - - - - - - - - - - -
- - - - - - - - - - - - - - -
Q
a:30 - - - - - - - - - - - - -\- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
G • /41\ ,R.
U
20 \
\
10 - - - - - - - -� \\- - -r \ - - - - - i --L._- - - - - - - - - - - - - - - - - - ' -
\ _\ / -A
0 • --w-_ • • �_
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
YEAR
—•— Station 4a — . — Station 4b

Figure 6-2. TCDD Concentrations in Catfish Fillets Collected from Stations 4A and
4B in Waterville Lake, 1997-2003.
2.50
2.00
C \ —0—Station 4A --a— Station 4B
0
a
1.50
rn d \
9z 1.00 \ /
\ / b \
0.50
0.00
1997 1998 1999., .. . 2000__.,, 2001 2002 2003
YEAR
a) TCDD concentrations at Stations 4A and 4B were not detected,therefore,the values plotted represent the detection limits for those samples.
b) TCDD concentrations at Station 4B were not detected,therefore,the value plotted represents the detection limit for that sample.

7. REFERENCES
Cordle, F. 1983. Use of epidemiology in the regulation of dioxins in the food supply, in
Accidental Exposure to Dioxins: Human Health Aspects (F. Coulston and F. Pocchiara,
eds.), pp 245-256. Academic Press, New York.
Cunningham, W.R. 1990. Letter to Paul Wiegand. 30 January.
EA Engineering, Science, and Technology, Inc. 1990. Study Plan for the Monitoring of
Dioxin in Fish Tissue. EA Report No. 11370.01, prepared for Champion International
Corporation, Canton, North Carolina.
EA Engineering, Science, and Technology, Inc. 1991. Results of 1990 Dioxin Monitoring in
Fish Tissue. EA Report No. 11370.02, prepared for Champion International Corporation,
Canton, North Carolina.
EA Engineering, Science, and Technology, Inc. 1992. Results of 1991 Dioxin Monitoring in
Fish Tissue. EA Report No. 11370.03, prepared for Champion International Corporation,
Canton, North Carolina.
EA Engineering, Science, and Technology, Inc. 1993a. Results of 1992 Dioxin Monitoring
in Fish Tissue. EA Report No. 11370.05, prepared for Champion International
Corporation, Canton, North Carolina. April.
EA Engineering, Science, and Technology, Inc. 1993b. Results of 1993 Dioxin Monitoring
in Fish Tissue. EA Report No. 11370.06, prepared for Champion International
Corporation, Canton, North Carolina. December.
EA Engineering, Science, and Technology, Inc. 1994. Results of 1994 Dioxin Monitoring
in Fish Tissue. EA Report No. 11370.07, prepared for Champion International
Corporation, Canton, North Carolina. December.
EA Engineering, Science, and Technology, Inc. 1995. Results of 1995 Dioxin Monitoring
in Fish Tissue. EA Report No. 13043.01, prepared for Champion International
Corporation, Canton, North Carolina. December.
EA Engineering, Science, and Technology, Inc. 1996. Results of 1996 Dioxin Monitoring
in Fish Tissue. EA Report No. 13176.01, prepared for Champion International
Corporation, Canton, North Carolina. December.
EA Engineering, Science, and Technology, Inc. 1997. Results of 1997 Dioxin Monitoring
in Fish Tissue. EA Report No. 13353.01, prepared for Champion International
Corporation, Canton, North Carolina. November.
7-1

EA Engineering, Science, and Technology, Inc. 1998. Results of 1998 Dioxin Monitoring
in Fish Tissue. EA Report No. 13478.01, prepared for Champion International
Corporation, Canton, North Carolina. December.
EA Engineering, Science, and Technology, Inc. 2000. Results of 1999 Dioxin Monitoring
in Fish Tissue. EA Report No. 13478.01, prepared for Champion International
Corporation, Canton, North Carolina. January.
EA Engineering, Science, and Technology, Inc. 2001a. Study Plan for Pigeon River Dioxin
Monitoring in Fish Tissue. Prepared for Blue Ridge Paper Products, Canton, North
Carolina. November.
EA Engineering, Science, and Technology, Inc. 2001b. Results of 2000 Dioxin Monitoring
in Fish Tissue. EA Report No. 13745.01, prepared for Blue Ridge Paper Products,
Canton, North Carolina. January.
EA Engineering, Science, and Technology, Inc. 2001c. Results of 2001 Dioxin Monitoring
in Fish Tissue. EA Report No. 13900.01, prepared for Blue Ridge Paper Products,
Canton, North Carolina. December.
EA Engineering, Science, and Technology, Inc. 2003. Results of 2002 Dioxin Monitoring in
Fish Tissue. EA Report No. 13900.02, prepared for Blue Ridge Paper Products, Canton,
North Carolina. January.
Food and Drug Administration. 1981. FDA advises Great Lake States to monitor
dioxin-contaminated fish. FDA Talk Paper dated 28 August, in Food Drug Cosmetic Law
Reports, paragraph 41, 321. Commerce Clearing House, Inc. 8 September.
Food and Drug Administration. 1983. Statement by Stanford A. Miller, Director, Bureau of
Foods, FDA before the Subcommittee on Natural Resources, Agriculture Research and
Environment, U.S. House of Representatives. 30 June.
North Carolina Department of Environment, Health, and Natural Resources. 1991. Fish
Tissue Dioxin Levels in North Carolina: 1990 Update. Division of Environmental
Management, Water Quality Section.
U.S. Environmental Protection Agency (U.S. EPA). 1994. Analytical Procedures and
Quality Assurance for Multimedia Analysis of Polychlorinated Dibenzo-para-dioxins and
Polychlorinated Dibenzof trans by High-Resolution Gas Chromatography/High-Resolution
Mass Spectrometry (Method 8290).
U.S. Environmental Protection Agency (U.S. EPA). 1989. Interim Procedures for
Estimating Risk Associated with Exposures to Mixtures of Chlorinated Dibenzo-p-Dioxins
and Dibenzofurans (CDDs and CDFs) and 1989 Update Report No. EPA/625/3-89/016,
U.S. EPA, Risk Assessment Forum, Washington, D.C.
7-2

Versar, Inc. 1984. Sampling Guidance Manual for the National Dioxin Study. U.S.
Environmental Protection Agency. EPA Contract 68-01-6160. Work Order Number 8.7.
Office of Water Regulations and Standards, Monitoring and Data Support Division, I
Washington, D.C. Final draft. July.
World Health Organization(WHO). 1997. Exposure and Human Health Reassessment of
2,3,7,8-Tetrachlorodibenzo-p-dioxin(TCDD) and Related Compounds: Part II Health
Assessment of 2,3,7,8-Tetrachlorodibenzo-p-dioxin(TCDD) and Related Compounds.
7-3

APPENDIX A
CHAIN OF CUSTODY FORMS

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,;
_: ` . � _
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n
c
Chain of STL
Custody Record Severn Trent Laboratories, Inc.
STL4124 (0901)
Client n( 1 {l�� Project Manager Dale p Chain of Custody Number
LA e
129067
Address Telephone Number Area C0deJ7F Number Lab Number j B Mu n S� . ear 6 6-7y Page of
City State zip Code Sire Contact Lab Contact Analysis(Aflach list it
6/.
-,n -E-J;•� Ake' e�n h i e mares ace is needed
Project Name and Localion(Sfa(eJ CarnerANaybi4 Number uer - u
on i� Special instructions/
Contra Purchase Order/Ouole No. _. 0
Matrix Containers& „ Conditions of Receipt
Preservatives t o
Sample I.D.No.and Description d8 x x k �+
(Containers for each sample may be combined an one line) Date Time the O R o m f1 0
Low fifak 2N 5 P. F)1e-is 8z3 r:O""
So
VA
0
} LC (z µ $ 2$ 0 0830
RE EP ED i ,GOOD' NOD'1014
r L V
E a3 No
PoS;ible Hazard identification Sample Disposal r —1-
,R.r(1/ ( fee may(Iqlassessetl ifs are retarnee
Non-Hazartl ❑ Flammable El Skin lailanl ❑ Poison B ❑ Unlrnown El Return To Client ❑Disposal By Lab ❑Archive For_Months I awLwalam= _-- -
Turn Around Time Required QC Requirements(Specify) .. ..
❑24 Hours ❑4B Hours ❑ 7 Days ❑ 14 Days ❑ 21 Days ❑ Other
L Relinquished By Date Time i.Bgc Dare � Time1
-.�-- i3 Z-P O3 '2:�� ��</J v�t//i�lq /ct--,
2.Retinquis ad By Dale Timo 2.Received y Dale Time
dif1 F0 F) '� ro l Z
3.Relinquished By Date Time 3.Receiv y ate Timms
Comments
A
rn
D1STRlBUTION., WHITE-Returned to Client with Report., CANARY-Slays with the Sample; PINK-Field Copy
A
N '

n
N ' SQL
Chain of
Custody Record Severn Trent Laboratories, Inc.
STL-4124 (09011
Client Project Manager Date Chain of Custody Number
R, 3 G�e SN e� sz1o3 129068
Address 5 Telephone Numbe (Area Code/)/F x Number Lab Number 6I%- 6 V y Page of i—
City I State Zip Code Site Contact f, Lab Contact Analysis(Agach list if
1 atn-t-ci• C 1 2 I Ca Ik e I tu,ir mores ace is needed
Project Name and Location(State) CarderlWayblll Number �'
N
Pre R;dr� ris a,e ' Sh
> y Speciallnstructions/
Con ac'Purchase Order/Ouole No. Containers& f b Conditions of Receipt
Matrix Preservatives r; o �?
Sample I.D.No.and Description .y x a -.1Z
(Containers for each sample maybe combined on one line) Date Time F p b g ° g A�
�X i� x i Q 0C
Lac _ v. -• tr/ >�r � 9zb 0 0� - Lr-�la'oe t.c 5 5 r(, .
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0
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W
N _
8 - ___-
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u IDEA cn
Possible Hazard Idenlilcation Sample Disposal
(A lee maybe assessed ff samples are retained
Non-Hazard ❑Flammable ❑ Skin Irritant ❑Poison B ❑ Unknown ❑ Relum To Client ❑ Disposal By Lab ❑Archive For_Months longer than i month)
Turn Around Time Required OC Requirements(Specify)
❑ 24 Hours ❑48 Hours ❑ 7 Days ❑ 14 Days ❑21 Days ❑ Can
1. elinquished8 q Dale Time I.Received ` Oala Time
2 elf uished By /�, Da(e� Time 2.Received By Date Time
me!
3.RelitiatYshod By Data Time 3.Received Ty VDale Time
Comments
N
O'
DISTRIBUTION: WHITE-Returned to Client will,Report: CANARY-Stays will)the Sample;PINK-Field Copy
in
N

APPENDIX B
SEVERN TRENT LABORATORY-SACRAMENTO
ANALYTICAL REPORT

STL
September 30,2003
STL SACRAMENTO PROJECT NUMBER: G3I030256
PO/CONTRACT: 266777
Melanie Samuels Gardner
Blue Ridge Paper Products Inc
175 Main Street
P.O. Box 4000
Canton,NC 28716
Dear Ms. Samuels Gardner,
This report contains the analytical results for the samples received under chain of custody by
STL Sacramento on September 3, 2003. These samples are associated with your Pigeon
River Tissue project.
The test results in this report meet all NELAC requirements for parameters that accreditation
is required or available. Any exceptions to NELAC requirements are noted in the case
narrative. The case narrative is an integral part of this report.
If you have any questions,please feel free to call me at(916) 374-4402.
Sincerely,
Jill KeIlmann
Project Manager
Severn Trent Laboratories, Inc.
STL Sacramento•880 Riverside Parkway,West Sacramento,CA 95605
A purl of Sewn Trent plc Tel [phone] Fax [phone]•www.sV-inc.com -

TABLE OF CONTENTS
STL SACRAMENTO PROJECT NUMBER G31030256
Case Narrative
STL Sacramento Quality Assurance Program
Sample Description Information
Chain of Custody Documentation
BIOLOGIC, 8290,Percent Lipids
Samples: 1 through 9
Sample Data Sheets
BIOLOGIC, 8290, Dioxins/Furans,
Samples: 1 through 9
Sample Data Sheets
Method Blank Report
Laboratory QC Reports

CASE NARRATIVE
STL SACRAMENTO PROJECT NUMBER G3I030256
There were no anomalies associated with this project-
G-.J30256 STL Sacramento 916-373-5600 1 of 645

%rA ACCOR
�o n F
STL Sacramento Certifications/Accreditations
Alaska UST-055 Oregon CA 200005
I :n +: 4 ' ! 'fa fCE 5,': J' e s�. r{y FN
AZofi1:6a& );s as Pens luama. :ati.s .:* „tr&Q12.72. „rx,':."
Arkansas NA South Carolina 87014001
ICalrfosnt '� �x3r ? 0fi1:79CA ��i uteicas +des TX270=2003A`;{br,.'
rC'oYorfidO Fes.r fish N 4 A ,.r bfww Utah M Q
UANl_
Connecticut PH-0691 Virginia 00178
Georgia 960 West Virginia 9930C,334
,s_ ;Flawau: a �Q�,:t-rv-.,< N<t" ` rk ;r'' W..tsconsln <V* '99820"4880 4 "
3,
Louisiana' 01944 NFESC NA
`^ +. {
New Jerse ' CA005 USDA Forei n Plant 37-82605
° "fafew,+ orl� ,". n"aid .i1656 r ° *i t�J Day,.:oret h ot4n>. :kzri�i 466 3 c ._.
'NELAP accredited. A more detailed parameter list is available upon request.
QC Parameter Definitions
QC Batch:The QC batch consists of a set of up to 20 field samples that behave similarly(i.e., same
matrix) and are processed using the same procedures, reagents, and standards at the same time.
Method Blank: An analytical control consisting of all reagents, which may include internal standards
and surrogates, andJs carried through the entire analytical procedure. The method blank is used to
define the level of laboratory background contamination.
Laboratory Control Sample and Laboratory Control Sample Duplicate(LCS/LCSD): An aliquot
of blank matrix spiked with known amounts of representative target analytes. The LCS (and LCSD as
required) is carried through the entire analytical process and is used to monitor the accuracy of the
analytical process independent of potential matrix effects. If an LCSD is performed, it may also used
to evaluate the precision of the process.
Duplicate Sample(IJU): Different aliquots of the same sample are analyzed to evaluate the
precision of an analysis.
Surrogates: Organic compounds not expected to be detected in field samples, which behave
similarly to target analytes. These are added to every sample within a batch at a known
concentration to determine the efficiency of the sample preparation and analytical process.
Matrix Spike and Matrix Spike Duplicate(MS/MSD): An MS is an aliquot of a matrix fortified with
known quantities of specific compounds and subjected to an entire analytical procedure in order to
indicate the appropriateness of the method for a particular matrix. The percent recovery for the
respective compound(s) is then calculated. The MSD is a second aliquot of the same matrix as the
matrix spike, also spiked, in order to determine the precision of the method.
Isotope Dilution: For isotope dilution methods, isotopically labeled analogs (internal standards) of
the native target analytes are spiked into the sample at time of extraction. These internal standards
are used for quantitation, and monitor and correct for matrix effects. Since matrix effects on method
performance can be judged by the recovery of these analogs, there is little added benefit of
performing MS/MSD for these methods. MS/MSD are only performed for client or QAPP
requirements.
Control Limits:The reported control limits are either based on laboratory historical data, method
requirements, or project data quality objectives. The control limits represent the estimated
uncertainty of the test results.
Revised 919103 PAS
G.,,o30256 STL Sacramento 916-373-5600 2 of 645

Sample Summary
G31030256
WO# Sample# Client Sample ID Sampling Date Received Date
FXHV 1 1 LOC 1 BLACK RH 5R FILLETS 8/27/2003 02:30 PM 9/3/2003
09:15 AM
FXHV? 2 LOC 2 CARP 5R FILLETS 8/26/2003 01:00 PM 9/3/2003
09:15 AM
FXHWC 3 LOC 3 CARP 5R FILLETS 8/26/2003 10:50 AM 9/3/2003
09:15 AM
FXHWE 4 LOC 4A CARP 5R FILLETS 8/26/2003 05:00 PM 9/3/2003
09:15 AM
FXHWJ 5 LOC 4A FH CATFISH 5R FILLETS 8/27/2003 10:30 AM 9/3/2003
09:15 AM .
FXHWM 6 LOC 4B CARP 5R FILLETS 8/26/2003 06:30 PM 9/3/2003
09:15 AM
FXHWQ 7 LOC 411 FH CATFISH SR FILLETS 8/27/2003 09:28 AM 9/3/2003
09:15 AM
FXHWX 8 LOC 5 BLACK RH 5R FILLETS 8/28/2003 08:30 AM 9/3/2003
09:15 AM
FXHW4 9 LOC 4A CARP WHOLE FILLETS 8/26/2003 05:00 PM 9/3/2003
09:15 AM
Notes(s):
• The analytical results of the samples listed above are presented on the following pages.
- All calculations are performed before rounding to avoid round-off errors in calculated results.
- Results noted as"ND"were not detected at or above the slated limit.
- This report must not be reproduced,except in full,without the written approval of the laboratory.
- Results for the following parameters are never reported on a dry weight basis:color,corrosivity,density,flashpoinl,ignitability,
layers,odor,paint filter test,pH,porosity,pressure,reactivity,redox potential,specific gravity,spot tests,solids,solubility,
temperature,viscosity,and weight
C_.�30256 STL Sacramento 916-373-5600 3 of 645

MINIMUM L3
STL Sacramento
CLIENT 1 I. /� G Q PM _ LOG I
LOT (QUANTIMS ID) �`/^-� O� �(Z OUOTEf :2-1 2 TION �©
p Initials Date
DATE RECEIVED `� 3 3 TIME RECEIVED
DELIVERED BY Z/FEDEX ❑ CA OVERNIGHT .:' ❑ CLIENT.
El AIRBORNE ❑ GOLDENSTATE ❑ OHL
❑ UPS ❑ BAX.GLOBAL : ❑ GO-GETTERS
❑ STL COURIER• ❑ COURIERS ON DEMAND:
❑OTHER '
CUSTODY SEAL STATUS giNTACT ❑ BROKEN N/A
CUSTODY SEAL ®(S)
SHIPPPING CONTAIN ER(S)�TL ❑ CLIENT ❑ N/A
TEMPERTURE RECORD (IN °C) IR 1;.A 2 ❑ ^❑ OTHER
CDC #(S)
TEMPERATURE BLANK
SAMPLE TEMPERATURE
COLLECTOR'S NAME: ❑Verified from CDC Not On CDC
pH MEASURED ❑YES ❑ ANOMALY eo'N/A .
LABELEDBY................................................. ........................................
LABELSCHECKED BY...........................................................................
SHORT HOLD TEST NOTIFICATION SAMPLE RECEIVING
WETCHEM N/A
" VOA- Encores Y N/A
METALS NOTIFIED OF FILTER/PRESERVE VIA VERBAL &EMAIL;3/N/A
] COMPLETE SHIPMENT RECEIVED IN GOOD CONDITION WITH ❑ N/A
APPROPRIATE TEMPERATURES, CONTAINERS, PRESERVATIVES
❑ Clouseau ❑TEMPERATURE EXCEEDED (2 °-6-C) ❑N/A
WET ICE [:1 BLUE ICE ❑ GEL PACK '
[] PM NOTIFIED ❑ NO COOLING AGENTS USED
Votes:
L_. 302E§AVE NO-SPACES BLANK. USE WA-IF NOT APPLiCAI§L-Z.9 MftMNE)SIXB LOON/A-.ENTRIES.. ..., . OA185 61DDN.EK..,:,-.�,, ;•, , 6:0f 645

BIOLOGIC, 8290, DlM'nS1 Fh-ranS
U.,J30256 STL Sacramento 916-373-5600 7 of 645

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BLUE RIDGE PAPER PRODUCTS 3NC
Client Sample ID: LOC 1 BLACK RH SR FILLETS
Trace Level Organic Compounds
Lot-Sample #_ . _: G3I030256-001 Work Order #._ .: FXHVIIAA Matrix- --- - --- -- BIOLOGIC
Date Sampled. ._: 08/27/03 Date Received._ : 09/03/03
Prep Date. .. .. .: 09/09/03 Analysis Date_. : 09/13/03 -
Prep Batch #. ..: 3252577 -
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 2.2 SW896 8290
G-J30256 STL Sacramento 916-373-5600 8 of 645

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 1 BLACK PH SR FILLETS
Trace Level Organic Compounds
Lot-Sample #. . .: G3I030256-001 Work Order #---: FXHVI3.AC Matrix- - - --- --- BIOLOGIC
Date Sampled...: 08/27/03 Date Received. .: 09/03/03
Prep Date. .-- ..: 09/09/03 Analysis Date. . : 09/13/03
Prep Batch #... : 3252573
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND 0.20 pg/g SW846 8290
Total TCDD ND 0.20 pg/g SW846 8290
1,2,3,7,8-PeCDD ND 0.48 pg/g SW846 8290
Total PeCDD ND 0.48 pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 0.34 pg/g SW846 8290
1,2,3,6,7,8-HxCDD ND 0.28 pg/g SW846 8290
1,2,3,7,8,9-HxCDD ND 0.29 pg/g SW846 8290
Total HxCDD ND 0-34 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD ND 0.48 pg/g SW846 8290
Total HeCDD ND 0.46
OCDD P9/g SW846 8290
ND 1.6 pg/g SW846 8290
2,3,7,8-TCDF ND 0.15 pg/g SW846 8290
Total TCDF ND 1.2 pg/g SW646 8290
1,2,3,7,8-PeCDF ND 0.23 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.23 pg/g SW846 8290
Total PeCDF ND 0.23 pg/g SW846 8290
1,2,3,4,7,8-HpCDF ND 0.22 pg/g SW846 8290
1,2,3,6,7,8-HxCDF ND 0.19 pg/g SW846 8290
2,3,4,6,7,8-HpCDF ND 0.22 pg/g SW846 8290
1,2,3,7,8,9-HXCDP ND 0.25 pg/g SW846 8290
Total HxCDF ND 0.30 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 0.43 pg/g SW846 8290
1,2,3,4,7,8,9-HpCDF ND 0.51 pg/g SW846 8290
Total HpCDF ND 0.51
P4/g SW846 8290
OCDF ND 0.61 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 70 (40 - 135)
13C-1,2,3,7,8-PeCDD 70 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 62 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 68 (40 - 135)
13C-OCDD 57 (40 - 135)
13C-2,3,7,8-TCDF 65 (40 - 135)
13C-1,2,3,7,8-PeCDF 73 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 69 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 64 (40 - 135)
NOTE M :
The-Totals-repotting limit for the TCDF homologue series has been raised due W the presetoe of a diphe„eyl ether(DPE). No flagging is
required.
Gj.030256 STL Sacramento 916-373-5600 9 of 645

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BLUE RIDGE PAPER PRODUCTS INC
client Sample ID: LOC 2 CARP SR FILLETS
Trace Level Organic Compounds
Lot-Sample #_ __: G3I030256-002 Work Order #.. .: FXHV72AA Matrix- -- - - - --- BIOLOGIC
Date Sampled___ : 08/26/03 Date Received__ : 09/03/03
Prep Date..... .: 09/09/03 Analysis Date. .: 09/13/03
Prep Batch #.. . : 3252577
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 3.2 t SW846 8290
C_30256 STL Sacramento 916-373-5600 10 of 645

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 2 CARP 5R FILLETS
Trace Level Organic Compounds
Lot-Sample #. ..: G31030256-002 Work Order #.. .: PXHV71AC Matrix- - - --- - -- : BIOLOGIC
Date Sampled.. . : 08/26/03 Date Received..: 09/03/03
Prep Date. . . .. .: 09/09/03 Analysis Date.. : 09/13/03
Prep Batch #.. .: 3252573
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND
Total TCDD 0.18 pg/g SW846 8290
ND 0.18 pg/g SW846 6290
1,2,3,7,8-PeCDD NO 0.48 pg/g SW846 9290
Total PeCDD - NO 0.48 pg/g S9846 8290
112,3,4,7,8-1xCDD ND 0.40 pg/g SW846 8290
1,2,3,6,7,8-HxCDD ND 0.59 pg/g SW846 8290
1,2,3,7,8,9-HxCDD ND 0.35 pg/g SW846 8290
Total HxCDD ND 0.59 pg/g SW846 8290
112,3,4,6,7,8-HpCDD ND 2.1 pg/g SW846 8290
Total HpCDD ND
OCDD 2.1 P9/g SW846 8290
11 pg/g SW846 8290
2,3, 7,8-TCDF - ND 0.39 pg/g SW846 8290
Total TCDF ND 0.39 pg/g SW846 8290
1,2,3,7,8-PeCDF ND 0.26 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.26 pg/g SW846 8290
Total PeCDF ND 0.26 pg/g SW846 8290
1,2,3,4,7,8-HxCDF ND 0.29 pg/g SW846 8290
1,2,3,6,7,8-HXCDF ND 0.25 pg/g SW846 8290
2,3,4,6,7,8-HxCDF ND 0.30 pg/g SW846 8290
1,2,3,7,8,9-HxCDF ND 0.34 pg/g SW846 8290
Total HxCDF NO 0.47 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 0.37 'pg/g 'SW846 8290
1,2,3,4,7,8,9-HpCDF ND 0.43 pg/g SW846 8290
Total HpCDF ND 0.43
OCDF NDPg/4 SW846 8290
0.67 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 79 (40 - 135)
13C-1,2,3,7,8-PeCDD 81 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 72 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 71 (40 - 135)
13C-OCDD 61 (40 - 135)
13C-2,3,7, 8-TCDF 74 (40 - 135)
13C-1,2,3,7,8-PeCDF 75 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 72 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 71 (40 - 135)
uo,030256 STL Sacramento 916-373-5600 11 of 645

13LUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 3 CARP 5R FILLETS
Trace Level Organic Compounds
Lot-Sample #...: G3I030256-003 Work Order #. .. : FXHWCIAA Matrix--- ---- - - BIOLOGIC
Date Sampled. . .: 08/26/03 Date Received. .: 09/03/03
Prep Date. . . . .. : 09/09/03 Analysis Date.. : 09/13/03
Prep Batch #. . .: 3252577
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 6.6 SW846 8290
W030256 STL Sacramento 916-373-5600 12 of 645

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BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 4A CARP SR FILLETS
Trace Level Organic Compounds
Lot-Sample #... : G3I0302SG-004 Work Order #. . .: FXHWEIAA Matrix. . .... . ..: BIOLOGIC
Date Sampled. . .: 08/26/03 Date Received.. : 09/03/03
Prep Date... ... : 09/09/03 Analysis Date. .: 09/13/03
Prep Batch #. . . : 3252577
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 16 SW846 8290
G_j30256 STL Sacramento 916-373-5600 14 of 645

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 4A CARP 5R FILLETS
Trace Level Organic Compounds
Lot-Sample #. .- : G3I030256-004 Work Order #- . -: FXHWElAC Matrix- -- - -- - --: BIOLOGIC
Date Sampled. . .: 08/26/03 Date Received. .: 09/03/03 '
Prep Date- - . . . . : 09/09/03 Analysis Date..: 09/13/03
Prep Batch #. . . : 3252573
Dilution Factor: 1
DETECTION
PARAMETER RESULT 2,3,7,6-TCDD LIMIT UNITS METHOD
3_4
T pg/g SW846 8290
Total TCDO 3.4
Pg/4 SW846 8290
1,2,3,7,8-PeCDD 2-5 pg/g SW846 8290
Total PeCDD 2-5 Pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 1.7 pg/g SW846 8290
1,2,3,6,7,8-HxCDD 7.7 Pg/g SW846 8290
1,2,3,7,8,9-HxCDD ND 1.4 pg/g SW846 8290
Total HxCDD 7.7 Pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD 24 pg/g SW846 8290
Total HxCDD 34
OCDD Pg/g SW846 8290
92
pg/g SW846 8290
2,3,7,6-TCDF
3-4 CON pg/g SW846 8290
Total TCDF 3-4 pg/g SW846 8290
1,2,3,7,8-PeCDF ND 1.9 pg/g SW846 8290
2,3,4,7,8-PeCDF 2.6 T pg/g SW846 6290
Total PeCDF 2-6 pg/g SW846 8290
1,2,3,4,7,8-HxCDF ND 1.4 pg/g SW846 8290
1,2,3,6,7,8-HxCDF NO 1.2 _ pg/g SW846 6290
2,3,4,6,7,8-HXCDF ND 0.71 pg/g SW846 8290
1,2,3,7,8,9-HpCDF ND 0.30 - Pg/g SW846 8290
Total HxCDF NO 2.3 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 2.3 pg/g SW846 8290
1,2,3,4,7,8,9-HpCDF NO 0.69 pg/g SW846 8290
Total HpCDF ND
OCDF 2'3 Pg/g SW846 6290
ND 0.50 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 74 (40 - 135)
13C-1,2,3,7,8-PeCDD 76 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 68 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 70 (40 - 135)
13C-OCDD 65 (40 - 135)
13C-2,3,7,E-TCDF 72 (40 - 135)
13C-1,2,3,7,8-PeCDF 73 (40 - 135)
13C-1,2,3,4,7, 8-HxCDF 69 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 76 (40 - 135)
NOTE(S) :
CON CoMrrnation amlysis.
J Fmimattd result.Result is less Than We reporting limit.
C.—,-30256 STL Sacramento 916-373-5600 15 of 645

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 4A PH CATFISH 5R FILLETS
Trace Level Organic Compounds
Lot-Sample #. . .: G3I030256-005 Work Order #...: FXHWJIAA Matrix. . .... .. . : BIOLOGIC
Date Sampled. . . : 08/27/03 Date Received.. : 09/03/03
Prep Date.. . . .. : 09/09/03 Analysis Date. .: 09/13/03
Prep Batch #. . .: 3252577
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 2.5 g SW846 8290
fi, i30256 STL Sacramento 916-373-5600 16 of 645

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 4A FH CATFISH SR FILLETS
Trace Level Organic Compounds
Lot-Sample #--- : G3I030256-005 Work Order #.. . : FXHWJIAC Matrix. . ... . .. . : BIOLOGIC
Date Sampled. .. : 08/27/03 Date Received.. : 09/03/03
Prep Date. . . . .. : 09/09/03 Analysis Date. . : 09/13/03
Prep Batch #... . 3252573
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND 0.35 pg/g SW846 8290
Total TCDD ND 0.35 pg/g SW846 8290
1,2,3,7,8-PeCDD ND 0.83 pg/g SW846 8290
Total PeCDD ND 0.83 Pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 0.61 pg/g SW846 8290
1,2, 3,6,7,8-HxCDD ND 0.50 pg/g SW846 8290
1,2,3,7,8,9-HXCDD ND 0.52 pg/g SW846 8290
Total HxCDD ND 0.61 pg/g SW846 8290
112,3,4, 6,7,8-HpCDD ND 1.4 Pg/g SW846 8290
Total HpCDD ND
OCDD 1'4 Pg/g SW846 8290
6.4 T pg/g SW846 8290
2,3, 7,8-TCDF ND 0.98 pg/g SW846 8290
Total TCDF ND 0.98 pg/g SW846 8290
1,2,3,7,8-PeCDF ND 0.48 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.48 pg/g SW846 8290
Total PeCDF ND 0.48 pg/g SW846 8290
1,2,3,4,7,8-HxCDF ND 0.43 pg/g SW846 8290
1,2,3,6,7.,8-HXCDF ND 0.36 pg/g SW846 8290 t
2,3,4,6,7,8-HxCDF ND 0.44 pg/g SW846 8290
1,2,3,7,8,9-HxCDF ND 0.50 pg/g SW846 8290
Total HxCDF ND 0.74 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 0.67 pg/g SW846 8290
1,2,3,4,7,8, 9-HeCDF ND 0.79
Total HpCDF ND Pg/g SW846 8290
0.79 pg/g SW846 8290
OCDF ND
1.0 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 54 (40 - 135)
13C-1,2,3,7,8-PeCDD 52 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 44 (40 - 135)
13C-1,2,3,4,6,7, 8-HpCDD 48 (40 - 135)
13C-OCDD 41 (40 - 135)
13C-2,3, 7,8-TCDF 50 (40 - 135)
13C-1,2,3,7,8-PeCDF 51 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 45 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 48 (40 - 135)
NOTE(S) .
1 Estimated result.Result is less thin the reporting Limit.
G_._j30256 STL Sacramento 916-373-5600 17 of 645

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BIDE RIDGE PAPER PRODUCTS INC
Client Sample ID:, LOC 4A CARP WHOLE FILLETS
Trace Level Organic Compounds
Lot-Sample #.. . : G3I030256-009 Work Order #...: FXHW41AC Matrix. . ... . .. . BIOLOGIC
Date Sampled. . .: 08/26/03 Date Received.. : 09/03/03
Prep Date... ...: 09/09/03 Analysis Date. . : 09/13/03
Prep Batch #.. . : 3252573
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS. METHOD
2,3,7,8-TCDD 1.9 pg/g SW846 8290
Total TCDD 1 g
pq/q SW846 8290
1,2,3,7,8-PeCDD ND 1.7 pg/g SW846 8290
Total PeCDD ND 1.7 pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 0.34 pg/g SW846 8290
1,2,3,6,7,8-HxCDD 5_O pq/g SW846 8290
1,2,3,7,8,9-HxCDD ND 0.91 pg/g SW846 8290
Total HxCDD 8.0
pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD 21 pg/g SW846 8290
Total HpCDD 28
OCDD Pq/q SW846 8290
81 pg/g SW846 8290
2,3,7,8-TCDF 1.5 CON pg/g SW846 8290
Total TCDF 1.5
P4/q SW846 8290
1,2,3,7,8-PeCDF ND 0.69 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 1.7 pg/g SW846 6290
Total PeCDF ND 1.7 pg/g SW846 8290
1,2,3,4,7,8-HXCDF ND 0.82 pg/g SW846 8290
1,2,3,6,7,8-HxCDF ND 0.73 pg/g SW846 8290
2,3,4,6,7,8-HxCDF NO 0.26 pg/g SW846 8290
1,2,3,7,8,9-HXCDF ND 0.29 pg/g SW846 8290
Total HxCDF ND 1.8 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 1.4 pg/g SW846 8290
1,2,3,4,7,8,9-HpCDF ND 0.71 pg/g SW846 8290
Total HpCDF ND
1.4 pg/g SW846 8290
OCDF ND 0.51 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,718-TCDD 71 (40 - 135)
13C-1,2,3,7,8-PeCDD 79 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 74 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 70 (40 - 135)
13C-OCDD 64 (40 - 135)
13C-2,3,7,8-TCDF 69 (40 - 135)
13C-1,2,3,7,8-PeCDF 72 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 75 (40 - 135)
13C-1,2, 3,4, 6,7,8-HpCDF 68 (40 - 135)
NOTE(S) -
CON Confirmation amlysls.
G.J30256 STL Sacramento 916-373-5600 25 of 645

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 4B CARP 5R FILLETS
Trace Level Organic Compounds
Lot-Sample #.. .: G3I030256-006 Work Order #.. . : FXHWMIAA Matrix.. . ...... : BIOLOGIC
Date Sampled. . .: 08/26/03 Date Received. .: 09/03/03
Prep Date. ... . . : 09/09/03 Analysis Date. .: 09/13/03
Prep Batch #. . . : 3252577
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS _ METHOD
Percent Lipids 22 $ SW846 8290 •
C-J30256 STL Sacramento 916-373-5600 18 of 645

Ali
ILL,

BLUE RIDGE PAPER PRODHCTS INC '
Client Sample ID: LOC 413 CARP SR FILLETS ...
Trace Level Organic Compounds
Lot-Sample #. ._: G3I030256-006 Work Order #. . .: FXHWMIAC Matrix. ..- . .. .. : BIOLOGIC
Date Sampled.-. : 08/26/03 Date Received.. : 09/03/03
Prep Date. . .... : 09/09/03 Analysis Date..: 09/13/03
Prep Hatch #. ..: 3252573
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD 12
Total TCDD Pg/g SW846 8290
12 pg/g SW846 8290
1,2,3,7,8-PeCDD 3.7 J pg/g SW046 8290
Total PeCDD 3.7
pg/4 SW846 8290
1,2,3,4,7,8-HxCDD 3.1 J pg/g SW846 8290
1,2,3,6,7,8-HxCDD 11 pg/g SW846 '8290
1, 2,3,7,8,9-HxCDD ND 1.8
Total HxCDD Pg/g SW846 290
14 6
pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD 30
pg/g SW846 8290 '•
Total HxCDD 35 pg/g SW846 8290
OCDD 76
pg/g SW846 8290
2,3,7,8-TCDF
- 3_5 CON pg/g SW846 8290
Total TCDF 3.5 CON
Pg/g SW846 8290
1,2,3,7,E-PeCDF ND 1.4
pg/g SW846 8290
2,3,4,7,8-PeCDF .. 4.4 J pg/g SW846 8290
Total PeCDF 7.2
pg/g SW846 8290
1,2,3,4,7,8-HXCDF ND 1.6 pg/g SW846 8290
1,2,3,6,7,8-HXCDF ND 1.8 pg/g SW846 8290
2,3,4,6,7,8-HxCDF ND 0.93 pg/g SW846 8290
1,2,3,7;8,9-HxCDF ND 0.30 pg/g SW846 8290
Total HxCDF ND 5.5 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 2.4
pg/g SW846 8290
1,2,3,4,7,8,9-HpCDF ND 0.76 pg/g SW846 8290
Total* HpCDF ND 2.4 pg/g SW846 8290
OCDF ND 0.30 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 81 (40 - 135)
13C-1,2,3,7,8-PeCDD 81 (40 - 135)
13C-1,2,3,6, 7,8-HxCDD 63 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 71 (40 - 135)
13C-OCDD 69 (40 - 135)
13C-2,3,7,8-TCDF 74 (40 - 135)
13C-1,2,3,7,8-PeCDF 80 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 65 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 67 (40 - 135)
NOTE(S) -
J Esumaten result.Result is less than the reporting limit.
CON Continuation analysis.
The'TOWs'reporting limit for the Hera Fuan homologue suiea has been raised due to the preseae of a diphenyl ether(DPE). No
flagging is necespry.
G_.330256 STL Sacramento 916-373-5600 19 of 645

BLUE RIDGE PAPER PRODUCTS MC
Client Sample ID: LOC 4B PH CATFISH 5R FILLETS '
Trace Level Organic Compounds
Lot-Sample #. ..: G31030256-007 Work Order #. ..: FXHWQIAA Matrix. . . . .. ...: BIOLOGIC
Date Sampled. . . : 08/27/03 Date Received. . : 09/03/03
Prep Date. . . . .. : 09/09/03 Analysis Date..: 09/13/03
Prep Batch #. -. : 3252577
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD _
Percent Lipids 3.4 $ SW846 8290
l,_.J30256 STL Sacramento 916-373-5600 20 of 645

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID. LOC 4B FH CATFISH SR FILLETS r
Trace Level Organic Compounds
Lot-Sample #.. . : G31030256-007 Work Order #...: FXHWQIAC Matrix. . . .. . . ..: BIOLOGIC
Date Sampled.. . : 08/27/03 Date Received.. : 09/03/03
Prep Date.. . . .. : 09/09/03 Analysis Date. .: 09/13/03
Prep Batch #- ..: 3252573
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND 0.20 pg/g SW846 8290
Total TCDD ND 0.20 pg/g SW846 8290
1,2,3,7,8-PeCDD ND 0.50 pg/g SW846 8290
Total PeCDD ND 0.50 pg/g SW846 8290
1,2,3,4, 7,8-HXCDD ND 0.37 pg/g SW846 8290
1,2,3,6,7,8-HxCDD ND 0.38 pg/g SW846 8290
1,2,3,7,8,9-HxCDD ND 0.32 pg/g SW846 8290
Total HxCDD ND 0.38 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD ND 0.54 pg/g SW846 8290
Total HpCDD ND
OCDD 0.54 P5/g SW846. 8290
ND 0.96 pg/g SW846 8290
2,3, 7,8-TCDF ND
Total TCDF 0. 6 pg/g SW846 8290
ND 0.46 pg/g SW846 8290
1,2,3,7,8-PeCDF ND 0.26 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.26 pg/g SW846 8290
Total PeCDF ND 0.26 pg/g SW846 8290
1,2,3,4,7,8-HXCDF ND 0.26 pg/g SW846 8290 ,
1,2,3,6,7,8-HXCDF ND 0-22 pq/g SW846 8290
2,3,4,6,7,8-HpCDF ND 0.27 pg/g SW846 8290
1,2,3,7,8,9-HxCDF ND 0.31 pg/g SW846 8290
Total HxCDF ND 0.31 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 0.50 pg/g SW846 9290
1,2,3,4,7,8,9-HpCDF ND 0.59 pg/g SW846 8290
Total HpCDF ND 0.59
OCDF ND P9/g SW846 8290
0.54 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3, 7,8-TCDD 71 (40 - 135j
13C-1,2,3,7,8-PeCDD 75 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 66 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 67 (40 - 135)
13C-OCDD 56 (40 - 135)
13C-2,3,7,8-TCDF 71 (40 - 135)
13C-1,2,3,7,8-PeCDF 71 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 62 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 64 (40 - 135)
L_.D30256 STL Sacramento 916-373-5600 21 of 645

13LUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 5 BLACK RH SR FILLETS
Trace Level Organic Compounds
Lot-Sample #. ._: G31030256-008 Work Order #--. : FXHWXIAA Matrix- -- -- - --- BIOLOGIC
Date Sampled__. : 08/28/03 Date Received__: 09/03/03
Prep Date. ... ..: 09/09/03 Analysis Date.. : 09/13/03
Prep Batch #- --: 3252577
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids6-1 SW846 8290
C )30256 STL Sacramento 916-373-5600 22 of 645

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 5 BLACK RH SR FILLETS a
Trace Level Organic Compounds
Lot-Sample #. .. : G3I030256-008 Work Order #.. .: FXHWXIAC Matrix. . . .. . ...: BIOLOGIC
Date Sampled. ._: 08/28/03 Date Received._: 09/03/03 •'
Prep Date. . .... : 09/09/03 Analysis Date. .: 09/13/03
Prep Batch #.. . : 3252573
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND
Total TCDD 0.19 Pg/g SW846 8290
ND 0.19 pgJg SW846 8290
1,2,3,7,8-PeCDD NO 0.58 pg/g SW846 8290
Total PeCDD ND 0.58 Pg/g SW846 8290
1,2,3,4,7,8-HpCDD ND - 0.35 Pg/g SW846 8290
1,2,3,6,7,8-HxCDD ND 0.29 pg/g SW846 8290
1,2,3,7,8,9-H%CDD ND 0.30 pg/g SW846 8296
Total HxCDD ND
0.35 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD ND 0.55
Total HpCDD ND Pg/g SW846 8290
OCDD 0.55 pg/g SW846 8290 -
ND 0.74 pg/g SW846 8290
2,3,7,8-TCDF 0.66 CON,J
Total TCDF Pg/g SW846 8290
0.66 pg/q SW846 8290
1,2,3,7,8-PeCDF ND 0.28 Pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.28 pg/g SW846 8290
Total PeCDF - ND 0.28 pg/g SW846 8290
1,2,3,4,7,8-HXCDF ND 0.22 pg/g SW846 8290 -
1,2,3,6,7,8-HxCDF ND 0.19 pg/g SW846 8290
2,3,4,6,7,8-HxCDF ND 0.23 Pg/g SW846 8290
1,2,3,7,8,9-HpCDF ND 0.26 pg/g SW846 8290
Total HxCDF ND 0.26 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 0.37 pg/g SW846 8290
1,2,3,4,7,8,9-HpCDF ND 0.44 pg/g SW846 8290
Total HpCDF ND 0.44
OCDF. Pg/g SW846 8290
0.63 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 75 (40 - 135)
13C-1,2,3,7,8-PeCDD 75 (40 - 135)
� 13C-I,2,3, 6,7, 8-HpCDD 72 (40 - 135)
13C-1,2,3,4, 6,7,8-HpCDD 71 (40 - 135)
13C-OCDD 67 (40 - 135)
13C-2,3,7, 8-TCDF 69 (40 - 135)
13C-1,2,3,7,8-PeCDF 74 (40 - 135)
13C-1,2,3,4,7,8-HXCDF 71 (40 - 135)
13C-1,2,3,4, 6,7,8-HpCDF 68 (40 - 135)
NOTE(s) :
CON Confirmation aralysls.
7 Estimated«salt.Result is Imam the reporting limit.
L__)30256 STL Sacramento 916-373-5600 23 of 645

QC DATA ASSOCIATION SUMMARY
G3I030256
Sample Preparation and Analysis Control Numbers
ANALYTICAL LEACH PREP
SAMPLE# MATRIX METHOD BATCH # BATCH # MS RUN#
001 BIOLOGIC SW846 8290 3252573
BIOLOGIC SW846 .8290 3252577
002 BIOLOGIC SW846 8290 3252573
BIOLOGIC SW846 82.90 3252577
003 BIOLOGIC SW846 8290 3252573
BIOLOGIC SW846 8290 3252577
004 BIOLOGIC SW846 8290 3252573
BIOLOGIC SW846 8290 3252577
005 BIOLOGIC SW846 8290 3252573 `
BIOLOGIC SW846 8290 3252577
006 BIOLOGIC SW846 8290 3252573
BIOLOGIC SW846 8290 3252577
007 BIOLOGIC- SW846 8290 3252573 '
BIOLOGIC SW846 8290 3252577
008 BIOLOGIC SW846 8290 3252573
BIOLOGIC SW846 8290 3252577
009 BIOLOGIC SW846 8290 3252573
BIOLOGIC SW846 8290 3252577
G_ _30256 STL Sacramento 916-373-5600 26 of 645

METHOD BLANK REPORT
Trace Level Organic Compounds
Client Lot #... . G3I030256 Work Order #.. . : FXXLJIAA Matrix----- -- -- 131OLOGIC
MB Lot-Sample #: G3I090000-573
Prep Date. .. ... : 09/09/03
Analysis Date- . : 09/13/03 Prep Batch #.. .: 3252573
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND
0.18 pg/g SW846 8290
Total TCDD ND 0.18 pg/g SW846 8290
1,2,3,7,8-PeCDD ND 0.40 pg/g SW846 8290
Total PeCDD ND 0.40 pg/g SW846 8290
1,2,3,4,7,8-HXCDD ND 0.37 pg/g SW846 8290
1,2,3,6,7,8-HxCDD ND 0.31 pg/g SW846 8290
1,2,3,7,8,9-HxCDD ND 0.32 pg/g SW846 8290
Total HxCDD ND 0.37 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD ND 0.40 pg/g SW846 8290
Total HPCDD ND 0.40
OCDD Pq/q SW846 8290
ND 0.66 pg/g SW846 8290
2,3,7,8-TCDF ND 0.13 pg/g SW846 8290
Total TCDF ND 0.13 pg/g SW846 8290
1,2,3,7, 8-PeCDF ND 0.25 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.25 pg/g SW846 8290
Total PeCDF ND 0.25 pg/g SW846 8290
1,2,3,4,7,8-HxCDF ND 0.21 pg/g SW846 8290
1,2,3,6,7, 8-HxCDF ND 0.18 pg/g SW846 8290
2,3,4,6,7,8-HXCDF ND 0.22 pg/g SW846 8290
1,2,3,7,8,9-HxCDF ND 0.25 pg/g SW846 8290
Total HxCDF ND 0.25 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 0.37 pg/g SW846 8290
1,2,3,4,7, 8,9-HpCDF ND 0.43 Pg/g SW846 8290
Total HpCDF ND 0.43
pq/g SW846 8290
OCDF ND 0.64 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 77 (40 - 135)
13C-1,2,3,7,8-PeCDD 79 (40 '- 135)
13C-1,2,3,6,7,8-HxCDD 75 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 75 (40 - 135)
13C-0CDD 66 (40- - 135)
13C-2,3, 7,8-TCDF 72 (40 - 135)
13C-1,2,3,7,8-PeCDF 74 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 75 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 73 (40 - 135)
NOTE(S) :
Calculations are perforated before rounding to avid round-eff errors in calculated results.
u-330256 STL Sacramento 916-373-5600 27 of 645

LABORATORY CONTROL SAMPLE EVALUATION REPORT
Trace Level Organic Compounds
Client Lot #__.: G3I030256 Work Order #. .. : FXXLJIAC Matrix.. . . . .. . ... BIOLOGIC
T. Lot-Sample#: G3I090000-573
Prep Date. . . . . .: 09/09/03 Analysis Date..: 09/13/03
Prep Batch #. . . : 3252573
Dilution Factor: 1
PERCENT RECOVERY
PARAMETER RECOVERY LIMITS METHOD
2,3,7,8-TCDD 103 (50 - 150) SW846 8290
1,2,3,7,8-PeCDD 104 (50 - 3.50) SW846 8290
1,2,3,4,7,8-HxCDD 120 (50 - 3-50) SW846 8290
1,2,3,6,7,8-HxCDD 96 (50 - 250) SW846 8290
1,2,3,7,8,9-HxCDD 107 (50 - 350) SW846 8290
112,3,4,6,7,8-HpCDD 95 (50 - 150) SW846 8290
OCDD 99 (50 - 150) SW846 8290
2,3,7,8-TCDF 102 (50 - 150) SW846 8290
1,2,3,7,8-PeCDF 96 (50 - 150) SW846 8290
2,3,4,7,8-PeCDF 100 (50 - 150) SW846 8290 e
1,2,3,4,7,8-HxCDF 94 (SO - 150) SW846 8290
1,2,3,6,7,8-HxMF 93 (50 - 150) SW846 8290
2,3,4,6,7,8-HxCDF 99 (50 - 150) SW846 8290
1,2,3,7,8,9-HxCDF 99 (50 - 150) SW846 8290
1,2,3,4,6,7,8-HpCDF 93 (50 - 156) SW846 8290
1,2,3,4,7,8,9-HpCDF 87 (50 - 150) SW846 8290
OCDF 96 (50 - 3.50) SW846 8290
PERCENT RECOVERY
INTERNAL STANDARD RECOVERY LIMITS
13C-2,3,7,8-TCDD 78 (40 - 135)
13C-1,2,3,7, 8-PeCDD 79 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 73 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 76 (40 - 135)
13C-OCDD 66 (40 - 135)
13C-2,3,7,8-TCDF 73 (40 - 135)
13C-1,2,3,7,8-PeCDF 76 (40 - 135)
13C-1,2, 3,4,7,8-HxCDF 74 (40 - 135)
13C-1,2,3,4,6, 7,8-HpCDF 70 (40 - 135)
NOTE(S) :
Qlcu1260M are per(ormW before rounding to avoid found-of(erron in miculated results.
Bold print denotes control parameters
L,:)30256 STL Sacramento 916-373-5600 28 of 645

LABORATORY CONTROL SAMPLE DATA REPORT
Trace Level Organic Compounds
Client Lot #__ .: G31030256 Work order #__. : FXXLJIAC Matrix-- --- - -- - : BIOLOGIC
LCS Lot-Sample#: G31090000-573
Prep Date_ ___ _ _: 09/09/03 Analysis Date__: 09/13/03
Prep Batch #. .. : 3252573
Dilution Factor: 1
SPIKE MEASURED PERCENT
PARAMETER AMOUNT AMOUNT UNITS RECOVERY METHOD
2,3,7,8-TCDD 20-0 20_7 pg/g 103 SW846 829D
1,2,3,7,8-PeCDD 100 104 pg/g 104 SW846 8290
1,2,3,4,7,8-HxCDD 100 120 pg/q 120 SW846 8290
1,2,3,6,7,8-HxCDD 100 96.4 pg/q 96 SW846 8290
1,2,3,7,8,9-HxCDD 100 107 pg/g 107 SW846 8290
1,2,3,4,6,7,8-HpCDD 100 95.1 pg/g 95 SW846 8290
0 200 198 pg/g 99 SW846 8290
2,3,7;8-TCDF 20-0 20_3 Pg/g 102 SW846 8290
1,2,3,7,8-PeCDF 100 96.3 pg/g 96 SW846 8290
2,3,4,7,8-PeCDF 100 99.6 pg/g 100 SW846 8290
1,2,3,4,7,8-HxCDF 100 94_2 pg/g 94 SW846 8290
1,2,3,6,7,8-HxCDF 100 92.9 pg/g 93 SW846 8290
2,3,4,6,7,8-HxCDF 100 98-8 pg/g 99 SW846 8290
1,2,3,7,8,9-HxCDF 100 99.0 _ pg/g 99 SW846 8290
1,2,3,4,6,7,8-HpCDF 100 93.2 Pg/g 93 SW846 8290
1,2,3,4,7,8,9-HpCDF 100 87_2 P3/g 87 SW846 8290
OCDF 200 192 pg/g 96 SW846 8290
INTERNAL STANDARD PERCENT RECOVERYRECOVERY LIMITS
13C-2,3,7,8-TCDD 78 (40 - 135)
13C-1,2,3,7,8-PeCDD 79 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 73 (40 - 135)
13C-1,2,3.,4,6, 7,8-HpCDD 76 (40 - 135)
13C-OCDD 66 (40 - 135)
13C-2,3,7,8-TCDF 73 (40 - 135)
13C-1,2,3,7,8-PeCDF 76 (40 - 135)
13C-1,.2,3,4,7, 8-HxCDF 74 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 70 (40 - 135)
NOTE(S) :
Calwbdom are performed before rounding to avoid mundoff MOTS in calwlated results.
Hold prior dnwtes control pammemm
1__.J30256 STL Sacramento 916-373-5600 - 29 of 645

"�ISD sr4 F 15 l7 i',_i�s_�� Ill lg
a
s. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Fa '
' r ,Arm w REGION 4 MAY - 7 issa _
i ATLANTA FEDERALSTREET,
SCENTER r8
�F o2 61 FORSYTH STREET, SW 1 f I
4714 m0177 ATLANTA, GEORGIA30303-8909
APR 2 9 --
Mr. A. Preston Howard, Jr., P.E., Director
Division of Water Quality
North Carolina Department of
Environment, Health, & Natural Resources
P.O. Box 29535
Raleigh, NC 27626-0535
Mr. Paul Davis, Director
Division of Water Pollution Control
Tennessee Department of
Environment& Conservation
6th Floor, L& C Annex
401 Church Street
Nashville TN 37243-1534
Mr. Aubrey D. McKinney, Chief
Environmental Services Division
Tennessee Wildlife Resources Agency
Ellington Agricultural Center
P.O. Box 40747
Nashville, TN 37204
SUBJ: Evaluation of Existing Pigeon River Data
Dear Gentlemen:
As you recall, Item 33 of the December 22, 1997 Champion Settlement Agreement calls for
the Environmental Protection Agency(EPA) to lead, in cooperation with North Carolina and
Tennessee, in convening an independent scientific panel that will evaluate existing information on
the overall health of the Pigeon River and Waterville Reservoir. I recommend that a scoping
meeting be held in mid-June with appropriate members of your staff to lay out the process and
timeframes needed to implement this item and volunteer our Atlanta office for this meeting.
In order to facilitate this process, I recommend that you begin to: 1) compile the various
studies and data that you possess; 2)consider possible funding sources for convening the
independent scientific panel; and 3) develop specific questions that you believe the panel should
address. At the meeting, I recommend that we share a listing of the data/studies that we possess,
discuss how.to obtain copies-of studies that other groups/organizations possess, discuss a data
management system for the compiled studies, and develop a consensus of the questions that the
panel should address.
Recycle"ecycloble•Printed with Vegetable ON Based Inks on 100%Recycled Paper(40%Postconsumer)

Mr. David Melgaard will be the point of contact for Region 4 for the scoping meeting and this
effort. His phone number is [phone]. Please let him know who you have designated as
your representatives for this effort and the dates in mid-June that they are available for the
meeting. Thank you in advance for your cooperation in this effort.
Sincerely,
Robert . McGhee, Director
Water Management Division
cc: Mr. David Jenkins, ACA
Honorable James E. Robinson, Mayor of Newport
Honorable Harold Cates, Cocke Co. Executive
Mr. John Noel, TEC
Mr. Richard J. Diforio, Jr., Champion
Mr. Gary Guzy, EPA

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F.G.
Easley, Governor N C®EN R
William G.Ross,Jr., Secretary
Alan W.Klimek, P.E.,Director NORTH CAROLINA DEPARTMENT OF
Division of Water Quality ENVIRONMENT AND NATURAL RESOURCES
WATER QUALITY SECTION
November 6, 2003
Mr. Bob Williams
Blue Ridge Paper Products
Post Office Box 4000
Canton, North Carolina 28716
Subject : Color Limit Reduction
NPDES Permit NC0000272
Blue Ridge Paper Products
Haywood County
Dear Mr. Williams :
According to the subject permit, the Technology Review Workgroup
(TRW) will evaluate mill performance and recommend a new color limit.
If the limit recommended by the TRW is below 40, 000 to 42 , 000 pounds per
day that limit will become effective December 1, 2003 . Since the TRW
has not recently met, they are not prepared to make a recommendation on
a new proposed color limit at this time. Therefore, the old limit will
remain in effect until you are advised of the Division of Water
Quality' s decision regarding a new limit .
If you have any questions concerning this subject, please do not
hesitate to contact Mr. Keith Haynes or me at 828-251-6208 .
Since ly,
l
Forrest R. estall
Enclosure
xc : Don Anderson
Dave Goodrich
59 Woodlu Place,Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/10%post-consumer paper

State of North Carolina
Department of Environment � '
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor NCDENR
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
November 15,2001
Mr. Robert Shanahan
Vice President- Mill Manager
Blue Ridge Paper Products
P.O. Box 4000
Canton,North Carolina 28716
Subject: NPDES Permit Issuance
Permit No.NC0000272
Blue Ridge Paper Products Inc.
Haywood County
Dear Mr. Shanahan:
After conducting a public hearing on Blue Ridge Paper's Request for renewal of the color
variance, temperature variance and the NPDES Permit,the Environmental Management Commission's
NPDES Committee approved renewal of the color variance, with the color conditions contained herein,
on October 10, 2001.The conditions related to color(as approved by the NPDES Committee) have been
incorporated into this permit and are an enforceable part of the permit.
In considering the comments presented at the September 6, 2001 public hearing, the hearing
officer made several recommendations for the color variance and the NPDES permit. The
recommendations made by the hearing clearly indicate the hearing officer's commitment to addressing
the concerns raised at the hearing and have been incorporated into the approved color variance and this
NPDES Permit. Specifically, the changes to the color variance and this permit include:
➢ The color variance and permit explicitly requires the Canton mill to implement all of the
`Highest Certainty' action items (as identified by the EPA's Tech Team).
➢ The initial color limit reduction to.42,000 pounds per day is now stipulated as a range of
40,000—42,000 pounds per day. After implementation of the `Highest Certainty' action
items, the Technology Review Workgroup will evaluate mill performance. If the limit
recommended by the TRW is within or below the 40,000 to 42,000 pounds per day, that limit
will become effective on December 1,2003, after written notification from the Director of
the Division of Water Quality.
➢ The color variance and permit explicitly'requires the Canton mill to evaluate.all of the
`Reasonable Certainty' action items.
➢ The color variance and permit explicitly states that the second 3,000 to 8,000 pounds per day
color reduction is in addition to the initial 6,000 to 8,000 pounds per,day color reduction.
➢ The range for the final color limit effective December 1,2005 is now 32,000 to 39,000
pounds per day. If the limit recommended by the TRW is within or below the 32,000 to
39,000 pounds per day,that limit will become effective on March 1, 2006, after written
notification from the Director of the Division of Water Quality.
➢ The report evaluating color reduction technologies for the Chloride Removal Process purge
stream is due on December 1,2004, so that this waste stream can be evaluated by the
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 -TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER- 50%RECYCLED/ 10%POST-CONSUMER PAPER
V151T US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

DEC - 2 2003
BLUE RIDGE
PAPER PRODUCTS INC. WAVEROoUALITYSECTI1
ASHEVILLE REGIONAL OFFICE
December 1, 2003
NC Emergency Response Commission
4714 Mail Service Center
Raleigh,NC 27699-4717
Re: NRC Case Number 706035, Ammonium Chloride Phosphate Solution Release
Dear Sir or Madam:
This letter is written notification of the release of Ammonium Chloride Phosphate
Solution that occurred on November 21, 2003 at the Canton Mill of Blue Ridge Paper
Products Inc. Verbal notification was made to the National Response Center and there
was also communication with Bob Rosen of EPA Region IV to clarify the details of the
spill event.
After carefully reviewing the MSDS for the Ammonium Chloride Phosphate Solution
and referencing EPA's Consolidated List of Chemicals Subject to the Emergency
Planning and Community Right-To-Know Act, we have determined that this was not a
reportable release. The supplier's MSDS incorrectly referenced an RQ for this material
that did not apply. The report to NRC was made based on the MSDS listing of ammonia,
which had an RQ of 100 lbs. However,EPA's List of Lists references an RQ of 1,000 lbs
for ammonia having a concentration of 20% or greater. The ammonia in the Ammonium
Chloride Phosphate solution is only 3%, therefore this product does not have an RQ and
reporting was not required.
Also, a miscommunication occurred somewhere within the regulatory chain of command.
The Blue Ridge Paper Products HAZMAT team and Haywood County Emergency
Management personnel were dispatched in response to a"reported" 17,000-gallon
chlorine release. No chlorine release was ever reported by Blue Ridge Paper Products.
In follow-up communication with EPA, it was reiterated that there was no chlorine
release and that the majority of the Ammonium Chloride Phosphate Solution (this
solution is being trialed as a nutrient supplement for Wastewater Treatment Plant
operations)was recovered in an offline, spare primary clarifier at the Wastewater
Treatment Plant. Approximately 1,290 gallons of the material went to the ground and
NEO Corporation was dispatched to begin soil excavation Friday evening. This soil
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone: [phone] • Fax: [phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
excavation was based on the supplier's incorrect ammonia MSDS listing. The supplier is
taking steps to correct their MSDS.
There were no adverse health or environmental effects from this release. The attached
form provides the details of this event. Please contact Melanie Gardner at (828) 646-
6749 or Louie Justus at(828) 646-2372 if you have any questions or need additional
information.
Sincerely,
Melanie Gardner Louie Jus s
Environmental Engineer Senior Env nnmen+a ngineer
Attachment

NOTIFICATION REPORT FOR SPILL/RELEASE
Canton Mill- 175 Main Street/P.O.Box 4000
Canton,NC 28716
Name of Chemical: Ammonium Chloride Phosphate Solution
Is Substance an Extremely Hazardous Substance ❑ YES X NO
Caller's Name &Position: Melanie Gardner, Environmental Engineer
Media into which release occurred: ❑ Air ❑ Water X Land
Quantity Released: (give reasonable estimate if known or that RQ may have exceeded, and will
call back as soon as possible- - do not delay reporting) 1,290 gallons to ground, 17,000—
18,000 gallons recovered by WWTP in low lifts and offline, spare clarifier.
Date, start and stop of release : Began—3:40pm 11/21, ended —4pm 11/21
Cause and source of release : Over-pressurization of tank
Action taken to respond to release and status of actions • Over 90% of material naturally flowed
back into WWTP low lifts. The flow was diverted into the offline spare primary clarifier to re-
use in the process NEO Corporation was dispatched immediately to excavate soil where spill
occurred. By 11/25/03, excavation was complete Upon further review of MSDS and EPA's
List of Lists, it was determined that this spill was NOT reportable The ammonia concentration
was only 3% and the MSDS incorrectly listed the RO of 100 pounds EPA's List of Lists
references ammonia with concentrations of 20% or greater having an RO of 1,000 pounds This
solution of 3% ammonia has no listed RO
Other Notification: National Response Center
Date: 11/21/03 Time: 7:04pm Report No.: 706035
Petty Officer Name : White
NCDEHNR- Asheville or NC Emergency Response- Raleigh
Date: 11/21/03 Time: 7:15 pm
Contact: NC ER was called to confirm receipt of report from NRC and they had already received
report.
Page 1 of 2
Revised 12/1/2003

Notification Report For Spill/Release - continued
Local Emergency Planning Committee
Date: N/A Time:
Contact:
Whether any injuries occurred: ❑ YES X NO
If yes, provide detail:
Name and telephone number of person to contact for further information:
Melanie Gardner, [phone], Louie Justus, [phone]
Action taken for clean-up: Majority of material was recovered in offline, spare primary clarifier.
Material that contacted soil was excavated by NEO Corporation.
Does release require written notification under Section 204 of Emergency Planning and
Community Right to Know Act(Title III SARA): ❑ YES X NO
Page 2 of 2
Revised 12/1/2003

BLUE RIDGE
PAPER PRODUCTS INC.
October 28, 2003
ATT: Central File
Mr. Bradley Bennett
Supervisor, Stormwater and General Permits
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh,NC 27699-1617
Subject: Request for Designation of Representative Outfall Status.
Blue Ridge Paper Products Inc., Canton Mill, Haywood County
Stormwater Permit NCS000105
Dear Mr. Bennett:
The purpose of this letter is to request representative status for stormwater outfall 6-17
with 6-4 and 6-10 being considered typical for closed landfills, as granted in our permit
for analytical sampling.
Outfall 6-17 is a new outfall. This outfall collects stormwater from the closed and capped
6A-East Cell in accordance with the Division of Solid Waste approved plans at the No. 6
Landfill (see attachments). Our"Stormwater Pollution Plan"has been revised to reflect
the addition of the new outfall and to include the outfall in our qualitative and facility
inspections.
If you have any questions or need additional information, please contact Louie Justus at
828-646-2372.
Sincer y,
Louie Ju tus Mr. Robert M. Shanahan
Senior En ' nm al Engineer Vice-Pres./Operations Manager
Lwr
28 ?A03
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 W TER UAUTY SECTION
Phone:[phone] • Fax: [phone] R GI NAL OFFICE
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
xc: Mr. Forest Westall
NCDENR
Water Quality Section
59 Woodfm Place
Asheville,NC 28801
Canton Mill:
Bob Williams—Director,Regulatory Affairs
Daryl Whitt—Manager, Environmental Affairs
D:New 6-17.doc Outfall

N
8 Q 8• i;�J I ` i/
: 7 e
04
W a t .
aMzcrrewrm
i' s ' e'�aOl'➢a ( _� L �1 ,6`1 G—•• .`�� .,:�I ]M . ,
aiafin '•' •,. Ski I'�1''I 1 ` ,, TING"
I
.,j EXISTING—_
AR
Landfill #6
General Location tfap
Outfall it 67
6.:u.c •icon :]61�19nl fcl_

04
OA
1.A0. .. ....��\A0
•� mil, \\
AO
_ _ I (
REPLACEMENT F'l 675 ..� AP`7. j' AC)"
--- 'M�-1E1
913 \,-1i /` .• `�\\ i `..r�' % �1<. j
\ \!1 SIC-_. � (
i .. (JEW`.7 AP '�- _ 1� �;��->\ `�� Mr
OZ69 1�1 \1g A� �' i - l :l r. •':[r r4..1
AP141' _.431
� _tea ��`-� \\_', { �� �%�• � — �� I � 4.;;• . .�' I , � /;�Qr „ �, I i
. `J Outfall
aloe ' _ ' Y /.• II ,, II
I,t EXISTING' See LEGEND next page
A�
74
zoo o zoo aoo r' ";' %
I4-
100
�, � J f � II I r/ (� l/ � .�.2✓ J ••\\ I I F' I 1 1

Drawing Legend: Outfall # 17 (Landfill # 6 )
Total Drainage Area: 148,104 Square Feet (See Note, Below)
Drainage Area Outline:
Drainage and Discharge Structures: Drop Basins
Culvert Pipes
Impervious Surfaces: Roads ---................
.............................................
Buildings
Stormwater Structural Control Measures: Rip-Rap
Springs ti1`�J
Hazardous Waste Storeage Area HW
Satellite Hazardous Waste Storage Area
Materials Loading and Access Areas LOAD
Note: New Outfall established 10/15/03 due to capping of 6-A East
area.

BLUE RIDGE
PAPER PRODUCTS INC.
February 3, 2003
Mr. Forrest Westall FEB 4 2003
Regional Water Quality Supervisor 0U tiTY gECiiO�
North Carolina Department of Environment ==SyF"/i l r REGIONt�TF1 L
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272, Blue Ridge Paper Products Inc. Canton Mill
Dioxin Monitoring in Fish Tissue Report-2002
Dear Mr. Westall:
Attached is the final report detailing the results from Blue Ridge Paper Products' thirteenth
annual Fish Tissue Study. This study, as required by our NPDES permit, consists of annual
sampling of fish at specific sites in the Pigeon River and analysis of those fish for dioxin. The
actual fish collection took place in September 2002. All surveys were conducted by EA
Engineering Science and Technology and the analyses were conducted by Severn Trent
Laboratories.
As you know, the Study Plan for the 2002 fish tissue monitoring was revised in response to the
fish consumption advisory on the Pigeon River being completely rescinded and the Walters Lake
advisory being partially rescinded. Carp in Walters Lake is the only fish species remaining under
advisory for both the North Carolina and Tennessee portions of the Pigeon River.
If you have any questions or comments,please call me at(828) 646-6749 or Derric Brown at
[phone].
Sincerely,
Melanie Gardner
Advanced Environmental Engineer
Attachment
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone: [phone] • Fax: [phone]
Raising Your Expectations

xc: Mr. Keith Haynes
Water Quality Section
Asheville Regional Office
59 Woodfin Place
Asheville,NC 28802
Attn: Central Files
Division of Environmental Management
and Natural Resources
NC Division of Environment and Natural Resources
P.O. Box 29535
Raleigh, NC 27626-0535
Mr. Marshall Hyatt
USEPA Region IV
345 Courtland Street,N.E.
Atlanta, GA 30365
Ms. Coleen Sullins
Chief,Water Quality Section
Division of Environmental Management
512 N Salisbury Street
P.O. Box 27687
Raleigh, NC 27611-7687
Mr. Paul Davis,Director
TN Dept. of Environment and Conservation
Division of Water Pollution Control
6`s Fl. L &C Annex
401 Church Street
Nashville, TN 37243-1534
Mr. David McKinney
TN Wildlife Resources Agencies
Ellington Agricultural Agency Center
P.O. Box 40747
Nashville,TN 37204

�OF W ATF90 �il Michael F.Easley
Governor
rWilliam G.Ross,Jr., Secretary
> North Carolina Department of Environment and Natural Resources
O Y Alan W.Klimek,P.E.Director
Division of Water Quality
Asheville Regional Office
July 30, 2003
198
MR. JOHN PRYATELY
BLUE RIDGE PAPER PRODUCTS.WWTP LAB
P.O. BOX 4000
CANTON, NC 28716
Dear Mr. Pryately:
Your letter, received July 21, 2003, concerning corrective actions for your analytical
procedures has been reviewed. The quality control measures taken in reference to the comments
cited in the May 27, 2003 inspection report are acceptable. This report does not attempt to
comprehensively address all certification requirements prescribed in the North Carolina
Administrative Code (15A NCAC 2H .0800), promulgated methods, and applicable Code of
Federal Regulations (40 CFR Part 136). It is the responsibility of the certified laboratory to address
any required changes in WastewaterIGroundwater Laboratory Certffication application information,
and to correct the Laboratory Standard Operating Procedures and the Laboratory Quality
Assurance Manual when requirements of the above cited codes are not in compliance.
If a future inspection should reveal that the deficiencies/requirements cited in the inspection
report were not corrected, enforcement actions will be recommended in accordance with 15A
NCAC 2H .0800.
Thank you again for your cooperation during the inspection. Contact us at 828-251-6208
ext. 285 if you have any questions or need additional information regarding our requirements.
Sincerely,
9z
Gary Francies
Laboratory Section
cc: James W. Meyer
N
Water Quality Section,59 Woodfin Place,Asheville,NC 28801-2414 Telephone: [phone] Customer Service
Fax: [phone] 1 800 623-7748

W c
Making ur mark for you.
BLUE RIDGE PAPER PRODUCTS INC. I111�►►►1
JUL21 20
tABORA ORY�SECTION
Certification Number 198 July'17, 2003
Mr. James W. Meyer EHE48LLE
� ( 0NCDENR, Division of Water Quality
Laboratory Section UL 2 4 ZOOZ1623 Mail Service Center Raleigh, North Carolina 27699-1623
ORATORY SECTIONSubject: Laboratory Certification Maintenance Inspection RespO REGIONAL OFFICE
May,6, 2003 Inspection Report.
Dear Mr. Meyer:
The laboratory inspection performed on May 6, 2003 by Mr. Gary W. Francies
included a comment that required a response. This correspondence is the response
that includes the description of how the cited item has been corrected.
Documentation
COMMENT: Tie laboratory needs to increase the Documentation of materials and
reagents used, made, and standard preparation. The preparation of all reagents,
standards and media should be documented in a preparation log or logs. Traceable
identifiers should link solution preparation information to analytical batches in which
the solutions are used. Documentation of solution preparation should include the
analyst's initials, date of preparation, the volume or weight of standard used, the
solvent and final volume of the solution. This information as well as the vendor,
manufacturer, lot number, and expiration date should be retained for primary
standards or chemicals and reagents used.
REQUIREMENT: Supporting records shall be maintained as evidence that these .
practices are being effectively carried out. All analytical records must be available for
a period of five years.
RESPONSE: Chemical receipt, preparation, and use logs are now being used that
document solution preparation information to analytical batches in which the
solutions are used. Documentation of solution preparation includes the analyst's
initials, date of preparation, the volume or weight of standard used, the solvent and
final volume of the solution. This information as well as the vendor, manufacturer, lot
number, date received & analyst's initials, date opened & analyst's.initials, and
expiration date are retained for primary standards, chemicals, filter pads, and
reagents used.
175 Main Street PO.Rnr annn r.nnm n,n ,ti cam. r , oo„o . ono �.�

BLUE RIDGE PAPER PRODUCTS INC.
If you have any questions, comments, or need additional information, I can be
contacted by phone at 704-646-6720 or by fax at 704-646-2993.
Sincerely,
John J. Pryately
Laboratory&WWTP Supervisor
i
{

BLUE RIDGE
PAPER PRODUCTS INC.
January 24, 2002 I
FEB `
Mr.Forrest Westall '
Regional Water Quality Supervisor
North Carolina Department of Environment _
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products Inc. Canton Mill
Dioxin Monitoring in Fish Tissue Report-2001
Dear Mr.Westall:
Attached is the final report detailing the results from Blue Ridge Paper Products' twelfth annual
Fish Tissue Study. This study,as required by our NPDES permit, consists of annual sampling of .
fish at specific sites in the Pigeon River and analysis of those fish for dioxin. The actual fish
collection took place in September 2001. All surveys were conducted by EA Engineering
Science and Technology and the analyses were conducted by Severn Trent Laboratories.
The Study Plan for the 2001 fish tissue monitoring was revised in response to the fish
consumption advisory on the Pigeon River being completely rescinded and the Walters Lake
advisory being partially rescinded. Carp in Walters Lake is the only fish species remaining under
advisory for the North Carolina portion of the Pigeon River. Ms. Coleen Sullens,Chief,Water
Quality Section, approved the primary changes to the Study Plan on August 22, 2001. A
complete revised Study Plan was submitted to the Division of Water Quality for approval on
January 7, 2002.
Table 6-4 provides the summary of the Canton Mill's Fish Fillet Tissue Analysis Results of
2,3,7,8 -TCDD from 1990 to 2001.
If you have any questions or comments,please call me at(828) 646 2318.
Sincerely,
Derric Brown
Manager of Environmental Affairs
Attachment
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone: [phone] • Fax: [phone]
Raising Your Expectations
I

xc: Mr.Keith Haynes
Water Quality Section
Asheville Regional Office
59 Woodfin Place
Asheville,NC 28802
Attn: Central Files
Division of Environmental Management
and Natural Resources
NC Division of Environment and Natural Resources
P.O.Box 29535
Raleigh,NC 27626-0535
Mr.Marshall Hyatt
USEPA Region IV
345 Courtland Street,N.E.
Atlanta, GA 30365
Ms. Coleco Sullins
Chief,Water Quality Section
Division of Environmental Management
512 N Salisbury Street
P.O. Box 27687
Raleigh,NC 27611-7687
Mr.Paul Davis,Director
TN Dept. of Environment and Conservation
Division of Water Pollution Control
6'sF1.L&CAnnex
401 Church Street
Nashville,TN 37243-1534
Mr. David McKinney
TN Wildlife Resources Agencies
Ellington Agricultural Agency Center
P.O. Box 40747
Nashville,TN 37204

QD
RESULTS OF 2002
DIOXIN MONITORING IN FISH TISSUE
Prepared for:
Blue Ridge Paper Products Inc.
Canton Mill
Canton, North Carolina
Prepared by:
EA Engineering, Science, and Technology, Inc.
444 Lake Cook Road, Suite 18
Deerfield, IL 60015
January 2003
13900.02

TABLE OF CONTENTS
Page
Listof Tables...................................................................................... iii
Listof Figures......................................................................................v
EXECUTIVE SUMMARY..................................................................... vii
1. INTRODUCTION...............................................................................1-1
2. SAMPLING LOCATIONS.....................................................................2-1
3. SAMPLING OBJECTIVES ....................................................................3-1
4. FISH COLLECTION TECHNIQUES AND LEVEL OF EFFORT .....................4-1
5. SAMPLE PREPARATION ....................................................................5-1
6. ANALYTICAL RESULTS.....................................................................6-1
7. REFERENCES...................................................................................7-1
APPENDIX A: CHAIN OF CUSTODY FORMS
APPENDIX B: SEVERN TRENT LABORATORY-SACRAMENTO
ANALYTICAL REPORTS
i

LIST OF TABLES
Number Title Page
2-1 Pigeon River sampling station information..........................................2-2
4-1 Fish collection techniques and level of effort.......................................4-2
4-2 Summary of fish composites collected in the Pigeon River,
September2002 .........................................................................4-3
6-1 Summary of Pigeon River fish tissues analysis results--2002.....................6-2
6-2 Toxicity equivalence factors for CDD/F isomers ..................................6-3
6-3 Summary of CDD/F isomer analyses, toxicity equivalent
factors, and toxicity equivalent values for the 2002 Pigeon
River fish tissue composites ...........................................................6-5
6-4 Blue Ridge Paper Canton Mill fish fillet tissue analysis results
1990-2002................................................................................6-9
iii

LIST OF FIGURES
Number Title Page
ES-1 TCDD concentrations in carp fillets collected from the Pigeon River,
1990-2002................................................................................vui
2-1 Sampling station locations on the Pigeon River ....................................2-3
2-2 Sampling Station No. 1 on the Pigeon River .......................................2-4
2-3 Sampling Station No. 2 on the Pigeon River .......................................2-5
2-4 Sampling Station No. 3 on the Pigeon River .......................................2-6
2-5 Sampling Station No. 4A on the Pigeon River .....................................2-7
2-6 Sampling Station No. 4B on the Pigeon River......................................2-8
2-7 Sampling Station No. 5 on the Pigeon River ......................................;2-9
6-1 TCDD concentrations in carp fillets collected from the Pigeon River,
1990-2002.............................................................................. 6-16
6-2 TCDD concentrations in channel catfish fillets (Station 4A) and flathead
catfish fillets (Station 4B) collected from the Pigeon River, 1997-2002...... 6-18
v

EXECUTIVE SUMMARY
Bottom feeding species were collected in 2002 from six locations in the Pigeon River and
analyzed for 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), 2,3,7,8-tetrachlorodibenzofuran
(TCDF), and other CDD and CDF isomers. TCDD and TCDF concentrations in fillet
composites from bottom feeders were very low (range=non-detected to 1.4 ppt) at the three
riverine locations downstream of the mill. Bottom feeders used at these locations were
common carp and black redhorse. TCDD concentrations in bottom feeder fillet composites at
the two Waterville Lake locations were 2.2 ppt and 6.6 ppt (Stations 4A and 4B, respectively)
for carp, non-detect for channel catfish at Station 4A and non-detect for flathead catfish at
Station 4B. Since 1990, TCDD concentrations in common carp fillets have declined
dramatically (90-99 percent) at all downstream stations (Figure ES-1).
The scope and methodology in 2001 and 2002 has changed from previous years due to
significant changes to the Pigeon River fish consumption advisory. In August 2001, the fish
consumption advisory in the Pigeon River was completely lifted and the Waterville Lake
advisory was partially lifted.
vii

Figure ES-1. TCDD Concentrations in Carp Fillets Collected from
the Pigeon River, 1990-2002 (Stations 2 and 3).
25
20 ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
—�— Station 2 -----+----- Station 3
c
0
15 --------------- ---------------------------------------------•-------------------------------------------------------------------------------------------------------------------- -----------------------------------------
d
a
y
F'• lQ
r• t1
0 10 ------------------------ --------------------- -•----------............------............. ------------................ ------ ..........................0
U
F-
5 ----------------------------------------------------- ---------------------------------------------------------------------------------------------------------------------------------------------------------------------
.----'t'------ b 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
YEAR
a) TCDD conentrations at Station 3 were not detected, therefore, the value plotted represents the detection limit for that sample.
b) TCDD concentrations at Station 2 were not detected,therefore, the value plotted represents the detection limit for that sample.
c) TCDD concentrations at Stations 2 and 3 were not detected, therefore, the values plotted represent the detection limits for those samples.

Figure ES-1 (Cont.). TCDD Concentrations in Carp Fillets Collected from
the Pigeon River,1990-2002 (Stations 4A and 4B).
70
4
60 -------------............................................................................ ..................................................................................................................................
` a
50 ..................S.-_----._--...._____-..----------------------------------------------------------------------..---.--------------------------------.---------------------...............................................
C 'S
O /
` 40 -----------------------� ----------- - - -
d
a
xQ30 ---------------------------------------------------------'-•---------------------------------------------------------------------------------------------------------------------------------------------------------------
❑
20 ------------------------------------------------...... .................................................................................................. ................................................... --------
------------------------------------------------------------------ - , -
S /c........ .._:y--------------------"--...-....-------.-......--------.-------------------
0
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
YEAR
Station 4a Station 4b

1. INTRODUCTION
This report details the results of a study conducted during 2002 to determine the concentrations
of 2,3,7,8,-TCDD (dioxin) and 2,3,7,8-TCDF (furan) in fish collected from the Pigeon River
near Canton, North Carolina. The study described herein is number 13 in a series of fish
tissue surveys designed and conducted to be completely responsive to the requirements of
A.(9.) Dioxin Monitoring Special Condition in Blue Ridge Paper's current NPDES permit for
the Canton Mill (Permit No. NC0000272). Sampling locations, selection of target species,
sampling methods, and sample preparation/preservation techniques are in accordance with the
study plan (EA 2001a). The approved study methods and scope detailed herein generally
follow those used since 1990 (EA 1990, 1991, 1992, 1993a, 1993b, 1994, 1995, 1996, 1997,
1998, 2000, 2001b, 2001c), however, selected project details were modified to be responsive
to the suggestions/recommendations of the North Carolina Department of Environment and
Natural Resources (NCDENR), the Tennessee Wildlife Resources Agency, U.S. EPA Region
IV, and the North Carolina Department of Health and Human Services (NCDHHS). The
principal change in the program was that the collection and analysis of sportfish composite
samples were not required in 2001 and 2002.
The 2002 study was conducted during 17-19 September, during which time biologists from EA
collected and prepared fish tissue samples from six sampling locations on the Pigeon River.
Details relevant to the location of Pigeon River sampling stations and fish tissue sampling
objectives follow in Sections 2 and 3, respectively. Fish collection techniques and level of
effort are detailed in Section 4; methods of sample preparation and shipment are presented in
Section 5. Analytical results are summarized in Section 6 and references are provided in
Section 7.
1-1

2. SAMPLING LOCATIONS
In accordance with the study plan (EA 2001a), fish were collected from six locations on the
Pigeon River. Five monitoring stations were located downstream from the Canton Mill outfall
(four in North Carolina and one in Tennessee) and one control or background site was located
upstream of it. Detailed sampling station information is provided in Table 2-1 and Figure 2-1.
Station 1, the background site, is located at Pigeon River Mile (RM) 64.5, approximately 1.2 RM
upstream from the Canton Mill outfall (Figures 2-1 and 2-2). Fish were collected from the river
reach adjacent to the Canton Recreational Park(located upstream from the city of Canton).
Except under extremely high flows, the Canton Mill dam blocks the movement of fishes and
thereby prevents the interaction of control and downstream monitoring station fishes. Monitoring
Station 2 is located upstream from Clyde, North Carolina at RM 59.0, approximately 4.3 RM
downstream from the Canton Mill outfall (Figures 2-1 and 2-3). Station 3 is 11.0 RM
downstream from the outfall (RM 52.3), in the vicinity of the old Rt. 209 bridge(Figures 2-1 and
2-4). Monitoring stations 4A and 4B are located in Waterville Lake at RM 41.5 and 39.0,
respectively (Figure 2-1). Station 4A is located approximately 21.8 RM downstream from the
Mill outfall, near the Messer Branch-Pigeon River confluence (Figure 2-5). Monitoring Station
4B is in the vicinity of the Wilkins Creek-Pigeon River confluence, approximately 24.3 RM
downstream from the Canton NEE outfall (Figure 2-6). Station 5 is located near Bluffton,
Tennessee at RM 19.0, approximately 44.3 RM downstream from the Mill outfall and about 6
miles downstream of the CP&L Hydro site(Figures 2-1 and 2-7). Sampling stations were
separated by at least 5.5 RM(with the exception of the Waterville Lake stations which are only
2.5 RM apart). All appropriate habitats were sampled within each study reach in an effort to
collect the desired complement of fishes. Brief sitelhabitat descriptions are provided in Table 2-1.
Fish sampling was conducted in the vicinity of each location described above, however, the
distance sampled at each station depended on how difficult it was to collect fish at that station.
At Station 1, an approximate 0.2 RM reach was sampled which extended from just downstream
of the downstream most River Road (Rt. 215) Bridge to the bridge by the city park. The
Station 2 sample reach was approximately 0.2 RM in length and was adjacent to a sharp bend
along Old Thickety Road. The Station 3 sample reach extended approximately 0.2 RM,just
upstream of the old Rt. 209 Bridge. In previous years, Station 4A in Waterville Lake has been
situated at and just upstream of the mouth of Messer Branch. However, low lake levels in 2002
precluded sampling upstream of the Messer Branch-Pigeon River confluence. Therefore, an
approximate 0.4 RM reach of Waterville Lake adjacent to and downstream of the Messer Branch-
Pigeon River confluence was sampled. The Station 4B study area consisted of a 1.0 RM reach of
Waterville Lake located near the Wilkins Creek-Pigeon River confluence. Sampling at
Stations 4A and 4B included gillnetting near the shore along both the left and right banks of
Waterville Lake. A large pool just upstream of the I-40 Bridge was sampled at Location 5.
2-1

Table 2-1. Pigeon River Sampling Stations.
Station River Station Location and
Number Mile Distance from Outfall Site Description/Habitat Tyne Fish Community
1 64.5 Pigeon River upstream from Canton, Characterized by ri01e,run,and pool habitats. Maximum Relative abundance dominated by minnows and darters. River
NC,adjacent to Canton Recreational depth approximately 5 ft. Substrate primarily cobble and boulders chub,grccnfm darter and ruck bass are dominant Northern hog
Park(1.2 RM upstream from Canton interspersed with gravel and sand. sucker,black redhorse,minor shiner,central sloncroller,greenside
Mill outfall). darter,and mottled sculpin are common.
2 59.0 Pigeon River upstream fiom Clyde,NC Characterized by run and pool habitats with canopy Relative abundance dominated by redbreast sunfish,central
(4.3 RM downstream from the Canton cover. Maximum depth approximately 6 ft. Substrate stoneroller,and northern hog sucker.
Mill outfall). primarily cobble/gmvel/md with some boulders and bedrock
3 52.3 Pigeon River in the vicinity of the Rt. Characterized by ran and pool habitats with some Redbreast sunfish,northern bog sucker,and common cup are
209 bridge(11.0 RM downstream canopy cover. Maximum depth approximately 5 tL dominant. Central stoncroller is commonn,
from the Canton Mill outfall) Substrate primarily bedrock and boulders with some
cobble and sand/graveVfmm deposited in pool areas.
N
I
N 4A 41.5 U Waterville Lake 21.8 RM Characterized b d water Imtic habitat with bedrock Relative abundance dominated b black er
PPer ( Y ccP' Y apple. Bluegill,flathead
downstrearn Goo the Canton Mill covered by loose,unconsolidated bottom sediments. Maximum catfish,channel catfish,and largemouth bass are common.
outfall) depth sampled approximately 15 R Cormnon carp an:present but no common.
4B 39.0 Lower Waterville Lake from the dam to Characterized by deep-water lentic habitat,bedrock, Relative abundance of catch dominated by black crappie. Bluegill,
confluence with Wilkins Cteck(24.3 RM and soft bottom sediments. Maximum depth sampled channel catfish,and flathead catfish are common. Common carp
downstream from the Canton Mill approximately 401E Very sleep banks with little cover. are present but not common
outfall)
5 19.0 Pigeon River near Bluffton,TN,just A single deep pool is sampled. Maximum depth approximately Northern hog suckcr is dominant Smallmouth bass,rock bass,
upstream of 140(44.3 RM downstream 8 7L Substrate primarily boulder and cobble. black redhorse,whitetail shiner,and banded sarlpin are common.
from the Canton Mill outfall) Except for smallmouth bass and rock bass,ce ttrarchids are
uncommon. Freshwater drum,gizzard shad,and buffalo are
occasionally common. Common carp are absent.

1.40
Station 5
RM 19.0 5
Bluffton,TN
(19.3)
(Hartford,TN
N,TENNESSEE N
—"� NORTH
�\\ CAROLINA
\
eK
Hydro Plant j/ 0
(26.0)
C. O \\
5G1.
Walters Dam 4B '
Station 48 Station 4A
RM 39.0 RM 41.5
4A Waterville Lake
Fines Creek ° r
New Hepco Brldger
FLOW Jonathan
Creek Old Rt 209
3 Station 3 Station 2 Mill OuHall
RM 52.3 RM 59.0 RM 63.3
Waynesville STP 2 Outfall Canton,NC
d
RM 54.7 �acK
Clyde Station 1 1
RM 64.5
(Control)
Figure 2-1. Fish tissue sampling station locations on the Pigeon River.
2-3

��u u \ �• •f o, rt n t
.I I w �•b/ L b
1? I I J 7
' M y3o
I/ per.
Ita
NZ, MSG
dye .1c v t2 rks Qll
Station 1 �\ ` , C7`
\C:: \ I-0 iA75 Is6�w i6h sS<h WE ,r _
l <•O 1 ounl le P I �•' , I•
$ G C'�rse �c '
✓;r_� I Pl =t m y4
w m a dltlOfi�\ d ��
1' Cho
ove �. r <•�` b
J ,g111 �� a //, •��'�
Figure 2-2. Sampling Station No. 1 on the Pigeon River.
�O
2-4

ke
rch
4
�- C
-ZM
70
L
e� A I C Station 2
ky]"n
2-5
V
`W' h SCM MOMr%.
•^\�\.— • � / / /' +ie"'�lersar,Tl ill CeCr��/��,
rk C,a'gwd d
N�
26900
-/n
2
Y.
N silm ✓C ,
71
........ ..
ey
tamey
4! Ove
Figure 2-3. Sampling Station No. 2 on the Pigeon River.
2-5

•rT
+ _ll
•�04 , Ii it •r'•�- aw e _ `
Jill
'-
D�LnaP \ .III `%\,r ac���( ( •.l L�
\
1 •}I.+i 1 -. •.� _•,, , Station 3; ;i�/- '•}!'���; ;A ai_:`�- �'-, �
:�• :�<-� J •f mil„/ I ; ��.• ,.,, �;- -�-- .,.`v'-
H3 -Mtn
Y M (/% rid%
ell
1
Figure 2-4• Sampling Station No. 3 on the Pigeon River.
I;
�O
2-6

MR
�l,j' \ yea \ /� �.�: '\ Ir•
cjj
() C
t p Redtnaalp i
UPU
i� � \j� r/�/-��.• .%\
Irl
i 1 `
Jj'' 4J�
rr
Mij
e' w +teb•
\\\ \ otR,muN Y.C.e
Figure 2-5. Sampling Station No. 4A on the Pigeon River.
�O
2-7

-�
PV
est area
�'� c �\\ ;'., lu I t �'Ir •:•�/�r��'1 (,� \.(��`�-•�i�•\�� �J�/ `�ras�Y l
/ � �• jr�' ): �„thy„ ` J '
`;V�� \— �j•q��\`� �ELEV
rr
Figure.2-6. Sampling Station No. 4B on the Pigeon River.
2-8
��

,ari 1 r
i
r
D�
Figure 2-7. Sampling station No. 5 on the Pigeon River.
2-9

3. SAMPLING OBJECTIVES
In accordance with the study plan (EA 2001a), the goal of the fish collection effort was to
collect one composite bottom feeder fillet sample at each of the six sampling stations. Each
composite consisted of 5 similarly sized (shortest specimen within 75% of the length of the
longest) adult individuals of the target species. Common carp (gprinus carpio) was the target
species at Stations 2, 3, 4A, and 4B. Common carp are absent at Stations 1 and 5, so at these
stations, black redhorse (Moxostoma duquesnet) was the target bottom feeder. In Waterville
Lake, one additional fillet composite sample using either channel catfish or flathead catfish was
collected at Stations 4A and 4B.
In addition to the fillet composites, a whole body composite consisting of 4 similarly sized
common carp was collected at Station 4B in Waterville Lake.
In summary, fish were collected as follows:
• Bottom feeder fillet composite—one sample at all six stations
• Catfish fillet composite—one sample at Stations 4A and at 4B
• Common carp whole body composite—one sample from Station 4B
The study plan called for the collection of catfish fillet composite samples at Stations 2 and 3 if
specimens were encountered. However, no specimens were encountered at these locations in
2002.
Every reasonable effort was made to collect the desired size, species, and/or number of fish,
however, the outcome of the sampling effort each year is dependent on physical river
conditions and the natural diversity and abundance of target fishes at each sampling location.
The 2002 Pigeon River collections yielded the desired complement of species at each sampling
station, except that the common carp whole body composite sample at Location 4B was based
on four rather than five specimens. Based on the effort associated with collecting them, it
appears that common carp in Waterville Lake are now less abundant than they once were. For
example, the number of common carp collected at Location 4B in 2002 (0.05 fish per net
hour) was similar to values observed since 1995 (range 0.02-0.08 fish per net hour), but
significantly lower than values observed in 1993 (0.041 fish per net hour) and 1994 (0.28 fish
per net hour). Similarly, the number of carp collected per net hour at Location 4A in 2002
(0.04 fish) was the lowest value to date, nearly ten times lower than the 1993 value of 0.34
fish per net hour (EA 1993b, 1994, 1995, 1996, 1997, 1998, 2000, 2001b, and 2001c).
Nonetheless, the number of specimens collected made it possible to composite individuals of
similar weight and length (with larger/adult specimens preferred), and the 75 percent rule was
met for all samples.
3-1

4. FISH COLLECTION TECHNIQUES AND LEVEL OF EFFORT
Sampling was conducted on 17-19 of September 2002. Notes were recorded at each sampling
station with regard to the type of sampling gear, level of effort (time), and habitat (Table 4-1).
Surface temperature measurements at each location are summarized below:
Station RM Date Temp m
1 64.5 9/19 19.5
2 59.0 9/17 25.5
3 52.3 9/17 23.2
4A 41.5 9/17 22.8
4B 39.0 9/17 24.8
5 19.0 9/18 22.7
All fish submitted for tissue analysis were measured to the.nearest millimeter (total length) and
weighed to the nearest gram (wet weight). These data are.summarized in Table 4-2.
The field investigators were equipped with an array of collecting gear which enabled sampling
of all habitats regardless of river conditions. U.S. EPA recommends active methods of fish*
collection in their Sampling Guidance Manual (Versar 1984), such as electrofishing, trawling,
angling, or seining. These methods are preferred over passive methods (e.g., gill nets, trap
nets, trotlines) because the collection period is typically shorter (i.e., hours versus days--
thereby minimizing decomposition), and because samples are collected from more definable
areas (Versar 1984). Electrofishing was used at all stations, except 4A and 4B (Waterville
Lake), where gill nets were necessary because of water depth. A boat electrofishing unit
- (pulsed direct current) was used to sample fish at Stations 3 and 5. The boat electrofisher was
equipped with a Smith Root Type VIA electrofisher, powered by a 240-volt, 5000W
generator. A pram electrofisher, equipped with a Coffelt VVP-2C pulser and powered by a
120-volt, 1800W generator, was utilized at Stations 1 and 2. Electrofishing techniques
followed those described in the National Dioxin Study (Versar 1984).
Fish collection techniques and level of effort (time) expended at each of the six stations are
summarized in Table 4-1. Total study effort involved —2.2 electrofishing-hours and —295 net-
hours. Total electrofishing duration (energized time) was 25, 75, 20, and 14 minutes at
Stations 1, 2, 3, and 5, respectively.
4-1

Tablc 4-1. Fish Collection Techniques and Level of Effort.
Station Sampling Sampling
Number RM Da s Techniques Level of Effort Comments
1 64.5 19 SEP 02 Praia Eleclrofishing 25 min An approximate 0.2 RM reach of river was sampled;water level low and stable--visibility good;
characterized by riffles,curs,and pools with primarily cobble/boulder substrates interspersed with gravel and
sand along margin. The entire reach was sampled using the pram.
2 59.0 17 SEP 02 Pram Mccuofishing 45 min Less than 0.2 RM reach of river was sampled;water level low—visibility good;station characterized by run
18 SEP 02 Pram Electrofohing 30 min and pool habitats with canopy coven,substrate primarily cobble/gravel with some boulders and bedrock,and
sand/gmvet/fines deposited along margins. Sampling involved several electrofishing passes rear woody
debris using the pram
3 52.3 17 SEP 02 Boat Electrofrshing 20 min An approximate 0.2 RM reach of river was sampled;water level low—visibility good;station characterized by
runs and pools with primarily bedrock and boulder substrates,with sand/gravel/fines deposited along
margins. Sampling involved several elecrrofishing passes over the reach utilizing a boat-mounted
eloctroftshing unit.
4A 41.5 17-18 SEP 02 (5)Gill nets —127 net-hrs An approximate 0.4 RM reach of river was sampled;lake level very low—visibility good,station
t" characterized by moderately deep-water lentic habitat with bedrock and soft,unconsolidated bottom
substrates. Sampling involved gill net setvjust off the left and right shores.
4B 39.0 17-18 SEP 02 (5)Gill nets —168 net-his An approximate 1.0 RM reach of river was sampled;lake level was very low—visibility good;station
characterized by deep-water lentic habitats with bedrock and soft bottom substrates. Sampling involved gill
nets. Effort was roneenVated near the rock pile near the dam and in the small bay at the mouth of Wilkins
Creck
5 19.0 18 SEP 02 Boat Electrofshing 14 min An approximate 0.1 RM reach of river was sampled;water was clear and moderately low—visibility good to
excellent;station characterized by pools and shoal habitats;substrate primarily bedrock,boulder,and cobble.
Sampling involved several electrolishing passes over a large pool using a boat-mounted electrofishing unit

fable 4 2 Summary offish composites collected at six stations in the Pigeon River. September 2002.
TOTAL TOTAL
LENGTH WHOLE BODY
DATE STATION SPECIES (mmm) WEIGHT(g) SAMPLE TYPE COMPOSITE
19 SEP 02 1 BLACK REDHORSE 405 520 FILLET R
(RM 64.5) BLACK REDHORSE 425 570
BLACK REDHORSE 372 465
BLACK REDHORSE 431 630
BLACK REDHORSE 375 460
MEAN 402 529
17 SEP 02 2 COMMON CARP 522 1960 FILLET R
(RM 59.0) COMMON CARP 548 2130
COMMON CARP 548 2080
COMMON CARP 527 2080
COMMON CARP 517 1820
MEAN 532 2014
17 SEP 02 3 COMMON CARP 575 2440 FILLET R
(RM 52.3) COMMON CARP 630 332b
COMMON CARP 632 3330
COMMON CARP 621 3050 „(
COMMON CARP 587 2600
MEAN 609 2948 -
17-18 SEP 02 4A CHANNEL CATFISH 475 910 FILLET R
(RM 41.5) 'CHANNEL CATFISH 470 950
CHANNEL CATFISH 446 700
CHANNEL CATFISH 425 680
CHANNEL CATFISH 452 730
MEAN 454 794
17-18 SEP 02 COMMON CARP 648 2900 FILLET R
COMMON CARP 523 2510
COMMON CARP 591 2760
COMMON CARP 565 2300
COMMON CARP 592 3400
MEAN 584 2774
17-18 SEP 02 4B FLATHEAD CATFISH 472 1230 FILLET R
(RM 39.0) FLATHEAD CATFISH 457 1050
FLATHEAD CATFISH 4B4 1260
FLATHEAD CATFISH 505 1430
FLATHEAD CATFISH 418 760
MEAN 467 1146
4-3

Table 4-2 (cont.).
TOTAL TOTAL
LENGTH WHOLE BODY
DATE STATION SPECIES (m) WEIGHT(g) SAMPLE TYPE COMPOSITE
17-18 SEP 02 4B(cont.) COMMON CARP 647 5400 FILLET R
(RM 39.0) COMMON CARP 670 5300
COMMON CARP 652 4750
COMMON CARP 670 5000
COMMON CARP 658 4500
MEAN 659 4990
17-18 SEP 02 COMMON CARP 579 2320 WHOLE BODY WB
COMMON CARP 630 3740
COMMON CARP 656 4100
COMMON CARP 615 3870
MEAN 620 3508
18 SEP 02 5 BLACK REDHORSE 452 1200 FILLET R
(RM 19.3) BLACK REDHORSE 430 1100
BLACK REDHORSE 489 1360
BLACK REDHORSE 441 980
BLACK REDHORSE 485 1470
MEAN 459 1222
4-4

Target species were collected at all sampling stations in 2002. Common carp, the target
bottom feeder at stations 2, 3, 4A, and 4B, were collected (and prepared for fillet and/or
whole body analysis) at those stations. In addition, the preferred target bottom feeding species
(black redhorse) was collected from Stations 1 and 5. The physiography of the Waterville
Lake Stations 4A and 4B necessitated the use of gill nets for the collection of bottom feeding
species. All nets were pulled and examined on a regular basis to reduce stress or specimen
mortality. All specimens submitted for analysis appeared healthy and in good condition.
Lengths and weights for each fish making up each composite are provided in Table 4-2.
Bottom feeder fillet composites consisted of five black redhorse at Stations 1 and 5 and five
common carp at Stations 2, 3, 4A, and 4B. In addition, a second bottom feeder fillet
composite, consisting of five channel catfish, was prepared for analysis from Station 4A; a
second bottom feeder fillet composite, consisting of five flathead catfish, was prepared for
analysis from Station 4B. A single bottom feeder whole body composite consisting of four
common carp from Station 4B was prepared for analysis (Table 4-2).
All nine composites submitted for analysis in 2002 met the US EPA Region IV
recommendation (Cunningham 1990) that the smallest specimen in each composite be equal to
' or greater than 75 percent of the total length of the largest specimen in that composite (Tables
4-2 and 6-4).
4-5

5. SAMPLE PREPARATION
All fish tissue samples were prepared in accordance with U.S. EPA Region IV
recommendations (Cunningham 1990) as described in EA (2001a). To prevent
cross-contamination between sampling stations, all sampling equipment likely to come into
contact with the fish was rinsed extensively with site water between stations.
Specimens collected at each station were sorted by size and species, and target species were
identified. The objective was to obtain a 3 to 5-fish composite sample at each station (plus a
catfish composite for each station in Waterville Lake as well as a common carp whole body
composite from either station in Waterville Lake) which met the species and size objectives
discussed in Section 3. From the target fishes collected, specimens of similar length and
weight were selected for each composite sample. All specimens retained were immediately
placed on ice for later processing. For each fish retained, length and weight data were
collected and recorded on the appropriate fisheries data sheet.
Following identification of target organisms, selection of composite samples, and collection of
length/weight data, each specimen was prepared for shipment and analysis. Bottom feeder
fillet samples consisted of epaxial muscle tissue and skin from one side of the fish. Bottom
feeder whole body samples consisted of the entire fish. Fillet samples were prepared by
removing the scales (or removing skin from catfishes) and then making an incision behind the
opercula (on both sides of the fish) from the base of the spine (behind the skull) to just below
the pectoral fin. Care was taken to cut through the epaxial muscle without puncturing the rib
cage or gut lining. A second incision was made along the length of the spine to the caudal fin
on both sides of the fish. The epaxial muscle was then gently cut away from the rib cage to
obtain a fillet. In this fashion, all flesh and skin was obtained from head to tail on both sides
of the fish. Fillet knives were solvent rinsed (hexane and acetone) between fish from different
stations. Each composite sample was wrapped in aluminum foil (dull side toward sample),
labeled, and placed on dry ice. Right side fillets were sent to Severn Trent Laboratory for
analysis; left side fillets were retained by Blue Ridge personnel as back-up fillets.
All individual specimens (fillets or whole bodies) composing a single composite sample were
placed together in a water-tight plastic bag labeled with the station name, sample number, and
the number of specimens in that composite. All labels contained the following information:
• sample identification number,
• sample location and station identification,
• sampling team initials,
• date of sample collection,
• species name,
• sample type (i.e., fillet or whole body)
5-1

A chain-of-custody form was filled out for each cooler of samples submitted for analysis.
Each form included composite-specific information and instructions. Copies of all
chain-of-custody records are provided in Appendix A.
All samples were frozen solid prior to shipment to the analytical laboratory. The frozen
samples were packed on dry ice, shipped via overnight delivery on 19 September and were
received, still frozen, at Sevem Trent Laboratory - Sacramento on 20 September 2002.
5-2

6. ANALYTICAL RESULTS
The fish tissue samples were received at Severn Trent Laboratory (STL) - Sacramento,
California under chain-of-custody on 20 September 2002. Once received at the laboratory,
samples were compared to the chain-of-custody record to verify the contents of each shipping
container. Each individual fish or fillet within a composite was homogenized separately by
STL personnel, and equal aliquots of the homogenate from each fish were removed to
constitute the composite. Dioxin and furan analyses were performed using high resolution Gas
Chromatography/Mass Spectrometry (GS/MS) as required by the U.S. EPA. Laboratory
documentation of all chemical extractions and analyses are provided in Appendix B. All
chemical analyses of the samples were conducted using EPA Method 8290 (U.S. EPA 1994)
as specified in the Canton Mill NPDES permit.
The quality of the analytical results was assured through reproducible calibration and testing of
the extractions and GC/MS systems. A laboratory method blank was prepared along with each
batch of samples. The laboratory also used precision and recovery standards for determination
of initial and ongoing precision and accuracy.
Laboratory reports for all 2002 Pigeon River fish tissue dioxin, furan, and lipid content
analyses are provided in Appendix B. Each laboratory analysis report form lists the
concentration of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), 2,3,7,8-tetrachlorodibenzofuran
(TCDF), and all other CDD/CDF isomers. Results of the dioxin, furan, and lipid content
analyses are summarized in Table 6-1. Detection limits are reported parenthetically on a
sample-specific basis. Only fillet results are discussed below because NCDHHS considers
only fillet results when issuing health advisories.
Concentrations of 2,3,7,8-TCDD in bottom feeder composite fillet samples were below the
level of detection at Stations 1, 2, 3, 4A (channel catfish), 4B (flathead catfish), and 5 (Table
6-1). Concentrations of 2,3,7,8-TCDD were detectable only in common carp composite fillet
samples from Stations 4A (2.2 ppt) and 4B (6.6 ppt). Furan isomer (2,3,7,8-TCDF) analysis
results indicated a concentration range from non-detect [Stations 1, 4A (channel catfish), and
4B (flathead catfish)] to 3.4 ppt (common carp at Station 4B).
Examination of the data in Table 6-1 indicates that all fish collected during this study had body
burdens well below the FDA dioxin health advisory level (25 ppt) for fish tissue [as
established and presented in FDA (1981 and 1983) and Cordle (1983)].
NCDHHS has identified a dioxin evaluation level of 3 ppt in fillet samples, expressed as
average toxicity equivalent (TEQ) (NCDEHNR 1991). The TEQ of each chlorodibenzo dioxin
and furan (CDD/F) isomer is based on the toxicity equivalence factor (TEF) (WHO 1997 and
Table 6-2) as described in the 2001 Study Plan (EA 2001b). The TEQ value is calculated
assuming additivity of effects from the individual congeners of dioxins and furans and is
expressed as an "equivalent amount of 2,3,7,8-TCDD" (NCDEHNR 1991). The measured
concentration of each CDD/F isomer, when multiplied by its appropriate TEF, yields the TEQ
6-1

Table 6-1. Summary of Pigeon River Fish Tissue Analysis Results,2002.
Station Percent
Number Sample ID Specie s Composite/Sample Tyne 2.3.7.8-TCDDI°1 23.7.8-TCDFt°1 Lipid
1 LOC 1 BLACK RH. Black redhorse 5 fillet samples ND(DL=0.14) ND(DL=0.27) 5.1
LOC 2 CARP
2 Common carp 5 fillet samples ND(DL=0.28) 1.1 8.1
3 LOC 3 CARP Common carp 5 fillet samples ND (DL=0.22) O.80ro1 12.0
4A LOC 4A C.CATFISH Channel catfish 5 fillet samples ND(DL=0.31) ND(DL=0.39) 6.5
LOC 4A CARP Common carp 5 fillet samples 2.2 1.8 9.1
413 LOC 4B FH. CATFISH Flathead catfish 5 fillet samples ND(DL=0.22) ND(DL=0.47) 4.0
LOC 4B CARP Common carp 5 fillet samples 6.6 3.4 18.0
LOC 4B CARP-WB Common carp 4 whole body samples 5.3 5.6 24.0
T
I
V 5 LOC 5 BLACK RH. Black redhorse 5 fillet samples ND(DL=0.14) 1.4 9.0
(a) Units=ppt(parts per trillion)or pg1g(plcogram per gram)
(b) Estimated result. Result is less than the reporting limit

Table 6-2. Toxicity Equivalence Factors for CDD/F Isomers.
DIOXIN DIBENZOFURAN
Isomer') TEF(b) Isomer(') TEF(b)
2,3,7,8-TCDD 1 2,3,7,8-TCDF 0.1
1,2,3,7,8-PeCDD 1 1,2,3,7,8-PeCDF 0.05
2,3,4,7,8-PeCDF 0.5
1,2,3,4,7,8-HxCDD 0.1 1,2,3,4,7,8-HxCDF 0.1
1,2,3,7,8,9-HxCDD 0.1 1,2,3,7,8,9-HxCDF 0.1
1,2,3,6,7,8-HxCDD 0.1 1,2,3,6,7,8-HxCDF 0.1
2,3,4,6,7,8-HxCDF 0.1
1,2,3,4,6,7,8-HpCDD 0.01 1,2,3,4,6,7,8-HpCDF 0.01
1,2,3,4,7,8,9-HpCDF 0.01
OCDD 0.0001 OCDF 0.0001
(a) In each homologous group, the relative toxicity factor for the isomers not listed is 1/100 of
the value listed for the other isomers in that homologous group.
(b) TEF =toxic equivalence factor= relative toxicity assigned.
6-3

of that isomer (the toxic concentration of that isomer relative to the toxicity of
2,3,7,8-TCDD). In cases where CDD/F concentrations were below the level of detection, a
value of zero was used in the TEQ calculation.
The TEQ calculation and summarization schemes presented in Table 6-3 followed methods
used by NCDHHS (NCDEHNR 1991). Bottom feeder fillet TEQ values were below the
NCDHHS limit of 3 ppt for all stations, except 4B in Waterville Lake. Although the TEQ
value of 9.3 ppt for the carp fillet composite at Station 4B exceeded the level of concern
(Table 6-3), the TEQ value for flathead catfish fillets from the same location was zero (i.e., all
dioxin and furan isomers were non-detect).
Table 6-4 illustrates the decline in 2,3,7,8 TCDD concentrations in carp fillet samples from
1990 through 2002. ,Since 1990, 2,3,7,8 TCDD concentrations in carp fillets declined
dramatically (90-99 percent) at all sampling stations (Table 6-4, Figure 6-1). The
concentrations of 2,3,7,8 TCDD in carp fillets from all stations in 2002 were similar to
concentrations observed in 2001. However, the concentrations of 2,3,7,8 TCDD in carp
fillets at Stations 4A and 4B appear to have increased slightly in recent years (Figure 6-1).
The modest increases in TCDD concentrations observed in carp fillets since 1999 may be due
in part to extended drought conditions, variability in collection sites, specimen size, and/or
dioxin biouptake/depuration rates of individual carp submitted for analysis rather than
representing a real increase in dioxin concentrations in Waterville Lake. However, TCDD
concentrations in channel catfish fillets from Station 4A and flathead catfish fillets from Station
4B have both declined since 1999 (Figure 6-2). Thus, despite possible modest increases in,
recent years, the concentration of 2, 3,.7, 8 TCDD in carp fillets from Waterville Lake has:
declined by 90-92 percent from 1990 through 2002 (Figure 6-1).
6-4

Table 6-3. SUMMARY OF CDD/F ISOMER ANALYSES, TOXICITY EQUIVALENT FACTORS AND TOXICITY EQUIVALENT VALUES FOR THE 2002 PIGEON RIVER
FISH TISSUE COMPOSITES. '
STATION 1 STATION 2 STATION 3
BLACK REDHORSE - Fillet COMMON CARP - Fillet COMMON CARP - Fillet
CDD/F ISOMERS TEF(c) Results(a) TEQ(b) Results TEQ Results TEQ
Dibenzodiozin
2,3,7,8-TCDD 1.0 0.14 + 0.000 0.28 + 0.000 0.22 + 0.000
1,2,3,7,8-PeCDD 1.0 0.31 + 0.000 0.61 + 0.000 0.30 + 0.000
1,2,3,4,7,8-HxCDD 0.1 0.21 + 0.000 0.29 + 0.000 0.15 + 0.000
1,2,3,6,7,8-HxCDD 0.1 0.19 + 0.000 0.84 + 0.000 0.97 + 0.000
1,2,3,7,8,9-HxCDD 0.1 ' 0.18 + 0.000 0.24 + 0.000 0.23 + 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.36 + 0.000 3.60(e) 0.036 2.70(e) 0.027
OCDD 0.0001 1.80 + 0.000 8.50(e) 0.001 11.00 0.001
Dib*nzofuran
2,3,7,8-TCDF 0.1 0.27 + 0.000 1.10 0.110 0.80(e) 0.080
I 1,2,3,7,8-PeCDF 0.05 0.19 + 0.000 0.32 + 0.000 0.17 + 0.000
u' 2,3,4,7,8-PeCDF 0.5 0.18 + 0.000 0.31 + 0.000 0.16 + 0.000
1,2,3,4,7,8-HxCDF 0.1 0.17 + 0.000 0.29 + 0.000 0.16 + 0.000
1,2,3,6,7,8-HxCDF 0.1 0.15 + 0.000 0.26 + 0.000 0.57 + 0.000
2,3,4,6,7,8-HxCDF 0.1 0.17 + 0.000 0.30 + 0.000 0.16 + 0.000
1,2,3,7,8,9-HxCDF 0.1 0.20 + 0.000 0.35 + 0.000 0.19 + 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.13 + 0.000 0.23 + 0.000 0.18 + 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.17 + 0.000 0.28 + 0.000 0.14 + 0.000
OCDF 0.0001 0.37 + 0.000 0.60 + 0.000 0.18 + 0.000
Total TEQ 0.00 0.15 0.11

Table 6-3 (cont.)
STATION 4A
CHANNEL CATFISH - Fillet COiMON CARP - Fillet
CDD/F ISOMERS TEF(c) Results (a) TEQ(b) Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.31 + 0.000 2.20 2.200
1,2,3,7,8-PeCDD 1.0 0.41 + 0.000 1.30 + 0.000
1,2,3,4,7,8-HxCDD 0.1 0.25 + 0.000 0.66 + 0.000
1,2,3,6,7,8-HxCDD 0.1 0.72 + 0.000 4.10(e) 0.410
1,2,3,7,8,9-HxCDD 0.1 0.22 + 0.000 0.66 + 0.000
1,2,3,4,6,7,E-HpCDD 0.01 0.79 + 0.000 12.00 0.120
OCDD 0.0001 2.80 + 0.000 33.00 0.003
Dibenzofuran
2,3,7,8-TCDF 0.1 0.39 + 0.000 1.80 0.180
1,2,3,7,8-PeCDF 0.05 0.25 + 0.000 0.66 + 0.000
2,3,4,7,8-PeCDF 0.5 0.25 + 0.000 1.70 + 0.000
o` 1,2,3,4,7,8-HpCDF 0.1 0.20 + 0.000 0.50 + 0.000
1,2,3,6,7,8-HxCDF 0.1 0.18 + 0.000 1.10 + 0.000
2,3,4,6,7,8-HxCDF 0.1 0.20 + 0.000 0.29 + 0.000
1,2,3,7,8,9-HxCDF 0.1 0.24 + 0.000 0.28 + 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.14 + 0.000 0.87 + 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.18 + 0.000 0.24 + 0.000
OCDF 0.0001 0.47 + 0.000 0.27 + 0.000
Total TEQ 0.00 2.91

Table 6-3 (cont.)
STATION 4B
FLATHEAD CATFISH - Fillet COMMON CARP - Fillet COMMON CARP - WB
CDD/F ISOMERS TEF(c) Results (a) TEQ(b) Results TEQ Results TEQ
Dibenzodioxin
2,3,7,8-TCDD 1.0 0.22 + 0.000 6.60 6.600 5.30 5.300
1,2,3,7,8-PeCDD 1.0 0.45 * 0.000 2.10 * 0.000 2.10 + 0.000
1,2,3,4,7,E-HxCDD 0.1 0.24 + 0.000 0.98 + 0.000 1.20 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.22 * 0.000 5.70 0.570 8.60 0.860
1,2,3,7,8,9-HxCDD 0.1 0.20 + 0.000 0.68 * 0.000 0.83 + 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.27 + 0.000 16.00 0.160 23.00 0.230
OCDD 0.0001 0.64 * 0.000 42.00 0.004 49.00 0.005
Dibsnzofuran
2,3,7,8-TCDF 0.1 0.47 * 0.000 3.40 0.340 5.60 0.560
1,2,3,7,8-PeCDF 0.05 0.28 * 0.000 1.20 * 0.000 1.50 * 0.000
2,3,4,7,8-PeCDF 0.5 0.27 + 0.000 3.30(e) 1.650 4.1(e) 2.050
I 1,2,3,4,7,E-HxCDF 0.1 0.20 * 0.000 0.60 + 0.000 1.40 * 0.000
1,2,3,6,7,8-HxCDF 0.1 0.17 * 0.000 3.50 * 0.000 1.50 * 0.000
2,3,4,6,7,8-HxCDF 0.1 0.20 + 0.000 0.42 + 0.000 0.79 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.23 * 0.000 0.48 * 0.000 0.25 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.12 * 0.000 1.20 + 0.000 2.10 + 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.16 * 0.000 0.34 + 0.000 0.17 + 0.000
OCDF 0.0001 0.39 * 0.000 0.72 + 0.000 0.33 * 0.000
Total TEQ 0.00 9.32 9.00

Table 6-3 (cont.)
STATION 5
BLACK REMORSE - Fillet
CDD/F ISOMERS TEF(c) Results (a) TEQ(b)
Dibonzodioxin
2,3,7,8-TCDD 1.0 0.14 * 0.000
1,2,3,7,8-PeCDD 1.0 0.29 * 0.000
1,2,3,4,7,8-HxCDD 0.1 _ 0.16 * 0.000
1,2,3,6,7,8-HxCDD 0.1 0.15 * 0.000
1,2,3,7,8,9-HxCDD 0.1 0.14 * 0.000
1,2,3,4,6,7,8-HpCDD 0.01 0.37 * 0.000
OCDD 0.0001 1.20 + 0.000
Dibenzofuran
2,3,7,8-TCDF 0.1 1.40 0.140
1,2,3,7,8-PeCDF 0.05 0.18 * 0.000
2,3,4,7,8-PeCDF 0.5 0.17 * 0.000
a, 1,2,3,4,7,8-HxCDF 0.1 0.15 + 0.000
ao 1,2,3,6,7,8-HxCDF 0.1 0.13 + 0.000
2,3,4,6,7,8-HxCDF 0.1 0.15 * 0.000
1,2,3,7,8,9-HxCDF 0.1 0.18 * 0.000
1,2,3,4,6,7,8-HpCDF 0.01 0.17 + 0.000
1,2,3,4,7,8,9-HpCDF 0.01 0.22 * 0.000
OCDF 0.0001 0.21 * 0.000
Total TEQ 0.14
(a) Units - ppt (parts per trillion) or pg/g picogram per gram) .
(b) Dioxin Toxic Equivalent Concentration using methodology from U.S. EPA (1989) .
(c) Toxicity Equivalent Factors from World Health Organization (WHO 1997) .
(d) Value less than or equal to 0.0005.
(a) Estimated result. Result is less than reporting limit.
(*) CDD/F isomer concentrations were below the level of detection, therefore a value of zero was applied
to the TEQ calculation.

Table 6-4. Blue Ridge Paper Canton Mill Fish Fillet Tissue Analysis Results, 1990-2002(a).
1990 ResultsP1 1991 Resullsot
Number of Length Number of length
Station Species Fah Range(mm) 2,3,7,8-TCDDty Station Species Fish Range(mm) 2,3,7,8-TCDDt•
I Rock bass 5 151-197 ND(0.15) 1 Rock bass 10 151-190 ND(0.40)
RM 64.5 Rock bass 5 153-213 ND(0.15) RM 64.5 Redbreast sunfish 10 106-178 ND(0.33)
Black redhorse 2 380-383 ND(0.20) Black redhorse 5 358-471 ND(0.35)
2 Redbreast sunfish 5 185-196 1.4 2 Redbreast sunfish 8 I54-189 0.87
RM 59.0 Redbreast sunfish 5 148-201 3.4 RM 59.0 Redbreast sunfish 8 154-202 0.93
Common carp 1 517 19.7 Common carp 10 491-570 9.7
3 Redbreast sunfish 5 188-203 0.79 3 Redbreast sunfish 10 176.209 ND(0.89)
RM 52.3 Redbreast sunfish 5 191-198 2.6 RM 52.3 Bluegill 6 164-197 ND(0.83)
Common carp 2 489-555 4.2 Common carp 10 408-063 2.4
4A Bluegill 5 178-192 ND(1.2) 4A Largemouth bass 7 313-468 3.0
RM 41.5 Bluegill 5 153-174 ND(0.63) RM 41.5 Black crappie 10 173-216 ND(0.63)
Common carp 1 574 27 Common carp 10 502-688 23
I
4B Bluegill 5 183-196 0.76 4B Bluegill 5 186-212 ND(0.34)
RM 39.0 Largemouth bass 2 2794M ND(1.8) RM 39.0 Bluegill 5 190-208 ND(0.62)
Common carp 4 551-638 66 Common carp 10 532-605 40
5 Redbreast sunfish 10 143-223 0.99
RM 16.5 Spotted bass 2 266-368 ND(0.35)
Common carp 2 511-539 1.7
Total Fish Filleted 57 138
f•�

Table 6-4 (cont.).
1992 Results" 1993 Res001
Number of Length Number of Length
Station Species Fish Range(min) 2,3,7,8-TCDD'^ Station Species Fish Range(mm) 2,3,7,8-TCDD(4
I Rock bass 10 147-194 ND(0.085) 1 Rock bass 10 185-209 ND(0.10)
RM 64.5 Redbreast sunfish 10 147-182 ND(0.075 RM 64.5 Redbreast sunfish 5 148-203 ND(0.12)
Black redhorse 6 365-441 1.4 Black redhoree 10 365-410 ND(0.80)
2 Redbreast sunfish 10 180-220 0.72 2 Redbreast sunfish 10 168-206 ND(0.27)
RM 59.0 Redbreast sunfish 10 178-220 ND(0.38) RM 59.0 Redbreast sunfish 10 140-191 ND(0.15)
Common carp 10 486-581 9.3 Common carp 10 462-620 3.1
3 Redbreast sunfish 10 175-200 ND(0.34) 3 Redbreast sunfish 10 155-210 ND(0.27)
RM 52.3 Redbreast sunfish 10 183-200 ND(0.29) RM 52.3 Redbreast sunfish 7 I80-213 ND(0.36)
Common carp 10 438-600 4 Common carp 10 440-576 3.4
4A Black cmppie 10 153-232 ND(0.094) 4A Black crappie 10 178-201 ND(0.15)
RM 41.5 Black crappie 10 177-224 ND(0.10) RM 41.5 Black crappie 10 192-204 ND(0.089)
I Common carp 10 492-622 29 Common carp 10 525-611 19
4B Bluegill 10 182-212 ND(0.23) 4B Largemouth bass 10 I90-310 ND(0.12)
RM 39.0 largemouth bass 5 215-332 ND(0.19) RM 39.0 Bluegill 10 185-210 ND(0.20)
Common carp 10 558-640 51 Common carp 10 530-644 28
5 Redbreast sunfish 10 175-245 ND(0.38) 5 Redbreast sunfish 6 I80-231 ND(0.17)
RM 19.0 Spotted bass 2 256-355 ND(0.30) RM 19.0 Smallmouth bass 9 212-281 ND(0.13)
Smallmouth buffalo 5 428-510 0.61 Smallmouth buffalo 5 450-550 ND 0.41
Total Fish Filleted 158 162
i
i
- — -j

Table 6-4 (cont.).
1994 Results*') 1995 Resultsro
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDD(O Station Species Fish Range(mm) 2,3,7,8-TCDD)O
1 Rock bass 6 156-185 ND(0.083) 1 Rock bass t0 162-205 ND(0.10)
RM 64.5 Redbreast sunfish 10 155-197 ND(0.10) RM 64.5 Rock bass 10 150-220 ND(0,26)
Black redhorse 3 367-435 ND(0.096) Black redhoree 7 375-464 ND(0.21)
2 Redbreast sunfish 10 176-206 ND(0.073) 2 Redbreast sunfish 10 152-194 ND(0.20)
RM 59.0 Redbreast sunfish 10 160-210 ND(0.092) RM 59.0 Redbreast sunfish 10 161-188 ND(0.16)
Common carp 10 490-590 0.99 Comon carp 10 435-664 1.7
3 Redbreast sunfish 10 149-196 ND(0.15) 3 Redbreast sunfish 10 170-206 ND(0.18)
RM 52.3 Redbreast sunfish 10 158-210 ND(0.074) RM 52.3 Redbreast sunfish 10 154-202 ND(0.20)
Common carp 10 456-565 0.74 Common carp 10 391-571 1.2
4A Black crappie 10 203-231 ND(0.085) 4A Largemouth bass 5 2BIA39 2.0
RM 41.5 Bluegill 10 185-205 ND(0.084) RM 41.5 Bluegill 10 167-199 ND(0.26)
r
Common carp 10 465-591 3.4 Common carp 10 520-615 5.8
4B Black crappie 10 200-215 ND(0.084) 4B Largemouth base 9 248-391 0.68
RM 39.0 Black crappie 10 195-220 ND(0.062) RM 39.0 Bluegill 8 158-216 ND(0.34)
Common carp 10 520-635 6.6 Common carp 4 532-626 11.0
5 Redbreast sunfish 6 129-289 ND(0.075) 5 Stnallmouth bass 9 28DA23 ND(0.11)
RM 19.0 Smallmouth bass 9 234-442 ND(0.1I) RM 19.0 Redbreast sunfish 7 163-192 ND(0.15)
Smallmouth buffalo 9 440-520 ND 0.089 - Black redhorse 7 44OA81 ND .45
Total Fish Filleted 163 156

Table 6-4 (coat.).
1996 Results" 1997 Resultso'
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDD°t Station Species Fish Range(ram) 2,3,7,8-TCDD-
I Redbreast sunfish 5 154-185 ND(0.13) 1 Redbreast sunfish 5 144-161 ND(0.11)
RM 64.5 Rock bass 5 160-208 ND(0.085) RM 64.5 Rock bass 5 162-194 ND(0.23)
Black redhorse 5 401-440 ND(0.089) Black redhoree 4 291-424 ND(0.22)
2 Redbreast sunfish 5 179-187 ND(0.10) 2 Redbreast sunfish 5 183-200 ND(0.26)
RM 59.0 Redbreast sunfish 5 193-191 ND(0.12) RM 59.0 Redbreast sunfish 5 160-181 ND(0.12)
Common carp 5 543-580 1.5 Common carp 5 506-615 1.4
3 Redbreast sunfish 5 184-190 ND(0.13) 3 Redbreast sunfish 5 187-202 ND(0.18)
RM 52.3 Redbreast sunfish 5 165.185 ND(0.13) RM 52.3 Redbreast sunfish 5 164-195 ND(0.18)
Common carp 5 516-630 0.87 Common carp 5 450-505 ND(0.33)
4A Black crappie 5 216-233 ND(0.15) 4A Black crapppie 5 215-231 ND(0.27)
RM 41.5 Black crappie 5 215-229 ND(0.18) RM 41.5 Black crappie 5 220-230 ND(0.10)
rn Common carp 5 562-632 4.2 Common carp 5 570-655 2.3
1 Channel catfish 5 418A82 2.0
N
4B Black cappic 5 223-258 ND(0.11) 4B Black crappie 5 226-241 ND(0.17)
RM 39.0 Largemouth bass 5 278-310 ND(0.13) RM 39.0 largemouth bass 5 270-360 ND(0.21)
Common carp 5 470-623 4.0 Common carp 5 605-690 11.0
Flathead catfish 5 430-540 0.62
5 Rock bass 4 169-186 ND(0.077) 5 Rock bass 5 143-214 ND(0.15)
RM 19.0 Smallmouth bass 5 315454 ND(0.12) RM 19.0 Smallmouth base 5 278-367 ND(0.27)
Smallmouth buffalo 5 451-555 ND 0.12 Smallmouth buffalo 5 406-525 ND .22
Total Fish Filleted 89 Total Fish Filleted 99

Table 6-4 (cunt.).
1998 Re iftsor 1999 Rmultsnt
Number of Length Number of Length
Station Species Fish Range(min) 2,3,7,8-TCDDtd Station Species Fish Range(ram) 2,3,7,8-TCDDt't
I Redbreast sunfish 5 145-176 ND(0.19) 1 Redbreast sunfish 5 141-177 ND(0.21)
RM 64.5 Rock bass 5 158-179 ND(0.29) RM 64.5 Rock bass 5 164-I80 ND(0.37)
Black redhorse 5 340-396 ND(0.18) Black redhorse 5 352427 ND(0.33)
2 Redbreaat sunfish 5 164-177 ND(0.20) 2 Redbreast sunfish 5 167-190 ND(0.37)
RM 59.0 Redbreast sunfish 5 166-193 ND(0.28) RM 59.0 Redbreast sunfish 5 158-178 ND(0.29)
Common carp 5 551-661 1.3 Common carp 5 544-615 ND(0.27)
3 Redbreast sunfish 5 168-193 ND(0.34) 3 Redbreast sunfish 5 169-189 ND(0.36)
RM 52.3 Redbreast sunfish 5 167-200 ND(0.22) RM 52.3 Redbreast sunfish 5 162-176 ND(0.37)
Common carp 5 449-550 ND(0.38) Common carp 5 500-591 0.57
4A Black crappie 5 220-240 ND(0.49) 4A Black crappie 5 22"68 ND(0.18)
RM 41.5 largemouth base 5 227-330 ND(0.15) RM 41.5 Black crappie 5 219-244 ND(0.08)
T Common carp 5 585-621 1.6 Common carp 5 574-645 0.59
Channel catfish 5 416-458 ND(0.28) Channel catfish 5 425-082 0.83
4B Black crappie 5 233-252 ND(0.15) 4B Black crappie 5 233-244 ND(0.27)
RM 39.0 Largemouth bass 5 259-330 ND(0.17) RM 39.0 Largemouth bass 5 276-305 ND(0.32)
Common carp 5 563-686 9.1 Common carp 5 621-680 4.7
Flathead catfish 5 414-523 ND(0.20) Flathead catfish 5 372-513 ND(0.46)
5 Rock bass 4 155-190 ND(0.11) 5 Rock bass 5 170-203 ND(0.29)
RM 19.0 Smallmouth bass 5 295-365 ND(0.21) RM 19.0 Smallmouth bass 5 297430 ND(0.19)
Smallmouth buffalo 5 464-537 ND 0.31 Smallmouth buffalo 5 476-565 ND 0.31
Total Fish Filleted 99 Total Fish Filleted 100
� . i

Table 6-4 (cont.).
2000 Results°) 2001 Results)^
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDD(') Station Species Fish Range(ram) 2,3,7,8-TCDD(4
I Redbreast sunfish 5 137-148 ND(0.48) 1 Black redhorae 5 312-407 ND(0.25)
RM 64.5 Rock bass 5 162-186 ND(0.45) RM 64.5
Black redhorse 5 357-396 ND(0.38)
2 Redbreast sunfish 5 169-176 ND(0.31) 2 Common carp 5 456-555 ND(0.27)
RM 59.0 Redbreast sunfish 5 164-181 ND(0.43) RM 59.0
Common carp 5 505-582 ND(0.42)
3 Redbreast sunfish 5 169-181 ND(0.43) 3 Common carp 5 504-615 ND(0.35)
RM 52.3 Redbreast sunfish 5 186-199 ND(0.32) RM 52.3
Common carp 5 514-569 ND(0.53)
4A Black crappie 5 212-241 ND(0.29) 4A Channel catfish 5 476-612 1.2
171 RM 41.5 Black crappie 5 220-241 ND(0.24) RM 41.5 Common carp 5 528-668 1.3
r- Common carp 4 559-604 1.1 -
41 Channel catfish 5 43S487 ND(0.70)
4B Black cmppie 5 213.231 ND(0.41) 4B Flathead catfish 5 405-463 ND(0.29)
RM 39.0 Black crappie 5 220-230 ND(0.37) RM 39.0 Common carp 5 654-723 5.6
Common carp 4 593-712 4.4
Flathead catfish 5 407450 ND(0.42)
5 Rock bass 5 171-198 ND(0.45) 5 Black redhorse 5 437-497 ND(0.26)
RM 19.0 Smallmouth bass 5 209-238 ND(0.31) RM 19.0
Black millions 5 427476 ND 0.35
Total Fish Filleted 98 Total Fish Filleted 40

Table 6-4 (cont.).
2002 ResultsldD
Number of length
Station Species Fish Range(mm) .2,3,7,8-TCDW
1 Black redhorse 5 372-431 ND(0.14)
RM 64.5
2 Common carp 5 517-549 ND(0.28)
RM 59.0
3 Common carp 5 575-632 ND(0.22)
RM 52.3
4A Common carp 5 523-648 2.2
RM 41.5 Channel catfish 5 425475 ND(0.31)
1
r
In
4B Common carp 5 647 670 6.6
RM 39.0 Flathead catfish 5 418-505 ND(0.22)
5 Black redhorse 5 430489 ND(0.14)
RM 19.0
Total Fish Filleted 40
(a) Survey conducted by EA Engineering,Science,and Technology. Analyses conducted by ENSECO Laboratories 1990-1994,Quanterra Laboratories 1995-1999,Severn Trent Laboratories in 2000-
2002.
(b) Survey conducted in August.
(c) Survey conducted in August and September.
(d) Survey conducted in September.
(e) Units = ppt(pails per trillion)or pglg(picogrnm per gram) -
ND =Non-detectable at the detection limit in parentheses.

Figure 6-1. TCDD Concentrations in Carp Fillets Collected from
the Pigeon River, 1990-2002 (Stations 2 and 3).
28
20 ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
—_— Station 2 -----+---- Station 3
c
0
rn
d
� a
M
0
a
a10 --------------------- ----------------------- ------------------------------------------------------------- ---------------- ---------------------------------------------------------......----------------------
0
(U
H
5 ----------------------------------------------------- ---------------------------------------------------------------------------------------------------------------------------------------------------------------------
+- b c c c
f------.. a a
i
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
YEAR
a) TCDD conentrations at Station 3 were not detected, therefore, the value plotted represents the detection limit for that sample.
b) TCDD concentrations at Station 2 were not detected, therefore,the value plotted represents the detection limit for that sample.
c) TCDD concentrations at Stations 2 and 3 were not detected,therefore, the values plotted represent the detection limits for these samples.

Figure 6-1 (Cont.). TCDD Concentrations in Carp Fillets Collected from
the Pigeon River,1990-2002 (Stations 4A and 4B).
70
60 ------- `- ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\
So 04
=------------------- -—--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
O
V
b \
a30 -----------------•------------------------------------\---------------------------------------------------------- ---------------------------------•--
U `
20 ----------------•--------------------------------------- --------------------------------------------•-•-------------------------------------------------------------------------------- ---------------------------------
10 ------- ------------------------------------------------------------ --- - .......... =��------••-------------------- ........ : --------------------------------------------------------------------
y' -.-A
0
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
YEAR
Station 4a ---A-- Station 4b

Figure 6-2. TCDD Concentrations in Channel Catfish Fillets (Station 4A) and Flathead
Catfish Fillets (Station 4B) Collected from Waterville Lake, 1997-2002.
2.50
2.00
\ —0— Station 4A —E—Station 4B
e \
o \
1.50
Co t \\
Q 1.00
0.50
0.00
1997 1998 1999 2000 2001 2002
YEAR
a) TCDD concentrations at Stations 4A and 4B were not detected,therefore,the values plotted represent the detection limits for those samples.
b) TCDD concentrations at Station 4B were not detected,therefore,the value plotted represents the detection limit for that sample.

7. REFERENCES
Cordle, F. 1983. Use of epidemiology in the regulation of dioxins in the food supply, in
Accidental Exposure to Dioxins: Human Health Aspects (F. Coulston and F. Pocchiara,
eds.), pp 245-256. Academic Press, New York.
Cunningham, W.R. 1990. Letter to Paul Wiegand. 30 January.
EA Engineering, Science, and Technology, Inc. 1990. Study Plan for the Monitoring of
Dioxin in Fish Tissue. EA Report No. 11370.01, prepared for Champion International
Corporation, Canton, North Carolina.
EA Engineering, Science, and Technology, Inc. 1991. Results of 1990 Dioxin Monitoring in
Fish Tissue. EA Report No. 11370.02, prepared for Champion International Corporation,
Canton, North Carolina.
EA Engineering, Science, and Technology, Inc. 1992. Results of 1991 Dioxin Monitoring in
Fish Tissue. EA Report No. 11370.03, prepared for Champion International Corporation,
Canton, North Carolina.
EA Engineering, Science, and Technology, Inc. 1993a. Results of 1992 Dioxin Monitoring,
in Fish Tissue. EA Report No. 11370.05, prepared for.Champion International
Corporation, Canton, North Carolina. April.
EA Engineering, Science, and Technology, Inc. 1993b. Results of 1993 Dioxin Monitoring
in Fish Tissue. EA Report No. 11370.06, prepared for Champion International
Corporation, Canton, North Carolina. December.
EA Engineering, ,Science, and Technology, Inc. 1994. Results of 1994 Dioxin Monitoring
in Fish Tissue. EA Report No. 11370.07, prepared for Champion International
Corporation, Canton, North Carolina. December.
EA Engineering, Science, and Technology, Inc. 1995. Results of 1995 Dioxin Monitoring
in Fish Tissue. EA Report No. 13043.01, prepared for Champion International
Corporation, Canton, North Carolina. December.
EA Engineering, Science, and Technology, Inc. 1996. Results of 1996 Dioxin Monitoring
in Fish Tissue. EA Report No. 13176.01, prepared for Champion International
Corporation, Canton, North Carolina. December.
EA Engineering, Science, and Technology, Inc. 1997. Results of 1997 Dioxin Monitoring
in Fish Tissue. EA Report No. 13353.01, prepared for Champion International
Corporation, Canton, North Carolina. November.
7-1

EA Engineering, Science, and Technology, Inc. 1998. Results of 1998 Dioxin Monitoring
in Fish Tissue. EA Report No. 13478.01, prepared for Champion International
Corporation, Canton, North Carolina. December. j
EA Engineering, Science, and Technology, Inc. 2000. Results of 1999 Dioxin Monitoring J
in Fish Tissue. EA Report No. 13478.01, prepared for Champion International
Corporation, Canton, North Carolina. January.
EA Engineering, Science, and Technology, Inc. 2001a. Study Plan for Pigeon River Dioxin
Monitoring in Fish Tissue. Prepared for Blue Ridge Paper Products, Canton, North
Carolina. November.
EA Engineering, Science, and Technology, Inc. 2001b. Results of 2000 Dioxin Monitoring
in Fish Tissue. EA Report No. 13745.01, prepared for Blue Ridge Paper Products,
Canton, North Carolina. January.
EA Engineering, Science, and Technology, Inc. 2001c. Results of 2001 Dioxin Monitoring
in Fish Tissue. EA Report No. 13900.01, prepared for Blue Ridge Paper Products,
Canton, North Carolina. December.
Food and.Drug Administration:_.1981. FDA advises Great Lake States to monitor �-
dioxin-contaminated fish. FDA Talk Paper dated 28.August, in Food Drug Cosmetic;Law:
Reports, paragraph 41, 321. , Commerce,Clearing House, Inc. 8 September. ,
Food and Drug Administration., 1983. Statement by Stanford A. Miller, Director, Bureau of.,
Foods, FDA before the Subcommittee on Natural Resources, Agriculture Research,and
Environment, U.S. House of Representatives. 30 June.
North Carolina Department of Environment, Health, and Natural Resources. 1991. Fish
Tissue Dioxin Levels in North Carolina: 1990 Update. Division of Environmental
Management, Water Quality Section.
U.S. Environmental Protection Agency (U.S. EPA). 1994. Analytical Procedures and
Quality Assurance for Multimedia Analysis of Polychlorinated Dibenzo-para-dioxins and
Polychlorinated Dibenzofurans by High-Resolution Gas Chromatography/High-Resolution
Mass Spectrometry (Method 8290).
U.S. Environmental Protection Agency (U.S. EPA). 1989. Interim Procedures for
Estimating Risk Associated with Exposures to Mixtures of Chlorinated Dibenzo-p-Dioxins —�
and Dibenzofurans (CDDs and CDFs) and 1989 Update Report No. EPA/625/3-89/016,
U.S. EPA, Risk Assessment Forum, Washington, D.C.
I
Versar, Inc. 1984. Sampling Guidance Manual for the National Dioxin Study. U.S.
Environmental Protection Agency. EPA Contract 68-01-6160. Work Order Number 8.7.
Office of Water Regulations and Standards, Monitoring and Data Support Division,
Washington, D.C. Final draft. July.
7-2

World Health Organization(WHO). 1997. Exposure and Human Health Reassessment of
2,3,7,8-Tetrachlorodibenzo-p-dioxin(TCDD) and Related Compounds: Part II Health
Assessment of 2,3,7,8-Tetrachlorodibenzo-p-dioxin(TCDD) and Related Compounds.
7-3

APPENDIX A
CHAIN OF CUSTODY FORMS
i

Chain of ® 2
Custody Record
® Severn Trent Laboratories, Inc.
snJ124 (1200)
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J U C ICY /q V o
Adlnsa f- ` ��. T°fapA°ae Nk�(Area Cod Number f Lab Number Page / of
CAy Sbt zo Code Slb Contact LaD ConteU Melysls(Attach Ilsl N
�.%yl( /°j n i moe more soace Is needs
Nameajd (State ! � CarrlwM'ayMNumber�
1' VC
SpeciallnstructtorW
rcheae Ortgnquota NA Maw o Containers d � ` Conditions of Receipt
*Preservatives .. DSoMp c S b
(Cmtalews for each Iaampb maybe combined nme he) Del9 nme tf ` i I z V b
c 99 f2 A-fle DZ 6? 0 Y Ji £ Go t i
eA $
? 'T 917 /3z0
(r �/
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c 'rti 91/19
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TM Around Tune Requlrad QC Requbamanb(SpedW
❑2i Noun ❑4e H M ❑T Days ❑ 14 Days ❑21 Days ❑Dfher
1.RaYnq By Dam f riMa 1 Tore /
d
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ed / (l� a T(.r".L Ito oz low-
Rftkulshed By Dab Tlma - elved By Dale Tkne
COrrunents
N
DISTRIBUTION: WHITE-Stays wah ale Sample; CANARY-lcetumedto Chenfwdh Report PINK-Fleld Copy
N

Chain of
Custody Record
® Severn Trent Laboratories, Inc.
=4124 (120Q
Cllanle Ptku Manager Date
ve ea e e 17
Chain W78 Ad&vss S Telephone Ncuy W(Ama Co/d�eyWO Nu /' q Lab Number
�r NI d 6 6 W 7 C / Page of
Clq' Slqa� TID Code she Contact • /+ Lab Contact Analysis(Attach lisf H
�{ �yy� /vL � Qry,re >,q e , more swoeIsneeded)
Prq'att Name jAd Lomflon tSfaby e CaMeMayNSNumber
!!rJ a, hV� t �� Speciallnshuctions/
ConbsodflUncow Odeuote MaMx Containers 6 `' Conditions of Receipt
. !e Preservatives
Semple I.D.No.ayb Description Deb T)me Y p 4 o�
fcenhlnm bwtlt r samph maybe comDlnedon one Ins) 1 Y el 9 ie
c 41& e 9//4 D Yrriev Ltd i A, 11
L y �/N
c4"'m Ki
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N
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Nm Mmld Q Flammable ❑Skin Initant ❑Pohon B ❑Unknown ❑Refum To Caent ❑Disposetey Let) ❑AmhNe For Months Mtperthan 3mamths)
Two Around Time Requked QC Requlmments(Spec(ry)
❑20 Hours ❑de Hours ❑T Days ❑ 14 Days ❑21 Days ❑ Ofiar..
1.Ref>nqufa y eJ Time 1.Reee
`7/ 0� ?. D 2
ate I
2Re By 'D. r ` T� OL Oglj�
A Relinquished By V Dater- TIM- 3. red By - Date VMS
Comments
m
a
N
DISTRIBUTION. WHITE-Slays whh On Semplq CWARY-Rafumedto G/enttm7h ReporL PINK-Field Copy
N

LOT RECEIPT CHECKLIST
STL Sacramento
CLIENT BL.+-2- pa06L PAPS- �' ZaL LOG e 11
LOT/(QWMMS'IDl auC EE 22 IO LorxnoN. r—
Initials Date
DATE RECEIVED " c�-io-02 TIME RECEIVED_ Ock-Lo. ac
DELIVERED BY ZFEDEX • ❑CA OVERNIGHT' ❑ CLIENT
❑AIRBORNE ❑GOLDENSTATE • ❑DHL'. •
❑ UPS Cl SAX GLOBAL ❑GO-GETTERS
❑STL COURIER ❑B &S Cl OTHER
CUSTODY SEAL STATUS FR INTACT ❑BROKEN El WA
CUSTODY SEAL 10 _eX13111
SHIPPPING CONTAINERG'j�j STL ❑ CLIENT ❑NIA
TEMPERTURE RECORD (IN°Q 1R 1❑ 2 �T ❑ OTHER
CDC jm O'1084(0 -CnC%"
TEMPERATURE BLANK
AMBIENT TEMPERATURE '-' Z$�
COLLECTOR'S NAME: ❑Verified from COC ID Not on COC
PH MEASURED ❑YES Cl ANOMALY \ ER NIA
LABELEDBY..........................................................................................
LABELSCHECKED BY........................................................................... ,
SHORT HOLD TEST NOTIFICATION SAMPLE RECEIVING
WETCHEM B NIA
❑METALS NOTIFIED OF FiLTERIPRESERVE VIA VERBAL &EMAIL NIA
COMPLETE SHIPMENT RECEIVED IN GOOD.CONDmON WITH ❑ NIA
APPROPRIATE TEMPERATURES, CONTAINERS, PRESERVATIVES
"'•❑ Ciouseau ` {]TEMPERATURE EXCEEDED f2°-6°Cl:, 9 NIA
❑WET ICE ❑BLUE ICE ❑GEL PACK
❑ PM NOTIFIED ❑NO COOLING AGENTS USED
Notes:
LEAVENOSPACFSBLANK USE'WA%FNOTAPPUWLE lNMALANDDATEALL'NIVENTWES. OAt6SWNEK
'21200246 STL-SaO onto(916)373-5600 60630

APPENDIX B
SEVERN TRENT LABORATORY-SACRAMENTO
ANALYTICAL REPORTS

STL Sacramento
880 Riverside Parkway
West Sacramento,CA 95605-1500
October 22, 2002
Tel: [phone]
Fax:[phone]
www.st-inc.com
STL SACRAMENTO PROJECT NUMBER: G2I200246
PO/CONTRACT: 201940
Melanie Samuels
Blue Ridge Paper Products, Inc.
P.O. Box 4000
Canton, NC 28716
Dear Ms. Samuels,
This report contains the analytical results for the samples received under chain of custody by
STL Sacramento on September 20, 2002.
The test results in this report meet all NELAC requirements for parameters that accreditation
is required or available. Any exceptions to NELAC requirements are noted in the case
narrative. The case narrative is an integral part of this report.
If you have any questions, please feel free to call me at [phone].
Sincerely,
Jill Kellmann
Project Manager
STL Sacramento is a part of Severn Trent Laboratories,Inc. . - -

TABLE OF CONTENTS
STL SACRAMENTO PROJECT NUMBER G21200246
Case Narrative
STL Sacramento Quality Assurance Program
Sample Description Information
Chain of Custody Documentation
BIOLOGIC,8290,Dios n&Wura Q
Samples: 1 through 9
Sample Data Sheets
Method Blank Report
Laboratory QC Reports
BIOLOGIC,8290,Petzent Lipids
Samples: 1 through 9
Sample Data Sheets

CASE NARRATIVE
STL SACRAMEN'I'O PROJECT NUMBER G21200246
General comments
The samples were received at-28'C and-30' C.
BIOLOGIC,8290,Dioxin�
Sample(s): 2, 5, 6,7, and 9
Some internal standard recoveries are lower than the method recommended goal of 40%.
Generally, data quality is not considered affected if internal standard signal-to-noise ratio is
greater than 10:1,which is achieved for all internal standards in all samples. There is no
adverse impact on data quality and no coauxive action is necessary.
Sample(s): 6
This sample has an estimated detection limit greater than the target detection limit for
1,2,3,6,7,8-HxCDF due to the presence of diphenyl ethers (DPE's). The analyst has flagged
the analyte as non-detect,with the reporting limit raised due to matrix interference.
The detection limit is still less than the lower calibration limit, so there is no adverse impact on
the data from this observation.
There were no other anomalies associated with this project.
�21200246 STL-Sacramento(916)373.5600 1 of 630

STL Sacramento
Quality Control Definitions
INTROWTI-IF '
A set of up to 20 field samples plus associated laboratory QC
QC Batch samples that are similar in composition(matrix)and that are
processed within the same time period with the same reagent and
standard lots
Consist of a pair of LCSs analyzed mithin the same QC batch to
Duplicate Control Sample monitor precision and accuracy independent of sample matrix
(I)CS) effects. This QC is performed only if required by client or when
insufficient sample is available to perform MS/MSD.
A second aliquot of an environmental sample,taken from the same
sample container when possible,that is processed independently
with the first sample aliquot The results are used to assess the
Duplicate Sample(DIJ) effect of the sample matrix on the precision of the analytical
process. The precision estimated using this sample is not
necessarily representative of the precision for ether samples in the
batch.
A volume of reagent water for aqueous samples or a contaminant-
free solid matrix(Ottawa sand)for soil and sediment samples
Laboratory Control Sample, which is spiked with known amounts of representative target
(LCS) analytes and required surrogates An LCS is carried through the
entire analytical process and is used to monitor the accuracy of the
analytical process independent of poteAnal matrix effects.
A field sample fortified with known quantities of target analytes
that are also added to the LCS. Matrix spike duplicate is a second
Matrix Spike and Matrix Spike matrix spike sample. MSs/MSDs are carried through the entire
Duplicate(MS/MSD) analytical process and are used to determine sample matrix effect
on accuracy of the measurement system.The accuracy and
precision estimated using MS/MSD is only representative of the
precision of the sample that was
A sample composed of all the reagents(m the same quantities)in
reagent wafer carried through the entire analytical process. The
Method Blank(NIB) method blank is used to monitor the level of contamination
introduced during sample preparation
Organic constituents not expected to be detected in environmental
media and we added to every sample and QC at a known
Surrogate Spike concentration. Surrogates are used to determine the efficiency of
the sample pfrparation and the anal ical process.
Source:STL Sacramento Laboratory Quality Manual
S m Sacramento Certifications.
Alaska(USi'-055),Arizona(#AW0616),Arkansas,California(IE1.AP#01119CA)99AP#I-2439),
Connecticut(#PIi 0691),Florida(BS7570),Hawaii,Louisiana(AI#30612),New Jersey(f ab ID 440()S ,
Nevada(#CA 044).New York W ID 11666 serial#107407),Oregon(LAB ID CA 044),South Carolina
(LAB ID 87014,Cert#870140),Utah(E168),Virginia(#00178),Washington(#C087),west Virginia(#
993DC),Wisconsin(lab 998204680),USNAVY,USAGE,USDA Foreign Plant(Permit#37-82605),USDA
Foreign Soil(Permit#S46613)..
1321200246 STL-Sacramento.[phone] 2 of 630

Sample Summary
G2I200246
WOO Soafle Client Saftlple ID Sampling Date Received Date
E8K39 1 LOC 1 BLACK RH 5 R FILLETS 9/19/02 08:30 AM 9/20/02 09:20 AM
E8K4H 2 LOC 2 CARP 9/18/02 920/02 09:20 AM
E8K4K 3 LOC 3 CARP 9/17/02 01.20 PM 920/02 09:20 AM
EML 4 LOC 4A CARP 9118/02 920/02 09:20 AM
EMN 5 LOC 4A C.CATFISH 9117/02 920/02 09:20 AM
E8K4T 6 LOC 4B CARP 9118102 920102 09:20 AM
E8K41 7 LOC 4B FH CATFISH 9/18/02 920/02 09:20 AM
E8K46 8 LOC 5 BLACK RH 9/18/0212:54 PM 920/02 09:20 AM
ESK49 9 LOC 4B-CARP-WHOLE BODY 9/18/02 920/02 09:20 AM
Notes(s):
7beaoelydalmd cftbeswnpktE=dnbove=j mthe♦21mvieypaVL
All edwWom am I otozd bdae rcundwg toavotd MM&WMM In atmtamd=9M
Results Doted w-ND'were rot detected at to ubcm mutated IaniL
Ibistepmtrmtamtbempmdocedaaptmfigwitbantbewriumapp valofthelabotatmy.
Resatts fortbe Wowing p=nmtm toes reported m a dy wci&basic color,ommsmW dmsny,f4sbpmi ipitabllity,layers.
odor.paint IDtcr=4 pK pmosi y,p me r-cd ity.ndot paw"specMc gmvoy.spotwM WRd&.soloFility.=maane.viarosty.
and aright
MW0246 STL-Sacramento(916)373-5600 3 of 630

BIOS RIDGE PAPER PSDIIOClS INC
Client Sample OD: IOC 1 BLACK R8 5 R F3IZZTS
Trace Level Organic compounds
Lot-Sample #...: G2I200246-001 Work Order 9...: EUX391AX Matrix.........: BIOLOGIC
Date Sampled...: 09/19/02 Date Received_.: 09/20/02
Prep Date......: 09/30/02 Analysis Date..: 10/03/02
Prep Batch 4...: 2273344
Dilation Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 5.1 w SW846 8290
21200246 STL-Sacramento(916)373-5600 7 of 630

BLUE R777G6 PAPER PRODIXTS INC
Clieat Sample ID: LOC 1 BLACK RH 5 R FIL*TS
Trace Level Organic Compounds
Lot-Sample $.._: G2I200246-001 Work Order #.. .: E8S391AC Matrix...... ...: BIOLOGIC
Date Sampled.._: 09/19/02 Date Received..: 09/20/02
Prep Date.. ....: 09/30/02 A=Iysis Date..: 10/06/02
Prep Batch #...: 2273336
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND 0.14 pg/g SW846 8290
Total TCDD ND 0.14 pg/g SW846 8290
1,2,3,7,8-PeCDD ND 0.31 pg/g SW846 8290
Total PeCDD ND 0.31 pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 0.21 pg/g SW846 B290
1,2,3,6,7,8-HxCDD ND 0.19 pg/g SW846 8290
1,2,3,7,8,9-HxCDD NO 0.18 pg/g SW846 8290
Total HxCOD ND 0.21 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD ND 0.36 pg/g SW846 8290
Total HpCDD ND 0.36 pg/g SW846 8290
OCDD ND 1.8 pg/g SW846 8290
2,3,7,8-TCDF ND 0.27 pg/g SW846 8290
Total TCDF ND 0.76 pg/g SW846 8290
1,2,3,7,8-PeCDF ND 0.19 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.18 pg/g SW846 8290
Total PeCDF ND 0.57 pg/g SW846 8290
1,2,3,4,7,8-HxMF ND 0.17 pg/g SW846 8290
1,2,3,6,7,8-HxMF DID 0.15 pg/g SW846 8290
2,3,4,6,7,8-HxCDF ND 0.17 pg/g SW846 8290
1,2,3,7,8,9-RxCDF ND 0.20 pg/g SW846 8290
Total HxCDF ND 0.53 pg/g SW846 8290
1,2,3,4,6,7,8-HPCDF ND 0.'13 pg/g SW846 8290
1,2,3,4,7,8,9-HpCDF ND 0.17 pg/g SW846 8290
Total HpCDF ND 0.17 pg/g SW846 8290
0CDF ND 0.37 pg/g SW846 8290
PERCENT RECOVERY
INTERWkL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 55 (40 - 135)
13C-1,2,3,7,8-PeCDD 52 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 69 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 72 (40 - 135)
13C-OCDD 59 (40 - 135)
13C-2,3,7,8-TCDF 51 (40 - 135)
13C-1,2,3,7,8-PeCDF 46 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 66 (40 - 135)
13C-1,2,3,4,6,7,8-Hp=F 70 (40 - 135)
121200246 STL-Sacramento(916)373-5600 801630

STAB RIDGE PAPHQ PBODUUTS I51C
Client Sample ID: LOC 2 CARP
. Trace Level Organic Compounds
Lot-Sample #.._: G21200246-002 Bork Order #...: E8&4HlAA Matrix......... BIOLOGIC
Date Sampled,...: 09/18/02 hate Received..: 09/20/02
Prep Date.... ..: 09/30/02 Analysis Date..: 10/03/02
Prep Batch #...: 2273344
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 8.1 V SB846 8290
t21200246 STL-Saeramento(916)373-5600 9 of 630

BLUE R33XE PAPER PRODUCTS IBC
Client Sample ID: LOC 2 CARP
Trace Level Organic compounds
Lot-Sample $...: G2I200246-002 Work Order $...: 88R4H1AC Matrix.........: BIOLOGIC
Date Sampled...: 09/28/02 Date Received..: 09/20/02
prep Date.. ....: 09/30/02 Analysis Date..: 10/06/02
Prep Batch I)...: 2273336
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD NO 0.28 Pg/g SW846 8290
Total TCDD NO 0.26 pg/g SW846 8290
1,2,3,7,8-PeCDD NO 0.61 Pg/g SW846 8290
Total PeCDD ND 0.61 pg/g SW846 8290
1,2,3,4,7,8-HxCOD NO 0.28 pg/g SW846 .B290
1,2,3,6,7,8-Hx=D NO 0.84 pg/g SW846 8290
1,2,3,7,8,9-HxCDD ND 0.24 pg/g SW846 8290
Total HXCDD ND 0.84 Pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD 3.6 S pg/g SW846 8290
Total HIJCM 3.6 pg/g SW846 8290
OCDD B.5 U _ Pg/g SW846 8290
2,3,7,E-TCDF 1.1 CON pg/g SW846 9290
Total TCDF 1.1 pg/g SN846 8290
1,2,3,7,8-PeCDF ND 0.32 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.31 pg/g SW846 B290
Total PeCDF ND 0.42 pg/g SW846 8290
1,2,3,4,7,8-HXCDF ND 0.29 Pg/g SW846 8290
1,2,3,6,7,8-HxCDF ND 0.26 pg/g SW846 8290
2,3,4,6,7,8-HxCDF NO 0.30 pg/g SW846 8290
1,2,3,7,8,9-HxCDF ND 0.35 pg/g SW846 829D
Total HxCDF ND _ 0.52 Pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 0.23 pg/g SW846 6290
1,2,3,4,7,8,9-HPCDF ND 0.28 Pg/g SW846 8290
Total HPCDF ND 0.23 pg/g SW846 8290
(CDF ND 0.60 Pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 30 * (40 - 135)
13C-1,2,3,7,8-PeCDD 29 * (40 - 135)
13C-1,2,3,6,7,8-HxCDD 53 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 48 (40 - 3.35)
13C-OCDD 39 * (40 - 135)
13C-2,3,7,8-TCDF 27 * (40 - 135)
. 13C-1,2,3,7,8-PeCDF 25 * (40 - 135)
13C-1,2,3,4,7,8-HxCDF 48 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 56 (4D - 135)
BOTE(S) -
J JiWUWW MA.RcrA L Ina d"me+Rmina fmit.
CON Ctmfitmmlm aeabsi
• Slr,19=1er1rvy b a,..''.oatd tsattd RmbL
21200246 STL-Sacramento(916)373-5600 10 01630

BLUE RIDGE PAPER PROWL= INC
Client Sample 3D: LOC 3 CARP
Trace Level Organic Compounds
Lot-Sample $_..: G2I200246-003 Work Older $...: ESR4RIAA Matrix.. .......: BIOLOGIC
Date Sampled...: 09/17/02 Date Received..: 09/20/02
prep Date....... 09/30/02 Analysis Date_.: 10/03/02
prep Batch $...: 2273344
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
percent Lipids 32 t SW846 8290
.21200246 STL-Sacramento(916)373-5600 11 of 630

BLUE RIDGE PAmm PEODD'CTS INC
Client Sample 0D: LOC 3 CARP
Trace Level Organic Compounds
Lot-Sample #...: C21200246-003 Work Order C...: E6K4T-AC MiLtrIX.........: BIOLOGIC
Date Sampled...: 09/17/02 Date Received..: 09/20/02
Prep Date......: 09/30/02 Analysis Date..: 10/06/02
Prep Batch $...: 2273336
Dilution Factor: 1
DETECTION
PARMASTER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND 0.22 Pg/g SW846 8290
Total TCDD ND 0.22 Pg/g SW846 8290
1,2,3,7,8-PeCDD ND 0.30 pg/g SW846 8290
Total PeCDD ND 0.30 pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 0.15 Pg/g SW846 8290
1,2,3,6,7,8-HxCDD ND 0.97 Pg/g SW846 8290
1,2,3,7,8,9-Hx,CDD ND 0.23 Pg/g SW846 8290
Total HxCDD ND 1.9 Pg/g SW846 8290
1,2,3,4,6,7,8-HpmD 2.7 J pg/g SW846 8290
Total HpCDD 2.7 pg/g SW846 8290
OmD 11 Pg/g SW846 8290
2,3,7,8-TCDF 0.80 J,CON Pg/g SW846 8290
Torai TCDF 0.80 pg/g SW846 8290
1,2,3,7,8-PeCDF ND 0.17 Pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.16 pg/g SW846 8290
Total PeCDF ND 3.9 Pg/g SW846 8290
1,2,3,4,7,8-RxCDF ND 0.16 Pg/g SW846 8290
1,2,3,6,7,8-HxCDF ,ND 0.57 Pg/g SW846 8290
2,3,4,6,7,8-HxCDF ND 0.16 Pg/g SW846 8290
1,2,3,7,8,9-HxCDF ND 0.19 Pg/g SW846 8290
Total HxCCDF ND 3.5 Pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 0.18 Pg/g SW846 8290
1,2,3,4,7,8,9-HpCDF ND 0.14 Pg/g SW846 8290
Total HpCDF ND 0.62 pg/g SW846 6290
OCDF ND 0.18 Pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 58 (40 - 135)
13C-1,2,3,7,8-Pe= 52 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 74 (40 - 135)
13C-1,2,3,4,6,7,8-HpCOD 75 (40 - 135)
13C-OCDD 66 (40 - 135)
13C-2,3,7,8-TCDF 51 (40 - 135)
13C-1,2,3,7,8-PeCDF 47 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 68 (40 - 135)
13C-1,2,3,4,6,7,8-HpMF 75 (40 - 135)
BOTH(S) •
l FxiMUd,mlt Ant[i•Is tl,m 4e repC,ltq 4mi[.
cop cw&mw o■MbI&
121200246 STL-Sacramento(916)373.5600 12 of 630

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LAC 4A CARP
Trace Level Organic Compounds
Lot-Sample #.. . : G21200246-004 Work Order #...: E8K4L1AA Matrix. . . .. . . . . BIOLOGIC
Date Sampled.. . : 09/18/02 Date Received..: 09/20/02
Prep Date.. . .. . : 09/30/02 Analysis Date.. : 10/03/02
Prep Batch #.. .: 2273344
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 9.1 SW846 8290
_21200246 STL-Sacramento(916)373-5600 13 of 630

SLDS R•m(B PAPER PRODUCTS INC
Client Sanple ID: LOC AA CAMP
Trace Level Organic Compounds
Lot-Sample 4...: G2I200246-004 Work Order #...: E8R4L1AC PEatrix...... ...: BIOLOGIC
Date Sampled...: 09/18/02 Date Reczived..: 09/20/02
Prep Date..... .: 09/30/02 Analysis Date..: 10/06/02
Prep Batch #...: 2273336
Dilution Factor: 1
DETECTION
PAP.WET•ER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD 2.2 pg/g SW846 8290
Total TCM 2.2 Pg/g SW846 829D
1,2,3,7,8-PeCDb ND 1.3 pg/g SW846 8290
Total PeCDD NO 1.3 pg/g SW846 8290
1,2,3,4,7,8-HxCDD NO 0.66 pg/g SW846 8290
1,2,3,6,7,8-BxCDD 4.1 J pg/g SW846 829D
1,2,3,7,8,9-HxMD NO 0.66 pg/g SW846 8290
Torsi MoCpD 4.3. Pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD 12 pg/g SW846 8290
Total SpCDO .12 pg/g SW846 829D
OCDD 33 Pg/g SW846 8290
2,3,7,8-TCDF 1.8 COS pg/g SW846 8290
Total TCDF 1.8 Pg/g SW846 8290
1,2,3,7,8-PeCDF NO 0.66 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 1.7 pg/g SW846 8290
Total PeCDF NO 4.3 pg/g SW846 8290
1,2,3,4,7,8-RxCDF ND 0.50 pg/g SW846 8290
1,2,3,6,7,8-HXMF NO 1.1 pg/g SW846 8290
2,3,4,6,7,8-HxCDF NO 0.29 pg/g SW846 8290
1,2,3,7,8,9-HxCDF NO 0.28 pg/g SW846 8290
Total HxCDF NO 4.0 Pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF NO 0.87 pg/g SW846 8290
1,2,3,4,7,8,9-HpCDF NO 0.24 pg/g SW846 8290
Total HpCDF NO 0.87 Pg/g SW846 8290
OCDF NO 0.27 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 62 (40 - 135)
13C-1,2,3,7,8-PeCDD 54 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 77 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 76 (40 - 235)
13C-OCDD 62 (40 - 135)
13C-2,3,7,8-TCDF 55 (40 - 135)
13C-1,2,3,7,8-PeCDF 51 (40 - 135)
13C-1,2,3,4,7,8-EXCDF 67 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 76 (40 - 135)
NOTH S :
J Ealmned mdLRa,h Is Tea gm me repwft IldL
CON Ca drm ba ngyde.
921200246 STL-Sacramento(916)373-5600 14 of 630

SLAB wTnas PAPER PRODD= INC
Client Sample ID: IOC 4A C. CATFIca
Trace Leval Organic Compounds
Lot-Sample $... : G21200246-005 Work Order $...: B8K4N1AA Matrix....... ..: BIOLOGIC
Date Sampled... : 09/17/02 Date Received--: 09/20/02
Prep Date...... : 09/30/02 Analysis Date..: 10/03/02
Prep Batch #... : 2273344
Dilution Factor: 1
DETECTION
PARAMETER RESULT L32aT UNITS METHOD
Percent Lipids 6.5 Y SW846 8290
i21200246 STL-Sacramento(916)373-5600 15 o1630

BLUE RTn= PAPER PRODUCTS INC
Client Sample ID: LOC 4A C. CATFISH
Trace Level Orgamc Compounds
Lot-Sample #. ..: G2I200246-005 Work Order #...: ESK4N3AC Matrix...... ...: BIOLOGIC
Date Sampled...: O9/17/02 Date Received..: 09/20/02
Prep Date......: 09/30/02 Analysis Date.-: 10/06/02
Prep Batch #. ..: 2273336
Dilution Factor: 1 '
DETECTION
PARAMETER RESULT LITSIT UNITS METHOD
2,3,7,8-TCDD ND 0.31 Pg/g SW846 8290
Total TCDD ND 0.31 pg/g SW846 8290
1,2,3;7,6-PeCDD ND 0.41 Pg/g SW846 8290
Total PeCDD ND 0.41 Pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 0.25 Pg/g SW846 6290
1,2,3,6,7,8-HxCDD ND 0.72 pg/g SW846 8290
1,2,3,7,8,9-HxCDD ND 0.22 Pg/g SW846 8290
Total HXCDD NO 0.72 Pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD ND 0.79 pg/g SW846 8290
Total HpCDD ND 0.79 Pg/g SW846 8290
OCDD ND 2.8 Pg/g SW846 8290
2,3,7,8-TCDF ND 0.39 Pg/g SW846 8290
Total TCDF ND 0.39 pg/g SW846 8290
1,2,3,7,8-PeCDF ND 0.25 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.25 Pg/g SW846 8290
Total PeCDF ND 0.41 Pg/g SW846 8290
1,2,3,4,7,8-HxCDF ND 0.20 Pg/g SW846 8290
1,2,3,6,7,8-HxCDF ND 0.18 Pg/g SW846 8290
2,3,4,6,7,8-HxCDF NO 0.20 Pg/g SW846 8290
1,2,3,7,8,9-HxCDF ND 0.24 pg/g SW846 8290
Total HxCDF ND 0.27 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 0.14 Pg/g SW846 8290
1,2,3,4,7,8,9-HPCDF ND 0.18 pg/g SW846 8290
Total HpCDF ND 0.18 Pg/g SW846 8290
OCDF ND 0.47 Pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 46 (40 - 135)
13C-1,2,3,7,8-PeCDD 41 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 62 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 63 (40 - 135)
13C-OCDD 53 (40 - 135)
13C-2,3,7,8-TCDP 40 (40 - 135)
13C-1,2,3,7,8-PeCDP 36 + (40 - 135)
13C-1,2,3,4,7,8-HxCDF 56 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 66 (40 - 135)
NOTE(S) -
• 'Sumrgcte rawcY b omsh mud comd hmu
i21200246 STL-Sacramento(916)373-5600 16 of 630

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: LOC 4B CARP
Trace Level Organic Compounds
Lot-Sample #-. - : G21200246-006 Work Order #. . . : E8R4T1AA Matrix. . . . . . . . . BIOLOGIC
Date Sampled.. .: 09/18/02 Date Received. .: 09/20/02
Prep Date- - - -- - : 09/30/02 , Analysis Date- -: 10/03/02
Prep Batch #. . . : 2273344
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 18 2 SW846 829D
_j21200246 STL-Sacramento(916)373-56D0 17 of 630

BLUE RIDGE PAPER PRODUCTS INC
Client Sample 1D: LOC 4B CARP
Trace Level Organic Compounds
Lot-Sample $...: G2I200246-006 Work Order $...: B8R4T1AC Matrix... ......: BIOLOGIC
Date Sampled...: 09/18/02 Date Received..: 09/20/02
prep Date. .....: 09/30/02 Analysis Date..: 10/06/02
prep Batch $...: 2273336
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD 6.6 pg/g SW846 8290
Total TCDD 6.6 pg/g SW846 8290
1,2,3,7,8-PeCDD ND 2.1 pg/g SW846 8290
Total PeCDD ND 2.1 pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 0.98 pg/g SW846 8290
1,2,3,6,7,8-EJc= 5.7 pg/g SW846 B290
1,2,3,7,8,9-HxCDD ND 0.68 pg/g SW846 8290
Total Hi@D 5.7 pg/g SW846 8290
1,2,3,4,6,7,8-Ep= 16 pg/g SW846 8290
Total Hp CUD 20 pg/g SW846 8290
OCpD 42 pg/g SW846 8290
2,3,7,8-TCDF 3.4 CON pg/g SW846 8290
Total qCDF 4.1 pg/g SW846 8290
' 1,2,3,7,8-PeCDF ND
1.2 pg/g SW846 8290
2,3,4,7,8-PeCDF 3.3 d pg/g SW846 6290
Total peCDF 3.3 pg/g SW846 8290
1,2,3,4,7,8-HxCDF ND
0.60 pg/g SW846 8290
1,2,3,6,7,8-HxCDF ND G 3.5 pg/g SW846 8290
2,3,4,6,7,8-HxCDF ND 0.42 pg/g SW846 8290
1,2,3,7,8,9-HxCDF ND
0.48 pg/g SW846 8290
Total HxCDF ND 3.5 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 1.2 Pg/g SW846 8290
1,2,3,4,7,8,9-HpCDF ND 0.34 pg/g SWB46 8290
Total HpCDF ND 3.6 pg/g SW846 8290
OCDF ND
0.72 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 25 * (40 - 135)
13C-1,2,3,7,8-PeCDD 23 * (40 - 135)
13C-1,2,3,6,7,8-HxCDD 46 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 43 (40 - 135)
13C-OCDD 33 * (40 - 235)
13C-2,3,7,8-TCDF 21 * (40 - 135)
13C-1,2,3,7,8-PeCDF 21 * (4A -.135)
13C-1,2,3,4,7,8—H3CCDF 43 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 51 (40 - 135)
BOTS(S) -
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21200246 STL-Sacramento(916)373-5600 18 of 630

BLUE RIDG'B PAPER PRODUCTS INC
Client Sample ID: LOC 4B PH t WTIFIS r
Trace Level Organic compounds
Lot-Sample ...: G2I200246-007 Work Order $...: R8R411AA Matrix. ........: BIOLOGIC
Date Sampled...: 09/18/02 Date Received. .: 09/20/02
Prep Date......: 09/30/02 Analysis Date..: 10/03/02
Prep Batch 9...: 2273344
Dilutian Factor. 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 4.0 V SW046 8290
0200246 STL-Sacramento(916)373-560D 19 of 630

RT 121D(;B PAPER PRODUCTS IBC
Client Sample ID: LOC 4B PH CATFISH
Trace Level Organic Compow2ds
Lot-Sample #...: G2I200246-007 Work Order #...: ESK412AC Matrim... . .....: BIOLOGIC
Date Sampled...: 09/18/02 Date Received..: 09/20/02
Prep Date. .....: 09/30/02 Analysis Date..: 10/06/02
Prep Batch #...: 2273336
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND 0.22 Pg/g SW846 829D
Total TCDD NO 0.'22 pg/g SW846 8290
1,2,3,7,8-PeCDD NO 0.45 pg/g SW846 8290
Total PeCDD ND 0.45 Pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 0.24 pg/g SW846 8290
1,2,3,6,7,8-HXMD ND 0.22 pg/g SW846 8290
1,2,3,7,8,9-HxMD NO 0.20 Pg/g SW846 8290
Total HxCDD NO 0.24 Pg/g SW646 8290
112,3,4,6,7,8-Hp= NO 0.27 pg/g SW846 8290
Total HpCDD NO 0.27 pg/g SW846 8290
OCDD NO 0.64 Pg/g SW846 8290
2,3,7,8-TCDF ND 0.47 pg/g SW846 8290
Total TCDF ND 0.47 pg/g SW846 8290
1,2,3,7,8-PeCDF ND 0.28 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.27 Pg/g SW846 8290
Total PeCDF ND 0.49 pg/g SW846 8290
1,2,3,4,7,8-HxCDF NO 0.20 pg/g SW846 8290
1,2,3,6,7,8-HxCDF NO 0.17 pg/g SW846 8290
2,3,4,6,7,8-HxCDF ND 0.20 Pg/g SW846 8290
1,2,3,7,8,9-HxCDF NO 0.23 pg/g SW846 8290
Total HxCDF NO 0.23 Pg/g SW846 8290
1,2,3,4,6,7,8-HPCDF NO 0.12 pg/g SW846 8290
112,3,4,7,8,9-HpCDF ND 0.16 pg/g SW846 8290
Total HpCDF ND 0.16 Pg/g SW846 9290
OCDF NO 0.39 pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 31 * (40 - 135)
13C-1,2,3,7,8-PeCDD 30 * (40 - 135)
13C-1,2,3,6,7,8-HxCDD 55 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 55 (40 - 135)
13C-OCDD 42 (40 - 135)
13C-2,3,7,8-TCDF 28 * (40 - 135)
13C-1,2,3,7,8-PeCDF 27 _* (40 - 135)
13C-1,2,3,4,7,8-HxCDF 56 (40 - 135)
13C-1,2,3,4,6,7,8-HPCDF ' 63 (40 - 135)
NOTES)
SYumYte rwW y 5 eeoLle"wd mnvd fm im
121200246 STL-Sacramento(916)373-56DO 20 of 630

BLUE I?Tn= PAPER PECOUm3 INC
Client Sample O.D. LOC 5 BLAM RH
Trace Level Organic Compounds
Lot-Sample #.-.: G2I200246-008 Work Order #...: ESK463AC Matrix.........: BIOLOGIC
Date sampled...: 09/18/02 Date Received..: 09/20/02
prep Date......: 09/30/02 Analysis Date..: 10/06/02
Prep Batch #...: 2273336
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND 0.14 pg/g SW846 8290
Total TCDD ND 0.14 pg/g SW846 8290
1,2,3,7,8-PeCDD ND 0.29 pg/g SW846 8290
Total PeCDD NO 0.29 pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 0.16 pg/g SW846 8290
1,2,3,6,7,8-HxCDD ND 0.15 pg/g SW846 8290
1,2,3,7,8,9-HxMD ND 0.14 pg/g SW846 8290
Total HxCOD ND 0.16 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD ND 0.37 pg/g SW846 8290
Total HpCDD ND 0.37 pg/g SW846 8290
OCDD ND 1.2 pg/g SW846 8290
2,3,7,8-TCDF 1.4 CON pg/g SW846 8290
.Total TCDF 1.4 pg/g SW846 8290
1,2,3,7,8-PemF ND
0.18 pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.17 pg/g SW846 8290
Total PeCDF ND 0.53 pg/g SW846 8290
1,2,3,4,7,8-HxCDF NO 0.15 pg/g SW846 0290
1,2,3,6,7,8-HxCDF ND 0.13 pg/g SW846 8290
2,3,4,6,7,8-HxCDF ND 0.15 pg/g SW846 8290
1,2,3,7,8,9-HxCDF ND 0.18 pg/g SW846 8290
Total HxCDF ND 0.38 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDF ND 0.17 pg/g SW846 8290
1,213,4,7,8,9-HpCDF NO 0.22 pg/g SW846 8290
Total HpCDF ND 0.22 pg/g SW846 8290
OCDF ND 0.21 pg/g SW846 8290
PERCEPT RECOVERY
INTERNAL, STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD Be (40 - 135)
13C-1,2,3,7,8-PeCDD 52 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 78 (40 - 235)
13C-1,2,3,4,6,7,8-HpCDD 80 (40 - 135)
13C-OCDD 59 (40 - 135) .
13C-2,3,7,8-TCDF 51 (40 - 135)
13C-1,2,3,7,8-PeCbF 48 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 74 (4.0 - 135)
13C-1,2,3,4,6,7,8-HpCDF 84 (40 - 135)
AOTS(S) •
CON ewfannSm antytiL
i21200246 STL-Sacramento(916)373.5600 22 of 630

BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: IOC 4B - CARP- WHOLE BODY
Trace Level Organic Compounds
Lot-Sample #. ..: G21200246-009 Work Order #_. . : E8K491AA Matrix. . . . . . . . . : BIOLOGIC
Date Sampled. . . : 09/18/02 Date Received. .: 09/20/02
Prep Date. . .. . . : 09/30/02 Analysis Date. .: 10/03/02
Prep Batch #. . .: 2273344
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 24 4; SW846 8290
G21200246 STL-Sacramento(916)373-5600 23 of 630

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BLUE RIDGE PAPER PRODUCTS INC
Client Sample ID: IOC 5 BLACK RH
Trace Level Organic Compounds
Lot-Sample #... : G2I200246-008 Work Order #- - - : ESK461AA Matrix. . . . . ... . : BIOLOGIC
Date Sampled. . .: 09/18/02 Date Received. .: 09/20/02
Prep Date. . .. . . : 09/30/02 Analysis Date. . : 10/03/02
Prep Batch #. .. : 2273344
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
Percent Lipids 9.0 $ SW846 8290
21200246 STL-Sacramento(916)373.5600 21 of 630

QC DATA ASSOCIATION SUMMARY
G2I200246
Sample Preparation and Analysis Control Numbers
ANALYTICAL LEACH PREP
SAMPLE# MATRIX. METHOD BATCH # BATCH # ME RUN#
002 BIOLOGIC SW846 8290 2273336
BIOLOGIC SW846 8290 2273344
002 BIOLOGIC SW846 8290 2273336
BIOLOGIC SW846 8290 2273344
003 BIOLOGIC SW846 8290 2273336
BIOLOGIC SW846 8290 2273344
004 BIOLOGIC SW846 8290 2273336
BIOLOGIC SW846 8290 2273344
005 BIOLOGIC SW846 8290 2273336
BIOLOGIC SW846 8290 2273344
006 BIOLOGIC SW846 8290 2273336
BIOLOGIC SA46 8290 2273344
007 BIOLOGIC SW846 8290 2273336
BIOLOGIC SW846 8290 2273344
008 BIOLOGIC SW846 8290 2273336
BIOLOGIC SW846 8290 2273344
009 BIOLOGIC SW846 8290 2273336
BIOLOGIC SW846 8290 2273344
321200246 STD-Sacramento(916)373.5600 25 of 630

METSOD BLABS REPORT
Trace Level Organic Compounds
Client Lot $...: G2I200246 Work Order /...: E844W3-AA Matrix...... .. .: BIOLOGIC
MB Lot-Sample : G2I300000-336
Prep Date......: 09/30/02
Analysis Date..: 10/06/02 Prep Batch /...: 2273336
Dilution Factor: 1
DETECTION
PARAMETER RESULT LIMIT UNITS METHOD
2,3,7,8-TCDD ND D.13 pg/g SW846 8290
Total TCDD HD 0.13 pg/g SW846 8290
1,2,3,7,8-PeCDD ND 0.39 pg/g SW846 B290
Total PeCDD ND 0.39 pg/g SW846 8290
1,2,3,4,7,8-HxCDD ND 0.28 Pg/g SW846 8290
1,2,3,6,7,8-HxCDD ND 0.26 Pg/g SW846 8290
2,2,3,7,8,9-HXCDD ND 0.24 pg/g SW846 8290
Total HxCDD ND 0.28 pg/g SW846 8290
1,2,3,4,6,7,8-HpCDD ND 0.19 pg/g SW846 8290
Total HpCDD ND 0.19 pg/g SW846 8290
OCDD ND 0.46 pg/g SW846 B290
2,3,7,8-TCDF ND 0.28 pg/g SW846 8290
Total TCDF ND 0.28 pg/g SW846 8290
1,2,3,7,8-PeMP ND 0.20 Pg/g SW846 8290
2,3,4,7,8-PeCDF ND 0.20 pg/g SW846 8290
Total PeCDF ND 0.34 Pg/g SW846 8290
1,2,3,4,7,8-HxCDF ND 0.19 pg/g SW846 8290
1,2,3,6,7,8-HxCDF ND 0.17 pg/g SW846 B290
2,3,4,6,7,8-HxCDF ND 0.19 pg/g SW846 B290
1,2,3,7,8,9-HxCDF ND 0.22 pg/g SW846 8290
Total HxCDF ND 0.22 Pg/g SW846 8290
112,3,4,6,7,8-HpCDF ND 0.13 Pg/g SW846 8290
1,2,3,4,7,8,9-111>CDF ND 0.17 pg/g SW846 8290
Total HpMF ND 0.17 pg/g SW846 B290
OCDF ND 0.28 Pg/g SW846 8290
PERCENT RECOVERY
INTERNAL STANDARDS RECOVERY LIMITS
13C-2,3,7,8-TCDD 67 (40 - 135)
13C-1,2,3,7,8-PeCDD , 57 (40 - 135)
13C-1,2,3,6,7,8-Hx(MD 87 (40 - 135)
13C-1,2,3,4,6,7,E-HpCDD 82 (40 - 135)
13C-OCDD 72 (40 - 135)
13C-2,3,7,8-TCDF 59 (40 - 135)
13C-1,2,3,7,8-PeCDF 54 (40 - 135)
13C-1,2,3,4,7,8-HXCDF 85 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 79 (40 - 135)
NOTS(S) :
(]lIMM=yafmm,d 6dme mimdiq wowed ro,a forma malwhta!n=h
G212D0246 STL-Sacramento(916)373-56DO 26 of 630

LABORATORY CONTROL SAMPLE EVALUATION REPORT
Trace level Organic Compounds
Client Lot $...: G21200246 Work Order #...: E844WIAC Matriz.........: BIOLOGIC
LCS Lot-Sample$: G2I300000-336
Prep Date......: 09/30/02 Analysis Date_: 10/06/02
Prep Batch #...: 2273336
Dilution Factor: 1
PERCENT RECOVERY
PARAMETER RECOVERY LIMITS METHOD
2,3,7,8-TCOD 80 (50 - 150) SW046 8290
1,2,3,7,8-PeCDD 81 (50 - 150) SN846 8290
1,2,3,4,7,8-HXC10 86 (50 - 150) SW046 8290
1,2,3,6,7,8-HxCDD 84 (50 - 350) SW046 8290
1,2,3,7,8,9-HxCDD 71 (50 - 150) SN046 8290
1,2,3,4,6,7,8-Hp= 83 (50 - 150) SW846 8290
OCOD 88 150 - 350) SNO46 8290
2,3,7,E-TCDF 90 (SO - 150) SW846 8290
1,2,3,7,8-PeCOF 91 (50 - 350) SWO46 8290
2,3,4,7.8-PeCIF 200 (50 - 150) SKS46 8290
1,2,3,4,7,8-HSCDF 82 (50 - 150) SW846 8290
1,2,3,6.7,8-HXMF 84 (50 - 350) SW846 8290
2,3,4,6,7,8-HxCOF 83 (SO - '150) SW046 8290
1,2.3,7,B,9-HSCDF 54 (50 - 3.50) SW846 8290
1,2,3,4,6,7,8-HpCDF 86 (50 - 250) SW846 8290
1,2,3.4,7,8,9-H4;,CDF 64 (50 - 3.50) SW846 8290
OCDF 76 (50 - 350) SW846 8290
PERCENT RECOVERY
INTERNAL STANDARD RECOVERY LIMITS
13C-2,3,7,8-TCDD 49 (40 - 135)
13C-1,2,3,7,.8-PeCDD 47 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 75 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 71 (40 - 135)
13C-OCDD 59 (40 - 135)
13C-2,3,7,8-TCDF 45 (40 - 235)
13C-1,2,3,7,8-PeCDF 43 (40 - 135)
13C-1,2,3,4,7,87HxCDF 74 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 74 (40 - 135)
NOTH(S) -
m:Paiem,ed bd=Mwdw9 n mN,aml-aff [,,d Awd rmdtt.
Braid p=deoom mead parmems
1212D0246 STL-Sacramento(916)373-5600 27 of 630

LABORATORY CONTROL SAMPLE DATA REPORT
Trace Level Organic Conpounds
Client Lot #...: G2I200246 Work Order #...: E844WIAC Matrix..... ....: BIOLOGIC
LCS Lot-Sample9: G213000DO-336
PreP Date......: 09/30/02 Analysis Date..: 10/06/02
PreP Batch #...: 2273336
Dilution Factor: 1
SPIKE MEASURED PERCENT
PARAMETER AMOUNT AMOUNT UNITS RECOVERY METHOD
2,3,7,8-TCDD 20.0 16.0 pg/g 80 SW846 0290
1,2,3,7,8-Pc= 100 80.5 pg/g el SW846 8290
I,2,3,4,7,8-HxMn 100 85.7 Pg/g 86 SN046 8290
1,2,3,6,7,8-BsCDD 100 84.3 Pg/g 84 SN846 8290
1,2,3,7,8,9-Md= 100 70.8 pg/g 71 SW846 8290
1,2,3,4,6,7,8-HpCDO 100 83.4 pg/g '83 SW846 8290
OCZm 200 175 pg/g 88 SW846 8290
2,3,7,8-TCDF 20.0 17.9 pg/g 90 SW846 8290
1,2,3,7,8-PeCDF 100 90.7 pg/g 91 SW846 8290
2,3,4,7,8-PeCDF 100 100 pg/g 100 SW846 8290
I,2,3,4,7,8-Hx(9P 100 81.9 pg/g 82 SW846 8290
1,2,3,6,7,8-HrCDF 100 84.1 Pg/g 84 SW846 8290
2,3,4,6,7,8-H=MF 100 82.6 pg/g 83 SW846 8290
1,2,3,7,8,9-HbcCDF 100 54.2 pg/g 54 SWB46 8290
1,2,3,4,6,7,8-HpCDF 100 85.7 pg/g 86 S9846 8290
1,2,3,4,7,8,9-BjXOF 100 63.9 Pg/g 64 SN846 9290
OCDF 200 152 pg/g 76 SW846 8290
PERCENT RECOVERY
INTERNAL STANDARD RECOVERY LIMITS _
13C-2,3,7,8-TCDD 49 (40 - 135)
13C-1,2,3,7,8-PeCDD 47 (40 - 135)
13C-1,2,3,6,7,8-HxCDD 75 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDD 71 (40 - 135)
13C-OCDD 59 (40 - 135)
13C-2,3,7,8-TCDF 45 (40 - 135)
13C-1,2,3,7,8-PeCDF 43 (40 - 135)
13C-1,2,3,4,7,8-HxCDF 74 (40 - 135)
13C-1,2,3,4,6,7,8-HpCDF 74 (40 - 135)
Calpdtlioro arepedomxd bda,c smmft b avoid romdcJl tamsla cOwWW rnma. _
Bold prim drinks caodW Qazamgga .
B212DO246 STL•Sacramento(916)373-56DO 28 of 630

BY-PASS TO NC
WTP DRAIN 4 -WASTE MIXED LIQUOR —I + PERMIT—REQUIRED INSTRUMENT
OR O3 10 SAMPLING
L POINT (OTHERS ARE FORPROCESS CONTROL)
ACID SEVER
FORCEMAIN ACID SEVER # ACID SEVER AEROBIC DIGESTER AERATION BASIN I FE1
(RESERVE AERATION 3.4 MGAL F J
FEl PH1 AS O BASIN) - 2.3 MGAL 6, 125/56 HP SURFACEE
�El i
JFE451A + FE754 `J p3 u H 4, 125/56 HP AERATORS 4
CLARIFIER 1.3 LBS 02/HP-HR
IFIER ` u
W SURFACE AERATORS TEI
d 200 FT DIA Y o 'a 1.3 LBS 02/HP-HR TWO SPEED T DIA Wa
u 14.75 FT SVD c 'a4 SVD ` o
3.47 MGALS `pH1 I MGALS `pH 1`FE 4 14
PRIMARY O W PRIMARY NC O V31
NIXEDSECONDARY CASCADE FINAL
INFLUENT 6 a EFFLUENT O LIQUOREFFLUENT AERATION AND EFFLUENT TO
NC SECONDARY DIFFUSER PIGEON RIVER
INFLUENT 5
(3 -H) CLARIFIER IFIER SE
O V54 �' 1 - J 200 FT DIA PE T ➢IA
2 FE1 LE 14.75 FT SVO I WASTE AEROBIC DIGESTER AERATION BASIN SVO # O WASTEWATER SAMPLERS
2 3.47 MGALS I SLUDGE (RESERVE AERATION
64 MGAL6 HP SURFACE MGALS 13
TOWN OF = I 4, 125/56 HP AERATORS LL LOW LIFT — TIME PACED
CANTON VV CANTON ICE, SURFACE AERATORS 1.3 LBS 02/HP-HR
}<\ I 1.3 LBS 02/HP-HR TWO SPEED
$ SPILL i I --------- I RETURN As ACID SEWER — TIMED PACED
`per p[ COLLECTION SLUDGE
MILL SEVER GRIT BAR CLARIFIER CLARIFER RETURN SLUDGE
FROM 4A MH CHAMBER SCREENS 125 FT DIA L- ----- PE PRIMARY EFFLUENT — TIME
MILL SEVER 11 FT SVD O T PACED
O 4 B IS MGD, EACH IN 1.01 MGALS 9 %1
LL 2 SETS - 1 FIXED I I `FJ sE SECONDARY EFFLUENT
' AND 1 VARIABLE FEl - FLOW PACED
O VIP DRAIN I I 6
SPEED IN EACH SET PRIMARY SLUDGE ��_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - IFIERJf� _� _ _ J L T DIAVASTE SLUDGE 6 I SVDINSTRUMENTS
FILTRATE MGALS SEASONALFEUSE CLARIFIER rl FLOW ELEMENT — FLUME
CONTROL LOOPS I l J FE
I FILTRATE 12 LJ OR MAG METER
LOW LIFT LEVEL — CONTROLS VARIABLE SPEED 11 CALCULATED TOTAL INFLUENT LOADING `T� TEMPERATURE ELEMENT
LOW LIFT PUMPS TO MAINTAIN LEVEL SETPOINT I IS
OF 14 FEET (21 FT IS OVERFLOW) LL FLOW = SE FLOW — AS FLOW cE CONDUCTIVITY ELEMENT
SLUDGE DEVATERING C 1
4, 2-METER BELT DEVATERED `J
PRIMARY INFLUENT pH — CARBON DIOXIDE FEED — PRESSES SLUDGE TO C LL FLOW X LL CONC ) + C AS FLOW X AS CONC )
TO LOW LIFT PUMPS LANDFILL TI CONC = --------------------------------------------- PH pH ELEMENT
SE FLOW
SECONDARY INFLUENT pH — SULFURIC ACID LE1 LEVEL ELEMENT
(H2SO4) FEED TO PRIMARY EFFLUENT TI MASS = TI CONC X SE FLOW L J
0 MS 0 CW + 0 AS + 4O LL + SO TI O6 PI O7 SI O8 ML O9 RL 10 WAS 11 PS 12 ♦ 13 SE + 14 FE
MILL SEWER CANTON ACID SEWER LOW LIFT TOTAL PRIMARY SECONDARY MIXED RETURN WASTE MIXED PRIMARY SLUDGE PRESS SECONDARY FINAL
WASTEWATER FORCEMAIN INFLUENT INFLUENT INFLUENT INFLUENT LIQUOR SLUDGE LIQUOR SLUDGE FILTRATE EFFLUENT EFFLUENT
26 TO 29 MGD 0.9 MGD 3.0 MGD 26.9 MGD 29.9 MGD 29 TO 32 MGD 60 MGD 60 MGD 15 TO 30 MGD 0.5 TO 1.5 MGD 0.6 MGD 0.55 MGD 29.9 MGD 29.9 MGD
NEUTRAL AND TOWN OF CANTON ACID FILTRATES INFLUENT TOTAL INFLUENT INFLUENT TO INFLUENT TO ACTIVATED SLUDGE RETURN ACTIVATED WASTE ACTIVATED PRIMARY CLARIFIER FILTRATE FROM COMPLIANCE COMPLIANCE
AKALI MUNICIPAL FROM BLEACH WASTEWATER WITH TO WASTEWATER PRIMARY TREATMENT SECONDARY MIXED LIQUOR SLUDGE SLUDGE SLUDGE SLUDGE MONITORING POINT MONITORING POINT
WASTEWATER
ER WASTEWATER PLANTS AND WASTE EXCEPTION OF ACID TREATMENT FOR INCLUDING WASTE TREATMENT OE WATERING FOR DISSOLVED
STREAMS FROM MILL ACID FROM C102 SEVER PERMIT-REQUIRED SLUDGE, FILTRATE INCLUDING RETURN 2500 TO 4500 MG/L 50 TO 100% OF WASTED TO FIBER AND PRIMARY FLOW OXYGEN,
CHLORINE GENERATION REPORTING AND WTP DRAIN ACTIVATED SLUDGE 3000 MG/L TARGET FORWARD FLOW AEROBIC DIGESTION SETTLEABLE SOLIDS 15 MEASURING DEVICE TEMPERATURE,
DISINFECTION 3, B-HOUR TIME 65% VSS AT 2 TO 5% OF PLUS WASTE - 8 FT PARSHALL CONDTIVITY AND PH
INCLUDES 111, 2, SYSTEM OPERATED DISCHARGED TO COMPOSITE SAMPLES CALCULATED FROM MAY OR MAY NOT pH CONTROL POINT 5000 TO 10000 MG/L FORWARD FLOW TO ACTIVATED SLUDGE FLUME
2B, 3, 3A, 4, 5A 6 BY TOWN EITHER PRIMARY EACH DAY TO LOW LIFT AND ACID INCLUDE ACID FOR H2SO4 SYSTEM, DISCHARGED TO 7500 MG/L TARGET MAINTAIN TARGET AND FILTRATE DEWATERE D MEASURED AT END
5B SEVERS INFLUENT OR CREATE A 24-HR SEVER COMPOSITE SEVER NUTRIENTS ARE SECONDARY MLSS SLUDGE 3. 8-HR FLOW OF CASCADE
FLOW METER PRIMARY EFFLUENT COMPOSITE SAMPLES NH4 4 PO4 CLARIFIERS FOR CONTINUOUS SLUDGE COMPOSITE SAMPLES
INCLUDES 6A ACID OPERATED BY TOWN TO MINIMIZE pH CONTROL POINT SETTLING AND CAN BYPASS WITHDRAWAL 300 WET TPD EACH DAY TO
SEWER BYPASS AS SEVER-GENERATED 2-HR B 8-HR SEE CALCULATION FOR CO2 SYSTEM, SI = PE IF AS RETURN DIGESTION TO WTP CREATE A 24-HR
REQUIRED COLOR, 24-HR COLOR COMPOSITE NOTES IN DRAWING POLYMER ADDITION ADDED TO P1, DRAIN TARGET C 2 FT 25 TO 45% SOLIDS COMPOSITE SAMPLE
TIMED COMPOSITE SAMPLES FOR BMP POINT FOR PRIMARY OTHERWISE I TO 5% WASTING SLUDGE BLANKET BULKED WITH BARK
SAMPLE PROGRAM TREATMENT SI = PE + AS RATE I
AS REQUIRED
WASTEWATER TREATMENT SIMPLIFIED PFD WITH COMPLIANCE AND PROCESS CONTROL SAMPLE NOTES
BLUE RIDGE PAPER PRODUCTS INC. — CANTON MILL — NPDES NC0000272
P. DICKENS REV 0 8/19/05

BLUE RIDGE
PAPER PRODUCTS INC.
February 27, 2001
Mr. Forrest Westall FEB 2 8 2001 J J
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources V" TEROUAUTYSEL'TIOi!
59 Woodfin Place AS44EVIlL ftEGICIALOFFICE
Asheville, NC 28801
RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc. March 1, 2001
Report On End-Of-Pipe Color Reduction Technologies and Ongoing and Planned
Color Reduction Activities
Dear Mr. Westall:
In accordance with Part III, Section E(14) of the above-referenced N PDES Permit,
Blue Ridge Paper Products Inc. (Blue Ridge) submits this report on end-of-pipe color
reduction technologies and other ongoing and planned color reduction activities.
Attached is a report prepared by Jacobs Engineering Group, Inc. on behalf of Blue
Ridge on end-of-pipe color removal technologies. With the submittal of this report,
Blue Ridge or its predecessor will have evaluated these technologies three times in
the past thirteen years in an effort to identify either a breakthrough improvement in
color removal efficiency or reduction in cost. It is clear that, among these prescribed
end-of-pipe color removal technologies, no breakthrough in economic or technical
feasibility is likely to occur. During this same period, however, alternative
technologies (including oxygen delignification, Elemental Chlorine Free bleaching,
Bleach Filtrate RecycleTN and those technologies comprising the "Near-Term"
package) were implemented resulting in significant improvements. Therefore, based
upon this record, it is Blue Ridge's intention in the future to focus primarily on'the
potential treatment of selected, colored wastewater streams before they enter the
wastewater treatment plant (WWTP). These wastewater streams hold the greatest
likelihood of success for future color reduction, and Blue Ridge believes its time and
resources would be better devoted to in-mill treatment of particular wastewater
streams. Blue Ridge requests that this change in focus be incorporated into the next
NPDES Permit and Color Variance Review for the Canton Mill.
Since the issuance of the Permit, Blue Ridge or its predecessor has undertaken the
following color reduction activities:
1. Identified and implemented certain Best Management Practices (BMP's) to
reduce color. The following BMP's were implemented before June 1, 1998,
and a report on the implementation was submitted to DWQ, the TRW and
the NPDES Committee on that date.
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

a. Installation of replacement digester recirculation pu mps.
b. Installation of a double-chambered pine courtyard spill collection
sump.
c. Installation of weak black liquor tank containment, and
d. Correction of evaporate set demister clogging, installation of
condensate instrumentation and sampling ports for the evaporator
set and assurance of continued dry conveying of knot rejects.
2. Submitted Low Flow Contingency Plan to DWQ and TRW by December 1,
1998 (approved by NPDES Committee in February 1999).
3. Prior to December 1, 1998, complied with a reduced color limit in the
Permit of 60,000 lbs. per day (annual average) and 69,000 lbs. per day
(monthly average).
4. Began implementation of partial Eo stage filtrate recycle on the hardwood
line before January 1, 1999 and submitted a report on the color reduction
benefit resulting from the partial implementation and a projection of
potential color reduction benefit to be gained from full implementation of
BFR on the hardwood line to DWQ, TRW and the NPDES Committee by
December 1, 1999.
5. Submitted a color limit feasibility report to DWQ, TRW and the NPDES
Committee before January 1, 2001, which concluded that the Canton Mill
could comply with a color limit within the range of 48,000-52,000 lbs. per
day (annual average).
Implementation of these BMP's, together with improved mill operations, has reduced
color by 32% over the term of this NPDES Permit (see attached graph). As
described in the January 1s`, 2001 Report, the mill has achieved a target annual
average color loading of 48,000 — 52,000 pounds per day. Based on data received
from the National Council on Air and Stream Improvement (NCASI), the Canton Mill
has the lowest color of any mill in our industry category.
In addition to the aforementioned activities, Blue Ridge has conducted the following
activities:
Polyamine trials have recently been conducted at the primary clarifier, secondary
clarifier, and colored in-mill wastewater streams. Numerous trial approaches were
conducted to comprehensively study the effectiveness of polyamine for color
removal. While treating colored wastewater streams in the pulping and recovery
area appeared to remove color, the color bodies re-solubilized and there was no
significant reduction in secondary effluent color. Treating the primary clarifier
resulted in color reductions, but sludge quality declined to an unmanageable
condition and recycled belt press filtrate solids increased significantly. Treating the
secondary effluent resulted in color reductions; however, this type of treatment
would require the installation of equipment and operating costs described in the
attached Jacobs Engineering Group, Inc. report.

As described earlier, Blue Ridge recommends a shift in the treatment technology
evaluation focus from end-of-pipe to the treatment of selected colored wastewater
streams. Blue Ridge intends to evaluate and report on the treatment of selected
colored streams in the pulping and recovery areas and requests this change in focus
be incorporated into the next Canton Mill NPDES Permit and Color Variance review.
Blue Ridge Paper Products would appreciate you distributing the enclosed copies to
the members of the Technology Review Workgroup. Please call Derric Brown,
Manager - Environmental Affairs at [phone] or the undersigned at (828) 646-
2033 if you have any questions or need additional information.
Sincerely,
Robert Williams
Director - Environmental, Health, and Safety Affairs

Canton Mill Secondary Effluent Color Performance
Annual Averages: 1988 - 2000
400,000 Including Permit Limitations
Permit Limitations:
350,000 1-258,945#/d Monthly Ave.efl.4/14/94
2-172,368#/d Annual Ave.eft.4114/94 -
3-125.434#/d Monthly Ave.efl.12/12/96
4-98.168#Id Annual Ave off.12/12/96
6-95,000#/d Monthly Ave off.1/1/98 1
300,000 6-69,000#/d Monthly Ave.efl.1211/98
a 7-60,000#/d Annual Ave.efl.1211/98
t0 8-48.000-52,000#/d Target Annual Ave
N
250,000
1
`o
0
U
Y
w 200,000
7
Ul
W
9 150,000 2
c
0
u
m 3
N
100,000
4 5
50,000 6 7 8
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000
M Permit Limitaions +SE Color Annual Ave. Wd
Blue Ridge Paper Products, Inc.
Canton, NC 2/27/01

BLUE RIDGE PAPER PRODUCTS INC.
copy: Keith Haynesro
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

9 �
BLUE RIDGE
PAPER PRODUCTS INC.
April 27, 2001
11 I_, APR 3 0 2001'
Mr. Dave Goodrich
NPDES Unit Supervisor
C u R0!'h! ySECI1O'•i
North Carolina Department of -
Environment and Natural Resources
512 North Salisbury Street
Raleigh,NC 27604
Dear Mr. Goodrich:
The purpose of this letter is to request an exemption from the Centralized Waste Treatment
(CWT) Point Source Category 40 CFR Part 437. The Canton Mill treats wastewater from the
Town of Canton.
The reason for this request is 40 CFR Part 437.1 b2b which states, in part, as follows:
"...demonstrates that the off-site wastes are of similar nature and the treatment of such wastes
are compatible with the treatment of non-CWT wastes generated and treated". The Canton Mill
began treatment of the Town of Canton's wastewater when wastewater treatment plant
operations began prior to February 24, 1964 (Agreement Attached).
The continuing treatment of municipal wastewater from prior to 1964 to present and the
excellent wastewater treatment plant performance demonstrate that off-site wastes are similar in
nature and compatible with the treatment of non-CWT wastewater.
If you have any questions or need additional information please call me at(828) 646-2318.
Sincerely,
Derric Brown
Manager, Environmental Affairs
xc: Forrest Westall
Mike Meyers
RMftj ayrie�
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

Canton,North Carolina 28716 t Vice President—Operations Manager ,
• ' 704 646-2840, Canton Mill
U Champion
Champion International Corporation
February 26 , 1990
Mr. William G. Stamey
Manager
Town of Canton
Canton, North Carolina 28716
Dear Mr. Stamey:
Pursuant to your -inquiry regarding an Economic
Development Assistance Grant, Champion International
Corporation agrees to allow the Town of Canton to
increase its wastewater volume by 300,000 gallons per
day. This allowance brings the total allowable
volume to 900, 000 gallons per day (dry weather) , and
is subject to the terms and conditions of the present
agreement, dated February 28, 1964, as the same may
be modified or superseded by future agreement between
Champion and the Town of Canton.
This additional volume, and that already collected in
the Town of Canton municipal sewer system, will be-
treated in the wastewater treatment system owned and
operated by Champion International- Corporation in
Canton.
If you require further information, please contact me
directly.
Sincerely,
J. Ross Kilpatrick
Vice President - Operations Manager
s

P
BLUE RIDGE
j PAPER PRODUCTS INC.
May 22, 2001
Mr. Keith Haynes
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
RE: Wastewater Release Response Evaluation,NPDES Permit NC0000272
May 17, 2001
Dear Mr. Haynes:
Blue Ridge Paper Products Inc. is providing written notification as a follow-up to Louie Justus
telephone call to you on May 17, 2001. Please contact Louie Justus at [phone] if
additional information is needed.
Sincerely
Louie Jus jJ :es A. Giauque
Sr. Environmental Engineer pal Environmental Engineer
copy: Derric Brown .
200,
f �
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

i
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Sewage Spill Response Evaluation
(1 of 3)
Permittee: Blue Ridge Paper Products Inc. Permit Number: NC0000272 County: Haywood
Incident Ended: (Date/Time) 5117101 / 3:15 p.m. Estimated Duration(Time) I hour 45 minutes
First knowledge of incident: (Date/Time) 5117101 / 1:30 p.m.
Estimated volume of spill/bypass 105 gallons. Show rational for volume.
Visual observation used to estimate flow. Pencil size stream flowing from top of manhole. Flow was
estimated at 1 gpm.
If spill is ongoing, please notify Regional Office on a daily basis until spill can be stopped.
Reported to: Mr. Keith Haynes (Date/time) 5117101 / 2:35 p.m.
Weather conditions: clear and sunny
Source of spill/bypass (check one): ®Sanitary Sewer Pump Station E]WWTP
Level of treatment(check one): ®None Primary Treatment
Secondary Treatment Chlorination Only
Did spill/bypass reach surface waters? ®Yes ❑No (If Yes, please list the following)
Volume reaching surface waters? < 105 gallons
Name of surface water: Pigeon River
Did spill/bypass result in a fish kill? Elyes ®No
If Yes, what is the estimated number of fish killed? N/A
Please provide the following information:
1. Location of spill/bypass: North of Champion Drive in coal unloading and fresh water treatment
Area. The manhole is located on the right side of the mill road and north of the second coal
conveyance tower from the coal unloading process.
2. Cause of spill/bypass: Plugged sewer line from restroom at coal unloading process.

Sewage Spill Response Evaluation
(3 of 3)
Permittee: Blue Ridge Paper Products Inc. Permit Number: NC0000272 County: Haywood
8. Repairs made are: ®Permanent Temporary
Please describe what repairs were made. If the repairs are temporary, please indicate a date by
which permanent repairs will be completed, and notify the Regional Office within 7 days of the
permanent repair:
Plugged line was cleaned using high pressure jet truck
9. What actions have been made to prevent this discharge from occurring again in the future?
Through cleaning of line.
10. Comments:
Other agencies notified:
Person reportingspill/bypass: lou;S ZKSTS Phone Number: 82$-6,16-2372
Signature: Date: S 17 40o l
For DWQ Use Only:
DWQ requested additional written report? Yes No
If yes, what additional information is needed?
Requested by:

QUESTIONS FOR BLUE RIDGE, TO CLARIFY THEIR 5/18/2001 COMMENTS
Prepared by the EPA Tech Team, MAY 25, 2001
Please see Blue Ridge's responses in bold.
Introduction: What is the long-term average color discharge (lb/day) on which further color
improvements will be built?Figure 2.6 in the materials presented to the Tech Team on March 14,
2001 presented a color balance for 9/l/00 to 12/31/00. The average color load was 37,696
lbs/day. Should this be considered the baseline long-term average?
Blue Ridge's response:
On December 28, 2000, the Canton Mill submitted a Color Limit Feasibility Report as
required by the Color Variance and NPDES Permit. The report included a statistical
analysis using a 95`h percentile confidence interval and concluded that an annual daily
average color of 48,388 lbs/day and monthly average color of 55,556 lbs/day were
achievable discharge limitations.
This represented a 20% reduction in the color discharge permit limitations in effect at that
time.
The EPA Technology Review Workgroup (TRW) accepted this analysis and recommended
to the North Carolina Department of Environment and Natural Resources (NCDENR)that
a new daily limit of 48,000 lbs/day and new monthly limit of 55,000 lbs/day be adopted as
the new limitations. Those limits became effective on May 1,2001.
1

The data set that was used to calculate these new limits was based on the period from
January 1998 through October 2000. There are two important reasons this analysis
continues to be representative of the long term average color discharge:
1. In November of 2000, substantial process improvements were implemented on No.
19 Paperboard Machine to improve product quality and yield. No. 19 Paperboard
Machine manufactures over half of the total daily production of the Canton Mill.
As of June 5, 2001, this machine is still under-performing,which limits pulp mill
production by as much as 100 to 150 tons per day. During November 2000, an
equivalent of one fiberline was out of service.
2. In order to investigate opportunities for further color control,the Canton Mill
conducted polyamine trials in January 2001. The trials were not successful but did
have some marginal color removal benefit while creating substantial upsets in the
wastewater treatment system.
Therefore, under no circumstance is the 9/1/00 to 12/31/00 period representative of long
term achievable color performance. As has been previously reported, this period was
selected and submitted to the EPA's TRW to illustrate the effect turbidity has on influent
color and the favorable impact of the new NCASI color test method on reducing turbidity
interference.
Attached is the primary influent and secondary effluent color data file from November
2000—April 2001 that you requested in your May 24, 2001 email. While Blue Ridge is
2

providing this information, it should not be used as the basis for future color limitations or
an evaluation of the baseline long-term average.
1. BFR Reliability Improvement
Why will O&M costs for the MRP increase by $85,000/year as shown in Table 1,with the
improvements to the reliability of the MRP? (Improvements include a new media filter and
softener,rebuilding piping and valves, and changing materials of construction.)
Blue Ridge's response:
The $85,000/year in additional costs for MRP O&M is a conservative estimate of the actual
costs associated with operating and maintaining the additional equipment. This cost
estimate is based primarily on replacement of resin for the softeners and sand for the
media filters.
2. Improved Black Liquor Control
100
kg/t
Figure 1
75 Daily color at influent to WWTP for Canton
50
25
0 30 60 90 120 150 180
Plot - daily color at influent to WWTP for Canton: The plot depicts influent color for the first six
months of 2000. There was some confusion in the units used in the plot presented in the May 4
3

draft memo. Figure 1 is a redrawn graph, with units correctly presented as kg/t.
How does `sewer generated color' contribute to the variability of the color measured at the
influent to the wastewater treatment system?
Blue Ridge's response:
Sewer generated color (SGC) is measured in the primary influent and contributes color to
the primary influent from sources that cannot be directly measured at the source(i.e.
fiberlines). SGC is one contributor to unaccounted color as shown in Section 2 of the
March 14, 2001 materials submitted to the Technology Review Workgroup. Generally,
monthly average color is higher and the primary influent color variability is higher when
the SGC phenomenon occurs.
How does the variability of the daily measurements of color influent to treatment measured in
the last half of 2000 and to date in 2001,when Blue Ridge used the "new"NCASI color method,
compare to the first half of 2000, when the standard NCASI method was used? (Note,Blue
Ridge reported that the new NCASI method reduced the apparent `sewer generated color,'
because of the addition of a buffer to test samples. If `sewer generated color' contributes to
variabilty,measurements using the"new" method should have reduced variability.)
Blue Ridge's response:
The new NCASI method demonstrated slightly less variability in the last half of 2000 and
to date in 2001 compared to the standard NCASI test method in the first half of 2000.
Please note that the new NCASI color test method was developed to reduce the effects of
turbidity interferences, not sewer generated color. The new NCASI color test method does
4

not reduce the fraction of unaccounted color caused by sewer generated color. However,
the new NCASI color test method does reduce, on average, the unaccounted color by
reducing the turbidity interferences in the primary influent. Currently, the primary
influent color measurement using the new NCASI color test method is generally within
10% of the sum of the individual sources, which, in effect, reduces the "unaccounted color"
component to within the error of the color test method (i.e., all primary influent color is
generally accounted for by process area).
On page 5 of the Tech Team's May 4 draft memorandum,we explained that we assumed that the
80001b/day removed from the treatment system influent by reducing black liquor losses was
equivalent to a 6,100 lb/day decrease in the average final effluent color load. That is, we
assumed that the treatment system removed 24% of the color in the black liquor spills. To what
degree does Blue Ridge assume color originating from black liquor is removed by the treatment
system? (What percent removal?) What is the justification for this assumption?
Blue Ridge's response:
Based on previous studies conducted at the Canton Mill by Duke University graduate
students, an average of 64% of brown color (i.e. black liquor) was removed across the
simulated wastewater treatment plant while bleach color increased on average a small
percentage across the simulated wastewater treatment plant. Table 1 is a summary of the
brown and sewer generated color studies.
To what extent has Blue Ridge analyzed the specific variability of the influent color? What are
the sources of color spikes during the last half of 2000 and to date in 2001?
5

Blue Ridge's response:
Blue Ridge tracks primary influent, secondary effluent and the discrete source
contributions to the primary influent on a daily basis. When color is elevated, the mill
investigates to determine the probable cause. Primary influent color spikes in the past year
resulted from maintenance outages, equipment failures and process variability. Equipment
failures include a broken black liquor line and problems with the MRP and CRP. Process
variability includes BFR operation, problems associated with under cooked or"raw"
digester blows and issues discussed in the first part of this report. While there is detailed
planning for scheduled outages, we continue to learn ways to improve outage execution to
minimize the color discharged.
3. Ozone/C102 stage for HW line
Please provide the details of Dr. Liebergott's analysis of the color reduction that would result
from use of ozone on the HW bleach line.
Blue Ridge's response:
A report on the application of ozone on the hardwood line conducted by Mr. Norm
Liebergott, Ph.D., President of Liebergott and Associates Consulting Inc., and Mr. Lewis
Sbackford,Vice President, GL&V Pulping Group Inc. will be submitted to you and will
include an analysis of the estimated potential color reduction benefits.
Why does Blue Ridge question its ability to purchase the electricity needed for the ozone
6

generation system? What are the limitations of their"power supply capability."
Blue Ridge's response:
The utility substation for the Canton Mill is very near its maximum capacity. Current in-
mill transformers will not have the capacity to supply power to an ozone generation system.
Therefore, additional substation capacity, in-mill power distribution systems and
transformers would be required.
4. 2"d Stage OD for Pine Line,With Increased BFR Closure
Recently installed 2-stage OD systems have achieved greater than 60% delignification. Why
does Blue Ridge believe that 50 to 55% delignification is the maximum they will be able to
achieve on their pine line?
Blue Ridge's response:
For the Canton Mill's pulp, 60% delignification would yield unmanageable viscosities in
the pulp, which would cause No. 19 Paperboard Machine to have major probleg with
,h ,
paperboard strength characteristics. Liebergott and Sbackford believe maximum
sustained delignification rates would be in the 50—55% range. While 60% delignification
may be achievable on a short term basis, the maximum sustained delignification rate would
be in the 50—55% range.
Please explain the reference to "the new digester option... for NOx compliance," mentioned on
the top of Page 3 of 5. How will a new digester reduce NOx emissions?
7

Blue Ridge's response:
New digester systems would be more efficient and require less steam. Reduced steam
production would result in less NOx emissions from the power boilers.
Blue Ridge comments that 80% closure is the maximum they can achieve while maintaining a
metals purge. During the March 14 mill visit we were told that brown stock washing hydraulics
was the factor limiting how much of the bleach plant filtrate could be recycled. Please explain
what limits the pine line closure.
Blue Ridge's response:
While system hydraulics is a factor limiting bleach filtrate recycle, the primary factor
limiting filtrate recycle is the requirement to purge metals. The hydraulic limitation is
based on the recycled filtrate's propensity to scale (i.e. fiberlines, Brownstock washing,
evaporators, recovery furnace(s)). Scaling would result in additional process variability.
Through trial and error,the mill has optimized the metals purge rate via the MRP and
determined that an 80% closure rate, or a 20% bleach plant filtrate purge rate, maintains
an equilibrium concentration of non-process elements (metals),which does not cause severe
process scaling. Process scaling results in a cycle of poor brown stock washing, carryover
to the bleach plant, compensation in the bleach plant due to carryover, and ultimately,
additional color discharged to the wastewater treatment plant. Scaling can also affect the
black liquor evaporators and recovery furnace(s) resulting in additional process variability
and color.
8

Is the only color reduction benefit from 2nd stage od the reduction in the color of those filtrates
not captured by and reused in BFR?
Blue Ridge's response:
Yes, the only color reduction benefit from a 2-stage oxygen delignification system is the
reduction in color from a kappa reduction in the incoming pulp, and therefore, there is less
color in the bleach plant filtrates not recycled (i.e. the 20% which is purged for metals
control).
What is the discharge of color from the pine line bleach plant when BFR is operating at 80%
closure?
Blue Ridge's response:
At closure rates close to 80%, pine DI and Eo stage color is typically in the 6,000—8,000
lb/day range. However, adjustments to pulp quality parameters (primarily viscosity) to
support the No. 19 Paperboard machine have resulted in process changes in the pulping
and bleaching operation. These changes include increased pulp kappa into the bleach
plant which results in additional bleach plant filtrate color of the purge stream at any given
rate of bleach plant closure.
The first C102 stage currently uses 19.5 kg/MT C102.
Blue Ridge's response:
The Canton Mill's first C102 stage actually uses about 14.5 kg/MT C102.
9

If 2nd stage OD is added, the C102 would drop to 13.4 kg/MT, a 30%reduction.
Blue Ridge's response:
If a 2-stage oxygen delignification system were added, and C102 usage was reduced by
30%, C1O2 required in the first bleach stage would be approximately 10.1 kg/MT, not 13.4
kg/MT.
This suggests that the quantity of chloride to be removed from the liquor system by the CRP will
also drop by 30%, so that the quantity of filtrate to be discharged will drop in proportion, thus
reducing the color of the untreated effluent.
Blue Ridge's response:
Blue Ridge estimates that a 30% reduction in C1O2 usage on the Pine D1 stage would result
in approximately a 20% reduction in the total chloride input to the liquor cycle. Supply
wood and caustic also contribute chloride to the liquor system.
If the color discharge from the CRP is in the range 6000 to 7000 lbs/day, a 30%reduction would
amount to about 20001bs/day. Please comment.
Blue Ridge's response:
A reduction in chlorides does not necessarily translate into a reduction in the amount
purged from the CRP or to a reduction in color in the CRP purge. While reduced liquor
system chlorides may translate into a reduced CRP purge rate, a reduced purge rate would
not be expected to result in a reduction of the total mass of color in the CRP purge.
Chloride purging and CRP color are independent variables. The amount of color in the
10

precipitator-CRP loop is independent of chloride loading. Therefore, any reduction in
volumetric flowrate of the purge stream made possible by reduced chloride loading would
not reduce the amount of color 'purged' from the CRP. Since the absolute mass of color
would not change, the concentration of color in the purge stream would be expected to
increase accordingly resulting in no change in the total mass of color purged.
5. Removal of color from the CRP purge
We are not sure of the best estimate of the contribution of the CRP purge to the final effluent
color. Our site visit notes say that CRP carries 7000 lb color/day. Our calculations were based
on a final effluent discharge of 6000 lb/day. What is the best estimate?
Blue Ridge's response:
The CRP purge has approximately 4,500—5,000 lbs/day of color. Assuming CRP color is
treated similarly to brown color, a 64% reduction in CRP color would result in
approximately 2,300 lbs/day of discharge color.
We agree that treatment technologies other than precipitation should be investigated for the CRP
purge stream. What other treatment technologies has Blue Ridge explored? Have you
investigated the effectiveness of ozone treatment (or ozone-UV treatment) on color removal from
the CRP purge stream?
Blue Ridge's response:
Other potential color reduction technologies for the CRP purge stream have not been
investigated. Attached is Table 2,which summarizes the results from laboratory tests
treating the CRP purge with different sources of lime(or calcium).
11

6. Summary
final effluent color reduction lb/day
Process Tech Team Blue Ridge
BFR reliability improvement >6000 2000 to 4000
plus BMP improvement.
ZD on HW line 3000 to 6400 3550
2 stage od 1500 to 2000 tech team's color reduction is
appropriate range, but disagree
on yield improvement
CRP treatment up to 6000 <<4800*
*the Tech Team understood the 60001b/day as the CRP contribution to the final effluent.
Blue Ridge says it is 60001b/day in the influent and that it may be preferentially treated in
the WWTP, so that actual final effluent contribution is much less than 48001b/day.
Blue Ridge's response:
See response to #5, "Removal of color from the CRP purge"
12

Table 1: Brown Color Source Removal Across The Wastewater Treatment Plant
Blue Ridge Paper Products Inc., Canton Mill
Date of Study Objective of Study Experimental Description Results
On average, SGC for Pine D1 was 32-
47% and SGC for Hwd D1 was 64-88%.
To determine if Sewer SGC was created by increasing the pH of Data suggested some hardwood SGC
Generated Color(SGC) is bleach plant filtrates to 11 and raising the may be removable across the WWTP
Aug-95 removed across the temperature. This blend was then run through (3/o reduction in color after WWTP
process), but Pine filtrates
wastewater treatment plant a simulated WWTP process and the final color f21 /o in the
wed an
(WWTP). was analyzed. average increase in color of 2
simulated WWTP process. Data from this
study show brown source color removal
up to 70%.
To determine what type of Desorption experiments were conducted by
color the WWTP is desorbing color off the biosolids in reactors Brown color sources were removed
Aug-94 removing and what factors (simulated WWTP) and adding different color across the reactors on average 62%
sources back to the reactors. Color was again while bleach plant color increased on
are significant in the color desorbed to gage the extent physical color average 3%across the reactors.
removal process. adsorption was occurring.*
Above research conducted by Duke University graduate students for Champion International Corporation's Canton Mill.
*It is shown in previous studies (Stratton 1986)that much of the color removal that occurs across the WWTP is a result of physical
adsorption of color bodies to the biosolids. Generally, the higher the molecular weight of the solute, the easier it is adsorbed. Brown color
is known to have a higher molecular weight(McCord 1994).

Brown Color Removal
Table 2
Calcium Dose % color lb. Per day to treat % volume of sludge tons/day
source Ib./gal.purge removal 10 GPM of purge layer produced waste generated
lime mud 0 0 0 0
lime mud 0.69 -17 9936 4 5.0
lime mud 1.39 -11 19872 8 9.9
lime mud 2.78 7 39744 16 19.9
fresh lime 0 0 0 0
fresh lime 0.69 -47 9936 8 5.0
fresh lime 1.39 27 19872 15 9.9
fresh lime 2.78 64 39744 50 19.9
calcium chloride 0 0 0 0
calcium chloride 1.06 68 15264 10 7.6
calcium chloride 1.39 71 20016 15 10.0
calcium chloride 2.78 82 40032 35 20.0
calcium chloride 4.17 92 60048 50 30.0
milk of lime 0 0 0 0
milk of lime 3.97 28 57168 80 28.6
milk of lime 7.94 57 114336 90 57.2
Notes: _
1. Lime mud as 70% solids cake
2. Fresh lime is calcium oxide from supplier
3. 77% comercial grade calcium chloride
4. Milk of lime is 17.5%slurry and the resulting sludge layer required 30 minutes settling.

BLUE RIDGE
PAPER PRODUCTS INC.
April 27, 2001
Mr. Dave Goodrich
NPDES Unit Supervisor
North Carolina Department of
Environment and Natural Resources
512 North Salisbury Street
Raleigh,NC 27604
Dear Mr. Goodrich:
This letter is to certify that chlorophenolic containing biocides are not used at Blue Ridge Paper
Products Inc., Canton,North Carolina Mill.
If you have any questions or need additional information please call me at(828) 646-2318.
Sincerely,
Derric Brown
Manager, Environmental Affairs
xc: Forrest Westall
Mike Meyers
Keith Haynes
0 ZQ
—'"' �tiR�U`pSP1.04FCr
� p5HEV1�
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

State of North Carolina - V '�
Department of Environment e
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor NCDENR
William G. Ross, Jr., Secretary Noa CAROLINA DEPARTMENT OF
Ken-T. Stevens, Director ENVIRONMENT AND N/W RESOURCES
April 30,2001
Mr.Robert Cicale
Mill Manager
Blue Ridge Paper Products �( I ' MAY P.O.Box 4000 Lill (� 9i �U j
Canton,North Carolina 28716 Subject: Interim Color Limit �s
Permit No.NC0000272
Blue Ridge Paper Products Inc. I,___, ;,yi_•�p,� ,_,,, ,„ Cilr„, p
Haywood County
Dear Mr. Cicale:
The Division of Water Quality issued NPDES Permit NC0000272 to Blue Ridge Paper on December 22,
1997. Tine permit contained a condition requiring a review of the color limit by the Technology Review
Workgroup(TRW). The TRW has reviewed the mill's performance information and determined that it is
economically feasible for the mill to achieve an annual average color loading of 48,000 lbs/day and a monthly
average color loading of 55,000 lbs/day.
As stipulated in the NPDES permit,recommended color levels within the range of 48,000—52,000 lbs/day,
shall become effective May 1, 2001, after written notification from the Director of the Division of Water Quality.
Blue Ridge Paper is hereby notified that beginning May 1,2001 and lasting until expiration of NPDES Permit
NC0000272, on November 31,2001,the annual average color limit shall be 48,000 lbs/day and the monthly
average color limit shall be 55,000 Ibs/day. All other conditions of the permit, including the color monitoring
frequencies, sample type and color compliance points,remain as stipulated in NPDES permit NC0000272.
These limits are an enforceable part of the permit and Blue Ridge Paper is subject to enforcement action if the
mill fails to comply. If you have any questions concerning this permit modification, please contact Michael
Myers at(919) 733-5083, extension 508.
4CJ nceIE1 .
Ke to ens
cc: Central Files
CA�e�ille_Reg�onaI Offce ;Wa`_tei ua i —Section
Point Source Compliance Enforcement Unit
NPDES Unit
Bob Williams—Blue Ridge Paper
Derek Brown—Blue Ridge Paper
Don Anderson—Environmental Protection Agency
Mark Perez—Environmental Protection Agency
Paul Davis—State of Tennessee
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 Telephone[phone] FAX[phone]
An Equal opportunity Affirmative Action Employer VISIT US ON THE INTERNET @ htip:/1h2o.enr.state.nc.us1NP0ES

r-
BLUE RIDGE
PAPER PRODUCTS INC.
April 27,2001
Mr. Dave Goodrich
NPDES Unit Supervisor
North Carolina Department of
Environment and Natural Resources
512 North Salisbury Street
Raleigh,NC 27604
Dear Mr. Goodrich:
This letter is to certify that chlorophenolic containing biocides are not used at Blue Ridge Paper
Products Inc., Canton,North Carolina Mill.
If you have any questions or need additional information please call me at(828) 646-2318.
Sincerely,
7e'�e-c=
Derric Brown
Manager, Environmental Affairs
xc: Forrest Westall
Mike Meyers
Keith Haynes
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

xc: Paul Davis
Director, Water Pollution Control
Tennessee Department of Environment and
Conservation
150 9" Avenue, 4" Floor
Nashville, Tennessee 37243-1534
Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville, NC 28801
Keith Haynes
Environmental Specialist
North Carolina Department of Environment
and Natural Resources Q �]
59 Woodfin Place u
.Asheville, NC 28801 p 2 6 va
��RE��GF4SC0
I�Z\F.R1 a

n
BLUE RIDGE
PAPER PRODUCTS INC.
February 21 , 2001
Mr. Dave Goodrich, NPDES Unit Supervisor
North Carolina Department of
Environment and Natural Resources
512 North Salisbury Street
Raleigh, NC 27604
Dear Mr. Goodrich:
Please find the enclosed EPA Forms 1 and 2C for the renewal of Blue Ridge
Paper Products Inc.'s (BRPP) Canton Mill NPDES permit NC0000272. As you
are aware, this facility is subject to the EPA's Cluster Rules codified at 40 CFR
part 430.
We look forward to working with you and your staff in order to assure this
application meets your requirements. Please call Derric Brown, Manager -
Environmental Affairs at [phone] or Bob Williams, Director—
Environmental, Health and Safety Affairs at [phone] if you have any
questions or need additional information.
Sincerely,
A�6,c-,-&
Bob Cicale
Vice President of Manufacturing and Mill Manager
Canton Mill
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

Please print or type in the unshaded areas only
(fill-in areas art spaced for elite type,i.e., 12 charactersAnch). Forth Approved.OMB No.209000e6. Approval expires 531-9
FORM U.S.ENVIRONMENTAL PROTECTION AGENCY 1.EPA I.D.NUMBER
GENERAL INFORMATION
1 EPA Consolidated Permits Program F NC0000272 C
GENERAL (Read the"General Instructions"hefore starting.) 1 2 11a 15
IABEL ITEMS GENERAL INSTRUCTIONS
y Y �
hEPAj.D;NUMBERrr :=^ 3 - {,: 4e rapropdntesintel has been provided.aft ilinme designated spew.
Review line infmnatlan eareNllydeny of it N intoned,cross through it
and enter themiee dam in me appropriate fig.in area below. Also,if
¢a>uequ ems, HT- `,;` ' °• any of Me prepNtad data Is absent(the area to the left of the label
, V�'FACIL�I't-YIMAILiNG - space lists the cformagon that should appeaq)please provide it In the
properWharee(s) below. If the label is complete and coned,you
,
a� PLEASEPLACE'LtABEI IN THISSP CE. neadsnotco elealtems1.III,V,andVI(exceptVl-Bwhichmustbe
go
completed leAa Complete all items If label has been
provitletl, ftefu to lc Ithe ilia instructions for detailedd item descriptions and for
VI FACILITY1OCATION 0elegaleugmsations undervmidr ells data is coueded.
II.POLLUTANT CHARACTERISTICS
INSTRUCTIONS: Complete A through J to tletermine her 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 pemut requirements:see Section C of the
Instruction. See also,Section D of the instructions for definitions of bold-faced terms.
MARK'X" MARK'W'
SPECIFIC QUESTIONS YES No SPECIFIC QUESTIONS vas No
ATTACHED ATTACHED
A. Is this facility a publicly owned treatment B. Does or will this facility(either existing orproposed) include a
works which results in a discharge to waters of the X concentrated animal feeding operation or aquatic animal production X
U.S. facility which results in a discharge to waters of the U.S.? (FORM
(FORM ZA) 16 17 1a 2B) 16 17 18
C. Is this facility which currently results in discharges X X D. Is this a proposed facility(other than those descried b in A orB X
to waters of the U.S.other than those described in A above)which will result In a discharge to waters of the U.S.?
or B above?(FORM 2C) 22 23 24 (FORM 2D) 22 23 24
F. Do you or will you inject at this facility industrial or"unicipal X
E. Dees or will Ulis facility treat,store or dispose of X effluent below the lowermost stratum containin,within one quarter
hazardous wastes? (FORM 3) mile of the well bore,underground sources of drinking water?
29 29 30 (FORM 4) 28 28 29
G.Do you or will you inject at this facility any produced water H. Do you or will you inject at this facility fluids for sped at or other fluids which are brought to the surface In connection X processes wuch as mining of sulfur by the Frasch process,solution X
with conventional oil or natural gas production,inject fluids
used for enhanced recovery of oil or natural gas,or inject mining Of minerals,in situ combustion of fossil fuel,or feecovery of
liquid
fluids for storage of hydrocarbons?(FORM 4) geothermal energy?(FORM 4)
34 35 36 34 35 36
I.Is the facility a proposed stationary source which Is one of J. Is this facility a proposed stationary source which is NOT one of
the 28 industrial categories listed in the Instruction and which X the 28 Industrial categories listed In the instruction and which will X
will potentially emit 100 tons per year of any air pollutant potentially emit 250 tons per year of any air pollutant reel ulated
regulated under the Clean Air Ad and may affect or be located under the Clean Air Act and may affect
area ffect or be located in an
in an attainment area?(FORM 5) attainment FORMS
40 41 42 ( ) 40 41 42
FIII.NAME OF FACILITY Z�
FACILITY
Blue Ridge Paper Products Inas, Trs tie B.PHONE(area coda 8 no.)
Brown -Manager of Environmental Affairs 828 646 2318
MAILING ADDRESS
A.STREET OR P.O.BOX
3 P.O. Box 4000
p.
B.CITY OR TOWN C.STATE D_ ZIP CODE
4 Canton NC 28716
VI.FACILITY LOCATION
A. STREET,ROUTE NO.OR OTHER SPECIFIC IDENTIFIER
s 175 Main Street
B. COUNTY NAME
Haywood
C. CITY OR TOWN C.STATE D_ZIP CODE pflwown)
e Canton NC 28716

CONTINUED FROM THE FRONT
I91,m or er or peon y
A.FIRST B.SECOND
74 2621 (SPECIFY) (SPECIFY')
Integrated Pulp Mill
C.THIRD D.FOURTH
C (SPECIFY) C (SPECIFY)
7 7
15 16 19 75 6 19
tg1,In or er o peon y
A.NAME 1B. Is the name listed
Blue Ridge Paper Products Inc. Item Vill-A also the owner?
e YES ONO
15 16 J
86
C.STATUS OF OPERATOR(Enter the appropriate lefterinto the answerbox;if'Other specify) D.PHONE(area code&no.)
_ = Specl
S=STATE 0=OTHER(SPECIFY) P A $2$ 454 0676
P=PRIVATE to-1e 19-21 a.0
E.STREET OR P.O.BOX
1 West Pack Square, Suite 1100
N 5s
F.CITY OR TOWN, G.STATE H.ZIP CODE
c (SPECIFY) Is the facility located on Indian lands?
B Asheville NC 11 2880-1 1 [::]YES :]NO
15116 141 Ql 47 51 52
A. LAISTINU ENVIRONMENTAL PERMITS
A. NPDES(Dish carge to Surface Water) D.PSD(Air Emissions from Proposed Sources)
91vTH
I NC0000272 9 P 20294
15116117 18 30 15 i6 Wile 30
a. UIC(Under mundlnjechonofFlulds) E. OTHER(specify)
(SPECIFY)
9 u 9 See Attachment I for List of Permits
15116117118
30 75 16 77 18 30
C. RCRA(Hazardous Wastes) E. OTHER(Specify)
(SPECIFY)
9 R 9
Al.MAP
15 17 18 30 15 76 17 18 30
Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must show the outline of the facility,the location of each
of its existing and proposed intake and discharge structures,each of its hazardous waste treatment,storage,or disposal facilities,and each well where it injects Fluids underground.
Include all springs,rivers and other surface water bodies in the map area. See Instructions for precise requirements.,
prow e a btie f RE57poon
The Canton Mill is an integrated bleached papergrade kraft pulp and paper manufacturing facility producing
paperboard and fine papers.
see instructions)
I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and all attachments and that,
based on my inquiry of those perons immediately respnsible for obtaining the information contained in the application, I beleive that the information is true,
accurate and complete. I am aware that there are significant penalites for submitting false information, including the possibilty of fine and imprisonment.
A.NAME&OFFICIAL TITLE(type or print) B.SIG URE C.DATE SIGNED
Robert Cicale-Vice President of
Manufacturing and Mill Manager 2-12,,2 / 2e
c
C
101 16 55
EPA Form 3510-1 (8-90)

Attachment I
Form 1
NC0000272
X. Existing Environmental Permits
Permit Type Permit No. Agency Unit
A. NPDES NC0000272 N.C. Dept. of Environment Wastewater
and Natural Resources-DWQ Treatment
Facility
NCS000105 N.C. Dept. of Environment Stormwater
and Natural Resources-DWQ
D. PSD 20294 N.C. Dept. of Environment No. 4 Coal Fired
and Natural Resources-DAQ Power Boiler
E. Other 44-06 N.C. Dept. of Environment No. 6 Landfill
and Natural Resources-DAQ
44-159(C) N.C. Dept. of Environment No. 19 Project
and Natural Resources-DAQ
44-819C2 N.C. Dept. of Environment Causticizing Project
and Natural Resources-DAQ
11740 N.C. Dept. of Environment Pump Station
and Natural Resources-DAQ for No. 6
Landfill leachate
20065' N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ
20066' N.C. Dept. of Environment Bark/Coal Boiler
and Natural Resources-DAQ
20067' N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ
20068• N.C. Dept. of Environment Coal Boiler
and Natural Resources-DAQ
20069' N.C. Dept. of Environment Coal Boiler
and Natural Resources-DAQ
20070' N.C. Dept. of Environment Coal Boiler
and Natural Resources-DAQ
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

Attachment I continued
NC0000272
20152* N.C. Dept. of Environment Black Liquor
and Natural Resources-DAQ Oxidation
20386* N.C. Dept. of Environment Lime Slaker
and Natural Resources-DAQ
20392* N.C. Dept. of Environment No. 4 Limekiln
and Natural Resources-DAQ and NCG system
20427* N.C. Dept. of Environment Tall Oil Scrubber
and Natural Resources-DAQ
20451* N.C. Dept. of Environment No. 5 Limekiln
and Natural Resources-DAQ and NCG system
20452* N.C. Dept. of Environment Chlorine Dioxide
and Natural Resources-DAQ Scrubber
20463* N.C. Dept. of Environment No. 4 Lime
and Natural Resources-DAQ Unloading System
20485* N.C. Dept. of Environment No. 1 Fiberline
and Natural Resources-DAQ Scrubber
20486* N.C. Dept. of Environment No. 2 Fiberline
and Natural Resources-DAQ Scrubber
20487* N.C. Dept. of Environment No. 5 Lime Slaker
and Natural Resources-DAQ
20488* N.C. Dept. of Environment No. 5 Lime
and Natural Resources-DAQ Unloading System
20496* N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ Dissolv.Tank Vent
20497* N.C. Dept. of Environment White Liquor
and Natural Resources-DAQ Oxidizer Separator
20498* N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ Dissolv.Tank Vent
• On July 1, 2000, the air program was re-delegated from the Western North Carolina Regional
Air Pollution Control Agency to the North Carolina Department of Environment and Natural
Resources, Division of Air Quality. Effective October 27, 2000, the new Air Quality Permit
No. is 08961.
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

EPA I.D. NUMBER (copy from Item 1 of Form 1) Form Approved
NC0000272 OMB No.2040-0086
Please print or type In the unshaded areas only I Approval expires 5-31-92
FORM ; US ENVIRONMENTALPROTECTIONAGENCY an
2¢ PA
APPLICATION FOR PERMMTTO DISCHARGE WASTEWATER'" "�a 5
NP-DES EXISTING M➢1yUFACTURING„COMMERCIAL, ryIINING ANDSILYICULfURAL OPRAJION q.7;
_ a .� 'Consohdated'PermltsPror�m _-;^ , '^ _
It OUTFALL LOCATION
For,each cutfall, list the latitude and;longitude,of its location tothe+nearestl5.seconds and`the name of-the receivingwatee
A. OUTFALL: B. LATITUDE G IONGITUDEF•" " ` - %%'
NUMBER" D. RECEWING,W_ATER (Mime)
(list) 1. DEG, 2.MIN. 3. SEC_ . 1. DEG. 2,MIN. 3.SEC:
001 35 32 8 82 50 42 Pigeon River
IL FLOWS,SOURCES OF POLLUTION,AND TREATMENT TECHNOLOGIES
A.Attach a line drawing showing the water flow:through the facility. Indicate effluent,
.sources of Intake water,-operations contributing wastewater to theeuent,.
r'and treatment units,lab
elad to correspond to the,more detailed description;in.ltem-B.. Construct a water balance,on the bne„drawing by showing average
!„flows'between intakes,operations,treatment units,and outfalls:It a water balance cannot be determined(e.g,:for certain rni ing activitiesbrovide`a, ,.
.pictorial description ofthe.nature and,amount of any sources of water and,any collection or treatment measures.
B:For each oulfall,provide a'description of:,('I)All operations contnbuting din wastewaterto the effluent,Inclug process wastewater,sanitary wastewater, y.
cooling water,and storin water runet;(2)-fhe aV`erage flout contributed byeach-operation,and(3)The treatment recleved�bythe wastewater:; Cootfnue: . '
on additional sheets If necessary._ '
1. OUTFALL 2.OPERATION(S)CONTRIBUTING FLOW a. TREATMENT
NUMBER a, OPERATION (list) b.AVERAGE,FLOW a.DESCRIPTION to LIST CODES,FROM,
.
=TABEE 2C,=1
Pulp Mill: Chip Cooking 9.82 mgd Grit Chamber 32'X8'X16' 1-M
001 pulp washing, screening& 29.9 mgd, 1 minute retention
bleaching, recovery and solids to landfill 5-Q
regeneration of cooking
chemicals, production of Bar screens,two 6'wide each, 1-T
chlorine dioxide for pH control by COz injection. 2-K
bleaching. Coagulation by polymer addition. 2-D
Paper Mill 8.1 mgd Primary clarifiers, circular two 1-U
001 Production of fine papers 200' dia.X 14.75'deep 12.7 mgd ea.,
and paperboard 6.6 hour retention
one, 125'diam x 11'deep for spill
Steam and Power 3.9 mgd control, 1.01 mg capacity
001 Generation skimmed floating solids to landfill 5-Q
Settled solids dewatered by belt 5-C
press to landfill 5-Q
Unmetered and Misc., 2.93 mgd
001 Raw water, Sludge Secondary treatment by activated 3-A
WWTP Use sludge process
Average Stormwater 0.17 mgd based on 1998 rainfall Aeration basin 408'x240', 11.4 mg
Town of Canton 0.65 mgd capacity, 29.9 mgd plus recycle, 9.4
001 Municipal Wastewater and hrs retention
Landfill leachate-Variable
depending on storm events Continued on Attachment II-B1
OFFICIAL USE'ONLY(effluent guidelinessub-categories)- --
m
EPA Form 3510-2C (8-90) PAGE 1 OF 4 CONTINUE ON REVERSE

Attachment II — B1
Form 2C
NC0000272
Continued from IIB (3)(a) — (b)
a. Description b. List Codes from Table 2C-1
At low influent loading 3-A
Secondary Treatment by
activated sludge process
(and stand-by capacity
of 4.6 mg) with 6.8 mg
treatment and 5.6 hours
retention.
Secondary clarifiers,
circular, two, 200' dia. x 1-U
12' deep, 11 mgd, one
150' dia. x 14' deep,
6.2 hours retention
Aeration cascade, with 4-A
oxygen injection discharge
to Pigeon River
Oxygen injection capability XX
at 0.9 and 2.1 miles downstream
of discharge.
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

Attachment H - A
PIGEON RIVER
29.9 INCLUDES AVG.
STORMWATER FLOW
31.63 OF 0.17 MOD
WASTR o.s
EWATE
PUMP HOUSE TREATMENT
PLANT
RAW WATER USE 2.03
SLUDGE 0.30
FII,TER PLANT
MII L 8.0 0.6 0.60
COOLING WTP USE
PAPER MILL EVAP 0.7
NO. I1 PM 1.8
10.8 N0.12 PM 1.3 8.1
NU.20 PM 1.7
NO.19 PM 2.9
CHEM PREP 1.3
PCC PLANT 0.3
PULP DIST. 1.5
20 WHITE WATER
11.5 PULP MILL
13.50
ERGO CL02 1.2
CHEM PREP 0.6
COOKING 1.4
BLEACHING 4.9
RECOVERY 3A
EVAP 1.1
5.0 STEAM 3.9
POWER
GENERATION
0.9 MISCELLANEOUS 0.9
UNMETERED
BLUE RIDGE PAPER PRODUCTS INC. TOWN OF CANTON 0.9
CANTON MILL-WATER BALANCE WASTEWATERAND
PERMIT NO.-NC 0000272 MILL LANDILL
LEACHATE
FLOWS IN MGD DATE:2/14/01

MMMIED MOMTHE mover 0 NC0000272
Q Except forstorm runoff'Ieaks;:orspills,are any Of the discharges�described=in*Itemstl-A or Biintermittent orseasonal7 �. •',
Yes complete the following, " X NO(go to"SectionYlq
` 3v17REQUENCY 4.FLOW `®
`P.OU'YFALL '` 2.OPERATION'(S) ` _ � ���a DAYS b"(MONTHS a.FLOW RATE:-. ""-� b:TOTAL VOLUME - -
NUMBER, CONTRIBUTING FLOW' ° ?PER WEEK PER YEAR (in mod) (specify with units) c.DUR-
(lfa!)' k`. - m '(speeily, ,r`(SPecify. ' ,LONGTERM;z.Mt,MUM +I LONG TERM 2;MA)gMUM? ATIO'N;-.
F. .
average) _ average)' " AVERAGE` .. DNLY ,`: AVERAGE DAILY_ -iin'days)
III:PRODUCTION:,
A.Dde_san,effluent guideline limitation romulgated by EPA:undebSectton304 otthe Clean Water Act=apply to,yourfacilit'1
X YES(complete Yfem Nl-8)' "` 'r. „�( - '� NO(gbdasectian
B.Are the limitations in the applicable eTue_ht,guideline expressed in terms of production(orotharmeasure ofoperaiion)? y.
YES(complete 7Fem I/hC); ND',g'o tozSection/Vj'..
, r:
C.If you answered'pes"to item ill'=B,list the..quantity which'represents an,'actual measurement of your'level of production;expressed in terms andvnits
useditn theapplicable effluent.guideline,;and indicate the'.affected outfalls,
"'' - 1.AVERAGE DAILY'PRODUCTION _ ' '°° "" 2,AFFECTED_.-
e`QUANTITY b.UNITS OF,. _ - C.OPERATION,PRODUCTION MATERIAL,ETC. - OUTFACES _.
.PERDAY=_ MEASURE', .p . ,._ :... a :i..,. OpeU89 c.
721.0 ADMT Bleached Papergrade Kraft and Soda paperboard
001
746.8 ADMT Bleached Papergrade Kraft and Soda fine papers
ADMT=Air Dry Metric Tons
NOTE:A project was completed on the No.19 Paperboard Machine in 2000 which increased
our capacity to produce paperboard in future years to 908 ADMT.
(See Attachment IV for correspondence with NCDENR-DWQ with respect
to the paperboard project.)
IV:IMPROVEMENTS;:. _.,, u _-
ti . 5,_...
A.Are you now requited by:any Federal,State.oe local authority to,meet any=impiementatien schedule for the�dbnstrucbon,upgrade oyoperation of waste '
=water treatment equipment or practices or any other,environmental,programs which may affect the discharges:descnbed'in;this application?,This,includes
birt ts'not limited to permit^condi ions,admihistrative or'enforcement orders,enforcer sent wrtipliende schedule lgtters„stipplationsl court�'orders,snd
_, . . - - ." ,grant
or loan conditions - •^'
` Y6S(completeihefo(lowing.table) X ;NO=(9ofo:1tem7V.=6
...,.. :: . . . 2.AFFECTED OUTFALLS' ..._._ _ ,. ` , F "4:'FINAL COM '•"-
,1.IDENTIFICATION OF CONDITION, -3.BRIEF,DESCRIPTION OF PROJECT • PLIANCE DATE;i
AGREEMENT,ETC,, e:fio: ejsouncEQFOISQNARGE.' E _ , a..RE-,�- °b.PRO
- - 'QUIRED ' JECTED,
B.OPTIONAL:You.may attach additional sheets describing,any=additionatWater pollution control progrems(ocother environmental projects which may affect :-..
yourdischarges)you now'have umierway or whlch,'you plam;lndicate whether,each program is nowunderway`o planned snit indicate your'actual or -
planned--.schedulesfor construction: - "` • " , "' '' '" '" " "t �' a..
,.: MARK"X'IF;DESCRIPTION OF ADDITIONAL CONTROLPROGRAMS IS` �
ATTACHED, -
- _
EPA Form 3510-2C(Rev.2-85) PAGE 2 OF 4 CONTINUE ON PAGE 3

Attachment IV
Form 2C, III-C-1
NC0000272
Average Daily Production
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

Making ur mark for VOu.
BLUE RIDGE PAPER PRODUCTS INC.
October 5,1999
Mr.Forrest Westall
North Carolina Department
Environmental and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
Re: NPDES Permit NC0000272
Blue Ridge Paper Products Inc.
No.19 Paper Machine Improvement Project
Mr. Westall:
Blue Ridge Paper Products Inc., (BRPP), Canton, North Carolina Facility, NPDES Permit No.NC0000272,
is notifying you of planned improvements to No.19 Paper Machine. The improvements will involve the
replacement of the paper machine's second press with a press of different design and the replacement of
the calendar stacks with two calendar nips. In addition, non-contact cooling towers will be installed to
mmuruze fresh water usage. The.improvements will enhance both product quality and yield and the
paper machine will be able to process lighter weight products at maximum production rates. The No.19
Paper Machine annual calendar day production rate is projected to be less than 1,000 air dried tons of
finished product per day.
This project includes no physical or operational changes that would increase the midis current pulp
production capacity. Therefore, there will be no additional color loading resulting from this project The
current maximum,annual average production capacity of the pulp mill is not sufficient to supply all four
paper machines. The Canton Mill has purchased an average of approximately 39,000 tons of dry
furnished pulp per year for each of the last six years to supplement on-site pulp production and supply
the paper machines. The pulp mill will continue to nm as efficiently as possible, but additional dry
furnish purchases will be necessary to support production at the paper machines.
Blue Ridge Paper Products Inc., is not requesting any revisions or modifications to the NPDES Permit
effluent limitations, monitoring requirements, or other conditions. Completion of the No.19 Paper .
Machine Project will result in continued full compliance with the Settlement Agreement, Color Variance
and NPDES Permit.
If you have any questions or need additional information please contact me at(828) 646-2033.
Sincerely,
W ftiv,
Robert V.Williams
Director,Environmental,Health&Safety Affairs

n
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
® � ASHEVILLE REGIONAL OFFICE
NCDENR WATER QUALITY SECTION
=' November 19, 1999
IAMEs EL HUNTJR. T"?
;OVERNOR r`f
Mr. Robert Williams
Blue Ridge Paper Products Inc.
175 Main Street
VAYNEMCDEV= :-A Post Office Box 4000
iECItETARY Canton, North Carolina 26716
CERRT.'.u'TLVENS.)IRECTOR , fT-`.` Subject: Improvements to No. 19
' '�'a
^T, Paper Machine
Blue Ridge Paper Products Inc.
._-t^4Y_. NPDES Permit Number NC0000272
Haywood County
x
• ~v
Dear Mr. Williams:
a We have reviewed your letter .-dated October 5, 1999
concerning planned improvements to the No . 19 Paper Machine
and offer the following comments .
As you are aware, stipulation 30 of the NPDES Permit
Settlement Agreement states, "The 1997 Permit shall also
provide that neither Champion nor any successor-in-interest
to Champion' s ownership and/or operation of the Canton mill
will increase the mill 's current pulp production capacity
during the. permit term, unless this can be done in a way
that also reduces color loading. " Since the Mill will be
purchasin dr furnished g y pulp to supplement this
improvement, and there will be no increase in the mill ' s
current pulp production capacity, the improvements to the
No . 19 paper machine meet the condition of the
aforementioned stipulation.
_ytn`
-In discussing this matter with Mr. Don Anderson,
=x 'y'" °. Chairman of the Technical Work Group, he agrees that .no
w>.: a significant changes will occur in the quality of the
. effluent with regards to color loading. He also agrees that
':^.err-•..7.c:.._. .
these improvements are allowed under the settlement
agreement. •
aaVtwi INTERCHANGE BUILDING, 59 WOODFIN PLACE. ASHEVILLE, NC 20801-2414
_ PHONE H28-231-6208 FAX BZa-251-6452
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST-CONSUMER PAPER

Mr. Robert Williams
November 19, 1999
Page Two
If you have any questions concerning t1ais matter,
please do not hesitate to contact Keith Haynes or me at 251-
6208 .
Sincerely,
Forrest R. Westall
Water Quality Regional Supervisor
cc: Don Anderson
Keith Haynes
N019IMP.LET

EPA I.D. NUMBER (copy from Item 1 of Form 1)
CONTINUED FROM PAGE 2 NC0000272
V. INTAKE AND EFFLUENT,CHARACTERISTICS--'
A;e,&,C, seednstruphooa befo"rearfopeedin =Gomplete'one tei of=tables four each`outfall-Annotate,the outfel`I numbers , spree provtd6 t
fSote;Tattles V A,V-B,and V-Care included on seperate sheetshumbered V-h'througliV=9 D.-Use the space below to list any of the pollutants listed,in Table 2c-3 of.the;instructions',,which you know or have reason to believe is discharged or,may be
; s';
dl5chargedfrbm any outfall,For every pollu'tantyou list;bdeflY'tlescribe`the'feasens yousti6h'- -rNN be pre ent and`repod arxly ana[ytrcai data in your u
possession.
1;POLLUTANT - 2.,$©URGE i 1.POLLUTANT ". :. , 2;SQURC
N/A
VI.. POTENTIAL DISCHARGES NOT COVERED BYANALYSIS
Is any,pollutant IlsleQxin7tem V-Coo substance or a component oY,a`substanbe which yodacurrently.us$or man�tactOte asap�intetmediate�ot�fl"nal product-r
... ., - -
6y,producl7,.t f : :_ r ,. :e • ,'' -
YE$,(lisf 9!l�such pollutants Trelow) JC NO(go to Y(em
N/A Pollutant analysis is included with V-C
EPA Form 3510-2C (8-90) PAGE 3 OF 4 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT NC0000272
V,II;;,BJQLOGICALTOXICITI'TESTINGOATA "' "`, :,' • :•I
.. . , :'.
Oo ou have an,knowted a or,reason to believe that an biol - _ _ `" `-
y� Y 8 y ogical testior acute:or chromc:tox city'.has been made on any'of yourd ischarge or on a. ,
receigjng;waterin relation to your discharge wnthin+the last 3'yegns?'
X YES,(idenhfy thetYast(s)a'nddescnbe their puiopse below) NO�(go to SeaUon Vpl)
See Attachment V
VIILCONTRACT'ANALYSIS'INFORMATION
Where a ny,�of,the4analyses,reported,in Item V performed,by.a c#ontractaaboratory ar consulting firm? a,
I- YES(list fhe name, adress,and=telephone numberof, and,pollutants NO,(go to Section 1?9
analyzed by„back sGc6 laboratory or,firm below)A. NAME B.ADDRESS C.TELEPHONE `, a ,D POLLUTANTS ANALYZED
._.
:(area coda rn0.)r r ,. ,., 'M . +• (trsf}
8540 Baycenter Road [phone] All 2C Analysis except Dioxin, Mercury
Columbia Analytical Jacksonville, FL 32256 and self monitoring
Brooks Rand 3950 6th Ave NW
Seattle,WA 98107 [phone] Mercury
Severn Trent Laboratories 880 Riverside Parkway
West Sacramento, CA 95605 [phone] Dioxin
IX:GERTIFICAT=Ib,N0 "7 4i,
I cemrfy under penalty of;law that this document and`all attachments were prepared under my�direction or supervision in accgrdanca.with a system deigned t-
assure that quAffed pe onnetproperly gat %and,evatustath@ nronnahon subr�jitled.Ba bn m�Io ai sMtha arson or- ersorflswh
n,a, ! +.•. ;h ., , Y q ry P P paryranage the syste�rr or z
chose persons 81rectly responsible for.gatherm8,lhe�lnformationythe Snf rmation submdted i3,toNhe best of,my knowledge end beliHf.trud;accurate`'ard complete., ^; -
I am a m that them are significant peneitles forsg6mitung,false.informafion,including the possibility.of fine and imprisonment fora Pmowing violafions. `a ,
A. NAME AND OFFICIAL TITLE (type orprint) B. PHONE NO. (area code &no.)
Robert Cicale-Vice President of Manufacturing and Mill Manager [phone]
C.SIGN RE D. DATE SIGNED
EPA Form 3510-2C(8-90) PAGE 4 OF 4

CYA I.U.NUMbLK(copy nom Item T or homy 7)
PLEASE PRINT OR TYPE IN THE UNSHADED AREAS ONLY.You report some or all of Form Approved.
this information on separate sheets(use the same format) instead of completing these pages. NC0000272 OMB No.2040-0086
SEE INSTRUCTIONS. Approval expires 7-31-88
OUTFALL NO.
V.INTAKE ANDEFFLUENT CHARACTERISTICS(continued.from page 3 of Farm 2-0
001
PARTA-You must provide the results of at,least one analysis for every pollutant in this.table.,..Complete one tabl&for each outfall. Sea instructions for additional"details -` ""_` •"'"' " " ` _
-2,EFFLUENT,; _. - _ .� _ 3.UNITS ::P•4.INTAKE:'(optional)'
1t,BOLLUTANT ' a.MAXIMUM DAILY.VALUE 7, b.MAXIMUM 30 DAY VALUE ,p c.LONGTERM,AVRG.VALUE ' -- -(aperJy;rglane), " .,,; a.LONG TERM
flfavaltable) fifavai7able) d'NO.OF AVERAGE VALUE "b.NO.OF
"(1) (1) (1) ANALYSES a.CONCEN (1) - ANALYSES.
(2)MASS (2j MASS (2)MASS. - b,MASS (2)MASS
. CONCENTRATION CONCENTRATION CONCENTRATION TRATION '„ CONCENTRATION
a.Biochemical Oxyge 11 n 36.2 8,761 10.98 2,299 6.68 1,386 1096 mgll Ibs/day
Demarld,(BOD)-'_
b.chemical Oxygen'. 480 54,467 256 52,326 118 24,498 49 mg/1 Ibs/day
Demand(COD)
,c Total Organic,:;-w, 33.2 7141 33.2 7141 1 mgll Ibs/day
d.Total Suspended 86 19,771 24 4,999 14.98 3,099 1096 mg/I Ibs/day
'SolidslTSS)
a.Anmonla(es N) 4.12 1,049 0.77 179 0.267 55.36 1096 mg/1 Ibs/day
VALUE VALUE VALUE VALUE
Flow 58 27.93 24.87 1096 MGD
' VALUE VALUE VALUE VALUE
g.Temperature 33.6 31.3 29.8 92 cC
,(winter)
:VALUE VALUE VALUE VALUE
h.Temperature 38.7 36.4 36.0 92 OC
(summer) ,�:___
MINIMUM MAXIMUM MINIMUM MAXIMUM
i.pH 7.3 8.4 7.68 7.92 366 STANDARD UNITS
PART Mark"X"in column 2-a for each,pollutant you know or have reason to believe is present Mark%7 in column 2-b for each pollutant you Believe to be absent. If you mark column 26 for any pollutant
whicb1s limited eii}ier directly.orindiredly but expressly,in an.etfluent limitations guideline,;you must provida,ftie results ofat least one analysis for that.pollutant,Forother pollutants:for which your
mark
'..^ column 2a,you musfprovide`quantitabJe data or an'explanation of their presence iri your discharge.Complete on,table for each outfalL Sea the instructions for additlonaf details and(reguirements. "
1.POLLUT- 2.MARK"X" -,.'. - � ., - 3. l).EFFLUENT - - _ - -4.UNITS ", 5.INTAKE(optional), 'A'ANTND, a.BE- b.9E� a.MAXIMUM.DAILY VALUE' _ `.b2 MAXIMUM 30 DAY VALUE t c.LONG TERM AVRG.VALUE I a.LONG TERM'
GA5N0. ilEUEQ tIEVEa (aaYaiiaa�e�. prarailao)e_� a nor o� , _: nY�w+o�vnLUE 4 No oF..
(ravauable) pRE- (1) • , (1) .(1) ANALYSES a.CONCEN `(1) ANALYSES
SENT-` ABSENT CONCENTRATION (2)MASS (2)MASS, (2)MASS b MASS. '.(2)MASS
e CONCENTRATION r, CONCENTRATION , , ,.TRATION CONCENTRATION
a.Bromide X <0.2 ND 2 mgll
(24959-67m9)
b.Chlorine X'see V-9
Total Residual
c.'CotoP _ X 425 89,403 256 68,009 210 43,382 366 mgn Ibs/day
d-Fecal X 110 17 10.53 49 #1100 ml
e:Fluoride X 0.34 61.11 0.17 31.49 2 mgll Ibs/day
(1698.4-48'8):
f.Nitra(e, X <2.0 NO 2 m91I
Nltdte-(as IV,)
EPA Form 3510-2C(Rev.2-85) L!apt m Cobalt Units ND=Non-Detect PAGE V-1 CONTINUE ON REVERSE

ITEM V-B CONTINUED FROM FRONT NC0000272
--- 3.,EFFLUENT-,,'I.-FOLLUT-9 V2.-'MARV)V -,"AUNITS 1 7 Si NTAKS(op Fiona/
-
ANT,'41 ,.a.,MAXIMUM AILYVALUE I !'b.,MAXIMUM'30.DAYVALUE 'e.LONGTER, RG. a.LONGTERW
CASNO.' uEvEo UEVM - claV�R.w - I I :AVERAGE VALUE' i b:,NO.OF
, (it aUabfe) d,NO-OF
(r..Pa0g) PRE;-: 7,- (1)V M ASS ANALYSES ANALYSES
SE��'AMENi��bONCENJR46N ffss 6`6NC5NTRAT10N CONCENTRATION -M" ----TRATION 1; 'col
g.NiUogen,Total Organic. x 1.84 350.8 1.66 307.5 2 migil lbs/day
(as!V)
fi,bii a-nd*4i j A 3.26 621.6 1.63 302 2 mg/1 Ilbsiday
Grease
is Phosphows
(esf);,Total, x 0.92 165.4 0.78 145 2 mg/1 lbs/day
(7723-14ro)
I.Radioactivity'
Total x
(2)Beta,Total x
(3)Radium; x
Total
(4)Radium
226,Total, x
k SUIla("So x 830 158254 660 122,264 2 mg/l lbsfday
(14808-79-8)'] I
I.Suffide x <0.2 ND 2 M911
lass)
m.Sulfite:
(as SOS x <2 ND 2 mg/l
(14265-4&3) ,
-1-
n.I Surfac 9te,, x 0.283 54.0 0.1416 26.21 2 mg/1 11as/day
o,Aluminum,
Total , - x 0.54 103 0.51 94.48 2 mg/1 11as/clay
(7429790-5) 1 1
P,Aarfump- ,
Total -,;� " x 0.11 21 0.105 19.36 2 mg/1 Ilas/clay
(7440-39=3)-
11 11071-1 -1,Total, �0,11 1, x 0.062 11.8 0.031 5.91 2 mg/1 lbs/day
(7440-42-8)
r.Cobalt,
Total, x <0.03 ND 2 mg/l lbsiday
(7,440-46-4)-]
0.07 U 0.064 mg/1 1hamay
(7436-8946) x
t Magnesium,!
iota) x 7.4 1411 6.75 1250 2 mg/1 Itasiday
(7439-954) 1 1
u.Molybd6num
Total Vi-' x 0.01 1.8 0.005 0.926 2 mg/l lbsiday
v.Manganese,
Total .11,�I" x 0.8 153 0.63 117 2 mgll lbsiday
C74394,64Yq_,I I I I
<111n,70tal % X <0.004 ND 2 mg/1 lbsiday
(7440-31-5), L
x.Titanburn,,'-
Total•Titanium,
, x 0.15 0.079 14.63 2 millIbs/clay
EPA FORM 3510-2C(Rev.2-85) PAGE V-2 CONTINUE ON PAGE V-3

trA W.NUMHtrc fWpy From Item 7 or YORrl 7) OU I I-ALL NUMbhK
Form Approved.
OMB No.2040-0086
CONTINUED FROM PAGE 2 OF FORM 2-C NC0000272 001 Approval expires 7-31-88
PART C. If you are a primary Industry and this outfa]]contains process wastewater,refer to Table 2F2.in the instructions to-determine which of the GCIMS fractions you must test for.Mark°X in column -
�: � 2.a]orail such6CtMSfrac(Iom;,that epplyto yourindust and foe-ALL tonic mess, `ry, cyamdes end total phepols:3fyou are not required to margrcolumn'2-a(segonda)y lnduslnes,nonpmcess; ° •, ,;,,
wastewater ouhalls,;and nonrequired'GPJMS fractions) mark- in column 2'bfar eaGi pollutant you know or have reason to Believe is presegl.Mark X"fn column 2-c for each pollutant you. ^
-. believe is abseniatyou mark column 2a for any pollutant,you must pmvidetheresults of atleast'one analysts(or that pollutant if you mark column 2b for any pollutanL%you most provide the results -
' of at least one analysis for that pollutant otyou know or`have reason to believe it will be discharged inconcentrationsof 10 ppb or greateclf you:mark column 2b foreacrolein,acrylonitnie,2,4,
'„ k •diniVophenol'}ti-iethyl•4;+8 dinitrophenol you,mukf provide thetesuds of at,least one analysis for each of these pollutants which you knowerhave reaspn.to,deiieve that you discharge,In_
concentiationso11ooppb,orgreater.Oiti rvgise;forpeilutanis for which you mark column+2b.you must'elther suom@ at least one analysis or briefly descri the reasons the pollutant is expected to
!' be discharged.Note that them are?pages todhispart;please review each carefully.Complete one table(all 7 pages)far each outfall.See instructions for additional,details and requirements.
1.P.OLLUTANT "'.- 2."MARK:"X'." '. r'- ._.,.._. .. _"3I:EFFLUENT: _ . . _ - 4.UNITS:: "_. 5.INTAKE optlodazi .. - .._
NO OAS, a�TEST o�BE�•It,sE-E a.MgXIMUM.D(tILY VALUE; b.MAXIMUM 3o DAY VAL^UE p.LONG TEITMA,RG.VALUE _ - .� -'e +,tea.LONGTERM, . .
NUMBER MD LIEVED: .tiEVEO (dsiailatile) '6Favafable) d NO O p�IERAGEUALUE, b.NO OE
(raradable) REfllllR PRE 'A& - (1) - (1) {7)- - ANALYSES a.`CONCEN• 6:MASS (1) ANALYSES:
(2)MASS al MASS (Y)MASS ,. (�i-MASS -
;EO SENT.,, ,§ENT CONCENTRATION CONCENTRATION CONCENTRATION t TRATION r CONCENTRATION . ..
METALS,CYANIDE,ANDTOTACP.RENOLS^"" "_ " ` s - -
a
1M.Antlmony„ X <0.005 ND 2 mgll
Total (7440-35-0)'
2440-38w2)Totalt X 0.009 1.62 0.0088 1.63 2 mgll Ibslday
3M Beryitium, X <0.003 ND 2 mg/1total(74400.}14).'
4M.Cadmium, X <0.01 ND 2 mgll
Total(7440-03-9)
5M."Chipmmlum; X <0.005 ND 2 mg/1
Total(7440-07-3)
SM.Capper,Total X <0.005 ND 2 mg/1
�aaasaa>r;^ .
7M.Lead,Total X <0.002 ND 2 mgll
(7439-92-1)'-
B,439-97gd);totali X <0.2 ND 24 ugll
(7439rB76),
9M.Nicket'Tatal . X 0.0063 1.1 0.0032 0.59 2 mg/1
16M.Selenfum, X <0.005 ND 2 mgll
Total,(7782-09-2)
1tM.Silver Total. X <0.001 ND 2 mBit
12M.Thallium X <0.002 ND 2 mgll
total�74,41
13M.7inc;Total X <0.02 ND 2 mg0
14M:Cyanide„'' + X <0.01 ND 2 mg/1
Total(57-12-5)
15M.P.h¢nols •u„( X <0.01 ND 2 mgll
Tote] '�.; , . ,.
DIOXIN
2=3,78 Tetra DESCRIBE RESULTS
chloroditieP- X All data for permit term were non-detect pass than the detection limit of 10 pg/I)by Method EPA-161613A.
Dioxin,(1764-01-6)
EPA FORM 3510-2C(Rev.2-05) PAGE V-3 CONTINUE ON REVERSE

GUN I INULU FRUM I Ht I-KUIN I NL UUUUZ rZ
1:POLLUTANT "- 2..MARK2'X' _ = "'` ". 3:EFFLUENT. -1 4S:UNITS- 5.INTAKE,(o(optional) "
ANDCAS I.-TE.517-11b..BE-- -c SE a::MAXIMUM DAILY VALUE b;:MAXIMUM:30 DAY VALUE' "a LONGTERM AVRG.VALUE - - - - a:LONG TERM
NIIMBER ING, uEVEo LIEVED - ,Cfa.a7.bfe) fdaraaeble). d.NO.OF - - AVERAGE VALUE b.NO::OF
(py-7abre) , REOUIR PRE-. AB- -.(1) ` ' '(1) (1) ANALYSES a.CONCEN- b..MAS9 -. (1) 'ANALYSES'
,dry,'-• ED, SENT:`. +SENT CONCENTRATION -(2}�MASS :COIJCeNTRATION.+ (2)MASS CONCENTRATION (2)MAS .•«. . TRATIDN (2)N'AS9.
-,:. CONCENTRATION
GCIMSIFRACTION VOLATILE COMPOUNDS _. ._
1V.Aaolem: ..X. . <25 ND. 2 u9/I. .. -
(107.02-8). . _
2V Acry)onibile X <8 ND 2 ug/I
(107_13y1)'`
3v.Benzene(71-43-2) X <1 ND 2 ugll
me(hyll=LLEther.
(542-5e-1);:
SG..Brcmoform X <1 ND 2 ugll
VS-25-2)
Tetracnorlde X <1 ND 2 ug/I
7V.Chlorohenzene X <1 NO 2 ugll
(108-9o-7);'.
BV,C0lorodt "-
bromo,me pane X <1 ND 2 ugll
(12445,1).
9V.Chloroelhane X <1 ND 2 ugll
(75-004).;: .
1 W 2«Gtiiorb
ethylvinyl,Ell er X <1 NO 2 ugll
(110-75-8).
i W-Chloroform: X 1 0.191 1 0.185 2 ug/l Ibs/day
(67-66-3j:+ _._
12V.Oichlorc -
bromomethane X <1 ND 2 Ug/l
(75-27-4)- -
13V:1Dlchloro-
di0uoromethane X <1 ND 2 ug/l
(75=71ee)
14V.t,i'-Diohlora X <1 ND 2 ug/l
ethane.(75-34-3)
15V.1,2-Qichloro-, X <1 ND 2 ugll
W.I!ethane
a' l��f6 ' X <1 ND 2 ugli
ethylen_e',(75-35-4)
17V.1,24Dlchtora" X <1 ND 2 ugll
propade;"—`87-5)
18V.1,a7Wddcro- X <1 ND 2 ugll
popylana:(542-75.8).
19V,Ettiylbenzene, X <1 ND 2 ugll
20V,Met)tyl X <1 ND 2 ugll
Bromide(74-83-9),
21V.Methyl X <1 ND 2 ugll
Chlorlde(7A97,-3)
EPA FORM 3510-2C(Rev.2-85) NU Non-Detect PAGEV-4 CONTINUE ON PAGE V-5

t I.u.Numumm(ropy nom uem 1 or Tom r) UU I rH L INUMBtR
Form Approved.
NC0000272 001 OMB No.2040-0086
CONTINUED FROM PAGE V4 Approval expires 7-31-88
1 -2,MARK-"X"- "_ '" ,, :. " -r 'S EFFLUENT - S : `_-. " ,'_..'... :. 4.UNITS = ';.:;.: - - - 5.-INTAKE(o fiona),
AND CAS ,» a:TESTfu
bSE.., aBE a:MAXIMUM OAILY;VALUE bMAXIMUM30DAYVALt)E'r �c LONGTERM AVRG:VALU_E r - °- .n'.LONGTERM
DUMBER INGEVEO� uEVED ` ' pl'aveiiebie) '' ' - bfe5airetile) d NO;OFV � AVERA23EVALUE b.NO:QFefaja-010) , REOUIRpRE-; ' AB- 1. ',(1) (2j MAss lt) (2)MAss (1) ':' - 1z)MAss ANALYSES a.CONCEN- b.MASS '(1) ANALYSES.
'irEO SENT sEw CONCENTRATION _ CONCENTRATION CONCENTRATION TRATION', ' .CONCENTRATION -
.__ _.
GC/MS!FRACTION:-VOLATILE COMPOUNDS(eontlnued)
22V.Methylene," X <5 NO .: _ " 2 _ ugfl,
Chlodde(75-09.2).
23V,1;t;2,2-Tetra+'
chloroetfiene- " X <1 NO 2 ug/1
24V.Tetrachloro- X <1 NO 2 ug/l
ethylene:(127=18-4)
25V.TQlu�ne"r X <1 NO 2 ug/I
26VAII,2-Trans-,
DichloroeRylene X <1 NO 2 ug/l
156-6�0.5),-r
27V:1�1 1-Trt-`
ehioroetliane :' X <1 NO 2 ug/l
28V,1 i 2 Tri -,;•
Chloroethane X <1 NO 2 ug/l
(79=00.5)'
29V.,Tnchiono-
X <7 NO 2 ug/I
ethylene(79401.6)
30V.Tnchlor _
Ouoromethane X <1 NO 2 ugll
(75.6_4t "
31V.VInYh , X <1 NO 2 ugll
Chlonde.(75-014).
GCIMSTAACTION LACID COMPOUNDS
1A.2•GLilo"roptienol X <5 NO 2 ugll
2A 2,4-Oithlor ' X <5 NO
phenol'(120-H3-2), I 2 Ugll
SA 2,4-0methyl- X <5 NO 2 ugll
phenol;(105-67-9)'..
4A.4.6DIm6o•as' X <20 ND 2 ugll
Cresoll(S34'-52A),
5A1Z)i-Gltr X <20 ND 2 ugll
phenol(51-2&5)
6A_2-Nih9plienol X <5 NO 2 ug/I
(88-Z5;5)_ s'
7A 4-Nitrophenol'": X <20 NO 2 ugll
(100-62-7) "
BA PRCl loco-M " X 420 NO 2 ugll
6(esol(59}504.)„
9A,PentolMgk-.', X <20 NO 2 ug/l
phenol(87-HeSj._
tOA.Rliegol,� .-, X <5 ND 2 ug/l
(10S;96Z)`
11A 2;4,5-'Tr1-
phlo(opM1enaF: X <5 NO 2 ug/l
EPA FORM 3510-2C(Rev.2-55) NO=Non-Detect PAGE V-5 CONTINUE ON REVERSE

1.POLLUTANT' . :i,2 MARK"XT .. "' `"" 3.EFFLUENT`-.". _. . .-'..•' . -_ - ,.'= 4:'UNITS . . ..S.INTAKE(optional),. . ..
AND CAS e;:'fEsr- b.BE- " c BE-.- a.MAXIMUM DAILY VALUE bi MAXIMUM.30'DAY VALUE - c.LONG TERM AVRG.VALUE ' a.LONGTERM
NUMBER 'ING UEVED UEVED 'a .(Lava➢aWe) . (da.,7able) d.NO.OF ;- AVERAGEVALUE 6,:NO.OF
(Oevarrabre) ;ED $ENT CONCENjRATION _ ,CQNCENTRATION: . -a
� ss. CONCENTRATION (2)N✓SS TRATION +CONCENTRATION (2)MASS
,.
REOma- PRE- " A& fl) Wee (1) (t) ANALYSES a.CONCEN- b,MASS (i) ANALYSES
GCIMS!FRACTION'-BASEINEUTRALCOMPOUNDS"
18;Acensphthene X .<5 ND .. 2 u911 x .
83-32-9)
2B.:Aceneptiylene X <5 ND 2 ug/l
(206.95$)r
3-9.Antl(acme X <5 ND 2 ugll
120-12-7)
4B.Benzidine X <20 ND 2 ugll
02;07- %,
58..Benzo'(a).
nlhracene X <5 ND 2 ug/l
(56-55-3) '
6B.Benzo.(a). X <5 ND 2 ugll
P. rene''(50-32-B)
7B.13,4'-B-enzw '
Pouranthene° X <5 ND 2 ugll
zos-ss-z)
8B.Ben a,(ghi)
Perylene., X <5 ND 2 ug/l
9B.Be=a(k)
Floumnthene- X <5 ND 2 ug/l
267-06-6)
I OBCBie'(2-0nlom-
ethaxyyMaI Inane;. X <5 ND 2 ugll
plt=si+1>=
11B.Bis(2-Chlorp-.
ethyo Ether' X <5 ND 2 ugll
(1114 -4)
12B.Bis:(2-Chloro-
lsopropyl)Eiher X <5 ND 2 ugll
(102-60-1)
13B.Bis,(2-Chloro-.
elhyD,F[Ithalate X <5 ND 2 ug/l
14B::4.Bmmo-`
phenyl Fhenyl' X <5 ND 2 ug/l
Ether(101-55,3).
158.Bum'Benz X <5 ND 2 ug/l
Phthalate.85.60.7
15�I�-G111vry
haplhalene X <5 ND 2 ugA
(91-58-7);.,...
17B.4-,Chloro-
phenyl;Phenyt X <5 ND 2 ugll
Ether(7005'-72+3)
188.ghrrysene X <5 ND 2 ugll
�z16-ot=s)
19B.,otenzo(a,hp.
<5 ND 2 ugll
zoB.1,2=Dichlora X <5 ND 2 ugll
benzenei(95-50-1)
218,1,3;-DichloYo X <5 ND 2 ugll
benzenes 54f-79-1
EPA FORM 3510-2C(Rev.2-85) NO=Non-Detect PAGE V-B CONTINUE ON PAGE V-7

n,.v., morn ryopynum nem rm mnn p uu i rnu nomoen
Fonn Approved.
NCOOD0272 001 OMB No.2040-0086
CONTINUED FROM PAGE V-6 Approval expires 7-31-88
1.POLLUTANZ` ..:` 2TMARKr)C' "6-. - - ?: `�• • -s; t •• :3:.EFFLUENT - �• "`7 " "` =4.UNIT6 r� .S.'INTAKE optlona
aaTE6T 'b:BE a eE z oM(QSIMUM•DAILYYALUE bSMAXIMt1M 3,40AY VALUEo.LONG TER�IAVRG.VALUE a.LQNG�T,ERM
NUMBERa `ING L1E4ED 4iEVED `' r -'(rtavalhama) .- "" �(;(erellableA tl NO:,l3P " ` AVERAGEVALUE b.NO.OF
QCava kola RED 5EN6 SENT' CONCENTRATON y _l2)MASS CONCENTRATION .(2) -MA�SCONCENTRA110N " (2)rd/(SS TRATION CONCENTRATION', (2)MA6S ` -
EOUIR PRE. AB- (p _ (t) (t) ANALYSES a.CONCEN- "b:.MASS;.' (q" ANALYSES
GC/MS';FRACTION-BASEIIIEUTRAL COMPOUNDS,(eondnuedp
22B.1,4-0chloro- X <5 ND 2 Usti 64
23B:3;3'-Dichlor'.`
benzidine r' X_ <20 ND 2 ugll
21B Diethyl
Phthalate;;.:-. - X <5 ND 2 Usti
(84-66-2)
25B.gDlmethYl'
Phthalate X <5 ND 2 Usti
131-tk3)
26B.Di-N=B_utyl
Phthalate..• ' X <5 NO 2 Usti
27B:2,4.D(mtro, - X <5 ND 2 Ug/l
t
toluene(1'Ttr 2)
lower t606`2D X <5 ND 2 ug11
Toluene(606-20-2)
29B.Di-N300
t111.
Phthalate:_.. X <5 ND 2 ugll
30B 12-DiphanyP
hydmiiriW*Aza X <5 ND 2 ugll
aemane)t]2z•BB•7). _..
31B.F,luorathene X <5 ND 2 ugll
208 44-6).
32B.-Fluorerie' X <5 ND 2 Ugll
(86=73-7)-"e -
33B.Hezachl6ro X <5 ND 2 Usti
benzene:{Alle-74-i)r
348.lieir;-'
e¢mmtiateajen`e.. X <5 ND 2 Usti
87.8"4 ).T _
35B.Hexachlord
cyUopentadiene X <5 ND 2 Usti
3eB Refraamoro X <5 ND 2 Usti
elhan�;�67,72,1)
37B.Inden6 _ -
(1,2;3sdJ);Pyene X <5 ND 2 ug/l
193-39;5}.;
38B."Isop¢01one . ' X <5 ND 2 ugll
398.Naphthalene.-"" X <5 ND 2 Usti
408:NiGobenien_le X <5 ND 2 ug/l
41B;MNilro;'"
sddlmeitytamine(62 X <5 ND 2 Usti
42B.N-L41trds6
d1
-N
Pro mm pylae X <5 ND 2 u911
621-64-7
EPA FORM 3510-2C(Rev.2-85) ND=NOD-Detect PAGE V-7 CONTINUE ON REVER5E

CONTINUED FROM THE FRONT
1.POLLUTANT 2.MARKiW' '-"- " 3;'.EFFLUENT- -' -- -- - - "" 4.UNITS-- "-" - 5..INTAKE(optional) '
AND CAS o:TES r- e.eE- usE- a-,MAXIMUM DAILY VALUE b::MAXIMUM 30'DAY VALUE c.LONGTERM AVRG.VALUE- - �" a.LONGIERM - -
,NUMBER INO UEVED; uEv°Eli "" (d.,I.We) _ (MarariaµN). d.NO.OF + AVERAGE-VALUE b,NO.OF
' (Iavd�6to REpuIR PRE A& f1) - (1) (1) ;, ANALYSES a.CONCEN- 'b-MASS 11) " -- ANALYSES
:. {2)MA59 (2)MASS - ;(2)MASS :
ED SENT„-SENT CONCENTRATION =+ - "CONCENTRAT.ION. CONCENTRATION "- TRATION CONCENTRATION
GC)MS FRACTION'•BASEINEUTRALCOMPOUNDS(conOnued)? ,.-
43B..N-Nltra
sodiphenylamine X <5 ND 2 ugll
(86-3o-6),
4B.Phenanthrene X <5 ND 2 ug/1
(65-01-8).
51K"Pyrene , X <5 ND 2 ug/I
46B114A4-Td„'
Chtorobanzene, X <5 ND 2 u9/1
(120-82-)
GCIMS.FRACTIONj-PESTICIDES
i P. _,-
(309,0,2) X <0.02 ND 2 ugll
2P.a-Bric X <0.02 ND 2 ug/l
(319-85-7)
3P,0?BHC-
(stse5aj X <0.02 ND 2 ug/l
4P.Y-BHC "(56 X <0.02 ND 2 ug/I
89-9)
SPi,§-BHC. X <0.02 ND 2 ugll
(319-86-6)
6P.Ohlomdane X <0.02 ND 2 ugll
(57.74.9) .
7P.4,4'•DDT', X <0.02 ND 2 ugll
(50-29=3) -
eP. X <0.02 ND 2 ugll
90;.4;4=0DD(72s4-e) X <0.02 ND 2 ug/l
10P-,Dleiddn X <0.02 ND 2 ugll
(60-57-1).
11P. m-Endosulfan X <0.02 ND 2 ug/1
12P B=Endosulfan„ x 10.02 ND 2 ugn
13P.Endosulfan X <0.02 ND 2 ugll
Sulfate,(1031.07-8)
14P1;'Enddn X <0.02 ND 2 ugll
(72.20-6).
15P:Enann
Ide(,yd&- X <0.02 ND 2 ug/I
(7421=98-0)
16P li tachlo`r" X <0.02 ND 2 ug11
EPA FORM 3510-2C(Rev.2-85) ND=Non-Detect PAGE V-8 CONTINUE ON PAGE V-9

ern r...numomm Iwpyrmmrem r of to"t/ Uu rrnLL numeert
Form Approved.
NC0000272 001 OMB No.2040-0086
CONTINUED FROM PAGE V-8 Approval expires 7.31-88
r2WPOL'I:LRANTi ,�.`i^fi2iMAR..X7 a1+,w+,q '�+, .;, X`,[„�f y,.,xz,?'C""•"s:5.,?,'«r".`k.*.tT:3xEFF,LUENR}_t( ..1',a�"S v,.ma uv.,..a :;;,T�' ,>x v, ,""r3 O"''S s '" 4.UNIT.S,`.-` '"-„e13 Gam ': riy,Ez<+!_55'INTigKE40 Ud172. :;'C"x,y.5r.,
_ ' x- 5 "x u Y S 5 x .
i „ayANU,CAS L �oy*'rE6Y BB '? :c3TMe car IMUM DA)L',hpVALUE t$,. IMUMl 0=D Y7VALpUE,=,p L NG'CEyRM,AVRW,ALUE c
RR� r*iNOil OEVEO= LEt�rtO f11031'a ,s.^`''..,c" Y' x r fi=(A'aveu bl'e>;��'r(�:...:+'.� "O u'.'�--b r(d'arrelkAb1=,"`T.Y`x' f&NO'OO t .)I, �''p, £": 's°''r"'i ? s-?x'�`AVERAGE'V11LUE b NOi OFn
REQUrIft N.,PaEc.. :A&5' •ta.:rf:li) n'�W r:= Sa '; `i . I7��. i �+ hANALI'SES s C019CEN M1x°fi`"MASSit. s,*�.rtj<:�C AN,ALY5E5.
'r5,'i`�s>:....y:.-� r'4#2 ;•. Ep : .[SM. f„SENT ,CONCEMfRATI0IJ ;;aev 'te„+dy,. CONCENinADON 'y,Aa'MASS) CONCENinATIO�I h ��MASS p �-'z,�;"te,h .,;TRATIO�Ir.. ` G�r'•"^�`'t✓..�`.. CONCEMitAT10t�F Rx�it,
IcdnUnue�PESTICIOES ,c �
l ",. t ?5 r : ir+.r"y * w c K r- F .c-`'; .. . '"'_".v+ .s•, r -`r t x r F `� r r t ,"e
GCMIS.FRACTiON.. ._' ._, _. ,.g - f ...a- „_.. ,.... ..,- ,- x. :._ .!._�• ?(,�.�....-'.,:i-,..�_c...�
FjepCachiorr..r _.. __
EQrixide X <0.02 ND 2 ugll
(102�4u�3)� r~W,
18FMCB42422 e X <0.2 ND
(SA4s9iffiB ;a§'7 2 ugll ,
i,PR-D X <0.2 ND 2 ugll
(urps�,ssjs„t�a;
20Pr.Q@;122V 1 X <0.2 ND 2 u hl
g
21 P�[ 8'�1232 X <0.2 ND 2 u 11
X <0.2 ND 2 ugll
(127T2
23P'"P(1)1l60-
X ND 2 ugn
z"4d pc Ko�st
X <0.2 ND 2 ugll
25P rT„soiaphene '�
X <0.2 ND 2 ugll
EPA FORM 3510-2C(Rev.2-85) PAGE V-9
ND=Non-Detect
footnote from page V-1
'One of the two secondary effluent priority pollutant scans showed a 0.05 ppm concentration for residual chlorine. The second scan resulted in a non-detect at 0.01 ppm.
BRPP has evaluated this reported residual chlorine result and,in consultation with NCASI,does not believe residual chlorine can exist in our effluent.
This is based on the very reactive nature of chlorine,which readily combines with all elements except rare gases and nitrogen(source:The Merck Index, 11th edition).
In addition,Standard Methods,18th-20th editions,states known analytical interferences(organic matter)with the colorimetric method used for our type of wastewater.
Therefore,"Believed Absent"is checked for residual chlorine.

Attachment V
Quarterly Chronic Toxicity Data
NC0000272
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

NPDES Permit Renewal Application
2C-Atttachment V
Summary of Historical Toxicity Data from 1998 -2000
Results of 7-Day Ceriodaphnia Survival and Reproduction
No Observable Effect Concentration (NOEC)
Sample Date NOEC % Effluent
3/23/98 100
6/8/98 100
9/7/98 100
12/14/98 100
3/8/99 100
6/14/99 100
10/14/99 100
12/6/99 75
12/28/99 100
2/14/00 100
3/10/00 100
6/5/00 100
9111/00 100
12/11/00 100
Testing performed by Burlington Research Laboraoty
1302 Belmont Street
Burlington, NC 27215-6935
[phone]
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC
NC0000272

r StatF.of North Carolina
Department of Environment �, a
and Natural Resources
Division of Water Quality — —
61
Michael F. Easley, Governor NCDENR
William G. Ross, Jr., Secretary
KerrT. Stevens, Director
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
February 26, 2001 i L�
Mr. Derric Brown
Blue Ridge Paper Products Inc. �+ ll ; MAR - 2 2001 1
PO Box 4000 f 1
Canton,North Carolina 28716 — __s
�iCll s'' i"CT17'
Subject: NPDES Permit Renewal Application
Permit NC0000272
Blue Ridge Paper Products Inc.
Haywood County
Dear Mr. Brown:
The NPDES Unit received your permit renewal application on February 23,2001. Thank you for submitting
this package.
The permit renewal for this facility will be assigned to a member of the NPDES Unit staff. That staff
member will contact you if further information is needed to complete the permit renewal. Please note that
the NPDES Unit has several vacant positions. This staff shortage has lasted for over a year and is delaying
all permit renewals. Our remaining permit writers are currently reviewing Authorizations to Construct,
speculative limit requests, major permit modifications and 201 plan updates ahead of permit renewals. This
is necessary due to a variety of factors, including mandatory deadlines in the statutes which govern our
program.
If this staff shortage delays reissuance of NC0000272 the existing requirements in your permit will remain
in effect until the permit is renewed (or the Division takes other action). We appreciate your patience and
understanding while we operate with a severely depleted staff. If you have any additional questions
concerning renewal of the subject permit,please contact me at(919)733-5083, extension 520.
Sincerely,
U 3A -U
Valery Stephens
Point Source Unit
cc AshevillecRegio_nat Office,Water Quality Section
NPDES File
1617 Mail Service Center,Raleigh,North Cwolina27699-1617 919733-5083,extension 520 (fax)919733.0719
VISIT US ON THE INTERNET®httpl/h2o.enr.state.nc.us/NPDES Valery.Stephens®ncmail.net

BLUE RIDGE
PAPER PRODUCTS INC.
February 21, 2001
Mr. Dave Goodrich, NPDES Unit Supervisor FEB 2 3 2001 -�
North Carolina Department of
Environment and Natural Resources orl:a - e,a1rn aunur
512 North Salisbury Street Pu,°:T
Raleigh, NC 27604
Dear Mr. Goodrich:
Please find the enclosed EPA Forms 1 and 2C for the renewal of Blue Ridge
Paper Products Inc.'s (BRPP) Canton Mill NPDES permit NC0000272. As you
are aware, this facility is subject to the EPA's Cluster Rules codified at 40 CFR
part 430.
We look forward to working with you and your staff in order to assure this
application meets your requirements. Please call Derric Brown, Manager-
Environmental Affairs at [phone] or Bob Williams, Director—
Environmental, Health and Safety Affairs at [phone] if you have any
questions or need additional information.
Sincerely,
P2,41�6fc
Bob Cicale
Vice President of Manufacturing and Mill Manager
Canton Mill
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

4 +
xc: Paul Davis
Director, Water Pollution Control
Tennessee Department of Environment and
Conservation
150 9" Avenue, 4" Floor
Nashville, Tennessee 37243-1534
Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville, NC 28801
Keith Haynes
Environmental Specialist
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville, NC 28801

Please print or type in the unshaded areas only
(fill-in areas are spaced for elite type,Le., 12 chara0teryndh). Forth Approved.OMB No.2040-0086. Approval expires 531-9
FORM U.S.ENVIRONMENTAL PROTECTION AGENCY 1.EPA I.D.NUMBER
GENERAL INFORMATION 1 EPA Consolidated Permits Program F_ NC0000272
GENERAL (Read the"General Instructions"before starting.) 1 1 2 14 1 15
LABEL ITEMS rn.,4s ^, 4: GENERAL INSTRUCTIONS
' *+ If a preprinted label has been Mounded. ffix tled.a It In vie designated space.
L;EP,�A 1 D,NUMBE
Review the information coretugy,if any of It is Incorrect,cross through it
and enter vie correct data in the appropriate,fill-in area below.Also.If
any of the preprinted data is absent(via area to the left of the label
sPacelists the Information tat should appear,)please moves it In Me
"ADDREu.S• �+f�.,• ;? poPar fill-in areas)below. If Me label is complete and coned,you
x RLEASE`PLA E+LABEL tN1� iS+S?ACE needs not complete Items 1,Ill.V,and VI(excopt w-B which must be
completed regardless.) Complete all items If no label has been
provided. Refer to the Instructions for detailed item descriptions and for
FACILIY ! ATC ` he legal mMoribationsunderwhichthisdataiscogeded.
II.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 forth 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.
MARK W' MARK'W'
SPECIFIC QUESTIONS Yes No ATTACL SPECIFIC QUESTIONS vas NO
AT AOHFD
A. Is this facility a publicly owned treatment B. Does or will this facility(either existing orpreposed)include a
works which results In a discharge to waters of the X concentrated animal feeding operation or aquatic animal production X
U.S. facility which results In a discharge to waters of the U.S.? (FORM
(FORM 2A) 16 1 17 1 18 2B) 16 17 to
C. Is this facility which currently results in discharges X X D. Is this a proposed facility(other than those described in A orB X
to waters of the U.S.other than those described in A above)which will result In a discharge to waters of the U.S.?
or B above?(FORM 2C) 22 23 24 (FORM 2D) 22 23 24
F. Do you or will you inject at this facility industrial or municipal
E. Does or will this facility treat,store or dispose of X effluent below the lowermost stratum containin,within one quarter X
hazardous wastes? (FORM 3) mile of the well bore,underground sources of drinking water?
26 29 30 FORM 4 28 1 28 29
G.Do you or will you Inject at this facility any produced water H. Do you or will you Inject at this facility fluids for special
or other flMds which are brought to the surface in connection X processes witch as mining of sulfur by the Frasch process,solution X
with conventional oil or natural gas production,inject fluids
used for enhanced recovery of oil or natural gas,or inject mining of minerals,In situ combustion of fossil fuel,or recovery of
fluids for storage of liquid hydrocarbons?(FORM 4) 34 35 geothermal energy?(FORM 4) 34 35 36
I.Is this facility a proposed stationary source which is one of J. Is this facility a proposed stationary source which is NOT one of
Me 26 industrial categories listed in the instruction and which X the 28 industrial categories listed in the Instruction and which will X
will potentially emit 100 tons per year of any air pollutant potentially emit 250 tons per year of any air pollutant regulated
regulated under the Clean An Act and may affect or be located under the Clean Air Act and may affect or be located in an
in an attainment area?(FORM 5) attainment areal FORMS
40 41 42 ( ) 40 41 1 42
III.NAME OF FACILITY
1 SKIP I Blue Ridge Paper Products Inc.
GUNTALA
A.NAME&TITLE ar;4 first&title) B.PHONE(me coda 8 no.)
2 Derric Brown - Manager of Environmental Affairs 828 11 64611 2318
V.FACILITY MAILING ADDRESS
A.STREET OR P.O.BOX
3 P.O. Box 4000
B.CITY OR TOWN C.STATE D.ZIP CODE
4 Canton NC 28716
VI.FACILITY LOCATION
A. STREET,ROUTE NO.OR OTHER SPECIFIC IDENTIFIER
5 175 Main Street
1011.
B. COUNTY NAME
Haywood
V.COUNTY CULL
C. CITY OR TOWN C.STATE D.ZIP CODE "ahem!
B Canton NC 28716

CONTINUED FROM THE FRONT
digit,In or er o peon y
# 2621 'SPECIFY) Integrated Pulp Mill (SPECIFY)
01
C.THIRD D.FOURTH
C 19(SPECIFY) C (SPECIFY)
15 16
7 7
15 6 79
rgr,to oraerof pnon y
A.NAME B. Is the name listed
C Blue Ridge Paper ProductsInc. Item VIII-A also the owner?
e YES�NO
15 1fi 35 86
C.STATUS OF OPERATOR(Enter the appropriate letter Into the answerbox,,if'Other,specify) D.PHONE(area code&no.)
_ = spec)
S=STATE O=OTHER(SPECIFY) P A 828 454 0676
P=PRIVATE 1e-1e W21 zz•u
E.STREET OR P.O.BOX
1 West Pack Square, Suite 1100
¢I 55
F.CITY OR TOWN G.STATE H.ZIP CODE
c (SPECIFY) Is the facility located on Indian lands?
s Asheville NC 11 28801 YES XQNO
15 16 41 42147 - 511 53
A. NPDES(Oishcarge to Surface Water) D.PSD(Air Emissions from Proposed Sources)
a N NC0000272 e P 20294
15 1 161 17 JIB 30 151 16 1 11115 30
B. ulc( nderground Injection of Fluids) E. OTHER(Specify)
(SPECIFY)
e u e See Attachment I for List of Permits
15 16 17 18 30 151 16 1 1] 18 30
C. RCRA(Hazardous Wastes) E. OTHER(Specify)
(SPECIFY)
9 R 9
15 17 1B 301151 16 1 17118 30
Al.MAP
Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must show the outline of the facility,the location of each
of its existing and proposed Intake and discharge structures,each of Its hazardous waste treatment,storage,or disposal facilities,and each well where it Injects fluids underground.
Include all springs,rivers and other surface water bodies in the map area. See Instructions for precise requirements.
(provide a bnet descnptIon
The Canton Mill is an integrated bleached papergrade Kraft pulp and paper manufacturing facility producing
paperboard and fine papers.
see ins ons
1 certify under penalty of law that.I have personally examined and am familiar with the information submitted in this application and all attachments and that,
based on my inquiry of those perons immediately respnsible for obtaining the information contained in the application,I beleive that the information is true,
accurate and complete. I am aware that there are significant penalites for submitting false information,including the possibility of fine and imprisonment.
A.NAME&OFFICIAL TITLE(type or print) B.SIG URE C.DATE SIGNED
Robert Cicale-Vice President of
Manufacturing and Mill Manager
NC
16 55
EPA Form 3510-1 (8-90)

Attachment 1
Form 1
NC0000272
X. Existing Environmental Permits
Permit Type Permit No. Agency Unit
A. NPDES NC0000272 N.C. Dept. of Environment Wastewater
and Natural Resources-DWQ Treatment
Facility
NCS000105 N.C. Dept. of Environment Stormwater
and Natural Resources-DWQ
D. PSD 20294 N.C. Dept. of Environment No. 4 Coal Fired
and Natural Resources-DAQ Power Boiler
E. Other 44-06 N.C. Dept. of Environment No. 6 Landfill
and Natural Resources-DAQ
44-159(C) N.C. Dept. of Environment No. 19 Project
and Natural Resources-DAQ
44-819C2 N.C. Dept. of Environment Causticizing Project
and Natural Resources-DAQ
11740 N.C. Dept. of Environment Pump Station
and Natural Resources-DAQ for No. 6
Landfill leachate
20065' N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ
20066' N.C. Dept. of Environment Bark/Coal Boiler
and Natural Resources-DAQ
20067' N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ
20068' N.C. Dept. of Environment Coal Boiler
and Natural Resources-DAQ
20069' N.C. Dept. of Environment Coal Boiler
and Natural Resources-DAQ
20070' N.C. Dept. of Environment Coal Boiler
and Natural Resources-DAQ
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

o '
Attachment I continued
NC0000272
20152` N.C. Dept. of Environment Black Liquor
and Natural Resources-DAQ Oxidation
20386` N.C. Dept. of Environment Lime Slaker
and Natural Resources-DAQ
20392• N.C. Dept. of Environment Nd. 4 Limekiln
and Natural Resources-DAQ and NCG system
20427' N.C. Dept. of Environment Tall Oil Scrubber
and Natural Resources-DAQ
20451' N.C. Dept. of Environment No. 5 Limekiln
and Natural Resources-DAQ and NCG system
20452' N.C. Dept. of Environment Chlorine Dioxide
and Natural Resources-DAQ Scrubber
20463' N.C. Dept. of Environment No. 4 Lime
and Natural Resources-DAQ Unloading System
20485• N.C. Dept. of Environment No. 1 Fiberline
and Natural Resources-DAQ Scrubber
20486' N.C. Dept. of Environment No. 2 Fiberline
and Natural Resources-DAQ Scrubber
20487• N.C. Dept. of Environment No. 5 Lime Slaker
and Natural Resources-DAQ
20488' N.C. Dept. of Environment No. 5 Lime
and Natural Resources-DAQ Unloading System
20496' N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ Dissolv. Tank Vent
20497' N.C. Dept. of Environment White Liquor
and Natural Resources-DAQ Oxidizer Separator
20498' N.C. Dept. of Environment Recovery Furnace
and Natural Resources-DAQ Dissolv. Tank Vent
On July 1, 2000, the air program was re-delegated from the Western North Carolina Regional
Air Pollution Control Agency to the North Carolina Department of Environment and Natural
Resources, Division of Air Quality. Effective October 27, 2000, the new Air Quality Permit
No. is 08961.
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

EPA I.D. NUMBER (copy from Item f of 7771
Form Approved
' NC0000272 OMB No.2040-0086
Please print or type in the unshaded areas only Approval expires 5-31-92
4 jai Y0NMa z 'sE FORMt ENVI2 A2OT t IN,kiA'T
PERMTTOAPLCATOyNF€O R DCHAGE'WAST
2 G E
ti
s+:
NPDES "J� P EXISTING MANUFACTURING COConsol dlated PeN N s P o9 InLVICULTUL OPERATIONS j
-
e .
1. OUTFALL,LOCATION",
-:
For each�6utfall, list,the latitude and lohgitude ofits.looation to:the nearest 15,sec6nds and the t7ame of,the`recetuit g'jwaterr
A. OUTFALL Bi LATITUDE ;C,LONGITUDE,,'-
NUMBER D. RECEIVING WATER(name) '
(fist)_, 1. DEG. 2. MIN. 3. SEC. 1.DEG. 2.MIN: 1 SEC'.
001 35 32 8 82 50 42 Pigeon River
II. FLOWS, SOURCES OF`ROLLUTION,ANDITREATMENTTECHNOLOGIES ,-.,` ' " •`M ' '
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 description in Item B. Construct a waterbalance on the line drawing by showing average,
flows between,intakes,operations,treatment units,.and outfalls.df awaler balance:cannot be determined(e,g,for certain mining activioesprovide a
pictorial,descriptlon of the nature and amount.ofany sources,of water and%ny,collection or treatment measures. .
8,For'each outfall;:providd'"escription:of.,(1j:All operations�contributing.wastewater tdAhe efguen iihctdding proce"ssiWastewater sandary'wastewater
:v
cooling water„and storm waterrunofh(2)The average flow contributed by each operation;and(3j TFie treatment`ecieved by the wastewater:. Continue: •f
on,additional sheets if necessary: "
1. OUTFALL 2. OPERATION(S),CONTRIBUTING FLOW`_ 3.TREATMENT
NUMBER' , a, OPERATION'(Yst), < ' b>AVERAGE FLOW a.DESCRIPTION ', b: LIST CODES FROM,
(lis(}; , : (include unds) - TABL�I .2C
Pulp Mill:Chip Cooking 9.82 mgd Grit Chamber 32'X8'X16' 1-M
001 pulp washing, screening & 29.9 mgd, 1 minute retention
bleaching, recovery and solids to landfill 5-Q
regeneration of cooking
chemicals, production of Bar screens,two 6'wide each, 1-T
chlorine dioxide for pH control by COZ injection. 2-K
bleaching. Coagulation by polymer addition. 2-D
Paper Mill 8.1 mgd Primary clarifiers, circular two 1-U
001 Production of fine papers 200'dia.X 14.75'deep 12.7 mgd ea.,
and paperboard 6.6 hour retention
one, 125' diam x 11' deep for spill
Steam and Power 3.9 mgd control, 1.01 mg capacity
001 Generation skimmed floating solids to landfill 5-Q
Settled solids dewatered by belt 5-C
press to landfill 5-Q
Unmetered and Misc., 2.93 mgd
001 Raw water, Sludge Secondary treatment by activated 3-A
WWTP Use sludge process
Average Stormwater 0.17 mgd based on 1998 rainfall Aeration basin 408'x240', 11.4 mg
Town of Canton 0.65 mgd capacity, 29.9 mgd plus recycle, 9.4
001 Municipal Wastewater and hrs retention
Landfill leachate-Variable
depending on storm events Continued on Attachment II-131
OF.FILIAL,USEONLY(erytu ant guidelines s'ub-categories)
:
EPA Form 3510-2C (8-90) PAGE 1 OF 4 CONTINUE ON REVERSE

r `
Attachment II — B1
Form 2C
NC0000272
Continued from 1113 (3)(a) — (b)
a. Description b. List Codes from Table 2C-1
At low influent loading 3-A
Secondary Treatment by
activated sludge process
(and stand-by capacity
of 4.6 mg) with 6.8 mg
treatment and 5.6 hours
retention.
Secondary clarifiers,
circular, two, 200' dia. x 1-U
12' deep, 11 mgd, one
150' dia. x 14' deep,
6.2 hours retention
Aeration cascade, with 4-A
oxygen injection discharge
to Pigeon River
Oxygen injection capability XX
at 0.9 and 2.1 miles downstream
of discharge.
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

Attachment II - A
PIGEON RIVER
29.9 INCLUDES AVG.
STORMWATER FLOW
31.63 OF 0.17 MOD
EVAP 0.5
WASTEWATER
PUMP HOUSE TREATMENT
PLANT
RAW WATER USE 2.03
SLUDGE 0.30
FILTER PLANT
MILL 8.0 0.6 0.60
COOLING WTP USE
PAPER MILL EVAP 0.7
NO. 11 PM 1.8
10.8 NO. 12 PM 1.3 8.1
NO.20 PM 1.7
NO. 19 PM 2.9
CHEM PREP 1.3
PCC PLANT 0.3
PULP DIST. 1.5
20 WHITE WATER
11.5 PULP MILL
13.50
ERCO CLO2 1.2
CHEM PREP 0.6
COOKING 1.4
BLEACHING 4.9
RECOVERY 3.4
EVAP 1.1
5.0 STE&AM 3.9
POWER
GENERATION
0.9 MISCELLANEOUS 0.9
UNMETERED
BLUE RIDGE PAPER PRODUCTS INC. TOWN OF CANTON 0 9
CANTON MILL-WATER BALANCE WASTEWATER AND
PERMIT NO.-NC 0000272 MILL LANDILL
LEACHATE
FLOWS INMGD DATE:V14101

... i. � . . � �.
_. _ i
. .
i i• .
� Y
i
y
• (;

Mxr,NUEDmOMT EFRONT D NC0000272
C.Except for storm runoff,leaks,or spills,are any of the discharges described in Items II-A or intermittent or seasonal? --
' i As(complete the following table);_ _ . ee - _ _ X NO(go'.to.Sectiomlll) -
..:- .ifi .`3-FREQUENCY I :", _ ., .4,FLOW.
1.OUTFALL '2.OPERATION(Sf' a.DAYS bMONTHSI a.,FLOW RATE b.TOTAL VOLUME
NUMBER. CONTRIBUTING FLOW PER.WEEK PER.YEAR _ I(inmgd)_ (specify with units) c.DUR-.
(list)." (list) (specify (Specify ' 1-LONGTERM 2.MAXIMUM 1XONGTERM 2.MAXIMUM ATION
'.. average)', average)... AVERAGE, DAILY__ AVERAGE DAILY. (in days).
III.PRODUCTION.
A Does,aq,effluent,guideline..limitation promulgated by EPA under Section 304,of t ie�:Cleah WaterAcf apply to,your.facillly? „_. - e'
X YES(complete hefn 111-B) - - NO(go:to'section:IV)
B:Are the limitations in the applicable effluent guideline expressed in.terms of production(or other measure of operation)?
FXJ YES.(complete Item 111-C) NO(go to.Section dV).._ _
C.If you answered�'yes"to Item III-B,list the quantity which;represents an actual measurement of your level of production,expressed in terms and units "
used in;the ap Ilcable'ef8uentguideline,and indioate tlie�at(eated outfalls:_� `" _ f
- - I.AVERAGE.DAILY,PRODUCTION ' ' - 2.AFFECTED' _
a.QUANTITY b.''UNITSOF F.OPERATION;PRODUCTION MATERIAL,,ETC.: -- OUTFALLS
PER DAY MEASURE. _ .(specify) _"_ fAsfout(all numbers,
721.0 ADMT Bleached Papergrade Kraft and Soda paperboard
001
746.8 ADMT Bleached Papergrade Kraft and Soda fine papers
ADMT=Air Dry Metric Tons
NOTE:A project was completed on the No.19 Paperboard Machine in 2000 which increased
our capacity to produce paperboard in future years to 908'ADMT.
(See Attachment IV for correspondence with NCDENR-DWQ with respect
to the paperboard project.)
IV..IMPROVEMENTS -- -_ . __.. .
A.Are you now required by any Federal,State'.orlocal.authority to meet any_implementation schedule fgr the construction upgrade or operation.of waste-
water treatment equipment orpractices orany'o(her envirdnti]ental,prografns which:may'affect thedt'scharges described in thist his applicat on?'T includes;=
but is notlimited to,permit conditions,administrative or enforcement orders,enforcement compliance schedule letters,stipulations,court orders,:'and grant;
or loan conditions
YES(complete the following tattle) X NO..(go.toItemalV:B)
'2.AFFECTED.OUTFALLS .,,FINAL COM-
1.IDENTIFICATION OF'CONDITION; 3:BRIEE.DESCRIPTIONAF PROJECT 'PLIANCE DATE
AGREEMENT,.ETC. a.NO. b.SOURCE_OF DISCHARGE a;RE- b.PRO-
_ QUIRED JECTED.
B..OPTIONAL•You�.may attach'additional Sheets describing,any additional Water:,pollution control progrems'(or otherenvirohmentatprojects 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_forconstruction,
-, MARK"X"IF[DESCRIPTION OE ADDITIONAL CONTRQLPROGRAMSIS ATTACHED.
. " '."n. r•: ' -
EPA Form 3510-2C(Rev.2-85) PAGE 2 OF 4 CONTINUE ON PAGE 3

Attachment IV
Form 2C, III-C-1
NC0000272
Average Daily Production
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

Making ur mark for You.
BLUE RIDGE PAPER PRODUCTS INC.
October 5, 1999
Mr.Forrest Westall
North Carolina Department
Environmental and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
Re: NPDES Permit NC0000272
Blue Ridge Paper Products Inc.
No.19 Paper Machine Improvement Project
Mr. Westall:
Blue Ridge Paper Products Inc., (BRPP),Canton,North Carolina Facility, NPDES Permit No. NC0000272,
is notifying you of planned improvements to No. 19 Paper Machine. The improvements will involve the
replacement of the paper machine's second press with a press of different design and the replacement of
the calendar stacks with two calendar nips. In addition, non-contact cooling towers will be installed to
minimize fresh water usage. The improvements will enhance both product quality and yield and the
paper machine will be able to process lighter weight products at maximum production rates. The No.19
Paper Machine annual calendar day production rate is projected to be less than 1,000 air dried tons of
finished product per day.
This project includes no physical or operational changes that would increase the mill's current pulp
production capacity. Therefore, there will be no additional color loading resulting from this project The
current maximum annual average production capacity of the pulp mill is not sufficient to supply all four
paper machines. The Canton Mill has purchased an average of approximately 39,000 tons of dry
furnished pulp per year for each of the last six years to supplement on-site pulp production and supply
the paper machines. The pulp mill will continue to nm as efficiently as possible, but additional dry
furnish purchases will be necessary to support production at the paper machines.
Blue Ridge Paper Products Inc., is not requesting any revisions or modifications to the NPDES Permit
effluent limitations, monitoring requirements, or other conditions. Completion of the No.19 Paper
Machine Project will result in continued full compliance with the Settlement Agreement Color Variance
and NPDES Permit.
If you have any questions or need additional information please contact me at(828)646-2033.
Sincerely,
Robert V.Williams
Director,Environmental,Health&Safety Affairs

` NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
®�A DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
NODE_ NR WATER QUALITY SECTION
November 19, 1999
JAMESB.HUNTJR.
GOVERNOR JrK';
Mr. Robert Williams
Blue Ridge Paper Products Inc.
175 Main Street
WAYNEMCoEV= Post Office Box 4000
SECRETARY >}� Canton, North Carolina 28716
I
sf• F
KERRT.STEVEND,::
Subject: Improvements to No. 19
C7IREGTOR k Paper Machine
Blue Ridge Paper Products Inc.
NPDES Permit Number NC0000272
Haywood County
t
Dear Mr. Williams:
We have reviewed your letter dated October 5, 1999
::may concerning planned improvements to the No. 19 Paper Machine
: and offer the following comments .
As you are aware, stipulation 30 of the NPDES Permit
Settlement Agreement states, "The 1997 Permit shall also
provide that neither Champion nor any successor-in-interest
i; to Champion' s ownership and/or operation of the Canton mill
will increase the mill' s current pulp production capacity
_ during the. permit term, unless this can be done in a way
that also reduces color loading. " Since the Mill will be
{ purchasing dry furnished pulp to supplement this
improvement, and there will be no increase in the mill ' s
current pulp production capacity, the improvements to the
N No. 19 paper machine meet the condition of the
u. aforementioned stipulation.
= 4P411 -In discussing this matter with Mr. Don Anderson,
Chairman of the Technical Work Group, he agrees that .no
significant changes will occur in the quality of the
effluent with regards to color loading. He also agrees that
these improvements are allowed under the settlement
r agreement. .
iRe f
C
INTERCHANGE BUILDING, 59 WQODFIN PLACE, ASMEVILLEr NC 28801-2414
PHONE [phone] FAX [phone]S2
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - SOq RECYCLED/I 0% POST-CONSUMER PAPER

4
Mr. Robert Williams
November 19, 1999
Page Two
If you have any questions concerning this matter,
please do not hesitate to contact Keith Haynes or me at 251-
6208 .
Sincerely,
Forrest R. Westall
Water Quality Regional Supervisor
cc: Don Anderson
Keith Haynes
N019IMP.LET

EPA I.D. NUMBER (copy from Item 1 of Form 1)
CONTINUED FROM PAGE 2 NC0000272
V.INTAKE-AND'EFFL==UENTCHARACTERISTICS
kj%'&`C . See instructions before+ roceedfiig,4Coir late one setof tables(for each outfall'Annotate the outfall numberin the space provided€a
Note:Tables V-A,V-B;'-and V-C are included an seperate sheets:;numbered�V-1 through V-9.
6.Use the space below to list any of the,pollutants listed in Table 2c,,3'of the Instructions,which'you know or have reason Jo bell ave isAschatUed or may be: ^,
tlischa ged'fiom any'outfall,For,every pollutant;you list;briefly desenbe the reasons you believe It to be'present and report any anafyhcal data!I In your
possession:
1^: POLLUTANT 2;SOURCE a J. POLLUTANT ; ^;, 2„SOURCE
N/A
VI. POTENTIAL,DISCHARGES NOT,COVERED,BYANALYSIS
Is,any pollutant listed:in,item V-C'ah substance or,a`component ote substance which you currently-use or mahufacture as an Intermediate or.l'inal product pr
by product?"
YES,(lift:all such pollutants below)(,^ i s ;�" X NO"(go toJtoo vl-B) .;
N/A Pollutant analysis is included with V-C
EPA Form 3510-2C (8-90) PAGE 3 OF 4 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT NC0000272
VU.B1040CICAL• TOXICITY TESTING DATA, _
tDo you have any.kn0Wledge or reason to believe,that any;biological test for.acute or chronic;toxiaty.hae�been trade on any of your discharge or
receiving water in relation to your dischargipwithin thelast 3 years?
X YES,(identify the test(s)''and describe theirpuropse below) - NO'(go to Seotion.V/!I) `
See Attachment V
,V(I)s.cONTRACT ANALYSIS INFORMATION.
_ c
Where any of the analyses reported in'Item V performed by,a contract laboratory or consulting firm?' `
-YES'(1W the name,.adress and telephone.number of,and^pollutants; NO,(go to Section,pp
aHalyzedby,each such laborafo_ry'or'firm beloww)
A.NAME B.ADDRESS` C.TELEPHONE D. POLLUTANTS ANALYZED,
_ (are&code&no:) ,r(list)
8540 Baycenter Road 1(904)739-2277 All 2C Analysis except Dioxin, Mercury
Columbia Analytical Jacksonville, FL 32256 and self monitoring
Brooks Rand 3950 6th Ave NW
Seattle,WA 98107 [phone] Mercury
Severn Trent Laboratories 880 Riverside Parkway
West Sacramento, CA 95605 [phone] Dioxin
IX.CERTIFICATION
Icefr ify underpenaltyof.law.that this document and alljattachmenfs wereprepared.under my'dvection.or,supar fsion in accordance with'a system delgnedrt8,..
assure that ualified ersonnel property athet end evaluate the infomiafon submitted.Based on m inquiry of the erson or �etsanawh0 manage'the system or
'
o p P P. y 9 _ Y p P;
those persons directlyresponsible,for gathering the information,tthe information submitted is,,to the best of my knowledge and belief;true,accurate,and complete.
I am'aware that there;are aignifcanl,penalties,for subriittingifalse mformanon,including the powibifty of fine a nddmprisonmeot for knowing violations. "
A. NAME AND OFFICIAL TITLE (type or print) B. PHONE NO. (area code&no.)
Robert Cicale-Vice President of Manufacturing and Mill Manager [phone]
C. SIGNATUKV D. DATE SIGNED
EPA Form 3510-2C (8-90) PAGE 4 OF 4

EPA I.D.NUMBER(copyfmm Item 1 of Form 1)
PLEASE PRINT OR TYPE IN THE UNSHADED AREAS ONLY.You report some or all of Form Approved.
this information on separate sheets(use the same format) instead of completing these pages. NC0000272 OMB No.2040-0086
SEE INSTRUCTIONS. Approval expires 7-31-88
:.. OUTFACE NO.
V.INTAKE AND EFFLUENT CHARACTERISTICS,(continued from page 3 of Form 2-C)
001
PART:A-:you must provide.the results of at least one'analysis:for every pollutant in this table. Complete one tablefior each outfall:. See insWctlons for additional details - - -
" - 2:EFFLUENT - _- _. _ 3.UNITS 4 INTAKE(optional)
1.POLLUTANT a.MAXIMUM DAILY VALUE b.MAXIMUM"30'DAY VALUE c.LONG TERM AVRG.VALUE (Sped litelaok) a.LONGTERM
(ifavailaole)' pfavailable)1 d.NO.OF,- AVERAGE VALUE' „ „b:;NO.:OF
(1) • ANALYSES" aCONCEN- (1)' ANALYSES
CONCENTRATION (2}MASS CONCENTRATION (2)MASS CONCENTRATION (2)MASS TRATION 6.MASS CONCENTRATION (2)MASS
a.Biochemical Oxygen 36.2 8,761 10.98 2,299 6.68 1,386 1096 mg/l Ibslday
:.Demand(BOD).
b.chemioaloxD
Dams nd,(COD) 480 54,467 256 52,326 118 24,498 49 mg/l Ibslday
,
c;Total:Organic 33.2 7141 33.2 7141 1 mg/I Ibslday
Carbon"(TOC)
d.Total Suspended 86 19,771 24 4,999 14.98 3,099 1096 mg/1 Ibslday
SO14S(TSS)
e.Ammonia(as N) 4.12 1,049 0.77 179 0.267 55.36 1096 mg/I Ibs/day
VALUE VALUE VALUE VALUE
fc'Flow 58 27.93 24.87 1096 MGD
VALUE VALUE VALUE VALUE
g.Temperature 33.6 31.3 29.8 92 °
(winter) C
VALUE VALUE VALUE VALUE
h.Temperature 38.7 .4 36.0 92 °
(summerj. C 36
MINIMUM MAXIMUM MINIMUM MAXIMUM .. "�. a^ • " ' "
' -pH 7.3 8.4 7.68 7.92 366 STANDARDUNITS _
PART B-.. Mark"X"-in column 2-a for each,pollutant you know or have reason to believe is present.Mark'X in column 2 6 for each pollutant you believe to beatisent. If you mark column 2a for any pollutant
which is limited'.either directly,or indirectly but expressly,in an effluent.limitations guideline;you,must provide the results of at least one analysis for that pollutant.For other pollutants forwhich you mark
column 2a,you must provide quantitative data or an explanation of their presence in your discharge.Complete on table for each outfall.See the instructions for additional details and requirements..
1.;POLLUT• . .. 2:.MARK 1X : :: 3;:.EFFLUENT'»"-•" ;-:4,UNITS ;,,"„ 'a INTAKE(optional)
ANTAND a.BE °.BE.:'a.MAXIMUM DAILY VALUE b.MAXIMUM 30 DAY VALUE c.LONG TERM'AVRG.VALUE fspeayltblank) a.LONG.TERM
CAS NO. ! 'uEVEO UEVEO (ifavailabre) (ifavailabla)' d.NO'OF AVERAGE VALUE b.NO.OF
firaMHable) ANALYSES a.CONCEN- (1) ANALYSES'
SENT ABSENT CONCENTRATION (2)MASS " CONCENTRATION (?)MASS' CONCENTRATION (2)MASS TRATION b.MASS CONCENTRATION (2)MASS
a Bromide X <0.2 ND 2 mgll
(24959-87-9)_-
b.Chlorine X'see v-s
Total Residual
c.Color' X 426 89,403 256 58,009 210 43,382 366 mg/l Ibs/day
d.Fecal X 110 17 10.53 49 #/100 ml
Coliforrii:
e.Fluoide X 0.34 61.11 0.17 31.49 2 mgll Ibslday
(16964.48-8)
(.Nitnlitrate asi- X <2.0 ND 2 mg/l
Ne.(
EPA Form 3510-2C(Rev.2-85) 'Ptatimum Cobalt Units NO=Non-Detect PAGE V-1 CONTINUE ON REVERSE

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EPA I.D.NUMBER(copyfrom Item 1 of Form 1) OUTFALL NUMBER
Forth Approved.
OMB No.2040-0086
CONTINUED FROM PAGE 2 OF FORM 2-C NC0000272 001 Approval expires 7-31-88
' PARTC• If¢o"re a primary Industry and this outfall contairis process wastewater,refer to7able 2c-2 in-tile(nstmdions to determinewhioh of the GC/MS fractions you must test for,Madt'}q in column* �'-
2-a foGall such GCfMS fractions thaf apply to yourindustry and for ALL toxic metals,cyanidesand total phenols:;Ifyou are not required to mark column 2-a(secondary industries nonprocess
„ wasiewaterouNalls,,and nonmquiredGGMS tmcdpns);.markW in column 2-b for each pollutant you know or have mason to believe is present Mark"X"in column 2-c fareach pollutant you
believe is absentafyou mark column 2a for any pollutant:you must provide the results of at least one analysis for that pollutant If you mark column2b for any pollutant,you must provide the results
of affeastone analysis for that pollutant of you kngwor have reason to believe.itwill be discharged in concentrations of 10 ppb qr greater.if you markcol_umh2b for ,ac alein,acrylonitrile,2,4„
din tmphenol,or 2rmgthyl-0,6 diratrophenol you mustprovide the results of at least one analysis fort!ach of these.poilutants which.yoa know orhave reason fo:bepeve that you discharge 1n >r. . ^ "
concentrations of 100 ppb or greater Otherwise,for pollutants forwhich you mark'column 2b,you must either submit at least oneenalysis analysis or briefly describe the reasons the pollutant Is expected to
be discharged..Note that thereare7 pages to this part please review each corefaty.Complete ona fable(all 7 pages)for each auIfail.See instmc5ons for addiSonal details and regwrements.
1.POLLUTANT 2.MARK W 3.EFFLUENT _ -", -" _ 4.UNITS 5.INTAKE:(optronal) --
AND CAS 1:M T, b aE• :g eEreol
AXIMUM OAILYVALUI: b.MAXIMUM.30 DAY VALUE c LONGTERM AVRG:VALUE LONG TERM
NUMBER • r Li6VED tEYEO (Aauailable) !, flfavallibla). .d.NO.OF"' ,3 "?�` ,! .AVERAGEVALDE, bcNO,OK
plevanable) EQUra PRE -Ali (1) '"p) (1) ANALYSES a.CONCEN- b.MASS U ANALYSES,
ED SENT SENTCENTRATON (2)MASS CONCENTRATION 2)MASS :CONCEMRAn R)MASv`" TRATION CONCENTRATION (2)M/ SS
METALS,CYANIDE,AND,TOTAL PHENOLS I - _
1 M.Antimgny,Total X <0.005 ND 2 . ." mgll
(7§40-36.0),
2M.Arsenic,Total(7440-36-2) X 0.009 1.62 0.0088 1.63 2 mgll Ibs/day
3M:Beryllium, X <0.003 ND 2 mgll
Total,(7440'-47 7)''.
4M.C
Total(744043edmiom,-9), X <0.01 ND 2 mgli
5M.Chromium,, X <0.005 ND 2 mg/I
Total(7441147-3)'
SM.Copper,Total X <0.005 ND 2 mgn
(7440-5a8);.
7M.Lead,Total" X <0.002 ND 2 mgll
(7439-92-1)p
SM.Mercury,total: X <0.2 ND 24 ugll
(7439-97-6),..,
9M. 2D)'Total
(7a40-02-i) X 0.0063 1.1 0.0032 0.69 2 mg/l
10M.Selenium, X <0.005 ND 2 mg/l
Total(Z82-49e2)
11M.Siiver;Total X <0.001 ND 2 mg/I
(7440-22-4)
12M.Tha8ium, X <0.002 ND 2 mg/I
Total(7j4aze-o)
ISM.Zinc;Total(7440-66-6) X <0.02 ND 2 mg/1
.
14M.Cyamde;, X <0.01 ND 2 mgll
Total(5712.5)-.
ISM.Phenols, X <0.01 ND 2 mgll
Total
DIOXIN,_•.,
2,3,7,8 Tetra- ' DESCRIBE RESULTS
chlorodibeazo P X All data for permit term were non-detect(less than the detection limit of 10 pgll)by Method EPA-16 1613A.
Dioxin(I764-01-6)
EPA FORM 3510-2C(Rev.2-65) PAGE V-3 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT NC0000272
1..POLLUTANTrRETC
2:MARK'9P' _ `."" -3.EFFLUENT" " _--" - -- ,;" _"-4.UNITS _ -'.5i INTAKE(optional)
ANDCAS� ESF 'b_8E-' c eE- aMAXIMUM DAILY VALUE - b.,MAXIMUM.30DAY VALUE.--- c.70NGTERM AVRG.VALUE - a LONGTERM. - --
NUMBER -S LIEVEO, u_Eveo _,:. _ t 7ne�anaelal (nsvauabrel. _ d..NO.OF AVERAGE VALUE b.NO.OF
{Aay�rlege) 1iiPo t PRE- A6- .(t) - (t)- (0 'ANAhtiSES a,.CONCEN- b.,M ASS p) + ANALYSES"^ O ''SENT : GENT CONCENTRATION (2}MASs 'CONCENTRA710N� (2)MASS' - CONCENTRATION � (2)MAS6 TRATION � '.CONCENTRATION� (2)MASS t
GCIMS FRACTION=VOLATILEICOMPOUNDS • ..._ . . - ____. . . . _. ., ..
1V.Acroleih:(107-02-B) X 425 ND 2 ug/I
2V.Aciylooitrile X <8 ND 2 ug/l
(107.131)= -_
3V.Benzene(71-434r. X <7 ND 2 ugll
W.Bis.(Chlo c
methyl)Ether
(542-88-1):="".
5V.BmMotorm- X <1 ND 2 ugll
6V..Carbon
Tetrachlonpe.. X <1 ND 2 ugll
(56-23-5).
7V.Chlombenzene X <1 ND 2 ugll
(108.9g7j- ,
ev.cnlor_edl-
bromomettane X <1 ND 2 ug/l
(124-478-1)_
9V:,Chloioethane - X <1 ND 2 ugll
(75.00-3)�
1 OV.;2.CNom-""
ethylvinyl Ether- X <1 ND 2 ug/l
110.75'-8j ;-
tiV,Chlorotohn. X 1 0.191 1 0.185 2 ugll Ibs/day
(67-66-3)
12V.Dichloro
bromomethane X <1 ND 2 ugll
(75-27.4)M_
13VLDlchloro-
di0uoromethane X <1 ND 2 ugH
(75'-71-8).-
14V;1,1-D'ichlom X <1 ND 2 ug/1
ethane.(75-34-3)
W.1 z-Dichloro- X <1 ND 2 ug/l
ethane(107-b6.2)
16V.10-Dichlcro- X <1 ND 2 ugll
ethylene(75-35-4)
17V.1,2,6ibhlo'ro X <1 ND 2 ug/l
proppne(7s,3795).
16V:1,3.Tfistr�aia X <1 ND 2 ugll
pmpylena�(542.75-8)'
19V..Ethylbenzene X <1 ND 2 ugll
(100-01=4) -
20V.Methyl - X 41 ND 2 ugll
Bromide:(74,-83.9).:
21V.Methyl ' - X <1 ND 2 ugll
Chlodde;V4,87-3)
EPA FORM 3510-2C(Rev.2-85) NO=Non-Detect PAGE V-4 CONTINUE ON PAGE V-5

NUMBER(copy Imm Item I of fom LNUMBER
Pon Approved.
NCO000272 OD1 OMB No.2040-0086
CONTINUED FROM PAGE V-4
7 Approval expires 7-31-88
-4- - - -5.'INTAKEloptfcna1)-
��l,,PpLk�UTANT',I,.,,- ,2MARK"X" ' - - EFFLUENT, -UNITS
'A
" 1',.BE a2MA) MUM 1DAILY VALUE ] D.MAXIMLM 30,DAYVALU E llc'LONG ITERM AVRG-VALUE
a:LqNG TERM
M,
� I vaiwo I-NO,or AVERAGE VALUE A y.No,OF
REQ"R I - ' ANALYSES a.CONCEN- b.MASS (1) ANALYSE S
CONCENTRATION (2)MASS CONCENTRATION (2) ..'CONCENTRATION (2)MASS TRATION CONCENTRATION ,
GCIMSLFfZAqT1O?t-VOLATILE COMPOUNDS(coirithnue,:O
22V.Methylene,• x <5 ND 2 Ug/1
23V 1,1 12-Totra-1
: x <1 ND 2 ug/1
(79-34-5)',
24V.Td1ra616rq- <1 ND 2 U911
ethylenw{jji-'l 8-4)
X <1 N 2 U911ND
(I06-68-3); . - ,
26V.I,;-Trarls-
Dichlomethylene x <1 ND 2 ugI1
(156-60-5),-, I I I I I I
27.V;I[Ail-T.rl-
chlorciethane x <1 ND 2 Ugl]
28Vy
61oroethane x <1 ND 2 ug/1
(79-0a5)
29V.Trichloro- x <1 ND 2 UgIl
'ethylene(79,01-6),
3OV,TriWoro
-
X <7 ND 2 Ug/1
(75-694):
31V.Vinyl, <1 ND 2 Ug/1
o x
Chlodde(7S-01-4) l
GC FR-A Im CTIDk -ACIo COMPOUNDS
1X�2-6hl'ondp1he
001
x <5 NO 2 ug/1
X ND 2 Ug/1
phenol(I?0,83-2),
3A.2,4:Dr66thyI-
phenoi1'(j6r;,67-i1) x NO 2 Ug/1
4A,4,d-Dihhi6-6-' x <20
I ND 2 Ug/I
5A.2.4-bliiiho: -1�1 x <20 ND 2 Ug/1
phenol'(51.]A-5) I
6A,2-Wjtr6p 1113601, x <6 ND 2, Ug/1
7A 4rN((rophenol
x <20 ND 2 ugirl
Bk P-Cfitono-M x <20 ND 2 Ugn
cremr(59;50-7) I I I
9A.Fen66tilano. x <20 ND 2 ug/1
(10,8,- 5 x <5 ND 2 ug/l
ghlorop 2 ugli
phe- x <5 ND
CONTINUE ON REVERSE
EPA FORM 3510-2C(Rev.2-85) ND Non-Detect PAGE V-5

m IU Si- �Q
P7 P ��j
IN
ILI
pl� m
Z5
T W
> E'R
X X X X x x X X x x x x x x x X x x x x
rP
> z
5V
It A A A iA A A A A A A A A A fit N A A A A A A
z z z z z z z z z z z z z z z z z z z z
0 0 0 0 0 a a
C to

NUMBER(wpyfmm Item 1 of form 1) OUTFALL NUMBER
Fan Approved.
NC0000272 001 OMB No.204o-o086
CONTINUED FROM PAGE V-6 Approval expires 7-31-88
4.UNITS,�, ,� - 1'5 INTAKE'(60Uonal),
,i��POLLUTANr-,;'--,.2.MARK!,)C,,','t'I -32EFFLUENT
a�MAXIMUM DALYVA�YE, a;'LONGTERM TEST-11bBE b.,MAXIMUM.30DAY?VALUE a.LONGTERMAVR LUE
-11 — - .1 1 �1,11 , . P,�VA 71- I ki.No,OF awilablal:- lea"llable), a.,NO' AVrRAGtVA UE,
of ti I le � �OJFI -(I) ---- — 11
PEVEJ (2)MASS (1)� ,- )j V)MASS ANALYSES' a!CONPEN- K.MASS' AN,
NUMBER Pill, SENT, I CONCENTRATION CONCENTRATION-. I"ASS CONCENTRATION .- TRATI I ON CONCENTRATION' (2)MASS _
GC1675VlF,RACTiON'-BASEfNEUTRAL'COMPOUNDS(contfneo)
22B,1.4-Lpichlomo- x <5 ND 2 ugll
benzone(10646-7)
2313.-3 3'-'Dichlom-
benzidhe,'— x <20 ND 2 ugll
Yj
x <5 ND 2 ugll
25B.Diffiethyl
Phthafat,� X <5 ND 2 ugll
268.NN-Butyl„�
Phthalate x <5 ND 2 ugll
(64442)iv
27B'2,4_131nitrd-�, x <5 ND 2 ugli
iolu'6021-,14,4
x <5 ND 2 ugll
tolu.(606-20-2)
29B�DiwNpatyl
Phthalate x <5 ND 2 ugll
MS.1,2.Diphen*
I hyd.tawne-ja,sAzP, x <5 ND 2 ugli
ljnzpn.,�D22-657),
3113-Fluorathene, X <5 ND 2 ugll
7
328'Aluomne,, x <5 ND 2 ugli
7 "
a6bloro- x <5 ND 2 ugll
6e;Z.66618--74-1)]
34131 Hexa--: I- .
cWarobutadiene x <5 ND 2 ugll
35&He) cliloro-
cyqapSn <5 ND 2 ugli
lula#�e X
(7,7-47,-)10P`�l',�-I , I
X
36B;?HeiachIo­ro-� <5 ND 2 ugli
ethabi--e'(674724)
37B:Inddno
x <5 ND 2 ugll
(193-39-5),a.
38B;lsophorone X <5 ND 2 ug/l
X <5 ND 2 ugli
x <5 ND 2 ugll
i ad i filie-th"yl'a a i n e-'(6 2 X <5 ND 2 Ugli
42B.N-NitmckIkN-'
Propy(aifiimt` X <5 ND 2 ugll
21
EPA FORM 35I0-2C(Rev.2-85) ND=Non-Detect PAGE V-7 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
4 P,OLLUTANT 2:MARK::"X" - _ _ ' ""3.EFFLUENT" - - "- 4.UNITS I 5.INTAKE(optional) -
ANDCAS a:TEBT b.eE•d E a.,MAXIMUM DAILY VALUE b..MAXIMUM 30 DAY,VALUE C.LONG.TERM AVRG.:VALUE ""` "" a.LONGTERM "
NUMBER iND UEVED uEVED • GravaAa6fe (fmbbre) d..NO.OF ,:, _ AVERAGE VALUE b.NO.OF-
` pra[ar744- REDUIR, PRrc ,.•n�- , d) - - (1) „., (1y. - ANALYSES a.CCNCEN- b.,MASS U) ANALYSES
"064'�*` - ED SENT' ;:,$ENT• CONCENTRATION (2)MA88 "CONCENTRATION ._ (�)MA96 CONCENTRATION (4�M6,88 " TRATION -CONCENTRATION >^.(l�MA85 s
GCIMS FRACTION..BASEINEUTRR_L COMPOUNDS(ConGnueu),-- - -V
43S,WNIUo- -
sodiphenylamine: X <5 ND 2 ugll
44-01h8)antfiTene X <5 ND 2 ugll
45B.Pyrene, X <5 ND 2 ugll
Chlorobemene. X <5 ND 2 ugll
GC/Ms FRACTION1-PESTICIDES
1 P.AM n X <0.02 ND 2 ug/I -
(309-00-2)
20.a-BHC X <002 ND
(319.85 7) . 2 ugll
9P..0•BNd.. X <0.02 ND 2 ugll
4P.y-eHC' (58 X <0.02 ND 2 ugll
89-9)
5P.s")
(31s-86-8) X <0.02 ND 2 ugll
60.dhl6rodane. X <0.02 ND 2 ugli
(57-74-9)
7P°4,4'bbf' X <0.02 ND 2 ugll
7 45.9)0E X <0.02 ND 2 ugll
(72-55 14
sP;4,4'SiJDD X <0.02 ND 2 ugll
(Z2-54-5)
lop.Dielddn(60-57.1)� X <0.02 ND 2 ugll
UA. a,Endosuifan X <0.02 ND 2 ugll
o 15.29=zY
i2P.a• ndbsLlfar{ X <0.02 ND 2 ugll
(115-29.7}
13P.End'osuifan X <0.02 ND 2 ugll
Sulfate(-1131.0,7-8)
14P.Enddn X <0.02 ND 2 ugll
(72-20-0)
15P,Endnn' _;..
Idehyde i X <0.02 ND 2 ugll
(742t-83i4) =
iBP.Heptachlors X <0.02 ND 2 ugll
(75448)
EPA FORM 3510-2C(Rev.2-85) ND=Non-Defect PAGE V-8 CONTINUE ON PAGE V-9

EPA I.D.NUMBER(aopyaom Item 1 or form 1) OUTFALL NUMBER
Form Approved.
NC0000272 001 OMB No.2040-0096
CONTINUED FROM PAGE V-6 Approyal expires 7.31-88
2YMARK4': ,' lid:':?e�"a"5:`*•;s.": 'ip rs 1FzE:i£dz''":; . .?=€F,Fr.BUENTi
t+i' ? i'y T f,b9 y'ds' ; 'I UM DAILW'UAt:UEts xS#,hMR)CI UM30:9 ,AIFUEN" ML�QNCg7ERMM`,YRG'Yr IIUE4 'i"' + n ,,:. r
' .'_'-'Nu BER,,'F` ,�i+)�o, i u�VEor��VE :. a �, . �' ``• s'.K , - •'s� q�' Ava11e�`tea�k'„•.'a�c'��`�" dT�N„Q:Or `�#'�y,gti. >�r-��*�, '
sa t a'r ;� ,I= F AV G L z41' b3N
, REOUYR t'�fiR ..#`'u u�' �i'i, - 't1J x, i . . A 1 t, (tY w .,'rt S£; G,(t si4. ',YT«"r•. igi) NA1Y.S"ES •:te CONCEN,* 6# $ it #1 1-, A
i I. 's.FD}iu SENT.; BSENf C�?R TION,°ci.' '(;MASS IQANCF.mM710N...-_"uK(9µ.,�'eS9.ii s CONC �i n'' Cal-A ASS�y„ i,.Mw.vy, t C1,tTRA7�Q[+ti:. �`44� tiles'; .*d 0_ a-
v o.�a-s t.Sa 4 _ -
G'C-7h1SF -
17P ep�c8lor
E(ioe <0.02 ND 2 ugll
(a`�2T3
I
`
SB B�-z X <0.2 ND 2 ugll
1ECP4',#'-E
<0.2 ND - 2 ug/l
X <0.2 ND 2 ugll
X -_, <0.2 ND 2 ugN
220 ,MEN
X <0.2 NO 2 ug/I
2' 41aby,(tid9s,- X <0.2 ND 2 ug/I
PC
`e ' X <0.2 NID 2 ugN
,W
25PT.oica'p11en''"e,'�,
X <0.2 ND 2 ugN
EPA FORM 3510-2C(Rev.2-85) PAGE V-9
ND=Non-Detect
footnote from page V-1
*One of the two secondary effluent priority pollutant scans showed a 0.05 ppm concentration for residual chlorine. The second scan resulted in a non-detect at 0.01 ppm.
BRPP has evaluated this reported residual chlorine result and,in consultation with NCASI,does not believe residual chlorine can exist in our effluent.
This Is based on the very reactive nature of chlorine,which readily combines with all elements except rare gases and nitrogen(source:The Merck Index,11th edition).
In addition,Standard Methods, 18th-20th editions,states known analytical interferences(organic matter)with the colorimetric method used for our type of wastewater.
Therefore,"Believed Absent"is checked for residual chlorine.

. w
Attachment V
Quarterly Chronic Toxicity Data
NC0000272
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC

NPDES Permit Renewal Application
2C -Atttachment V
Summary of Historical Toxicity Data from 1998 -2000
Results of 7-Day Ceriodaphnia Survival and Reproduction
No Observable Effect Concentration (NOEC)
Sample Date NOEC% Effluent
3/23/98 100
6/8/98 100
9/7/98 100
12/14/98 100
3/8/99 100
6/14/99 100
10/14/99 100
12/6199 75
12/28/99 100
2/14/00 100
3/10/00 100
6/5/00 100
9/11/00 100
12/11100 100
Testing performed by Burlington Research Laboraoty
1302 Belmont Street
Burlington, NC 27215-6935
[phone]
Blue Ridge Paper Products Inc.
Canton Mill
Canton, NC
NC0000272

OPERATING EXPERIENCE WITH AN 1_2 _----
OZONE-BASED ECF BLEACHING 1.0
SEQUENCE
wn 0.8 6°& ° ♦ ♦ 1 • Aspen
Fred Munro,Manager Technical Services,Domtar Inc., o m 0.6 —As
°_�' • ° sotnvoo°
en
Eddy Specialty Papers Division w o ♦ ♦ softwood
John Griffiths,Senior Process Engineer,Domtar Inc., m 0.4 e
Eddy Specialty Papers Division o n 0.2
°
Y °
0.0
ABSTRACT 0 5 10 15 20 25
A medium consistency ozone stage was incorporated Black Liquor Carryover(kg CODA)
in a(ZD)configuration as part of a complete hardwood fibre
line modernization at the Espanola mill.The major Fig.1 Effect of COD carryover on ozone stage
expectations from ozone were improved bleaching economy,a delignification(Pilot plant results)
higher brightness ceiling,and reduced environmental impact.
Operating results have exceeded expectations.Ozone BLEACHING SEQUENCE DEVELOPMENT
has a chlorine dioxide replacement ratio of 3.5 (1 kg/t ozone In 1996 the Espanola mill began a project to
replaces 3.5 kg/t chlorine dioxide)on hard to bleach species modernize the hardwood pulping and bleaching line.The
and a replacement ratio of 2.5 on easily bleached species, objective was to build a pulping line to economically produce
significantly improving bleaching economy.Effluent AOX, world-class hardwood pulps with low environmental impact.
COD,and colour have decreased significantly. Pulp The old bleaching sequence was ODcEDnD. The
extractives and TOX content have decreased.Pulp cleanliness decision to retain the existing towers constrained the new
is exceptional.Pulp strength and viscosity have been sequence to four bleaching stages.The ozone pilot plant work,
maintained with the new bleaching sequence. in conjunction with Air Liquide's research on(ZD)bleaching
and extensive lab trials at PAPRICAN,identified the
INTRODUCTION OA(ZD)EDnD sequence as the best choice to maximize
The Espanola pulp mill has two complete pulping and brightness,maintain pulp physical properties,and minimize
bleaching lines,one producing softwood and the other chemical cost and environmental impact.
producing hardwood.Total production is 1000 ADMT/day of Although the pilot plant trials showed that acid pre-
fully bleached pulp.Weak black liquor from both lines is treatment did not improve an ozone stage,the A(acid)stage
combined and processed through a single recovery boiler and was installed to strip metals from the pulp and eliminate
recausticizing plant.Two integrated paper machines produce calcium-based scaling on the bleaching equipment.The acid
200 ADMT/day of specialty,packaging,and fine papers. charge required for the ozone stage is actually added to the A
Effluents from all areas are combined and treated in an aerated stage,extending the usefulness of the sulphuric acid.This
stabilization basin. stage has been successful in eliminating scale throughout the
In the late 1990s,environmental concerns arose with bleach plant.
dioxin and chlorinated organic compounds(measured as AOX) The ozone stage was installed in a(ZD)
in pulp mill effluent. In response,the Espanola mill began configuration.The stage is configured such that ozone is
investigating several chlorine-free bleaching alternatives, reacted,the residual oxygen is removed from the pulp,and
among which was ozone.A partnership was established with chlorine dioxide is added and reacted.The pulp is then
Kamyr Inc.and Canadian Liquid Air to install an ozone pilot washed.The Do segment is sized large enough to carry the
plant in the Espanola mill and use it to investigate ozone entire bleaching load of this stage.
bleaching on Espanola's oxygen delignified softwood and There were several reasons for the choice of a(ZD)
hardwood pulps. stage.We assumed(correctly,as it turned out)that there would
be some start-up difficulties with the ozone system,and
OZONE PILOT PLANT wanted-the full D0 backup to maintain pulp quality.In addition,
The 5 TPD ozone pilot plant was commissioned in our research had shown that there were no adverse quality
April 1992 and operated for 14 months.Early in the program effects on the pulp if ozone was utilized in a(ZD)
the effort was focused on medium consistency bleaching.The configuration,whereas more care had to be taken with a full
pilot plant work showed that ozone was a powerful, ozone stage(ZZ).The(ZD)configuration was chosen to
economical bleaching agent that could be applied without protect our pulp customers from adverse changes in physical
degrading pulp quality.Two of the key findings from the pilot properties.
plant work were:
• An ozone stage is sensitive to carryover(see.Fig.1) HARDWOOD LINE MODERNIZATION
• Espanola's northern hardwood pulps can absorb large Once the bleaching sequence was chosen,the
ozone doses without degradation in physical properties. modernization was designed around the unique requirements
of an ozone stage.

Primary concerns were: with 20 seconds retention time. At the top of this tube an
♦ Good brownstock screening for chive removal Ahlstrom degas unit removes 50%of the entrained gas and
♦ Good brownstock washing for low carryover into stabilizes the pressure in the tube.The pulp discharges from
the ozone stage. the degas unit through a pressure control valve into the
A 4 stage brownstock screening system was installed, standpipe.of the second MC`pump.The remainder of the
using a PI/P2 configuration.The first primary screen uses entrained gas is taken off the top of the standpipe and,along
0.060"hole baskets,followed by the second primary barrier with the gas from the degas unit,is passed through a fibre
screen with 0.006"slots. scrubber and into the ozone destruct unit.The pulp is pumped
Brownstock washing was designed with three to the CIO,chemical mixer and into the Do tower.
washing devices ahead of the oxygen stage(2 IMPCO®CB The ozone stage operates at 1035 kPa and 50 C.Stock
filters. 1 IMPCO®wash press)and three washing devices pH is controlled to 2.5—3.5.The ozone charge is fixed at 6
following the oxygen stage (1 IMPCO°CB filter, 1 IMPCO® kg/ADMT and the CIO,charge to the Do stage is varied to
Coru-Dek IV®vacuum drum filter, 1 IMPCO°wash press— compensate for incoming kappa number variations.
see Fig.2).The wash press was installed ahead of the ozone
stage as a thermal barrier for the ozone stage and a chloride OZONE STAGE PERFORMANCE
barrier for the recovery process. The hardwood line produces three pulps: aspen,
We commissioned the modernized hardwood line in maple,and birch.Aspen is the easiest to bleach and birch the
three stages—brownstock washing and upgraded most difficult.These two species were used to evaluate the
centricleaning in September 1997,brownstock screening in performance of the ozone stage
April 1998, and the bleach plant in September 1998.The
ozone stage was commissioned in May 1999.
ia®ga Hu&wd Una
•Y^I•••+9 3 Chip Bins Chip Pliess„
Broumttoek Wsmlting Bskh Wgsatsrs
u
u
w-
scmw ing
OX NnflaniftaUan
,n�NM
MACHINE tk' /yhlo*.. ftvr91�
go
is
Z Mkilrw Ohttdd M=Uafta2m Stage
BIMIChom ,. 6hlathm Illmilda Simp
Fig.2 Modernized hardwood line
The primary determinant of medium consistency
OZONE GENERATION ozone stage performance is the ability of the system to mix and
Ozone is purchased"across the fence"from Air react the ozone gas.A measure of this ability is the ozone
Liquide.The 3.6 tonne/day ozone plant consists of two consumption at a given ozone charge. As can be seen from
generators and two liquid ring compressors and is designed to Fig.3,ozone consumption decreases as the ozone charge
deliver 12.5%ozone at 1140 kPa to the ozone mixers. exceeds 4 kg/t,but remains above 94%even at high charges
The data scatter results from operating variations in carryover,
OZONE STAGE OPERATION incoming Kappa number,and pH.
The ozone stage consists of two Ahlstrom AMZT"
mixers fed by an MCO pump. Ozone is fed to each mixer,but
the majority of the flow(8001o)goes to the first mixer.The
second mixer discharges into a vertical flow stabilization tube
r

Selectivity
100 . "'►;" s ° The selectivity of the ozone stage(measured as
a 99 - viscosity loss per kg/ADMT ozone charged)is strongly
E 97 affected by the incoming viscosity(see Fig.5).
m
w` 0 96
95
e 94 ~ 0 1.6
° m 1.6
m H g3 _
o D 92 °Aspen ° 'n 1.4
O " 91 °Birch < • I
m O t2
90 u
N Y 1.0
0 2 4 6
N 0 O.H
Ozone Charge(kgIADMT) y. o.s
° m
Fig.3 Effect of ozone charge on ozone mixer efficiency-
February 2000 data 02
0.0
The effect of the following parameters on the 12 14 16 is 20 22
performance of the ozone stage was evaluated: Initial viscosity(cps)
♦ Reaction pH(2.5-5.5) • 4.4k ADMTA Oed O3- =0.0243 210.9931x-7.9756
♦ Temperature(50-6(k) Fig.5 Selectivity vs.incoming viscosity-Birch pulp,4.4
♦ Ozone charge(1 -6 kg/ADMT) kg/ADMT ozone charge,48°C,2.5 pH
Ozone stage performance was evaluated using two
parameters: Ozone charge,reaction temperature,or reaction pH does not
♦ Delignification efficiency(Kappa drop/kg O,applied) significantly affect the selectivity(see Fig. 6).The data in
♦ Selectivity(Viscosity drop/kg 03 applied) Fig.6 have been corrected for variations in incoming viscosity.
Delignification Efficiency
.0
As As ozone charge increases,the delignification 1.e
efficiency(measured as Kappa drop per kg/ADMT ozone s a 1.6
charged)decreases(see Fig.4). Lack of available lignin at m a` 1.4
higher ozone charges does not appear to explain this decrease W. $ 12
because data from a high input Kappa trial falls right on the g a 0.e °
curve(Fig.4).The effect may be due to reaction kinetics and 6 0.s
the retention times in Espanola's particular system,since w 0.4
raising the reaction temperature to 60`C appears to increase the 0 ' 02 °
delignification efficiency back to 1.0 and increasing the pH to 0.0
5.5 appears'to decrease the delignification efficiency. 0 1 2 3 4 5 6 7
Ozone Charge(kg 03/ADMT)
IS WC 2.5 PH•50C4.5 H A 50C,55 pH•55C 6 PH,high Viscas In 460C2.6 H
1.6 - Fig.6 Selectivity vs.ozone charge,temperature,and pH-
m 1.4 a Birch pulp,corrected to 14 cps incoming viscosity.
ma 12 °
w o 1.0 ® OZONE STAGE ECONOMY
o.e_ The economy of an ozone stage is mill dependent and
0 o.6 a ° ® is determined by the relative costs of ozone and chlorine
m a OA ° dioxide and by the ozone replacement ratio.
o x 02 Used in (ZD)configuration,ozone replaces some of
0.0 the chlorine dioxide normally used in the first stage.The
0 1 2 3 4 5 6 r kg/ADMT of chlorine dioxide replaced by 1 kg/ADMT of
Ozone Charge(kg 03/ADMT) ozone at equivalent final brightness is called the replacement
° 500,2.5;H • 5OC,pH as • 50C,pHs5 ratio(i.e. a replacement ratio of 2.5 means.that 1 kg/t of ozone
0 s5C,H .6,11.2xappin A e0C.cH26 -5=2.5PH replaces 2.5 kg/t of chlorine dioxide).
Fig.4 Delignification efficiency vs.ozone charge, The hardest to bleach pulps have the highest replacement ratio.
temperature,pH,and incoming kappa number-Birch Aspen is the easiest to delignify and has a replacement ratio of
pulp,9.2 Kappa In,50°C,2.5 pH 2.5, while birch,the most difficult to bleach,has a replacement
'ratio of 3.5. In all cases,ozone ECF is more economical than
C102 ECF with Espanola's chemical cost structure.
Stoichiometrically,ozone has a replacement ratio of
1.7.The higher replacement ratios achieved in practice are
likely due to the increased efficiency of the bleaching sequence .

once ozone has been introduced,since ozone reacts with more upgraded at the pulp machine.As a result.of these changes,all
lignin structures than CIO,. hardwood pulps have no measurable dirt content(see Fig.9)
The modern design of the new hardwood line reduced
ECF bleaching chemical cost by 23%in spite of an increase in
final brightness(see Fig.7).Addition of ozone to the sequence 5000 ----
reduced bleaching chemical cost by another 8%and further 4500 «`-
increased brightness.The average bleached brightness is now 4000
1.5%ISO higher than that from the old bleach plant at a 3500
reduction in chemical cost of 31%. 300o
m
'c 2500
LL
2000
u 100 :�� 91.0 1500
E 95 a r.i'� Ge 1000
90 '�"� 90.5 0
m 500
85 rw x
5 m 80 90.0 "u 0
m o 70 7 gg,g t 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1
m 65 d . m TAPP]Dirt(pptn)
a' 60 = .. 89.0 n
z so t, - 38.5 LL Fig.9 Hardwood pulp cleanliness histogram- 1999 Data
Old Line New Line New Line
ECF ECF Ozone ECF Extractives Content
Ozone bleaching has reduced the DCM extractive
ElRelative Bleachingchemical cost IQ Final Bd fitness _ content of the pulp by 30-50%compared to conventional ECF
Fig.7 Impact of modernized pulping line and ozone stage bleaching,and by 70-80%compared to high substitution
on final brightness and chemical cost-1997-1999 averages bleaching on the old hardwood line(see Fig.10).The majority
of the improvement between the old line and new line ECF is
OZONE ECF PULP QUALITY attributed to the better brownstock washing with the new
equipment.
Physical Properties
To protect Espanola's.pulp customers,ozone ECF
was brought on-line in stages and the pulps evaluated
internally prior to release to market.Ozone charges began at 1 025
kg/ADMT on pulp and were increased in a series of trials
which were lab evaluated and evaluated for performance in f 9zo nBo-nn
Domtar paper mills.No significant differences were found
between the ozone ECF pulp and conventional ECF pulp in d 0.15
any of the hardwood species in lab PFI analysis(see Fig.8)or
in actual paper machine performance. ` 0.10
MIMI
w`
S 0.05
Ole Line New Line New Una
8.0 60%Substitution ECF O.ne ECF
e 7.0 Bleaching sequence
HFig.10 Impact of hardwood modernization and ozone stage
6.0 on DCM extractives
` 5.0 Viscosity
The final viscosity of the fully bleached pulp was not
4.0 affected by the use of ozone(see Fig.11).Although viscosity is
100 80 60 Tensile 40 20 0 lost across the ozone stage,the viscosity loss in subsequent
ff -Bircn ECF 1999 Avg. ' n Birch Ozone ECF 1999 Avg. bleaching stages is reduced,resulting in a fully bleached
'�- A6 n ECF 1999 Av . Aspen Ozone ECF 1999 Av . viscosity equivalent to conventional ECF.
Fig.8 Tear/tensile relationship ECF vs.ozone ECF-1999 TOX Content
averages Conversion to ECF bleaching reduced the Total
Cleanliness Organic Halide(TOX)content of bleached aspen pulp by 60%
and birch pulp by 80%.Adding ozone to the ECF sequence
The shive bleaching ability of ozone was an early
concern in the project,so the screen room was designed with a reduced the aspen pulp TOX by 51%and the birch pulp TOX
0.006"slot barrier screen and the centricleaner system was by 69%(see Fig.12).

_ COD
18 The use of ozone reduced the COD content of the acid
-= effluent by 33%.The alkaline effluent COD content did not
74 -� change significantly(see Fig.14).
n 12
10
0 8 i ECF 18.00 --.
m 6 �� - ', EIZECF
4 16.00 ElAcid Effluent
1:
2 - 14.00 ©Alkaline Effluent
Aspen Birch _ 12.00 ?;
Species rn 10.00
s 8.00
Fig. 11 Impact of ozone stage on full bleached viscosity- C)
1999 averages 0 6.00
4.00
2.00
1000 0.00
900 13Bimh ECF Z ECF
800 MCI ®qs en
700 Fig.14 Impact of ozone stage on bleach plant effluent COD
fi 600
a 500 Colour
0 400 The colour of the treated effluent results from the
300 colour contribution of both softwood and hardwood bleaching
200 line effluents and other liquor losses from the mill.Installation
100 of the new hardwood line equipment reduced total effluent
colour by 21%,a considerable decrease considering the
Cs Line New Line New Llne improvement was in one bleaching line only.The use of ozone
60%BubstilNion ECF Ozone ECF p g y'
Bleaching Sequence reduced the total effluent colour by a further 27%,another
considerable decrease.Note that the conversion of the
Fig.12 Bleached hardwood pulp TOX content softwood bleach plant from high substitution to ECF bleaching
ENVIRONMENTAL IMPACT did not impact effluent colour.
The hardwood bleach plant effluents are segregated
into acid and alkaline streams .Each stream is processed 1wo
through a fibre filter for fibre recovery prior to discharge to the 'n s00
effluent treatment system. 000 ' ff
roo
0 fioo 3
AOX 6 s�
The majority of the hardwood bleach plant effluent
AOX is found in the acidic filtrate.The use of ozone reduced " 600
the AOX in this stream by 65%(see Fig.13). a 300
zoo s,
00
0.50
0.45 _ice 0
©, 6WBOZSubetltu0on 6W60%cub& SW 60%sub& 6W ECF&
040 Sz}`. ,y.p, ALIE EIIIIIE!nt &HW Old LIne HWNew LIne ELF HWNuwnne HW New One
�w• El Alkaline Efflue nt (60%Substbef.n) Ozone ECF Ozone ECF
0.35
G 0.30
Fig.15 Impact of hardwood modernization and ozone stage
s 0.25 on treated effluent colour
K 0.20
0 CONCLUSIONS
¢ 0.15 r $ Ozone has proven to be a practical,powerful
0.10 ' _.7�.• , ,
0.05 + *a* r bleaching reagent.When incorporated into an ECF sequence,
,r ."} ;`��.a. r•*�. ozone improved bleaching economy and pulp quality while
0.00 significantly reducing environmental loading.The medium
ECF Ozone ECF consistency ozone stage itself has a reasonable capital cost,a
Bleaching Sequence small footprint,and can easily be retrofitted into an existing
sequence.There are high potential capital costs,however,if
Fig.13 Impact of ozone stage on hardwood bleach plant washing and screening have to be upgraded to maximize the
effluent AOX benefits from ozone.

The(ZD)stage incorporated in Espanola's hardwood
modernization has improved bleaching economy,improved
pulp quality,and reduced the effluent load from the bleach
plant.Incorporation of ozone into the ECF bleaching sequence
has:
Reduced ECF bleaching chemical cost by 8%
while increasing final brightness by 0.5%ISO
• Reduced pulp DCM extractives content by 30-
50%
• Reduced pulp TOX content by 50—70%
• Had no impact on pulp mechanical strength or
viscosity
• Reduced hardwood bleach plant effluent AOX by
65%
• Reduced hardwood bleach plant effluent COD by
18%
• Reduced total mill effluent colour by 27%

BLUE RIDGE
PAPER PRODUCTS INC.
March 5, 2001
Mr. Mike Myers
NPDES Permits
North Carolina Department of
Environment&Natural Resources
512 North Salisbury Street
Raleigh,NC 27604
Dear Mr. Myers:
Please find enclosed the revised Attachment II-A for Blue Ridge Paper Products Inc.'s, Canton
Mill,NPDES Permit NC0000272. The water balance was revised from 20 to 2.0 mgd to reflect
an accurate white water contribution from the paper mill to the pulp mill.
Please call me if you have any questions at [phone].
Derric Brown
Manager, Environmental Affairs FmIA
R '�7 20017AIEi2OW _SECTIO@lHEVILLE 11EGIOtIAL OFF;CE
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
xc: Forest Westall
North Carolina Department of
Environment&Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
Keith Haynes
North Carolina Department of
Environment&Natural Resources
59 Woodfin Place
Asheville,NC 28801

Attachment II - A
PIGEON RIVER
29.9 INCLUDES AVG.
STORMWATER FLOW
31.63 OF 0.17 MGD
EVAP os
WASTEWATER
PUMP HOUSE TREATMENT
RAW WATER USE 2.03 PLANT
SLUDGE 0.30
FILTER PLANT
MILL 8.0 0.6 0.60
COOLING WTP USE
PAPER MILL EVAP 0.7
NO. 11 PM 1.8
10.8 NO. 12 PM 1.3 8.1
NO.20 PM 1.7
NO. 19 PM 2.9
CHEM PREP 1.3
PCC PLANT 0.3
PULP DIST. 1.5
2.0 WHITE WATER
11.5 PULP M MILL
13.50
ERCO CL)2 1.2
CBEM PREP 0.6
COOKING 1.4
BLEACHING 4.9
RECOVERY 3A
EVAP 11
5.0 STEAM 3.9
POWER
GENERATION
0.9 MISCELLANEOUS 0.9
UNMETERED
BLUE RIDGE PAPER PRODUCTS INC. TOWN OF CANTON
CANTON MILL-WATER BALANCE WASTEWATER AND 0•9
PERMIT NO.-NC 0000272 MILL LANDILL
LEACHATE
FLOWS IN MGD DATE:Z114I01

The best-looking paper
the Canton Min employees
have ever produced:
r
�National 4
Environmen"tal
Achievement*Track
US Ef(nN1lTfntaPO P9'�p
1
�M
S IRONMENTAL PROTECTION tAGENCY
RECOGNIZES
e aper Products; Pncurporatted
'..
AS A CHARTER MEMBER ITJ E'�
ONAL ENVIRONMENTAL ACHIEVEMENT TRACK
p . y MITMENT TO SOUND ENVIRONMENTA MANAGEMEN ,
ONTINOUS IMPROVEMEN�,PUBLIC OUTREACH,
AND SUSTAINED ENVIRONMENT AL COMPLIANCE.
'DECEMB3, 2000
W.Michael McWhe
�Carol, caner DeP N�dmi vats
'"''t@to� USE -to ratact o c
ern P ¢ctro �°
At Blue Ridge Paper Products,we're Carolina and Tennessee,concluded that striving for environmental progress and
extremely proud to be recognized by Blue Ridge Paper Products has gone community leadership.
the United States Environmental beyond regulatory compliance to better All of the employee-owners of Blue
Protection Agency for our cormnihnent protect die public health and the Ridge Paper Products are dedicated to
to outstanding environmental environment.We were selected as one manufacturing quality paper,and to
performance. of only a few Charter Members in the improving the quality of life in our
A rigorous application process,involving EPA's new program,and as such,we community through sound stewardship,
community members in both North will serve as a model for oilier companies of our resources.
BLUE RIDGE
PAPER PRODUCTS INC.
A Secure Future Through
Emtirontaental Petfortnaace
If you mould like to learn more about our enyironnaentel steoanlsldp programs,or to arrange a tour,call 828-646-2033,or Iisit our website at ow hlueridgepaper.cori

. �.
JIV lilt/
BLUE RIDGE � (---
PAPER PRODUCTS INC. 6'-�
February 27, 2001
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment 1 t.3 2 8 2001
and Natural Resources g
59 Woodfin Place + i
Asheville, NC 28801
Re:NPDES Permit No. NC0000272
Dear Mr. Westall:
As required under the referenced permit,Part III Special Conditions, Section L:
Temperature Variance Review, Blue Ridge Paper Products Inc. is required to submit a
complete temperature variance review report. Section L also states "...The report shall
be submitted with the request for permit renewal, no later than June 1, 2001." This letter
is notification that the temperature variance review report will be submitted no later than
June 1, 2001.
If you have any questions,please call me at(828) 646-2033.
Sincerely,
-
Robert Williams
Director—Environmental,Health,and Safety Affairs
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations ,

April 13, 2000 F,4
Mr. Forrest Westall , �
North Carolina Department of C� J
Environmental and Natural Resources
Division of Water Quality
59 Woodfm Place Y/
Asheville,NC 28801
RE: NPDES PermitNC0000272
Blue Ridge Paper Products Inc.
Causticizing Reliability Project
Mr. Westall:
Blue Ridge Paper Products Inc., Canton, North Carolina Facility, NPDES Permit No.
NC0000272, is notifying you of planned improvements to the causticizing area of the mill. The
improvements will involve replacing the lime kiln burners, adding continuous precoat renewal
(CPR)to the No. 4 and No. 5 Precoat Filters, replacing two lime slakers with a new No. 6 Slaker,
replacing the No. 4 Lime Silo with two new, smaller silos, adding a No. 6 fuel oil day tank and
associated delivery system, and improving the lime handling feed system to the No. 6 Slaker.
The improvements will increase reliability and enhance product quality while maintaining current
production capacity. In addition, these changes will also improve cost performance and increase .
safety.
This project includes no physical or operational changes that would increase the mill's current
pulp production capacity. Therefore, there will be no additional color loading resulting from this
project.
Blue Ridge Paper Products, Inc., is not requesting any revisions or modifications to the NPDES
Permit effluent limitations, monitoring requirements, or other conditions. Completion of the
Causticizing Reliability Project will result in continued full compliance with the Settlement
Agreement, Color Variance and NPDES Permit.
If you have any questions or need additional information, please contact me at(828) 646-2033.
Sincere
Robert V. Williams
Director,Environmental,Health& Safety Affairs
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]

Making iur mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
D f 'y
January 30, 2001 BAN
Mr. Keith Haynes ASNEVFR�4Uq 4t
Environmental Specialist /// Rf1/�ySfCT/
NC Division of Environmental Management Jqj OFF—
Water Quality Section
59 Woodfin Place
Asheville, NC 28802
RE: Daily BOD Exception at Blue Ridge Paper Products Inc. on January 18,2001
North Carolina NPDES Permit No. 0000272
Dear Mr. Haynes:
This letter is written notification of an exception with the daily maximum Biochemical Oxygen Demand
(BOD) test limitation for January 18, 2001. Verbal notification was made to Mr. Keith Haynes of North
Carolina Division of Water Quality on January 25, 2001. The reported BOD value for January 18 was
greater than 14,886 pounds, which is above the 12,458 pounds per day permit discharge limitation.
The BOD value is greater than 14,886 pounds because the oxygen depleted below the 1.0 mg/1
threshold established in the Standard Methods test procedure for the 5-day BOD test.
The probable cause of the elevated BOD test is a laboratory error in setting up the BOD
samples. As laboratory supervisor, I believe Primary Effluent was used in the Secondary Effluent BOD
bottles in error. All other mill and WWTP parameters were within normal ranges on this day, except
BOD Blanks that ran 0.41 and 0.43 mg/I. Typically, a high BOD is the result of upset conditions at the
WWTP that lasts for a period of days. We did not experience any upset conditions leading up to
January 18'1'. Infect, the BOD on the 17ih was 1,299 pounds (6.16 mg/1) and the BOD on the 19I'was
1,642 pounds (6.97 mg/1), demonstrating no increased BOD trend and no BOD problems before and
after January 18t'..
In addition, daily upstream and downstream river BOD's are performed. The river BOD's for January
18, 2001 are, upstream 736 pounds and downstream 2,547 pounds. Subtracting the upstream from
the downstream BOD yields the mill's BOD contribution at 1,811 pounds, the normal range of
Secondary Effluent BOD's and close to the values on January 174"and 19'1'.
Dissolved oxygen (DO)concentrations in the Pigeon River, taken at all daily stations below the mill were .
greater than 9 mg/I on the 18w and consistent with the DO's from the 17th. The river DO's on the 19'"
were higher due to a significant increase in river flow from 72.0 mgd on the 17'h to 928.5 mgd on the
191.
If you have any questions please contact me at(828)646-7620 or Derric Brown at(828)646-2318.
Sincerely,
Joh� �.�� �
ately
/�i/WWTP & Laboratory Supervisor
175 Main Street P.O.Box 4000 • Canton, North Carolina 28716 • 828.646-2000

Michael'r. Easley
�Q G Governor
William G.Ross,Secretary
>_ 1 North Carolina Department of Environment and Natural Resources
O Y Kerr T.Stevens,Director
Division of Water Quality
Asheville Regional Office
February 5, 2001
198
MR. JOHN PRYATELY
BLUE RIDGE PAPER PRODUCTS WWTP LAB
P.O. BOX 4000
CANTON, NC 28716
Dear Mr. Pryately:
We have evaluated results from your analysis of the wastewater / groundwater
laboratory certification performance samples we received January 23, 2001.
The information from this evaluation is surmnari2ed below:
Ampu1 IDI Analyte Units I Reported value True Value I Lower Limit I Upper Limit I Performance
......................... <..........................................._...................... f......................................._............................................
? NC976-Ft Pt Co Color i c.u. 70 t.........._70............).............._59:5............................80:5'..............:._Acceptable..:
<................................................................x.............................................................
No additional follow-up is required at this time.
Contact us at (828) 251-6208 extension 285 if you have questions.
Sincerely,
' d--4�
Gary Francies
Laboratory Section
cc: James W. Mever
s+a
Water Quality Section,59 Woodfin Place,Asheville,NC 28801-2414 Telephone: [phone] Customer Service
Fax: [phone] 1 800 623-7748

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
C�)
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
May 15, 1998
CD,ENR.
�JAMas B.HUNT.) .198
GOVERNOR -`'�: - MR.JOHN PRYATELY
CHAMPION INTERNATIONAL WWTP LAB -
afi P.O. BOX4000
Y.
CANTON,NC28716
4 '
ri '"YI�Av�9�5DEv1Tr
Dear Mr.Pryately:
r. We have evaluated results from your analysis of the wastewater laboratory certification performance
samples we received April 24, 1998.
EH" 4 The information from this evaluation is summarized below.
t5'
rto` U Am ul Analyte Units Reported True Value Lower Limit I Upper Limit Performance
NC188-F COLOR cu 25 25 21 29 Acce table
NC1MF S ecific Conductance € umho/cm 1498.5 1454 1288 1591 Acce table
NC190-F Total Residue mgLL i 192 178 146 209 Acce table
,.4 NC190-F Total Dissolved Residue ' m 140 136 103 169 Acce table
4
No additional follow-up is required as all results are acceptable.
a Contact us at(828)251.6208 extension 285 if you have questions.
A.
7'
Sg Sincerely,
�.i
m Gary Francies
Ism- Laboratory Section
W. James W. Meyer
EVAL. TR
INTERCHANGE BUILDING,59 WOODFIN PLACE,ASHEVILLE,No 28801-2414
PHONES28•251-8208 FAX [phone]
ey AN EQUAL OPPORTUNITY/AFFI RMATIVEACTION EMPLOYER-SO%RECYCLED/10q POST-CONSUMER PAPER

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality ,
59 Woodfin Place Asheville,North Carolina 28801
February 21, 2000
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Gordon Jones
Blue Ridge Paper Products
P.O. Box 4000
Canton, North Carolina 28786
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No.NC0000272
Blue Ridge Paper Products W WTP
Haywood County
Dear Mr. Jones:
f
This is to inform you that a review of your toxicity self-monitoring report form for the month of
December 1999 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent
toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation (TRE) which is a
site-specific study designed to identify the causative agents of effluent toxicity, isolate the sources of toxicity,
evaluate the effectiveness of toxicity control options, and then confirm reductions in effluent toxicity. Please be
aware that North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES
permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please hote updated mailing addresses for submitting your Discharge
Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this
information and if it would be helpful to discuss this situation or possible solutions to resolve effluent toxicity
noncompliance,please contact Mr. Keith Haynes with this office at(828)251-6208.
Sincerely,
;Forrest
Westall
' ) Regional Water Quality Supervisor
cc: Keith Haynes-Asheville Regional Office /
Aquatic Toxicology Unit V
Central Files

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COLLECTION . , , a„ DRAWING TITLE
CITY MWTP FLOW DIAGRAM
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1. ALL FLOWS AT DESIGN RATES IN M6D woES PERMIT NO.A "„ o°„m u" °" �"""°" NC0000272 A
on L. CMT�T unreaz-N-e1
MILL GRAVING NGl6ER
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1 2 3 4 1 5 6 7 B 9 10 I 11 12 13

Y f�
Making(Our mark for you. GORDON L.JONES
President and Chief Executive Officer
BLUE RIDGE PAPER PRODUCTS INC.
October 11, 1999
Mr. Forrest Westall, Sr.,P.E.
Water Quality Regional Supervisor
NCDENR
59 Woodfm Place
Asheville,NC 28801
Dear Forrest:
Thank you very much for taking the time to visit our corporate office.
I enjoyed our discussion and appreciated your candid thoughts. As I
mentioned during our conversation, our organization is very
committed to the environment and we look forward to working with
yo . Please give my regards to Keith Haynes and I hope that both of
y will visit us again soon.
4dsL,
. Jones
President and CEO
GLJ/bm
cc: George Henson
Bob Williams M {�
" ` SEyOfF�
1 West Pack Square,Suite 1100 • BB&T Building
Asheville, North Carolina 28801-3425 • Phone:[phone] • Fax:[phone]

BENEFITS AND COSTS FROM THE
REDUCTION OF COLOR EFFLUENT
FROM THE CHAMPION MILL
INTO THE PIGEON RIVER
n/eirrao

ieiria
NATIONAL ECONOMIC RESEARCH ASSOCIATES,INC.
CONSULTING ECONOMISTS
BENEFITS AND COSTS FROM THE REDUCTION
OF COLOR EFFLUENT FROM THE CHAMPION MILL
INTO THE PIGEON RIVER
PREPARED BY
NATIONAL ECONOMIC RESEARCH ASSOCIATES, INC.
AT THE REQUEST OF
CHAMPION INTERNATIONAL CORPORATION
REVISED APRIL 1988
A MARSH&MCLENNAN COMPANY
WHITE PLAINS,NY•WASHINGTON•LOS ANGELES•PALM BEACH•ITHACA,NY•LONDON

TABLE OF CONTENTS
Page
I. INTRODUCTION AND SUMMARY OF RESULTS 1
A. Introduction 1
B. Summary of the Economic and Employment 2
Impacts of Discharges from the Champion Mill
C. Evaluation of the Bach and Barnett Analysis 4
D. Organization of the Report 4
II. BENEFITS 4
A. Overall Approach 5
B. Rafting and Floating 7
C. Fishing and Sightseeing 13
D. Property Values 14
E. Apportioning Benefits 16
F. Nonuse Value 18
III. COSTS 21
A. 50 Percent Reduction 21
B. 50 Units at the Tennessee Border 22
C. 50 Units at the Mill 24
IV. COSTS AND BENEFITS 25
V. EMPLOYMENT CONSEQUENCES 27
VI. EVALUATION OF THE BACH AND BARNETT REPORT 30
A. Discounting 30
B. Indirect Benefits 31
C. The Costs of Color Reduction 34
D. Financial Impact on Champion 34
International Corporation
REFERENCES 35
1Le/1'/d®

BENEFITS AND COSTS FROM THE REDUCTION
OF COLOR EFFLUENT FROM THE CHAMPION MILL
INTO THE PIGEON RIVER
I. INTRODUCTION AND SUMMARY OF RESULTS
A. Introduction
Champion International Corporation owns and operates a paper mill at
Canton, North Carolina that is sited on the Pigeon River. The mill is about 37
miles upstream of the Tennessee and North Carolina border. The United States
Environmental Protection Agency (USEPA) has proposed an NPDES permit for the
mill that would significantly reduce the amount of color allowed to be discharged
from the mill into the Pigeon River. One of many submissions in this permit
proceeding was a report by Bach and Barnett entitled, An Economic Impact Analysis
on the Recreational Benefits of a Restored Pigeon River (see Reference [1]). This
study concluded that levels of reduction consistent with the April 1987 USEPA
proposal permit would be economic. In December 1987, USEPA published a second
proposal which limited color discharges even more severely than the April proposal.
At the request of Champion, National Economic Research Associates, Inc.,
an economic consulting firm specializing in energy and environmental economics,
evaluated the economic impacts of three color reduction strategies and also reviewed
and evaluated the Bach and Barnett report. First, we estimated the benefits and
costs under three strategies proposed to reduce color discharges from the Champion
mill. One of the plans was proposed by Champion; two were proposed by USEPA.
The most stringent plan (i.e., the December proposal by USEPA) would certainly
lead to plant shutdown. The less stringent USEPA plan would likely cause plant
shutdown. All the plans had costs significantly greater than benefits, and both
USEPA plans would have substantial unemployment impacts. However, Champion's
proposal yielded benefits that were closest to cost and exhibited small net gains in
employment. Second, based on our review and evaluation of the Bach and Barnett
n/e/r/w

-2-
analysis, we have concluded that there were several fundamental errors that
completely undermine their conclusion that substantial reductions in color discharges
could be justified on economic grounds.
B. Summary of the Economic and Employment Impacts of Reducing Color
Discharges from the Champion Mill
Table I summarizes our results. This table assumes that Champion would
take all actions technologically feasible to keep the plant open. The plan proposed
by Champion would reduce color discharges from the mill by 50 percent on a long-
term average basis. The costs associated with this program would be $38.4 million.
This is the present value of the costs over a 10-year period expressed in 1988
dollars. These costs would be over three times the benefits of $11.3 million. Thus,
an expenditure of one dollar achieves only 30 cents in benefits.
The two USEPA proposals would remove more color from the effluent
discharge but at substantially higher costs. Also, costs would exceed benefits by a
far greater margin than under Champion's proposal. Under the less stringent of the
two, which would consistently achieve less than 50 color units in the Pigeon River
at the Tennessee border, the cost would be $164.5 million, with corresponding
benefits of only $18.0 million. This results in a benefit of 11 cents per dollar of
expenditure. The more stringent proposal, contained in the second draft USEPA
permit, would limit discharges at the mill to 50 units of color. This proposed
effluent limit cannot be achieved with current technology and therefore would
require that the mill be shut down. The direct cost of this proposal would then be
the cost of building and operating a new facility in a different region net of any
operating and maintenance savings attributable to the new investment. We have
estimated these costs at approximately $290.0 million. The benefits under this
program would be $18.3 million. Thus, for every dollar of expenditure, this plan
would yield benefits of about one cent. These cost estimates do not include the
Tlih/I'ra

-3-
substantial economic and social cost impacts on the city of Canton, western North
Carolina or eastern Tennessee.
There are several reasons for the striking divergence between costs and
benefits. On the benefit side, only the relatively small stretches of the Pigeon
River which are immediately downstream of the Tennessee border have good
recreational potential. The whitewater rafting run of five miles is comparatively
short. The river is usable for rafting only when the `hydroelectric electric
generation demands at the Walter's Lake plant of Carolina Power and Light (CP&L)
result in adequate releases. Also, other factors unrelated to color tend to make the
river less attractive: the most scenic part of the river in North Carolina has
virtually no water in it at all and is not affected by color discharges from the mill
because of the CP&L water diversion tunnel; and low summer river levels,
particularly in North Carolina, restrict its suitability for most recreational activity.
On the cost side, the plant is already a low color producer in terms of
pounds of color effluent per ton of product. The incremental removal of color
requires increasingly more expensive and untested methods. The low river flows
make the achievement of the lowest level of color impossible without a complete
shutdown of the mill.
Employment is another measure of the impacts of the discharge reduction
plans. The Champion proposal would increase recreational-related employment in
Tennessee by 77 jobs. The other two plans would see net recreational employment
increases of about 123 jobs. Based upon U.S. Department of Commerce figures, the
50 percent reduction plan would increase the number of jobs in North Carolina by
176 jobs. If the mill were to shut down, as would be required under the USEPA
December proposal and would be likely under the earlier proposal, the loss of
employment in North Carolina would total over 12,000 jobs, with an added loss in
nle✓rlw

4-
Tennessee of over 800 paper-related jobs. Thus, under either USEPA proposal,
Tennessee would experience a net loss of almost 700 jobs.
C. Evaluation of the Bach and Barnett Analysis
Bach and Barnett estimate the direct and indirect recreational benefits
from reducing color discharges from the Champion mill to meet 50 color units at
the state line and the costs of achieving these benefits. Based on their analysis,
they conclude that reducing the color discharges to that level is justified on
economic grounds.
We have reviewed and evaluated their analysis and found it to be
seriously flawed. There are several key errors that cause them to incorrectly
conclude that the level of color reduction they evaluated would be justified on
economic grounds. They have failed to discount benefits and have overstated and
miscalculated indirect economic benefits. In addition, they have utilized company-
wide rather than plant-specific data to evaluate local impacts.
D. Organization of the Report
The remainder of the report is divided into five sections. Section II
describes the calculation of benefits. Section III discusses the costs of each plan.
Section IV compares the costs and benefits. Section V calculates employment
impacts. Section VI evaluates the Bach and Barnett analysis.
II. BENEFITS
This section discusses how the benefits from reducing color discharges
into the Pigeon River are calculated. We begin by describing our overall approach.
This is followed by a discussion of our estimates of the benefits from greater
recreational use and improved property value on the assumption that color
discharges are eliminated entirely. We then determine the benefits associated with
each of the color discharge reduction programs we evaluated. The section concludes
ia/ea'ao

-5-
with a discussion of other possible sources of benefits--option values and existence
values.
A. Overall Aonroach
There are two issues regarding the relationship between reductions in
color discharges into the Pigeon River and improvements in recreational benefits
and property values. First, it is not clear to what extent reductions in color
discharges from the Champion mill would be perceptible in the river. It is even
less clear that incremental improvements, say from 100 to 50 units on average,
would be noticeable in the river. Second, even if these changes were noticeable,
there is no direct evidence that they would affect either recreational activity or
property values.
Bach and Barnett allege, however, that color levels in excess of 50 units
reduce the attractiveness of the Pigeon River for recreational uses (whitewater
rafting in particular) and may also reduce property values for land adjacent to the
river. It is important to note that these supposed adverse effects are entirely
hypothetical. Despite an extensive review of the literature we can find no empirical
studies which relate color to recreational activity. Indeed, we have limited evidence
for certain naturally very dark rivers (the Androscoggin River in Maine for
example) on which whitewater rafting and fishing are quite popular activities.
While there is some limited support in the economic literature for a relation
between color and property values, this may simply reflect the statistical association
between color and other unrelated aspects of water quality.
Despite our reservations about the actual impacts of reducing color
effluents, for the purposes of this study we have adopted Bach and Barnett's thesis
and have assumed that color reduction will enhance recreational activity and
rL4EV /W

-6-
property values on the Pigeon River and have attempted to quantify the maximum
possible impacts of color changes.
The time available for this study has made a direct investigation of the
Pigeon River infeasible. Consequently, we have relied on data for other rivers to
estimate the benefits from reducing color discharges into the Pigeon River. In our
effort to transfer other results to the Pigeon River we have always allowed for the
maximum benefit potential. The actual benefit levels are quite likely to be lower.
Several recreational activities are feasible on the Pigeon River, including
whitewater activities (rafting, canoeing and kayaking), floating (primarily rafting
although it includes "inncrtubing," canoeing and kayaking), fishing and general
sightseeing. To calculate the increase in usage for these activities in the absence
of color effluent we used estimates of current usage on Tennessee rivers in the
vicinity with no perceived elevated color levels, particularly the Ocoee and
Hiawassec Rivers. Adjustments must be made to these estimates since these rivers
are different from the Pigeon River in respects other than color.
To estimate the value of a visit we have utilized a variety of published
sources. For the most part, they are the results of contingent valuation studies.
In these studies participants in an activity are asked to estimate the value of that
activity to them in excess of the costs incurred. These estimates, known as
consumer surplus, serve to define the value of a day. Bach and Barnett also employ
consumer surplus valuation. Multiplying the value per day by the increased number
of days gives our estimate of benefits from reducing color discharges.
Property value benefits presumably derive from scenic advantages of being
along a river of reduced color as well as the enhanced levels of wildlife and
recreation the river can support. Several studies [2,3,4] have related color and
general water quality to property values along coastlines and lakefronts. We have
n/e/ram

-7-
calculated current values of river-front property along the impacted portion of the
Pigeon River and have used these studies to estimate the increase in property
values attributable to a river with no added non-natural color.
B. Rafting and Floating
Whitewater rafting is feasible on a 4.5 mile stretch of river about
37 miles below the Champion mill--from River Mile (RM) 26 at the CP&L
powerhouse to RM 21.5 in Hartford, Tennessee (see Figure 1). As recently as last
summer, a commercial supplier offered whitewater rafting trips on this stretch. The
river below this point has too low a gradient to support whitewater rafting, while
over the 37 miles between the mill and the power plant, both the gradient of the
river and the volume of water are insufficient to support rafting.
Rafting on the Pigeon River is further limited for two reasons. First,
the climate is conducive to rafting only from April to October. Second, during this
period rafting is limited to periods of discharge from the CP&L power plant. When
the plant is not operating (or is operating only one of its three turbines) the
depths are insufficient to support rafting. CP&L's obligation as a public utility is
to generate power so as to minimize electric generation costs without regard to
potential rafting activity. However, for the purposes of this study we have assumed
that CP&L generates electricity during as many daylight hours as water levels in
Walter's Lake permit during the rafting season.
The relatively short length of the Pigeon River run makes whitewater
rafting less attractive than it would be on longer rivers. First, no more than a
half-day trip is possible, while other rivers offer full day trips. Second, since
congestion limits the number of potential rafters per mile, shorter rivers will have
lower capacities.

. -8-
To estimate the number of potential whitewater rafting trips for the
Pigeon River we used data for the Ocoee River, which is the closest comparable
river to the Pigeon River. The whitewater rafting portion of the, Ocoee River, like
the Pigeon River, is five miles long, allowing only half-day trips. In addition, it is
also dam-constrained. Total usage on the Ocoee River for 1987 was about 120,000
visits [5]. Following Bach and Barnett, we take this figure as a limit to usage on
the Pigeon River. We assumed that there is no current recreational usage on the
Pigeon River and that over five years usage for whitewater activities would rise to
120,000 visits per year. Thus, we have assumed that all recreational use of the
Pigeon River would be attributable to reductions in color discharges. This obviously
tends to overstate the benefits from lower discharges, since there is currently
recreational usage of the river. The attached brochure (Figure 2) illustrates the
recreational benefits of the Pigeon available today. These visit estimates are
displayed in column (1) of Table II.
To estimate the value for a rafting day we used a study conducted in
Colorado in 1978 [6]. This study found that the consumer surplus from a
whitewater rafting trip averaged $10.94 per person per day. Once again, this
represents the difference between what people would be willing to pay and what
they actually had to pay for a rafting trip. The estimate was made by eliciting
from rafters the amount of money in addition to what they had paid that day that
would cause them to forego that trip on these rivers. Converting this value to 1988
dollars, we find that the benefits are $19.28 per tourist day. Other whitewater
activities, for example, kayaking and canoeing, had similar values.
The equations from which these estimates were drawn show consumers to
be quite sensitive to congestion on the river. Since congestion levels on the Ocoee
n/e✓r/W

-9-
River are much higher than those observed in Colorado, we have lowered our
estimate to $13 per trip.
In addition to the five-mile stretch of whitewater between the power
plant and Hartford, there is a more placid stretch from RM 21.5 to RM 16.5 on
which floating is feasible during periods of higher water. On this stretch the river
resembles the Hiawassee River. We have estimated floating usage for the Pigeon
River based on data for the Hiawassee River. While this activity may be expected
to be constrained somewhat by power generation, water levels further downstream
are less affected by dam activities because of the lower gradient. Nonetheless,
river levels are probably too low to achieve any significant recreational activities in
August or September. Given that these months generate 35 percent of
noncommercial activity, we have reduced the Hiawassee River floating usage of
80,000 visits [7] by 35 percent to 52,000.
Unlike whitewater rafting, which has been growing at about 6 percent per
year on the rivers for which we have visitation data over time, floating activity
seems to be on the decline. On the Hiawassee River, usage has been declining by
about five percent per year since 1978. In estimating floating usage for the Pigeon
River, we have conservatively assumed no decline. Again, we assumed growth to
capacity would occur over a five-year period. The resultant demands appear in
column (2) of Table II.
Bach and Barnett assume a value of $12.94 per tourist day for floating
activity, based on Water Resources Council criteria. These values seem quite
severely overstated. Based on our visits to the river, a score of 36 would seem to
be a better indication of the value than their assigned score of 62. In particular:
1) Bach and Barnett assign a score of 10 out of 30 for recreation
n/e/rra°

-10-
experience, which measures crowding. The large crowds projected
here should reduce this value to 5.
2) Bach and Barnett assign a score of 12 out of 18 for availability of
opportunity. A 12 would indicate no floating opportunities with one
hour, which seems to ignore the French Broad and Hiawassee Rivers.
We find 4 to be a more objective classification.
3) Bach and Barnett assign a score of 10 out of 14 for carrying
capacity. This rating reflects "optimum facilities to conduct activity
at site potential." These facilities are simply nonexistent. A 5,
representing basic facilities, seems quite generous.
4) We accept Bach and Barnett's accessibility rating of 12 out of 18.
5) Their rating of an 18 out of 20 for outstanding esthetic quality seems
highly inflated. The river would still receive municipal waste
treatment discharges and both agricultural and urban runoff. We
have lowered their rating to 10.
The score of 36 translates to a value of $8.30 in 1982 dollars, converted
to $9.76 in 1988 dollars. We have used this value in our estimate for floating
activity.
Table II describes the annual benefits and the present value of these
benefits in 1988 dollars. The present value reflects the annual benefits over the
next 10 years discounted to reflect the time value of money. We used a 10-year
time frame since that is about the expected life of the investments for color
discharge reduction. Discount rates reflect the rate at which benefits can be traded
between years. We have discounted the benefits at an annual rate of 6.79 percent
in excess of inflation. The rate used reflects the after tax cost of money to
Champion (13.2 percent) net of a presumed six percent future inflation rate. The
nm✓r/aa

. -11-
Champion rate reflects the marginal cost of capital in the private sector, since
funds spent cleaning up the Pigeon River would otherwise. earn these private sector
rates. The benefits of cleanup should consequently be discounted at the same rate.
Using this method, we derive total benefits over the next 10 years of $8.9 million
for rafting and $2.9 million for floating. The annual benefits and the present value
of the benefits for whitewater activity and floating are given in columns (5) and (6)
of Table II.
We are quite confident that these estimates overstate the actual changes
in value on the Pigeon River. There are at least six reasons why we expect the
value of additional whitewater activity and floating visits to be substantially lower.
Fib we have assumed that there is currently no recreational usage on
the Pigeon River. In fact, there is a commercial operation on the river today.
Kayaking and canoeing have also been observed on the river. However, we have
been unable to secure estimates of current usage and have therefore ignored them.
Since our goal is to calculate increases in usage, the value of all current usage
should be' subtracted from our value estimates. Our failure to do so clearly
overstates the number of trips that can be attributed to reductions in color
discharge and thereby overstates benefits.
Second the benefits per trip used for whitewater activity were estimated
on much larger and more striking rivers in Colorado. The set of rivers on which
this estimate was based includes, for example, the Yampa River, which "is among
the few rivers in the U.S. on which rafters can spend from three to five days
without encountering roads, private land, or other evidence of civilization." [6,
page 8] The rivers sampled averaged 42 miles in whitewater length, over eight
times the length of the Pigeon River run. Trips on these rivers averaged 14 miles
per day. The shortest of the rivers was almost three times the length of the
nje/Tids

12
Pigeon River. Such unique characteristics would be expected to make this set of
rivers much more valuable than the Pigeon River.
Third the $13 consumer value assumes a very modest increase in
congestion. The value of a whitewater rafting day declines sharply with the number
of people encountered on a trip. The Colorado study users encountered an average
of only forty people on a trip. With visits of 120,000 per year, Pigeon River
whitewater rafters might well encounter hundreds of people per day. In the
Colorado study, a doubling of encounters reduces the benefits per day by over
40 percent. Thus, fairly moderate increases in usage could lower the benefit per
day estimate substantially.
Fourth of the two methods traditionally used to estimate the value of
recreational activities, we relied on the contingent valuation method which usually
leads to higher values. It is subject to a number of well-known biases in which
people tend to overstate the value of services. Alternatively, travel cost models
which estimate the demand for a service by the distribution of distances people
were willing to go to participate in an activity, typically give lower values than
contingent valuation.
Fifth the current physical facilities at both the dropoff and takeout
areas are grossly inadequate to the task of accommodating the estimated number of
rafters or floaters. We assume that these facilities could be developed over time if
demand warrants but have not included the costs of developing these facilities.
These costs would properly be a subtraction from the benefits associated with these
activities.
Sixth, increased recreation visits on the Pigeon River may consist largely
of visits currently made to other rivers. Thus, in equilibrium, the total increase in
whitewater rafting trips might be much less than the 120,000 visits per year
Tl�L/Zi`d,'a

-13-
projected on the Pigeon River even if that many people do raft on the Pigeon
River. Each visit "cannibalized" from the Ocoee, Hiawassee, or any other river
represents less new value than a new trip; most of its value reflects a shifting of
value from one site to another.
For these reasons we consider our estimates of both usage and value per
trip to be quite generous and would expect to see far less rafting and floating
usage of the Pigeon River.
C. Fishing and Sightseeing
For these activities we have used both the visit estimates and value
estimates of Bach and Barnett as a base. They have scaled fishing visits to usage
estimates for the Norris Dam tailwaters put-and-take fishery. Their sightseeing
visits are scaled to estimates for the Hiawassee River. The number of visits for
these activities are given in columns (3) and (4) of Table II.
Our only adjustment is to lower fishing values to account for the costs
of the presumed put-and-take fishery. Failure to include these costs overstates
potential net benefits. One study [61 suggests that these costs can range from
$4.50 to $11.00 per visitor day depending on the length of the fishery. We have
used the average of this range to reduce Bach and Barnett's estimate of the net
benefits for a fishing day of $17.00 to $9.25.
Further, while we have used Bach and Barnett's estimates for the number
of additional fishermen expected, the source of their estimate is unclear. A proper
estimate should take into account the fact that trout are not a viable species in the
Pigeon River below the Canton Mill discharge and that put-and-take fisheries are
generally less efficient in smaller bodies of water. We have accepted their
estimates for lack of better data.

-14-
It should be noted that fishing is a viable activity on the more scenic
portions of the river only when whitewater rafting is unavailable. Excessive stream
flow and heavy boating usage are detrimental to fishing quality. We do not regard
this as a very serious constraint given the limited time available for whitewater
rafting and have therefore made no adjustment.
The annual benefits and the present values for fishing and sightseeing are
described in columns (7) and (8) of Table II. The present value of fishing benefits
is about $1.2 million over ten years, while sightseeing accounts for about
$0.7 million.
D. Proyerty Values
It has been argued that reductions in color can enhance residential
values. A 1979 study [2] in Pennsylvania, which focused on overall water quality
rather than color, indicated that a completely clean river raises adjacent residential
property values about 28 percent. Similar values were obtained for apparent color
in a 1985 Michigan study [3] on lakefront property and for a combined index of
turbidity and distance in a 1980 study [4] of beachfront property in Massachusetts.
We have used the 28 percent figure as an upper bound on residential
property improvements on the Pigeon River. We have further assumed that all
property along the Pigeon River not currently blocked by roads, public land, or
Champion property is transformed to residential use. This is obviously an extreme
assumption and causes us to overestimate the impacts of reduced color discharge on
property values.
Our calculation of increased property values had three steps: 1) an
inventory of property along the Pigeon River, 2) a calculation of its value for
residential purposes, and 3) a calculation of the maximum increase in value
attributable to reduced color.
n/e✓r/W

. -1s-
1. Much of the land adjacent to the Pigeon River is publicly owned.
Route I-40 follows one side of the river while public forest land borders the river
in many areas. The land between the dam and the powerhouse which contains no
water due to the powerhouse diversion tunnel and is, therefore, unaffected by color
was also excluded. Only about 50 percent of the river is adjacent to usable private
land. We have also excluded plots belonging to Champion and the Cocke County
School District. Since the usage of these properties cannot be expected to change
with reductions of color in the Pigeon River, we have excluded this land from our
assessment.
2. We had assessed property values for land in Tennessee only and have
assumed that similar values prevail in North Carolina. Residential land and property
was valued at $52.49 per river-foot of frontage. We have assumed that all land
along the river would have this value in residential use. In fact, nonresidential
land and property in Tennessee had a value of only $32.01 per river-foot.
To calculate increases in the value per river-foot of frontage, we used
the 28 percent figure. This increases the value of all potential residential property
by $14.64 per river-foot to $67.13. The results of this calculation are given in
Table III. Property value increases, which are assumed to be instantaneous, total
$2.52 million in North Carolina and $2.05 million in Tennessee.
Again, we feel it quite likely that this estimate overstates potential
benefits. Fi= we have applied residential-level benefits to agricultural and
commercial land. This is based on the assumption that this land may ultimately be
converted to residential use. The available studies deal exclusively with residential
values. The links between property value and color are far less obvious for land
used for agricultural, forestry, or industrial purposes. However, it is unclear that
I1�2/Y'id,�

-16-
private land along the Pigeon River currently used for agricultural or industrial
purposes will be converted to residential use.
Second the 28 percent increase cited is partly attributable to the fact
that more expensive homes are constructed on more desirable land. The net
benefit, which would subtract the cost differentials, is not included here.
Third color may not be the true measure of property desirability but may
instead be a proxy for other measures of environmental quality. A 1973 study [8]
found color much less important to property owners than the ability to sustain fish
and other wildlife. The Michigan study of lakeside property owners found that
turbidity was an important factor in value but notes that turbidity is highly
correlated with other pollution variables which decrease both fishing and swimming
uses. To the extent that these variables are not correlated here, the effects might
well be less.
Fourth we have included several plots of land currently inaccessible by
road. Several areas of vacant land doubtless have no developed residential
infrastructure--for example, sewage, telephone and water access. The costs of
providing such facilities should be subtracted from any property value increases.
Given these caveats, we find it quite likely that the combined property
value effects will be lower than what we have estimated.
E. Atmortionina Benefits
The recreational and property benefits we calculated in Sections II.B.
through II.D. total $18.3 million over 10 years. These estimates are based on the
complete elimination of color discharges from the Champion mill. The next step is
to determine the proportions of these benefits that will accrue from each of the
specific proposed reduction plans.
11�/IYc1i°

-17-
Under the most stringent reduction plan, discharges of color would be
limited to no more than 50 units at the pipe. This strategy entails a reduction of
311,000 pounds of color per day on average. We have adopted the Bach and Barnett
assumption that 50 units is the limit of color acceptability. Consequently, we have
assumed that the 50 units at the pipe strategy achieves all of the $18.3 million in
benefits.
For the other two strategies, we have assumed that the benefits achieved
are proportional to the reduction in discharges. Further, for the 50 units at the
border scenario, we have assumed that the plant remains open. Thus, the strategy
•that achieves 50 units at the border would achieve all the potential benefits in
Tennessee. This includes all of the recreational benefits as well as the increase of
$2.05 million in property values in Tennessee. In addition, since this plan also
achieves 88 percent, of the discharge reductions under the 50 units at the pipe
strategy (274,000 divided by 311,000), we assume it achieves 88 percent of the
property value benefits in North Carolina. As a result, the total benefits from the
50 units at the border strategy are $18.0 million.
The 50 percent reduction plan removes 172,000 pounds of discharge per
day on average. This achieves 63 percent (172,000 divided by 274,000) of the
Tennessee benefits and 55 percent (172,000 divided by 311,000) of the North
Carolina benefits. Thus, the total benefits from this program are $11.3 million.
This proportionality assumption is somewhat arbitrary. In the absence of
specific recreational studies on color, it is unclear whether a 50 percent reduction
in effluent will garner more or less than 50 percent of the benefits. Instead, there
might be threshold, effects. That is, below a certain color level, all benefits accrue;
above a certain level, no benefits accrue. While 50 units in the stream may
represent the lower threshold, we have no such upper threshold. Further, even the
I1�E',/ZSd�

' -1s-
50 unit lower threshold is controversial. However, we have tested several different
upper thresholds in benefits. The assumption of proportionality yields larger
incremental benefits than any other set of assumptions tested.
F. Nonuse Value
It is often asserted that there are values other than those accruing to
users of the. river. Bach and Barnett cite a study which estimates those benefits at
five times the direct benefits. We reject the notion that there are significant
nonuse benefits for the Pigeon River. Fib it is unclear whether nonuse values for
the Pigeon River are positive or negative. Second even if these benefits are
positive, they are not likely to be large.
The economics literature considers two components of nonuse values:
option values and existence values. Option value is similar to a nonrefundable
admission price that must be paid before one knows whether or not he or she will
use the river. It represents for consumers the difference between (1) the
willingness to pay to shield themselves from uncertainties about their demands for
the river and its availability and (2) the expected value of their benefits from the
river.
Substantial theoretical research indicates that option value, this
difference between willingness to pay and expected value of benefits, is as likely to
be negative as positive. Further, in some important cases where it is positive, it is
likely to be small. Whether option values are positive or negative depends on the
nature of the uncertainties confronting users and nonusers. At least five sources of
uncertainty can create option values. These include: (1) supply of the resource,
(2) income, (3) taste, (4) price of the resource and (5) prices of substitutes or
complements. Examples can be constructed where option value is positive, negative,
or zero for reasonable uncertainty assumptions. Further, V. Kerry Smith's analysis
n/e/r/W

-19-
[9] shows the importance of uniqueness and irreplaceability in assigning a positive
option value. Given that the Pigeon River has no unique characteristics (especially
given the abundance of substitutes) and that the level of color is reversible at any
time, his analysis implies that option values are unlikely to be positive.
Regarding the magnitude of the option value in the case of uncertainty
about taste, Freeman [10] points out that the conditions for a large option value
are quite stringent. Option value is unlikely to be large unless "the probability of
demand is low, the expected consumer surplus is large, and the individual is highly
risk averse." [10, p.11] For the Pigeon River, these specific conditions are unlikely
to occur. In particular, rafting on the Pigeon River is quite unlikely to have a
large expected consumer surplus relative to income given the abundant potential
substitutes in the area, both for whitewater recreation and for entertainment in
general.
Finally, the empirical evidence on option value is generally unpersuasive.
While several studies (including the one cited by Bach and Barnett) have concluded
that option values were positive and substantial, these studies have been poorly
done and cannot be used to infer large positive values. There are various reasons
for this, including the fact that the survey questions addressed the wrong issues
and were posed in a confusing manner. As Smith [11] points out:
Empirical efforts to measure option price (and option value) have not
been clear in specifying (or attempting to determine the individual's
perceptions on) the terms of access to the resource and the time
horizon for future use. . . .[T]he terms of access and the individual's
ability to adjust to demand uncertainty . . . have not been clearly
described (or elicited) from the respondents involved in the
surveys. . . .[T]his limitation is especially important when the option
price is used to measure the value of changes in either features of
the resources or in the uncertainty itself. [11, p.8]
As a result, these studies have generated estimates of surplus much too large to be
easily explained on a theoretical basis.
11/e/t'/W

_20_
Further, applying estimates taken from these other studies to the Pigeon
River would be even more tenuous. Even if the wild and scenic rivers of Colorado
may have significant option values, the transfer of those results to the Pigeon River
is unwarranted.
Considering all of these issues, we have-not included any option values in
our estimates. Our best reason for doing so is stated by Professor Richard
Schmalansee [12] of the Massachusetts Institute of Technology, one of the original
contributors to the theory of option value:
Individuals' option prices may exceed or fall short of the expected
value of the contingent surpluses they would derive from a price
change, and it is not obvious how one might judge in a real situation
which was more likely. This suggests that when tastes are the main
source of uncertainty, the expected value of consumer's surpluses
ought to be employed as the best available approximation to the sum
of their option prices . . . . Benefits will be sometimes
underestimated and sometimes overestimated by this procedure, but
there would appear to be no practical way to obtain superior
estimates. 112, p.823]
Existence values represent the utility of knowing of the existence of a
resource for a person who knows he will never use it. We believe that this does
not represent a significant source of benefits on the Pigeon River and have
excluded them from our estimates for two reasons. Fib existence value is linked
to uniqueness of the resource. A resource with features available nowhere else (for
example, the Grand Canyon) may have substantial psychic value to nonusers. We do
not believe that nonusers place a large value on the Pigeon River given the
existence of nearby alternatives.
Second a full specification of existence values would of course include
foregone opportunities for the people of Canton. Those who would place a high
utility on lower color levels in the Pigeon River should also place high disutility on
the social disruption caused by the shutting of the Canton Mill. In scenarios in
I1/evr/ad

-21-
which the mill must be closed, a positive existence value.would mean that people
put less value on the disrupted lives of Canton than for color levels; in the Pigeon
River. Thus, in this case existence value is the sum of two effects: one positive
and one negative. It is not clear a priori which effect would predominate.
Third little is known empirically about existence value. Testing for
existence value is fraught with difficulty, since people not actually called upon to
pay for improvements may systematically overstate, for any number of reasons, their
willingness to pay. The most comprehensive study of existence (and option values)
suggests that together they might increase benefit estimates by as much as
50 percent. Even these estimates have come under attack. We find that an
increase of this size at the Pigeon River to be highly unlikely. However, we note
in passing that even a tripling of all benefits in Table I still results in an
unfavorable benefit-cost ratio for all reduction plans. The benefit cost ratios for
the more stringent USEPA proposals require assumptions of option and existence
values of ten to twenty times the direct effects.
III. COSTS
Colored effluent is the byproduct of the removal of lignin from wood
chips in the pulping process. Currently, the mill is one of the lowest producers of
pounds of color per unit of output in the United States.
A. 50 Percent Reduction
The primary source of color discharge is the caustic extraction stage of
the bleach plant. Improvements proposed by Champion to cut this contribution by
90 percent would achieve an overall reduction of 50 percent. This reduction is
proposed to be accomplished by the addition of oxidation chemicals.
The costs of the 50 percent reduction proposal have been estimated by
Champion at $10 million dollars in capital cost and $4 million per year in operating

-22-
and maintenance costs. We have converted these costs into a ten year stream and
discounted them at Champion's after-tax cost of money. This yields a discounted
present value of expenses over a 10-year period that is directly comparable with the
benefit estimates. The operating and maintenance expenses were discounted using
the 6.79 percent rate. The present value of the costs of this plan is therefore
$38.4 million. The costs are summarized in Table V.
B. 50 Units at the Tennessee Border
Other technologies that would treat more than the caustic extraction
stream require far greater investments. Champion submitted to the USEPA, at the
Agency's request, seven reports detailing methods of reduction sufficient to achieve
no more than 50 color units at the border at any time. Of these, the USEPA
deemed as potentially suitable the lime, polyamine and alum removal systems. Each
technology has a different capital and operating cost, with the alum removal system
being by far the lowest cost. Further, the systems have different risks associated
with them. Champion's engineers have supplemented the estimates of probable cost
of each of these technologies with a probability distribution of costs. The proper
cost to use ex ante in comparing the plans is the expected cost of the technologies,
i.e. where the costs are weighted by the probabilities that they occur. Under this
criterion, the polyamine technology has the lowest cost. The present value of its
costs are $164.5 million, as opposed to $192.5 million for the alum reduction plan
and $209 million for the lime reduction plan. Since the polyamine system is the
least expensive of the three technologies that would achieve 50 color units of the
border at any time, we have used it in the analysis.
We should note that the polyamine removal process is likely to understate
the cost, possibly greatly so. EjEaL no polyamine process on this scale has ever
been implemented before. Large scale experiments with new technologies often have
n/esrral

-23-
substantial unexpected cost increases. Second byproducts of the polyamine process
would almost certainly violate existing environmental standards. In particular,
operation of the sludge dryer would cause air quality deterioration in particulate
matter, hydrocarbons, SOZ, and NO, The cost of meeting existing standards have
not been included in these estimates.
In calculating the results in Table I, we have assumed that the plant
'remains open at this level of expenditure. Champion has submitted to USEPA
workpapers based on the USEPA gross margin test. This test compares the ratio of
net operating revenues to annual pollution control costs. Where this ratio exceeds
the average ratio of investment returns for the industry, "the test results indicate
that pollution controls would impose severe economic impacts, [and] a more detailed
plant closure analysis would be necessary." [14, page 92] Champion's submissions
indicate that the 50 unit at the border strategy fails to pass this test. This raises
the possibility of mill shutdown even under this plan. Were this the case, the quite
substantial resource and employment costs of the more stringent December USEPA
proposal would result. Only the 50 percent reduction plan would have costs within
a factor of 50 times benefits.
We have analyzed this case from a different perspective and find a
persuasive case for shutdown. Our analysis suggests that the internal rate of
return on an investment in pollution control (combined with the $200 million
necessary to keep the plant commercially viable) is considerably less than the
20 percent hurdle rate necessary to justify an investment for Champion. Even were
the investment of average risk for the company, the project would likely not be
justified. In fact, the risks involved in both the pollution cleanup and oxygen
delignification production process are substantial, requiring internal rates of return
in excess of the hurdle rate to warrant the investment. We therefore regard the
ri/evr/ i°

_24_
50 unit at the border proposal as likely to lead to shutdown of the Canton mill.
Again, were this the case, the true costs and benefits of the 50 units at the border
plan would be identical to those from the more stringent limit of 50 units at the
pipe.
C. 50 Units at the Mill
Engineering judgment has determined that these color treatment schemes
cannot simply be scaled up to achieve a discharge level of less than 34,000 pounds
per day on the average, the amount sufficient to assure less than 50 units at
Canton. Also, the mill would not be able to operate on pulp shipped in. Thus, the
only method of achieving 50 units at the mill is the shutdown of the plant. In this
case, the real resource cost of shutdown is the cost of constructing a new mill with
replacement capacity elsewhere in the country. Champion estimates that the
creation of a new mill capable of producing 600,000 tons of pulp per year would
have capital costs of $1.4 billion. To properly characterize the total resource costs,
we should subtract from this estimate the present value of savings in operating and
maintenance provided by a new plant.
Champion has proposed a $200 million investment in an oxygen
delignification process which would allow the plant to continue operations. As a
proxy for the operating and maintenance cost savings, we have assumed that the
$1.4 billion investment creates a profit stream which yields an internal rate of
return of 13.2 percent, i.e., represents an investment of average risk for Champion.
This profit stream is then subtracted from the profit stream arising from the
$200 million switch to oxygen delignification at the Canton mill. The present value
of changed profits must represent the present value of cost savings associated with
the new technology. The present value of resource losses thus totals about
$290 million. The additional impacts of a shutdown are discussed below.
Ili/r/w

-25-
IV. COSTS AND BENEFITS
The economic criterion for undertaking any investment, including
environmental enhancement programs, is that the benefits exceed the costs. Even
where environmental benefits are themselves large, undertaking a project whose
costs exceed its benefits is a waste of society's resources. Further, the difference
between incremental costs and benefits should guide the choice between projects.
While none of the three programs pass the benefit-cost test, the
50 percent reduction plan comes the closest by a wide margin. Under the
50 percent reduction plant the present value of the costs over a 10-year period are
$38.4 million. These are $27.1 million greater than the benefits of $11.3 million.
These costs and benefits translate into a benefit-cost ratio of 0.30 (11.3 divided by
38.4). The interpretation of this benefit-cost ratio is that a one dollar of
expenditure yields 30 cents in benefits. The comparison of benefits and costs
benefits are summarized in Table I. This is substantially less than one, and
consequently would not pass the economic criterion for undertaking the investment.
The plan to reduce discharges to 50 units at the border is even less
justifiable. Its costs are $164.5 million, and they exceed the benefits of
$18.0 million by $146.5 million. This results in a benefit-cost ratio of 0.11--nearly
half of what could be achieved under the 50 percent reduction plan.
The most costly program--50 units at the mill--achieves the poorest
benefit-cost ratio. The costs would be much greater than either of the other plans
because it would involve shutting down the Champion mill in Canton and
constructing a new one. Under this program the costs would be $290 million.
These are $271.7 million more than the benefits and would yield a benefit-cost ratio
of .06.
ri/2/r'rw

-26-
A very useful way to look at the alternative programs is by comparing
the increase in costs and benefits that occurs from imposing increasingly stringent
discharge removal plans. This is a comparison of the incremental costs and benefits
and describes the additional benefits and costs that accrue from removing additional
color. If the additional costs exceed the additional benefits, then the incremental
reduction in color is uneconomic.
As we have noted above, the least stringent of the programs--the
50 percent reduction plan--increases costs by $38.4 million and benefits by
$11.3 million for a benefit-cost ratio of 0.30. The incremental cost of removing
additional color under the 50 units at the border plan is $126.1 million--the
difference between $164.5 million and $38.4 million. This added expenditure removes
an additional 102,000 pounds of color per day (274,000 minus 172,000). However,
this additional color reduction only increases benefits by $6.7 million (18.0 minus
11.3). Thus, the incremental benefit-cost ratio is 0.05 (6.7 divided by 126.1).
The incremental comparison is even more unfavorable under the 50 units
at the pipe plan as proposed by the USEPA. This program would increase costs by
$125.5 million--from $164.5 million to $290.0 million. The added expenditures would
achieve an additional reduction of color discharge of only 37,000 pounds per day.
However, this additional reduction would only increase benefits by $300,000. As a
result, the incremental benefit-cost ratio would be virtually zero.
These incremental results depend crucially on the assumption of 50 color
units as an objective perceptibility standard. If, in fact, there is no perceptible
difference between 50 and 100 color units, then the conclusions are even more
clear. Since the 50 percent reduction plan essentially achieves 100 color units or
less at the border over 95 percent of the time, this plan would achieve all benefits,

-Z7-
no matter how large. Each of the more stringent plans, therefore, has incremental
benefits of zero and cannot be justified on any rational criterion.
In estimating the benefits and costs we have discounted the annual
impacts at Champion's after-tax cost of money. Some have argued that the proper
discount rate to use for the evaluation of projects should be a riskless discount
rate. The basis for this argument is that since the benefits are spread over the
population at large, the risk premium associated with private investment should not
be included. We disagree with this argument. The reason is that funds spent on
this project will deny Champion the ability to undertake other projects capable of
earning the private rate of return. Hence the rate we have used is appropriate.
We would agree, however, were this proposal financed with new money, but that
would not be the case.
Nonetheless, we have calculated the benefits and costs using a real
discount rate of three percent, which is intended to represent a riskless rate. This
substitution does not alter the results, and therefore our conclusions remain
unchanged. Using a lower discount rate raises both the costs and benefits. For
each case, the benefit-cost ratios are slightly less favorable. Table VI compares the
results at the alternative discount rates.
V. EMPLOYMENT CONSEQUENCES
We have also estimated employment impacts from the three color
discharge reduction strategies. Employment impacts are treated separately from the
benefit-cost impacts because they represent different issues. Jobs created cannot be
examined in isolation. For example, the cost side of the benefit-cost calculations
reflects the employment impacts of the discharge reduction plans. Higher cost
levels always create more jobs, whether or not the costs were incurred efficiently.
Djevr/w

-28-
Thus, the employment consequences of a particular strategy cannot be added to
benefits. Instead, they represent an alternative perspective.
The 50 percent reduction strategy would likely have modest employment
impacts of about 250 jobs. The 50 units at the border strategy, if implemented,
would yield about 600 jobs. Given the probability that the plant would shut down,
however, both this plan and the 50 units at the pipe strategy would impose very
substantial employment losses totalling over 12,000 jobs.
Jobs created and lost can be broken down into direct and indirect
components: the direct component consists of the jobs required either to provide
recreation or to maintain color reductions. Indirect employment gains and losses
relate to the employment in other sectors required to support the direct work force.
The U.S. Department of Commerce has issued state- and industry-specific estimates
of total direct and indirect job impacts for given changes in output in various
industries [13]. For recreation in Tennessee, we have used the hotels, lodging
places and amusements multiplier. It indicates that for an increase of $1 million of
expenditure in this industry group, direct and indirect employment will increase by
60.2 jobs. For discharge reduction activities, we have used the North Carolina
values for the paper and allied products classification and the Tennessee value for
forestry and fishing products. A $1 million expenditure in North Carolina provides
30.1 jobs, while a $1 million expenditure in Tennessee provides 54.5 jobs.
The direct employment gains in Tennessee follow from the staffing
requirements of the whitewater rafting facilities. Fishing, kayaking and sightseeing
generate no direct employment gains, since they have no direct costs other than the
costs of transportation. Using Ocoee River figures which show commercial rafting
to account for about 85 percent of whitewater activity and using the Bach and
Barnett figures of $20 per trip, we derive maximum expenditures in Tennessee for
Tl/e/r/am

_29_
whitewater rafting of $2 million (20x.85x120,000). This assumes the 120,000 visits
per year associated with complete color removal. The multiplier of 60.2 direct and
indirect jobs per $1 million in expenditures implies an increase of 123 jobs.
The employment impacts are summarized in Table VII. Under either the
50 units at the border plan or the 50 units at the pipe plan, the concentration of
color will be at the minimum levels of acceptability. Consequently, under either of
these plans there will be the full employment impact of 123 jobs in Tennessee.
The 50 percent reduction plan would have less of an employment impact
because the benefits in Tennessee are less. Recall that we assumed that the
benefits are proportional to the color reduction. Since with the 50 percent
reduction plan the recreational benefits are 63 percent of those under complete
color removal, the employment impacts also would be 63 percent of 123 or 77 jobs.
The plan to provide 50 units at the pipe suggested by USEPA causes mill
shutdown. This shutdown reduces Tennessee commercial output by $15 million as
cited by the Canton Mill Operations Manager, Oliver Blackwell. This in turn causes
a loss of 816 jobs, for a net loss of 693 jobs.
For North Carolina the employment impacts depend on the annual capital
and operating costs of a discharge reduction plan. The operating costs plus an
annualized capital charge represent additional employment at the mill. Under the
50 units at the border plan, the annual capital and operating costs would be
$17.91 million. This translates into 539 increased jobs (direct plus indirect) given
the 30.1 multiplier. Under the 50 percent reduction plan the annual costs would be
$5.85 million which would result in 176 more jobs.
Shutdown of the plant under the USEPA standard would have substantial
employment effects in North Carolina. The mill currently employs over
2,100 workers and produces $400 million of paper products per year. Using the
11/G/1/W

-30-
Department of Commerce multiplier of 30.1 jobs per million dollars of output for
paper and allied products in North Carolina, a total loss of over 12,000 jobs can be
projected. The direct losses to the community include the $160, million currently
paid to local factors.
Thus, in North Carolina and Tennessee combined, the USEPA standard
would lead to a loss of over 12,000 jobs as well as widespread social costs from the
withdrawal of Champion's substantial support both directly and indirectly through its
employees and suppliers and through Champion's support of the Western North
Carolina-Eastern Tennessee infrastructure through tax payments.
VI. EVALUATION OF THE BACH AND BARNETT REPORT
We have reviewed and evaluated the Bach and Barnett analysis and found
it to be seriously flawed. There are four key conceptual errors that undermine
their conclusions that it would be economic to substantially reduce color discharges
from the mill. First they have failed to take into account the fact that benefits
occurring in different years are not of equal value. Second they have included a
category of benefits (indirect benefits) which have no place in a properly designed
benefit-cost study and which have been misestimated in any case. Third, their
examination of costs was entirely hypothetical and bears no relationship to the
benefits achieved. Fourth they have employed the wrong standard in evaluating the
possibility of mill shutdown. The appropriate way to evaluate discharge reduction
strategies is on the basis of their impacts on the Canton mill. Bach and Barnett
evaluate the strategy on a Champion-wide basis. We will address each of these
issues in the following sections.
A. Discounting
The primary distinction in direct benefits between our analysis and that
of Bach and Barnett involves discounting. Bach and Barnett simply sum the year-
nj ✓I'/w

-31-
by-year benefits to yield a total. This is obviously incorrect. A dollar of benefits
today is worth more than a dollar of benefits tomorrow, just as a dollar of income
today is worth more than a dollar of income tomorrow. Discount factors which
reflect the relative utility of current and future consumption must be applied to
accurately measure the value of future benefits.
Indeed, once appropriate discount rates are applied, the Bach and Barnett
estimates of recreational benefits are slightly lower than ours. Application of our
6.79 percent discount rate lowers the Bach and Barnett direct benefit estimates from
$18.3 million to $13.1 million. Our corresponding estimate of direct recreational
benefits is $13.72 million (see Table II).
B. Indirect Benefits
Bach and Barnett add to the recreational benefits indirect benefits
reflecting increased expenditures in the community resulting from the recreational
activity. We have strong objections to this technique. Most importantly, this type
of benefit has no place in a properly done benefit-cost study. Secondly, even were
these benefits to be included, they have overstated both the level of expenditures
to which these indirect multipliers should apply and have overstated the multiplier
to be used.
The proper standard for a benefit-cost study is the real resource costs
and the real benefits. In comparing the real resource costs and benefits of the
specific proposals mentioned here, we have a criterion which is independent of the
indirect benefits. All programs have indirect benefits. Removing those indirect
benefits can therefore have no effect 'on the analysis. Since the money spent on
this project will be spent in some other way, the indirect benefits are essentially
independent of the program undertaken.

-32-
Indirect economic multipliers represent a flawed concept taken in
aggregate. The problem is that money spent on whitewater rafting does not reflect
new income but is instead the shifting of income from another purpose. A dollar
spent on whitewater rafting is a dollar not spent on other outdoor activities or
other recreation. The economic multiplier of the dollar spent on whitewater rafting
is offset by the loss of the same multiplier from the foregone activities. In
aggregate therefore, these indirect benefits should be ignored. Each dollar of
indirect benefit represents an indirect dollar of loss to someone else.
If one is interested in the net economic benefits for a smaller region,
this can be calculated. However, we must be careful to subtract out expenditures
which cancel out within the region. To the extent that persons from outside Cocke
County are induced to spend money in Cocke County, those dollars will create
indirect benefits in Cocke County. Only expenditures by those outside Cocke
County create these spillover effects within Cocke County.
However, the number of such visitors is likely to be small. Unpublished
data on a nearby river indicate that 41 percent of all river users travelled less than
one hour to the river. Using these data, we have defined the region of direct
economic interest is that within one hour of the Pigeon river. Thus, multipliers
would apply to only 59 percent of all expenditures.
Using the average expenditure figure cited by Bach and Barnett of $20
per day, we find that a total of $8.1 million (in present value terms) should have a
multiplier attached.
This value likely overstates the benefits. For those travelling in excess of
three hours, it is highly unlikely that they would take a trip as short as those on
the Pigeon River. The abundance of alternative fishing, floating and sightseeing
areas and the comparatively low value of these activities make it unlikely that any
IL�P-✓Ifd,®

-33-
long distance visitors would use the Pigeon River for these purposes. Either the
Chattooga or French Broad on which longer trips are available should be preferred
by visitors travelling long distances, especially given the uncertainty of water
supply on the Pigeon River.
Bach and Barnett use a multiplier of three to calculate the indirect
benefits. This estimate reflects the spillover effects for the whole country, not just
the region. The correct value is much smaller. For example, assume an individual
spends $500 on a raft. If the raft was not manufactured in Tennessee, the spillover
benefits will be created wherever payment for the raft goes. By the theory
outlined above, inclusion of these benefits as a spillover is illegitimate, since these
spillovers are exactly offset elsewhere. The U.S. Department of Commerce estimates
state-by-state multipliers for hotels, lodging and amusements. For Tennessee they
have calculated the direct and indirect benefits to the region as 2.1 times the
dollars spent. Indirect benefits therefore are 1.1 times direct dollars expended.
This is the 2.1 less the 1.0 for the direct effect.
Thus, instead of using an estimate of indirect benefits equal to three
times the direct benefits, a more realistic appraisal would be indirect benefits equal
to at most 65 percent of the direct costs, which is 1.1 times 59 percent of the
costs. Total indirect benefits would therefore total about $8.9 million.
Further, these indirect benefits have offsetting indirect costs in the mill
shutdown case. Given the net output losses of $400 million based on expected 1988
mill sales and using the Department of Commerce multiplier of 2.2, we project
indirect losses of $480 million for the most stringent plan, resulting in combined
indirect losses of over $470 million for both states.
Given the importance of the mill to the local economy as the largest
employer, it is possible that these values substantially understate losses associated
I1�L✓ZYd,�

-34-
with termination of pulping facilities. For instance, the mill pays almost
$1.7 million in taxes per year to counties and municipalities over and above taxes
paid by its employees. The impacts of these local tax losses on social services and
education are not calculated here.
C. The Costs of Color Reduction
Bach and Barnett assume a capital cost of $60 million and an operating
and maintenance cost of $6 million. The present value of this expenditure,
$102.5 million, is insufficient even to achieve 50 units at the border. Further, we
note that even by their own analysis, the costs of cleanup far exceed the benefits.
D. Financial Impact on Champion International Corporation
In evaluating the impact of these expenditures on Champion rather than
on the financial viability of the mill, Bach and Barnett have used the wrong
standard. No matter how small the impact on Champion's overall balance sheet, the
economics of the Canton mill must stand on its own merits. An incremental
investment which fails to achieve a suitable rate of return is not justified.
Champion has submitted to USEPA documentation supporting the fact that
the 50 units at the border plan fails to pass the plant gross margin test. Under
this standard, plant economics do not support even this less stringent plan.
Further, our analysis indicates that the returns to this investment are insufficient
to warrant continued operation of the plant.
Tl/,/Y9d®

-35-
REFERENCES
(1] Bach, Orville E. and Barnett, William H., "An Economic Impact Analysis on
the Recreational Benefits of a Restored Pigeon River and A Financial Analysis
of Champion International Corporation's Ability to Provide for a Clean Pigeon
River", unpublished mimeo., May 9, .
[2] Epp, Donald J. and Al-Ani, K.S., "The Effect of Water Quality on Rural
Nonfarm Residential Property Values," American Journal of Agricultural
Economics 61 August 1979.
[3] Brashares, Edith Nevins, "Estimating the Instream Value of Lake Water Quality
in Southeast Michigan," Ph.D. Dissertation, University of Michigan, 1985.
[4] Feenberg, Daniel and Mills, Edwin S. Measuring the Benefits of Water
Pollution Abatement. New York: Academic Press, 1980.
[5] Data supplied in correspondence with Eastern Professional River Outfitters
and confirmed in a conversation with Bob Allen, Tennessee Department of
Conservation.
[6] Walsh, Richard G., Ericson, Ray K., Arosteguy, Daniel J., and Hansen, Michael
P., "An Empirical Application of a Model for Estimating the Recreational
Value of Instream Flow," Completion report OWRT Project No. A-036-COLD.
(Colorado Water Resources Research Institute: Fort Collins Colorado, October,
1980).
[7] Telephone Conversation with Bob Allen, Tennessee Department of
Conservation.
[8] Dornbusch, David M. and Barrager, Stephen M. Benefits of Water Pollution
Control on Prooerty Values. Prepared for the Office of Research and
Monitoring, U.S. Environmental Protection Agency, Socioeconomic
w ✓r/ao

-36-
Environmental Studies Series. EPA-600/5-73-005. (Washington: U.S.
Environmental Protection Agency, October 1973).
(9] Smith, V. Kerry, "Option Value: A Conceptual Overview," Southern Economic
Journal Volume 49, Number 3 (January, 1983).
(10] Freeman, A. Myrick, "The Sign and Size of Option Value," Land Economics
Volume 60, Number 1 (February, 1984).
[11] Smith, V. Kerry, "Nonuse Benefits in Benefit Cost Analysis," Southern
Economic Journal. Volume 54, Number 1 (July ).
[12] Schmalansee, Richard, "Option Demand and : Valuing Price Changes Under
Uncertainty," American Economic Review Volume 65, September 1975.
[13] Bureau of Economic Analysis, U.S. Department of Commerce, Regional
Multipliers: A User Handbook for the Regional Input-Output Modeling System
(RIMS II). (Washington: May 1986).
[14] Office of Analysis and Evaluation, U.S. Environmental Protection Agency,
"Workbook for Estimating the Economic Effects of Pollution Control Costs,"
(Washington: USEPA, November 1983).
rl/ev at

FIGURES
I1�P/Tfd®

FIGURE 1
DIAGRAM OF THE PIGEON RIVER
BETWEEN CANTON, NC AND NEWPORTs TN
FRENCH BROAD RIVER
•u '
MKINFORT,TN
COfaT CREEK a FIILLOTI CREEK
Tennessee
FL RM°aer-J North Carollna
ov RM 26.06.0
T
CREEK
WALTERS DA
WALTERS LAKE
CREEK
am HMO BMDGE
ROW
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0
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FIGURE 2
k
CGO! with the P. R.-O.S
P.O. BOX 592
GATLINBURG,
f" P1GEON TENNESSEE
° 37738
° 615,RIVEK '
i436.5008
•`
OlJ. T®OORS
• ..
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32
C 4 + PIGEON FORGE FOOTHILLS
pARXWAY
Sr --- HARTFORD
+ e COSBY
TRAFFIC N
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With .;.;cNAT1ONAL PARK =:
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,,.. +. ��::•.�:.�;ti:j ;t'RFSERVATIONS •�. . ....�,.u::
T•r• 'l. `y - es[ ou hone for reservations(even •:
• �: '"To U134A:I trip with us we suR Y p
:^.: "-'. •.'`.K.onl an'hour or-two aMadll• Refunds will be given if we are
P6GE0�1• _ V,: _+;,•; Y m riur•conditlons,.or if given JO or more days
Ri�E R . ...ryaMr m raft err.
.,•�`C-..:.,.:.;/_:,v�:..__�•.: T: ..Rain ed eaneailatton..
1• CLi'vWting,WNITEWATER RAFTING TRIPS am on a scenic
• 'S '•dF;•�1, ! d•`SihUr stretch of that BIG PIGEON RIVER. Trips Isere TWICE
0��� ®C • '�?_ '.DAILY from our ougoa on h E. -in ere You
Me foot of the
�ORJ ',.•: V. •r+•; sRoanWro,we.Y+uttis you m tl+s paten there You receive inatfes.
..:.y.:,.. . -i.,..,�v.•. ;_.:•; :••3 •lion in whitowuer technique and ufety procedures.With a Drofes•
w _.;;y-_ .',."`•=;-="-�-��:' .'':.._- ...u ++'�:• Clonal guide in each raft and a kayak safety boat to lead the way.we
LA through TWELVE CLASS 35 AND TWO CLASS 4'SI
. — • Sp SH E BIG PIGEON RIVER has beautiful scenery,lots of splashes.�. .. _LOCATED �N A. .and LS LOTSOF,FUN!
• 1....� Ouc trftis Ire fun for• dI•- BEGINNERS To EXPERIENCED
4,'` PADDLERS-FUN FORTHE WHOLE FAMILY!We emDhasiae...
• �i.`..' ca•MO.EXPERIENCEISNECESSARYI •ear��alm®d,and
. +'2"'•1=•' a ali safety f
t `:PIGEON RIVER OUTDOORS omvm
•:••.;-"'Bea'Iackam;Pwasr..waar Swathing m est wet in. and TENNIS
Li`C+•.:SWE51 For.iooler day wrprovidS watarpeoef lacksts.
' . •`••" �'*p&iD:SERVICE'b iialiable.with a PACKAGE DEAL�toorneor'
Pit '.:•
., bdr thr•rapids bY_We also sell hand-designed T-shire with our BIG
• IGEON RIVER RAFTING ROUTE.
3y2 HOUR TRIPS _ _
1'I�RTHER INFORMATION
'WI of ... . for fiirthsr information on our one-daY rafting MPS,
••� •• I wsrrnlghf trios, kayak and canoe lesions,group rates,v+Aat m wear,
• accommodations,and age!knits. -....

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TABLE I
COSTS AND BENEFITS OF PLANS TO REDUCE
COIAR DISCHARGES INTO THE PIGEON RIVER
Total Benefits and Costs Marginal Benefits and Costs
Discharge Benefit/Cost Benefit/Cost
Reduction Plan Benefitsl Costsl Ratio Benefits2 Costs2 Ratio
-(Millions of -(Millions of
1988 Dollars)- 1988 Dollars)-
(1)/(2)- (4)/(5)
(1) (2) (3) (4) (5) (6)
50 Percent Reduction $11.3 $ 38.4 0.30 $11.3 $38.4 0.30
50 Units At Border 18.0 164.5 0.11 6.7 126.1 0.05
50 Units At Pipe 18.3 290.0 0.06 0.3 125.5 0.00
Sources and Notes
1 Total benefits are taken from Table IV. Total costs are taken from
Table V.
2 Marginal benefits and costs are the difference between the figures of a
plan and the plan immediately above it.
T1h�./T'icl.'

TABLE II
Page 1 of 2
ESTIMATES OF THE MAXIM BENEFITS FROM
A PIGEON RIVER WITH NO COLOR DISCHARGES
Visits Consumer Surplus
White- WhiteJ.
-
Year water Floating FishinR3 Other3 water Floating FishinE3 Other3
--------------(Thousands)----------- --------(Thousands of Dollars)
(1) (2) (3) (4) (5) (6) (7) -(8) -
1988 24 10 13 15 $ 312 $102 $117 $ 68
1989 48 21 14 16 624 203 126 73
1990 72 31 15 18 936 305 136 79
1991 96 42 16 19 1,248 406 147 85
1992 120 52 17 21 1,560 508 159 92
1993 120 52 19 22 1,560 508 171 99
1994 120 52 20 24 1,560 508 185 107
1995 120 52 22 26 1,560 508 200 116
1996 120 52 23 28 1,560 508 216 125
1997 120 52 25 30 1,560 508 213 135
Present Value4 $8,886 $2,892 $1,226 $711
Total Recreation Value
(Millions of 1988 Dollars) $13.72
Property Enhancements5
(Millions of 1988 Dollars)
Tennessee 2.05
North Carolina 2.52
Total Benefits
(Millions of 1988 Dollars) $18.29
n/eirr

TABLE II
Page 2 of 2
ESTIMATES OF THE MAXIMUM BENEFITS FROM
A PIGEON RIVER WITH NO COLOR DISCHARGES
Sources and Notes
1 Whitewater visits are set at a capacity of 120,000. This is in line
with 1987 visits to the Ocoee River of 124,449 visits supplied in
telephone conversation with Bob Allen at the Tennessee Department of
Conservation. Value of $13 per visit derived in text.
2 Floating visits are set at a capacity of 52,000. This was set from
current usage on the Hiwassee (80,000) reduced by 35 percent to account
for low Pigeon River water levels in August and September. Value of
3 $9.76 derived in text.
Fishing and Other taken from Bach and Barnett. Fishing value derived in
text.
4 Present discounted values over 10 years at a real rate of 6.79 percent,
derived by taking Champion's 13.2 percent after-tax cost of money and
netting out an assumed 6 percent inflation rate.
5 Property value adjustment taken from Table III.
Il�/Ifd'

TABLE III
ESTIMATES OF THE MA=MDM IMPROVEMENTS IN
PROPERTY VALUE FROM A PIGEON RIVER
WITH NO COLOR DISCHARGES
(1988 DOLLARS)
Increase in
Value per Foot Total
Miles of Valuel from Reduced Increase-
Frontage Per Foot Dischar eg s� in Value
-------(D'ollars/Foot)------- --(Thousand
Dollars)-
(1) (2) (3) (4)
North Carolina:
Residential 4.33 $52.49 $14.64 $ 335
Other Private 28.32 18.78 14.64 , 2,189
Public Land3 38.614 NA 0 0
Total $2,524
Tennessee:
Residential 5.53 52.49 14.64 427
Other Private 20.96 18.78 14.64 1,620
Public Lands 14.66 NA 0 0
Total $2,047
Total of Tennessee
and North Carolina $4,100
Sources and Notes
1 Assumes same value per river foot in North Carolina as in Tennessee.
2 For residential land this value represents an increase of 27.9 percent as
estimated by Epp and Al-Ani, reference [2] . For all other private land,
the same absolute value per foot was applied.
3 North Carolina Public includes: Interstate 40, Highways 19 and 23,
forest, mapping recon, unassigned territory, and Champion property.
4
Includes 9.34 miles to estimate the distance on missing maps. The
calculation was done by noting that there are 12.5 miles /from the dam to
the powerhouse and subtracting from this the distances on maps we have
between the dam and the powerhouse.
5 Tennessee public includes: Interstate 40, Edwina Rd. , forest, Cocke
County, unassigned territory, and publicly owned property.
I1/e/I7cl7

TABLE IV
ESTIMATES OF THE BENEFITS OF PLANS TO REDUCE
COLOR DISCHARGES IN THE PIGEON RIDER
50 Percent 50 Unit Maximum
Reduction At Border At Pipe
(1) (2) (3)
Pounds Per Day Removed 172,000 274,000 311,000
Proportion of Benefitsl
Tennessee 0.63 1.00 1.00
North Carolina 0.55 0.88 1.00
Total Benefits $11.33 $17.99 $18.29
Benefits Per Pound of
Color Per Day Removed2 66 66 59
Marginal Benefit
Per Pound Per Day3 66 66 8
Sources and Notes
1 Proportion of benefits is the proportion of total state benefits which
would be observed under each plan. Tennessee benefits include all
recreation benefits in Table II.
2 Total benefits divided by pounds per day removed.
3 Difference in benefits divided by difference in pounds per day removed
from less stringent to more stringent removal.
T1�✓IYd.'

TABLE V
ESTIMATES OF THE COSTS OF PLANS TO REDUCE
COLOR DISCHARGES IN THE PIGEON RIVER
50 Percent 50 Unit Maximum
Reduction At Border At Pipe
(1) (2) (3)
Pounds Per Day Removedl 172,000 274,000 311,000
Capital Costl
(1988 Dollars) $10,000,000 $95,120,000 $290,000,000
Operating and
Maintenance Costl
(1988 Dollars Per Year) 4,000,000 9,783,000 0
Present Value of
Total Cost2
(1988 Dollars) 38,366,000 164,496,000 $290,000,000
Cost Per Pound Per Day
of Color Removed3
(1988 Dollars) 223 601 933
Marginal Cost Per Pound
Per Day of Color Removed4 223 1,244 3,392
Sources and Notes
1 Pounds removed, capital and operating costs provided by the Company. For
50 units at the border plan, capital costs have been adjusted to reflect
probability distribution of capital cost equations.
2 Total cost taken by adding capital cost to operating and maintenance cost
stream discounted at 6.79 percent real discount rate for 10 years. Real
discount rate assumes 6 percent inflation applied to Champion after-tax
cost of money of 13.2 percent.
3 Total cost divided by pounds per day removed.
4 Difference in cost divided by difference in pounds per day removed from
less stringent to more stringent removal.
Ile/T9a.'

TABLE VI
Y
COMPARISON OF COST AND BENEFITS OF
PLANS TO REDUCE COLOR DISCHARGES
IN THE PIGEON RIVER AT ALTERNATIVE DISCOUNT RATESI
6.79% Discount Rate 38 Discount Rate
Discharge Benefit/Cost Benefit/Cost
Reduction Plan Benefits Costs Ratio Benefits Costs Ratio
-(Millions of -(Millions of
1988 Dollars)- 1988 Dollars)-
(1)/(2) (4)/(5)
(1) (2) (3) (4) (5) (6)
50 Percent Reduction $11.3 $ 38.4 0.30 $13.0 $ 45.9 0.28
50 Units at Border 18.0 164.5 0.11 20.7 196.0 0.11
50 Units at Pipe 18.3 290.0 0.06 21.0 343.0 0.06
Sources and Notes
1 All calculations are as in notes to Table I.
TLp✓IPd,•

TABLE VII
ESTIMATES OF EMPIDI!MENP IMPACTS OF PLANS
TO REDUCE COIDR DISCHARGES IN THE PIGEON RIVER.
Changes in Output Changes in the Number of Jobs
Discharge North North
Reduction Plan Tennessee' Carolina2 Tennessee3 Carolina3 Total
(Millions of 1988 $) -------(Number of Jobs)--------
(3)&(4)
(1) (2) (3) (4) (5)
50 Percent Reduction 1.29 5.86 77 176 253
50 Units At Border 2.04 17.94 123 539 662
50 Units At Pie Recreation 2.04
p Forest 15.00] -385.00 -693 -12,040 12,733
Sources and Notes
' Changes in output for Tennessee are derived by multiplying increased visits per
year (120,000) , the proportion of expenditures that are commercial (.85) , the cost
per trip (20) , and the proportion of benefits achieved (from Table IV) . The loss
of $15 million of output in the last case is taken from Oliver Blackwell's
testimony before USEPA, page 27.
2 Changes in output for North Carolina are calculated as follows: for the first two
plans they are derived by adding the operating and maintenance cost of a plant and
the capital cost multiplied by the capital recovery factor (.186) . For the 50
units at the mill plan, the loss in output is equivalent to the current output of
the mill.
3 Multipliers are derived from RIMS manual, reference [131 .
Ilip./IYd'

CHRONOLOGY
CHAMPION INTERNATIONAL
CANTON, NORTH CAROLINA
June 25, 1984 EMC Public Meeting for Champion' s
Temperature Variance
October, 1984 Temperature variance issued by EMC not to
exceed temperature increase at Fiberville
Bridge ( . 4 miles downstream of discharge)
of 13 . 9 degrees Centigrade . Maximum
temperature of 29 degrees Centigrade
October thru June and 32 degrees Centigrade
July thru September
May 14 , 1985 North Carolina issued NPDES Permit Number
NC0000272 to Champion International, Canton
Mill .
November 13 , 1985 - EPA assumes control of Champion' s NPDES
Permit after determining that it (EPA)
did not have sufficient time (90 days) to
review the permit prior to N. C. issuance
and in response to color concerns of
downstream residents in Tennessee.
January 17, 1986 - Champion challenged EPA' s claim of
authority over the permit process in US
District court .
March 24 , 1986 - North Carolina filed court action to
block EPA action.
March 26, 1986 - Champion asks for temporary restraining
order to block EPA action until
existing suit is settled.
March 31, 1986 - US District Court Judge Sentelle denies
Champion request for temporary
restraining order.
April 11, 1986 - Champion requests NPDES Permit from EPA.
May 2, 1986 - Motion by EPA to dismiss Champion
suit denied.

Page 2
December 1, 1986 - US District Court Judge Sentelle ruled
that EPA had jurisdiction to assume
authority over Champion' s NPDES Permit .
March 4, 1987 - Champion appeal of Sentelle ruling.
April 9, 1987 - First EPA Draft (public notice) of
Champion NPDES Permit with 50 unit color
limit applicable to Champion immediately
downstream of discharge at Fiberville
Bridge.
May 22, 1987 - Second EPA public notice for permit
issuance .
January 14, 1988 - First Public Hearing in Asheville Civic
Center for NPDES Permit issuance.
January 21, 1988 - First Public Hearing in Knoxville,
Tennessee Civic Center.
March 9, 1988 - Tennessee, North Carolina, Champion, and
EPA agree on change in proposed permit
from 50 Apparent Color units at NC/TN
state line (proposed as applicable at
the Fiberville Bridge immediately
downstream of the Champion Mill) to 85
True Color Units at the State line.
North Carolina and Tennessee to grant
variance from color stream standard to
allow permit issuance.
May 5, 1988 - Champion formally requests water quality
color standard variance from EMC NPDES
subcommittee at public hearing in Raleigh.
June 24, 1988 - Champion appeal of Sentelle decision
denied by three judge panel of 4th US
Circuit Court of Appeals - verifying EPA
authority over Champion' s NPDES permit .
Ron Levine, Director, Division of
Health Services, NC Dept . of Human
Resources issued advisory against eating
fish from Pigeon River as per studies
showing a presence of dioxin in fish and

Page 3
sediment downstream of the mill; albeit
.not in Champion' s effluent . Dioxin not
regulated to date in the proposed NPDES
Permit .
July 13 , 1988 - EMC issues water quality variance from
North Carolina color standard allowing
NPDES Permit for 85 True Color Units to be
placed in proposed NPDES Permit.
August 18-19, 1988- Tennessee color variance hearing in
Newport, Tennessee .
December 23, 1988 - Tennessee denies Champion' s color variance
request from standard, preventing
agreement reached 3/9/88 from being
formally enacted.
March 15, 1989 - EPA Issued a draft Discharge Permit for a
reconfigured Canton Mill, allowing it to
operate during reconfiguration.
July 12, 1989 - Second draft NPDES Permit (public notice)
for Champion with color limit consistent
with EMC variance and Tennessee
limit of 50 units at State Line . Permit
also including additional requirement for
chloroform and dioxin. Permit provided
for reduction in flow from 48 . 5 MGD
to 29 MGD and three (3) year schedule for
compliance (down from 5 year schedule in
initial draft) .
August 17, 1989 - Newport, Tennessee public hearing on EPA
NPDES Draft Permit .
August 24, 1989 - Asheville public hearing on permit .
September 8, 1989 - DEM issues Section 401 Water Quality
Certification for proposed Champion Permit.
September 25, 1989- Champion NPDES Permit issued by EPA.

Page 4
October 14, 1989 - Permit appealed first by Environmental
groups and then by Champion. EPA
administrative law judge grants hearing.
Hearing to be scheduled.
March 27, 1990 - Champion announces implementation of
modernization project despite pending legal
issues . Estimated cost of project is $250
million.
1990 - 1991 - Legal issues continue to be fought before
EPA Administrative Law Judge . Champion
continues modernization project.
April, 1991 - EPA Administrative Hearing held in Atlanta,
Georgia.
Early 1992 - Administrative Law Judge issues final
decision essentially leaving permit as is .
No appeal requested.

State of North Carolina
Department of Environment
and Natural Resources A94
Asheville Regional Office
IV
AMNON �
Michael F. Easley, Governor N C D EN R
Sherri Evans-Stanton, Acting Secretary
Kerr T. Stevens, Director NORTH CAROLINA DEPARTMENT OF
Division of Water Quality ENVIRONMENT AND NATURAL RESOURCES
WATER QUALITY SECTION
January 17, 2001
Mr. Derric Brown
Blue Ridge Paper Products Inc.
Post Office Box 4000
Canton, North Carolina 28716,
Subject: Acceptance of Activated Sludge
From Maggie Valley WWTP
Blue Ridge Paper Products
NPDES Permit No . NC0000272
Haywood County
Dear Mr. Brown:
This Office does not foresee a problem with your wastewater
treatment plant accepting activated sludge from the Town of Maggie
Valley. It is suggested that you maintain a record of all sludge
received including the date and number of gallons .
If you have any questions concerning this matter or if you
require additional information, please do not hesitate to contact me
at 251-6208 .
Sincerely,
ZZ
D. Keith Haynes/
Environmental Specialist
xc: Mike Mehaffey
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-consumer paper

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
L
Michael F. Easley, Governor NCDENK
Sherri Evans-Stanton, Acting Secretary
Kerr T. Stevens, DirectorNc A CARouNA 0FP TmE of
Division of Water Quality ENV aNmE AND NA[U ResouRc�
WATER QUAL= SECTION
.January 17, 2001
Mr. Derric Brown
Blue Ridge Paper Products Inc.
Post Office Box 4000
Canton, North Carolina 28716
Subject: Acceptance. of Activated Sludge
From Maggie Valley WWTP
Blue Ridge Paper Products
NPDES Permit No. NC0000272
Haywood County
Dear Mr. Brown:
This Office does not foresee a problem with your wastewater
treatment plant accepting activated sludge from the Town of Maggie
Valley. It is suggested that you maintain a record of all sludge
received including the date and number of gallons.
If you have any questions concerning this matter or if you
require additional information, please do not hesitate to contact me
at 251-6208 .
Sincerely,
D. Keith Haynes
Environmental Specialist
xc: Mike Mehaffey
59 Woodfin Place,Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Eaual Onoortunity Affirmative Action Fmnlnver 50% reevele MM' nncf-ennsnmer naner

Making ur mark fof you. (��V
BLUE RIDGE PAPER PRODUCTS INC. - -
January 9, 2001
Mr. Forrest Westall
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,North Carolina 28801
Re: North Carolina NPDES Permit No. NC0000272
Blue Ridge Paper Products,Inc. - Canton Mill
2000 Waterville Reservoir Sampling Requirement Results
Dear Forrest:
On August 15, 2000, in accordance with Part III, Section K of the Canton Mill's NPDES
Permit, Waterville Reservoir was sampled at three locations for temperature, dissolved
oxygen, conductivity, Secchi Depth,pH,Total Nitrogen (TN),Nitrite+Nitrate (NO2 +
NO3), Ammonia(NH3-N), Total Kjeldahl Nitrogen(TKN), Total Phosphates (PO4),
Total Phosphorous (TP), and Chlorophyll-a. As stated in the permit,water samples were
collected at 0.1 meters beneath the surface of the lake prior to Laurel Branch, near
Wilkins Creek, and near the dam as stated in the permit.
Temperature, dissolved oxygen, conductivity, Secchi Depth, and pH were measured in
the field while the remaining samples were collected,preserved, and sent to a North
Carolina certified laboratory for analysis. Attached is a table summarizing the results of
the above analyses for each sampling site. This table will be attached to the mill's
December DMR,which will be mailed at the end of January.
If there are any questions or comments please contact me at(828) 646-6749.
Sincerely C
Melame S. Hager
Environmental Engineer f�. " p`�•
e'' A
nq t
175 Main Street P.O. Box 4000 Canton, North Carolina 28716 828-646-2000

Blue Ridge Paper Products, Inc. -Canton, NC
Results of 2000 Waterville Reservoir Sampling NPDES Permit Requirement
Sample Waterville Reservoir Waterville Reservoir Waterville Reservoir
Parameter Units prior to Laurel Branch near Wilkins Creek near the dam
Temperature Celsius 25.5 24.8 24.6
Dissolved Oxygen mg17 13.2 7.5 7.3
Conductivity umhos 392 351 352
pH 9 7.9 8.3
TN mg/7(ppm) 1.1 1.0 1.0
NO2 + NO3 mg/I(ppm) both ND(0.10) ND(0.10) and 0.12 ND(0.10) and 0.10
TKN mg1l(ppm) 1.1 0.9 0.9
NH3-N mg/J(ppm) ND(0.10) ND(0.10) 0.11
PO4 mgA(ppm) 0.06 ND(0.02) ND(0.02) .
TP mg/7(ppm) 0.1 0.03 0.04
Chlorphyll-a ugA(ppb) 45.39 43.44 29.75
Secchi Depth meters 0.59 0.95 0.96
Sample Notes:
Laurel Branch Site Sampled on 8/15/00 at 10:20am
Wilkins Creek Site Sampled on 8/15106 at 11:10am
Dam Site Sampled on 8/15/00 at 11:30am
2000 Waterville Lake MSH 115101

d
BLUE RIDGE ,tt11
PAPER PRODUCTS INC.
vv QOQ
December 28,2000
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
January 1,2001 Color Limit Feasibility Report
Dear Mr. Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24,
and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 99a'percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 lbs/day and an average monthly color limit of 59,796 lbs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit), Blue Ridge Paper Products recommends using a 95a'percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 95's percentile statistical review of the
limited data available from January 1998—October 31, 2000 the annual average color is 48,388 lbs/day
and the monthly average color is 55,556 lbs/day. Blue Ridge Paper Products believes the 95 s percentile
confidence interval will be appropriate with the additional color data that will be available for the June 1,
2001 analysis. The attached Table includes the summary of the 99s' and 950'percentile statistical data.
Please call me at(828) 646-2033 or Derric Brown at(828)646-2318 if you have any questions regarding
this report.
Sincerely,
Bob Williams
Director-Environmental,Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

BLUE RIDGE
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1,2001— Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000—52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III,Paragraph E 12 of the 1997
Permit provides in part, as follows:
"...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 Ibs/day
based on full implementation of the Near-Term Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits..."
This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000, Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000— 52, 000 pounds per day is feasible.
1

January 1, 2001 - Color Limit Feasibility Report
Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
400000
N
d
v
0 300000
O
V
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1,2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I1. Color Performance
The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual
average amount of color discharged, as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project, full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRTM on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average
annual color discharged was 41,048 Ibs/day. The 2000 average annual color(through
October) is 44,837 Ibs/day. All of these values are within or below the target annual
average color range of 48,000—52,000 lbs/day specified in Part III, Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion(30Q2),historical flow records, and the
January 1998—October 2000 annual average color value of 45,4581bs/day, it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
3

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
III. Recommended Color Limits
The January 1998 —October 2000 actual average annual color of 45,458 lbs/day and the
January 2000—October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000—52,000 lbs/day specified in Part
III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated, that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 lbs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998—October 2000 annual color average using a 991'percentile
distribution is 49,612 lbs/day. The January 2000—October 2000 annual color average
using a 99"i percentile distribution is 48,911 lbs/day. These values are both within the
48,000—52,000 lb/day range. Based on a statistical review of the data and the limited
data set available, Blue Ridge Paper Products, Inc. recommends an annual average
effluent limit of 49,612 lbs/day.
The January 1998 —October 2000 monthly color average using a 99`s percentile
distribution is 59,796 lbs/day. The January 2000—October 2000 monthly color average
using a 990'percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available,Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,796 lbs/day.
4

January I, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
• Canton,North Carolina
III. Conclusion
Blue Ridge Paper Products,Inc. believes it is feasible to achieve a target annual average
color limit within the range of 48,000—52, 000 lbs/day. The Canton Mill recommends
_an average-annual color limit of 49,612.1bs/day and an average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria (30Q2), historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepeo gage will be less than 50 true color units approximately 97%
of the applicable time.
5

,
TABLE
January 1, 2001 Color Limit Feasibility Report
Monthly Average Data -Max Month Calc
Data Set= 1/1/98-10/31/2000 1/112000-10/3112000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. = 34 10
xbar • 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 55556 54773
99th safe MONTH from normal dist 69796 58953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58542 58009

---.. - -. --------
UJ
Making ur mark for you.
O
BLUE RIDGE 70
PAPER PRODUCTS INC. OCr COOZ
r
LARORAT
r 1 ASREVILL ORY SECTION
Dt �v�'_' l�Jr E REGIONAL OFFCE
� �v
Certification Number 198 r OCT 9 2000 October 5, 2000
Mr. James W. Meyer . DIM
DWQ Laboratory Section LABORATORY SECTION
NCDENR
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
Subject: Laboratory Certification Maintenance Inspection Response to
September 12, 2000 Letter and August 30, 2000 Inspection Report.
Dear Mr. Meyer:
The laboratory inspection report from August 30, 2000 by Mr. Gary Francies
contained four lettered comments that required a written reply. This correspondence
is the response to your letter dated September 12, 2000 that includes the reply to the
lettered comments.
Ammonia Nitrogen
A. COMMENT: The laboratory control standard is not from a second source:
occasionally, a second source standard is analyzed, but not daily as required.
RESPONSE: Beginning October 1, 2000 a mid-range second source standard is
analyzed daily to document accuracy.
B. COMMENT: The distilled versus undistilled comparison study results are
unacceptable. It appears this is due to the low concentration of the samples used.
It is recommended that the samples be spiked to a concentration of at least 1 to 5
mg/1. Please submit the results from the analysis of two sets of samples.
RESPONSE: Two sets of spiked samples were analyzed by Pace Analytical
Services, Asheville,N.C. for the distilled versus undistilled comparison. The
sample dates and test results follow:
Date Distilled Undistilled
8-30-00 5.62 mg/I 5.2 mg/1
9-05-00 4.88 mg/1 4.3 mg/1

BLUE RIDGE PAPER PRODUCTS INC.
Color—platinum cobalt
C. COMMENT: The linearity of the curve, slope value, and y-intercept are not
maintained on file for three years. The raw data is on file and the
spectrophotometer displays all this information, but once a new curve is
established all this information from the old curve is lost except the raw data
values. It is recommended that the raw data be entered into your computer, which
then can produce the curve, and all associated information, which can be printed
and stored with the raw data. Each daily bench sheet must document the date of
the curve.
RESPONSE: The slope values, y-intercepts, and correlation coefficients for all
curves used in the past three years have been restored in our files. Daily bench
sheets now contain the date the curve in use was made.
BOD
D. COMMENT: The laboratory is analyzing 5 mLs of standard not 6 mLs, as the
method requires. This has been done for several years and has been missed in
prior audits, both internal and those conducted by the state. All values obtained
for the standards reviewed were in the acceptable range.
RESPONSE: Beginning October 1, 2000 the laboratory changed from 5 mLs to
6 mLs of glucose glutamic acid standard in the 300 mL BOD bottles. The 5 mLs
of standard was required in the Federal EPA Method.
If you have any questions, comments, or need additional information, I can be contacted
by phone at 828-646-6720 or by fax at 828-646-2993.
Sincerely,
�,
/,
John J. Pryately
Laboratory & WWTP Supervisor

ll
National
I
Environmental
Achievement Track
I
_ Application Eorin _
Blue Ridge Paper Products, Inc.
Name of facility
Name of parent company(if any)
175 Main Street
Street address
Box 4000
Street address (continued)
Canton, North Carolina 28716
City/State/Zip code
Give us information about your contact person for the
National Environmental Achievement Track Program.
Name Robert V.Williams
Title Director, Environmental, Health and Safety Affairs
Phone [phone]
Fax [phone]
E-mail [e-mail]
Page 1 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

0
Why needs
s b need this inforion on you j 1% n A
EPA needs background information on our facilityto I
evaluate your application.
What do you need to do? 1 a 9t,$+'�'r t
• Provide background information on your facility.
• Identify your environmental requirements.
1 What do you do or make at your facility? Uncoated freesheet paper and paperboard products
2 List the Standard Industrial Classification (SIC) SIC
code(s) or North American Industrial Classification 2611 2621 2631
System (NAICS) codes that you use to classify
business at your facility. NAICS
3 Does your company meet the Small Business ❑ Yes ® No
Administration definition of a small business for your
sector?
4 How many employees (full-time equivalents) ❑ Fewer than 50
currently work at your-facility?
❑ 50-99
❑ 100-499
❑ 500-1,000
® More than 1,000
Page 2 Application far the National Environmental Achievement Track
OMB Approved No.2010-0032

_ Er �I� 0buy
5 Does your facility have an EPA ID number(s)? ® Yes ❑ No
If yes, list in the right-hand column. NCD 003148889
6 Identify the environmental requirements that apply to
your facility. Use the Environmental Requirements
Checklist, at the back of the instructions,as a
reference. List your requirements to the right or
enclose a completed Checklist with your application.
7 Check the appropriate box in the right-hand column. ❑ I've listed the requirements above.
® I've enclosed the Checklist with my application.
8 Optional: Is there anything else you would like to tell The Canton Mill has been under new ownership since
us about your facility? May 1999. Along with financial investors, it is now an
employee-owned company, Blue Ridge Paper Products
Inc.The Canton Mill is still in the process of converting
many of its existing programs and documents to those
of Blue Ridge Paper Products Inc. It is also in the
process of revising or establishing new programs that
were managed by the previous corporate EHS staff.
Some long standing facility practices, such as
environmental training for all employees whose job
responsibilities can significantly impact the
environment, are now being incorporated into the
facility's formal EMS.
The Canton Mill ranks among the top pulp and paper
mills in the world for water quality. The mill is already
in compliance with the effluent guidelines portion of the
federal government's new Cluster Rules, years before
many other facilities. Canton's kraft pulp mill is
Elemental Chlorine Free (ECF), using Oxygen
Delignification with 100% chlorine dioxide bleaching
and Bleach Filtrate Recycle (BFR)technology. The
BFR process recovers naturally ocurring minerals in
wood and other chemicals used to bleach pulp white.
Because BFR technology recycles the chemicals and
Page 3 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

water used in the bleaching process, water usage,
bleach plant effluent and effluent color are reduced,
allowing the Canton Mill to dramatically reduce its
impact on the environment.
Page 4 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

'Why we need this information ( r 7 j 0,00`
'Facilities must have an operating Environmental 14f{_-�)J�f�r1.1Lf f_'UG ll1/_I (��/! f�/ )fJ
;Management System (EMS)that meets certain rmv
'requirements.
What do you need to do? ; tFtS
• Confirm that your EMS meets the Achievement L' --
Track requirements.
• Tell us if you have completed a self-assessment or ,
have had a third-party assessment:of your EMS.
1 Check yes if your EMS meets the requirements for
each element below as defined in the instructions.
a. Environmental policy ® Yes
b. Planning ® Yes
c. Implementation and operation ® Yes
d. Checking and corrective action ® Yes
e. Management review ® Yes
2 Have you completed at least one EMS cycle ®Yes
(plan-do-check-act)?
3 Did this cycle include both an EMS and a ® Yes
compliance
audit?
4 Have you completed an objective self-assessment or ®Yes
third-party assessment of your EMS?
If yes, what method of EMS assessment did you ® Self-assessment
use?
❑ GEMI ® Other
❑ CEMP
American Forest& Paper Association Corporate
Survey to Verify Compliance with EHS Principles
❑Third-party assessment
❑ ISO 14001 Certification
❑ Other
Page 5 Applicalion for the National Environmental Achievement Track
OMB Approved No.2010-0032

Why rho we need this information? � ( y�
Facilities must show that they are committed to S�3 j:_� �tl '�� n
iimproving their environmental performance. This means
that you can describe past achievements and will make
future commitments, �tstt '
What do you need to do?
;Refer to the Environmental Performance Table in the
instructions to answer questions 1 and 2.
1 Describe your past achievements for at least two
environmental aspects. If you need more space than is
provided,attach copies of this page.
Note to small facilities: If you qualify as a small facility as
defined in the instructions,you are required to report past
achievement for at least one environmental aspect.
First aspectyou've selected
What aspect have What was the previous level What is the current level?
you selected? (2 years ago)?
Quantity Units Quantity Units
COD Discharges to Water 13.86 lbs./ 1000 lbs. 8.78 lbs./ 1000 lbs.
pulp pulp
I. How is the current level an improvement over the
previous level?
This improvement is a significant reduction of COD discharge to water and is also a significant
improvement in the overall efficiency of the facility's operations.This level of performance is less than
1/3 of the proposed Cluster Rule Limitation for Bleached Papergrade Kraft Mills.
ii. How did you achieve this improvement?
As a result of substantial capital investment in BFR(Bleach Filtrate Recycle), a proprietary technology
that allows for bleach filtrates to be recycled in its softwood fiber line.The Canton Mill is the only
bleach kraft mill in the world that employs this technology.
Page 6 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

Second aspectyou've selected
What aspect have What was the previous level What is the current level?
you selected? (2 years ago)?
Quantity Units Quantity Units
Water Use 26.8 million gallons 24.3 million gallons
daily daily
i. How is the current level an improvement over the
previous level?
On average, the facility has reduced the amount of intake water by two million gallons per day.
ii. How did you achieve this improvement?
This improvement was achieved through process optimization water conservation measures
throughout the mill. Focused efforts to reduce water usage have included the optimization of non-
contact cooling water.
2 Select at least four environmental aspects (no more than
two from any one category)from the Environmental
Performance Table in the instructions and then tell us
about your future commitments. If you need more space
than is provided, attach copies of this section.
Note to small facilities: If you are a small facility, you
are required to make commitments for at least two
environmental aspects in two different categories.
First aspect you've selected
a.What is the aspect? Material Use (Purchased lime reduction)
b. Is this aspect identified as significant in your EMS? ®Yes ❑ No
c.What is the current level?You may choose to state ® Option A:
this as an absolute value or in terms of units of Absolute value 55 tons/day
production or output. (Quantity/Units)
❑ Option B:
In terms of
units of production (Quantity/Units)
or output
Page 7 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

d.What is the improvement you are committing to ® Option A:
over the next three years?You may choose to state Absolute value 40 tons/day
this as an absolute value or in terms of units of (Quantity/Units)
production or output. ❑ Option B:
In terms of
units of production (Quantity/Units)
or output
e. How will you achieve this improvement? The objective is to reduce the amount of lime
purchased by 15 tons per day. This will be
accomplished by capital investment resulting in process
improvements and equipment upgrades. This will also
reduce the amount of solid waste generated by the
facility and landfilled.
Second aspect you've selected
a.What is the aspect? Material use(Reduce influent fiber losses)
b. Is this aspect identified as significant in your EMS? ®Yes ❑ No
c.What is the current level?You may choose to state ® Option A:
this as an absolute value or in terms of units of Absolute value 28 tons/day
production or output. (Quantity/Units)
❑ Option B:
In terms of
units of production (Quantity/Units)
or output
d. What is the improvement you are committing to ® Option A:
over the next three years?You may choose to state Absolute value 20 tons/day
this as an absolute value or in terms of units of (QuantitylUnits)
production or output. ❑ Option B:
In terms of
units of production (Quantity/Units)
or output
e. How will you achieve this improvement? The objective is to increase on-site manufactured fiber
useage by 8 tons per day. This will improve the
efficiency of the facility's operations and reduce the
amount of solid waste generated and landfilled. This
objective will be achieved through process and
operating practice optimization.
Page 8 Application for the National Environmental Achievement Track
OMB Approved No.2010-0031

Third aspect you've selected
a.What is the aspect? Total Solid Waste (Recycle of depoly)
b. Is this aspect identified as significant in your EMS? ®Yes ❑ No
c.What is the current level?You may choose to state ® Option A:
this as an absolute value or in terms of units of Absolute value 350 tons/month
production or output. (Quantity/Units)
❑ Option B:
In terms of
units of production (Quantity/Units)
or output
d.What is the improvement you are committing to ® Option A:
over the next three years?You may choose to state Absolute value 1.100 tons/month
this as an absolute value or in terms of units of (Quantity/Units)
production or output. ❑ Option B:
In terms of
units of production (Quantity/Units)
or output
e. How will you achieve this improvement? The objective is to increase the amount of waste
coated paperboard material recycled by 750 tons per
month. This objective will be achieved by making
process changes and increasing uptime to the recycling
process.
Fourth aspect you've selected
a.What is the aspect? Expected Lifetime Waste of Product(Increase
paperboard packaging efficiency)
b. Is this aspect identified as significant in your EMS? ®Yes ❑ No
c. What is the current level?You may choose to state ❑ Option A:
this as an absolute value or in terms of units of Absolute value
production or output. (Quantity/Units)
® Option B:
In terms of 282 Ibs/3000 sq. ft.
units of production (Quantity/Units)
or output
d.What is the improvement you are committing to ❑ Option A:
over the next three years?You may choose to state Absolute value
this as an absolute value or in terms of units of (Quantity/Units)
production or output. ® Option B:
In terms of 265 Ibs/3000 sq. ft.
units of production (Quantity/Units)
or output
e. How will you achieve this improvement? The objective of this improvement is to reduce the total
basis weight of our product line by 5% to 6% on
average. This will result in reducing the fiber content of
our product. This change came about as a result of
applying Design for the Environment and Life Cycle
Analysis thinking. Reducing the fiber content will make
our products lighter. A lighter product will result in
Page 9 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

reduced solid waste generated by our end-users. For
example, the 23 point paperboard grade product that
we produce for milk and juice cartons is currently 282
pounds per 3000 square feet of product area, after
capital investment and equipment upgrade the weight
will be reduced to approximately 265 pounds per 3000
square feet.
Page 10 Application jar the National Environmental Achievement Track
OMB Approved No.2010-0032

Why do we need this information?
/Oozr/a IB
Facilities must demonstrate their commitment to public tS,3(10
outreach and performance reporting. You should have
appropriate mechanisms in place to identify community
concerns,to communicate with the public, and to provide LAW W1 C t �Uw a a
information on your environmental performance.
What do you need to do?
• Describe your approach to public outreach.
• List three references who are familiar with your facility.
1 How do you identify and respond to community The Canton Mill's primary means of identifying and
concerns? responding to community concerns is through the
Community Advisory Committee that normally meets
once every three months. It is made up of local
citizens, the purpose of which is to discuss their
concerns that relate to the facility and educate them
about the facility's operations.
Canton Mill management also meets periodically with
an alliance of local nonprofit organizations in order to
communicate on environmental performance and report
on different environmental initiatives.
2 How do you inform community members of Community members are informed of pertinent
important matters that affect them? information through the Community Advisory
Committee, periodic leadership forums, legislative
updates and through a regular mill tour program.
3 How will you make the Achievement Track Annual ❑Website www.
Performance Report available to the public?
❑ Newspaper
® Open Houses
® Other
The report will also be disseminated through the
existing community outreach programs.
Page I Application for the.National Environmental Achievement Track
OMB Approved No.2010-0032

4 Are there any ongoing citizen suits against your ❑ yes ® No
facility?
If yes, describe briefly in the right-hand column.
5 List references below
Organization Name Phone number
Representative of Haywood Scenic Ron Moser, Director 828-456-5195
a Communityl Waterways Assocation
Citizen Group
StatelLocal Regulator North Carolina Forrest Westall, Regional 828-251-p208
Department of Water Quality Supervisor
Environment and Natural
Resources, Division of
Environmental
Management
Other communityllocal Haywood County Jack Horton, Haywood 828-648-2363
reference
County Manager
Page 12 Application far the National Environmental Achievement Track
OMB Approved No.2010-0032

On behalf of Blue Ridge Paper Products, Inc. Canton Mill
[my facility], 1W Ing,
e�
I certify that —Ali
• I have read and agree to the terms and conditions, as specified in the National Environmental
Achievement Track Program Description and in the Application Instructions;
• I have personally examined and am familiar with the information contained in this Application (including,
if attached, the Environmental Requirements Checklist). The information contained in this Application
is, to the best of my knowledge and based on reasonable inquiry, true, accurate, and complete, and I
have no reason to believe the facility would not meet all program requirements;
• My facility has an environmental management system (EMS), as defined in the Achievement Track
EMS requirements, including systems to maintain compliance with all applicable federal, state, tribal,
and local environmental requirements, in place at the facility, and the EMS will be maintained for the
duration of the facility's participation in the program;
• My facility has conducted an objective assessment of its compliance with all applicable federal, state,
tribal, and local environmental requirements, and the facility has corrected all identified instances of
potential or actual noncompliance;
• Based on the foregoing compliance assessment and subsequent corrective actions (if any were
necessary), my facility is,to the best of my knowledge and based on reasonable inquiry, currently in
compliance with applicable federal,state,tribal, and local environmental requirements.
I agree that EPA's decision whether to accept participants into or remove them from the National Environmental
Achievement Track is wholly discretionary, and I waive any right that may exist under any law to challenge EPA's
acceptance or removal decision.
I am the senior facility manager and fully authorized to execute this statement on behalf of the corporation or
other legal entity whose facility is applying to this program.
Signature/Date
Printed Name/Title George Henson,Vice President-Mill Division
Facility Name Canton Mill
Facility Street Address 175 Main Street
Facility ID Numbers NCD 003148889
Page 13 Application for the National Environmental Achievement Dwck
OMB Approved No.2010-0032

The National Environmental Performance Track is a U.S. Environmental Protection
Agency program. Please direct inquiries to 1-888-339-PTRK or e-mail
[e-mail]. Mail completed applications to:
The Performance Track Information Center
c/o Industrial Economics Incorporated
2067 Massachusetts Avenue
Cambridge, MA 02140
Page 14 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

National Environmental Achievement Track
Environmental Requirements Checklist
The following Checklist is provided to assist facilities in answering Section A, Tell us about your
facility, " Question 6. The Checklist is given to help facilities identify the major federal, state,
tribal, and local environmental requirements applicable at their facilities. The Checklist is not
intended to be an exhaustive list of all environmental requirements that may be applicable at an
individual facility.
If you use this Checklist and choose to submit it with your application, fill in your facility
information below and enclose the completed Checklist with your application (see instructions).
Facility Name: Canton Pulp &Paper Mill
Facility Location: Canton, NC
Facility ID Number(s): NCDO0314889
(attach additional sheets if necessmy)
Check All
Air Pollution Regulations That Apply
1. National Emission Standards for Hazardous Air Pollutants (40 CFR 61)
2. Permits and Registration of Air Pollution Sources
3. General Emission Standards,Prohibitions and Restrictions
4. Control of Incinerators ❑
5. Process Industry Emission Standards
6. Control of Fuel Burning Equipment
7. Control of VOCs
8. Sampling, Testing and Reporting
9. Visible Emissions Standards
10. Control of Fugitive Dust
11. Toxic Air Pollutants Control
12. Vehicle Emissions Inspections and Testing ❑
Other Federal, State, Tribal or Local Air Pollution Regulations Not Listed Above (identify)
13. ❑
14. ❑
Page AI—Environmental Requirements Checklist Application for the National Environmental Achievement Track

Hazardous Waste Management Regulations
1. Identification and Listing of Hazardous Waste (40 CFR 261)
- Characteristic Waste
- Listed Waste
2. Standards Applicable to Generators of Hazardous Waste (40 CFR 261)
- Manifesting
- Pre-transport requirements
- Record keeping/reporting
3. Standards Applicable to Transporters of Hazardous Waste (40 CFR 262) ❑
- Transfer facility requirements ❑
- Manifest system and record-keeping ❑
- Hazardous waste discharges ❑
4. Standards for Owners and Operators of TSD Facilities (40 CFR 264) ❑
- General facility standards ❑
- Preparedness and prevention ❑
- Contingency plan and emergency procedures ❑
- Manifest system, record keeping and reporting ❑
- Groundwater protection ❑
- Financial requirements ❑
- Use and management of containers ❑
- Tanks ❑
Waste piles ❑
- Land treatment ❑
Incinerators ❑
5. Interim Status Standards for TSD Owners and Operators (40 CFR 265) ❑
6. Interim Standards for Owners and Operators of New Hazardous Waste
Land Disposal Facilities (40 CFR 267) ❑
7. Administered Permit Program (Part B) (40 CFR 270) ❑
Other Federal, State, Tribal or Local Hazardous Waste Management Regulations Not
Listed Above (identify)
8. ❑
9. ❑
Page A 2—Environmental Requirements Checklist Application for the National Environmental Achievement Track '

Hazardous Materials Management
1. Control of Pollution by Oil and Hazardous Substances (33 CFR 153)
2. Designation of Reportable Quantities and Notification of Hazardous
Materials Spill (40 CFR 302)
3. Hazardous Materials Transportation Regulations (49 CFR 172-173)
4. Worker Right-to-Know Regulations (29 CFR 1910.1200)
5. Community Right-to-Know Regulations (40 CFR 350-372)
Other Federal, State, Tribal or Local Hazardous Materials Management Regulations Not
Listed Above (identify)
6. ❑
7. ❑
Water Pollution Control Requirements
1. ' Oil Spill Prevention Control and Countermeasures (SPCC) (40 CFR 112)
2. Designation of Hazardous Substances (40 CFR 116)
3. Determination of Reportable Quantities for Hazardous Substances
4. NPDES Permit Requirements (40 CFR 122)
5. Toxic Pollutant Effluent Standards(40 CFR 129)
6. General Pretreatment Regulations for Existing and New Sources ❑
7. Organic Chemicals Manufacturing Point Source Effluent Guidelines
and Standards ❑
8. Inorganic Chemicals Manufacturing Point Source Effluent Guidelines
and Standards ❑
9. Plastics and Synthetics Point Source Effluent Guidelines and Standards
(40 CFR 416) ❑
10. Water Quality Standards
11. Effluent Limitations for Direct Dischargers
12. Permit Monitoring/Reporting Requirements
13. Classifications and Certifications of Operators and Superintendents of
Industrial Wastewater Plants
14. Collection,Handling,Processing of Sewage Sludge
15. Oil Discharge Containment, Control and Cleanup ❑
16. Standards Applicable to Indirect Discharges (Pretreatment) ❑
Other Federal, State, Tribal or Local Water Pollution Control Regulations Not Listed
Above (identify)
17. ❑
18. ❑
Page A3—Environments]Requirements Checklist Application for the National Environmental Achievement Track

Drinking Water Regulations
1. Underground Injection and Control Regulations, Criteria and Standards ❑
(40 CFR 144, 146)
2. National Primary Drinking Water Standards (40 CFR 141) ❑
3. Community Water Systems, Monitoring and Reporting Requirements ❑
(40 CFR 141)
4. Permit Requirements for Appropriation/Use of Water from Surface or
Subsurface Sources ❑
5. Underground Injection Control Requirements ❑
6. Monitoring, Reporting and Record Keeping Requirements for Community ❑
Water Systems
Other Federal, State,Tribal or Local Drinking Water Regulations Not Listed Above
(identify)
7. ❑
8. ❑
Toxic Substances
1. Manufacture and Import of Chemicals, Record Keeping and Reporting ❑
2. Import and Export of Chemicals (40 CFR 707) ❑
3. Chemical Substances Inventory Reporting Requirements (40 CFR 710) ❑
4. Chemical Information Rules (40 CFR 172) ❑
5. Health and Safety Data Reporting (40 CFR 716)
6. Pre-Manufacture Notifications (40 CFR 720) ❑
7. PCB Distribution Use, Storage and Disposal (40 CFR 761) ❑
8. Regulations on Use of Fully Halogenated Chlorofluoroalkanes (40 CFR 762) ❑
9. Storage and Disposal of Waste Material Containing TCDD (40 CFR 775) ❑
Other Federal, State, Tribal or Local Toxic Substances Regulations Not Listed Above
(identify)
10. ❑
11. ❑
Page A 4—Environmental Requirements Checklist Application for the National Environmental Achievement Track

Pesticide Regulations
1. FIFRA Pesticide Use Classification (40 CFR 162) ❑
2. Procedures for Disposal and Storage of Pesticides and Containers (40 CFR 165) ❑
3. Certification of Pesticide Applications (40 CFR 171) ❑
4. Pesticide Licensing Requirements ❑
5. Labeling of Pesticides ❑
6. Pesticide Sales, Permits, Records, Application and Disposal Requirements ❑
7. Disposal of Pesticide Containers ❑
8. Restricted Use and Prohibited Pesticides ❑
Other Federal, State, Tribal or Local Pesticides Regulations Not listed Above (identify)
9. ❑
10. ❑
Environmental Clean-Up,Restoration, Corrective Action
1. Comprehensive Environmental Response, Compensation and Liability Act (Superfund)
(identify)
El
Ej
2. RXRA Corrective Action (identify)
Other Federal, State, Tribal or Local Environmental Clean-up, Restoration, Corrective
Action Regulations Not Listed Above (identify)
3. ❑
4. ❑
Page A 5—Environmental Requirements Checklist Application for the National Environmental Achievement Track

P17 :40 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P61/02
PW
PN ,�BLUE RIDGE
PAPER pRODUC75 INC,
FACSIMILE TRANSMITTAL SHEET
TO: FROM: •
e t i�y itie s 3-1-- I� I .* e< e
COMPANY: DATE:
Nc �a1v2 11/s/00
FAX NUMBER: TOTAL NO.OF PAGES INCLUDING COVER:
asr _ � sa
PHONE NUMBER: SENDER'S FAX NUMBER:
[phone]
RE: SENDER'S PHONE NUMBER:
(828) 646- -a'o�C6
❑URGENT 11<OR REVIEW ❑PLEASE COMMENT ❑PLEASE REPLY ❑PLEASE RECYCLE
NOTES/,C/O�MJMENT)S: p 1 L
I/ CCte Ce GC �m]/��l "U TD L(ptt/
ria
NN`'6 200J
`` IC,;ECTI
"The material contained in this communication is intended only for the use of the addressee. It
may contain information that is confidential, proprietary, attorney privileged, and exempt from
disclosure under applicable law. If the reader of this communication is not the intended recipient,
you are hereby notified that any dissemination,distribution or duplication of this communication
is prohibited. If you have received this communication in error, please notify us immediately by
telephone and return,by mail,the original message to us. Thank you."
175 Main Street C P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

0 17:40 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P02/02
BLUE RIDGE
PAPER PRODUCTS INC.
November 3, 2000
Mr. Keith Haynes
North Carolina Department of Environment
And Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,North Carolina 28801
Re: Release Notification,NPDES Permit NC0000272
419 Paper Machine Lubricating Oil Release, October 30-31, 2000
Dear Mr.Haynes: .
Blue Ridge Paper Products,Inc. is providing written notification as a follow-up to Jim
CTiauque's telephone call to you on October 31,2000,at approximately 11:40 AM,
concerning a lubricating oil release at the Number 19 Paper Machine.
At approximately 6:45 AM on Tuesday,October 31, 2000,maintenance personnel
noticed a low level alarm associated with the main lubrication system day tank for the
Number 19 Paper Machine. Upon investigation, it was found that the water trap drain
valve to the tank was open allowing oil to flow from the tank into an adjacent u-drain
leading to the mill sewer system. The valve was immediately closed, stopping the
release. It is estimated that the drain had been opened at approximately 8:00-8:30 PM on
Monday, October 30,2000.
Based on the flow rate and the total capacity ofthe processing equipment,the total
release was estimated to be approximately 800 gallons. There was no oil observed
released to the Pigeon River and no impact on Wastewater Treatment Plant operations.
The cause of the release remains under investigation, however, due to the suspicious
nature of the events, the Town of Canton Police have been involved with the
investigation.
If you have questions regarding this incident, please call Tim Giauque at$28-646-2028.
Sincerely,
*aeu
que 7
Copy: Denic Brown
Bob Williams
Tilchaynes113
175 Main Street • P.O. Box 4000
Canton,North Carolina 28716 • Phone_828-646-2000
Raising Your Expectations

NORTH CAROLINA DEPARTMENT OF
�••L ENVIRONMENT AND NATURAL RESOURCES
tNCDEMR DIVISION OF WATER QUALITY
= s ASHEVILLE REGIONAL OFFICE
,'•� October 10, 2000
.JA�1E;�$rN1Y(F�Y JRq
b�i'ExtroR ' 198
` T MR. JOHN PRYATELY
BLUE RIDGE PAPER PRODUCTS WWTP LAB
P.O. BOX 4000
ILL'HOLMAN• •+� CANTON, NC 28716
ECI;EE/TART
Dear Mr. Pryately:
Tie-rkRc '�+*"+L r°EEYYVs s' Your letter, received October 9 2000 concerning corrective actions for
b3RECj'yO � ' r r • g Your
y analytical procedures has been reviewed. The quality control measures taken
in reference to the deficiencies cited in the September 12, 2000 inspection
report are acceptable. We have also reviewed the information you provided for
the ammonia nitrogen comparative results performed by your laboratory. The
results are acceptable for the requirements of your laboratory certification.
r
This report does not attempt to comprehensively address all
£«� ' certification requirements prescribed in the North Carolina Administrative
Code (15A NCAC 2H .0800) , promulgated methods, and .applicable Code of Federal
Regulations (40 CFR Part 136) . It is the responsibility of the certified
laboratory to address any required changes in Wastewater/Groundwater
}gsg• Vyr; ;SCy Laboratory Certification application information, and to correct the
� a �'i• � r . ` Laboratory Standard Operating Procedures and the Laboratory Quality Assurance
Manual when requirements of the above cited codes are not in compliance.
If a future inspection should reveal that the deficiencies cited in
11 S ' i .A_r the inspection report were not corrected, enforcement actions will be
recommended in accordance with 15A NCAC 2H .0800.
A. y..
"�- Thank you again for your cooperation during the inspection. Contact us
at 828-251-6208 ext. 285 if you have any questions or need additional
..� ,t • , ��;, � information regarding our requirements.
Sincerely,
Gary Francies
Laboratory Section
155;rye.aaTffi°>�"
-s-
b
3s 1. cc: James W. Meyer
- -, Marilyn Deaver
_ ce
k .5
y P INTERCHANGE BUILDING, S9 WOODFIN PLACE, ASHEVILLE, NORTH CAROLINA 2880 1-24 1 4
y b PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST-CONSUMER PAPER
85$4�.S.iS�c=936Se R�r°so .

DIVISION oF WATER QUA urY .
Cberahl,Labar.I.,Report I War,,Quality Lab Number YW7226
W❑ SAMPLETYPE Date Rcocired: 9/6/2000
COUNTY HAYWOOD PRIORITY Time Received: IODDAM
RISER BASIN: ❑ AMBIENT O QA STREAM X� EFFLUENT Received By : IIMW
REFORTTO : ARO Regional Ofice ❑ COMPLIANCE O CfiAIN OF.CUSTODY I LAKE INFLUENT (���/�,/[j/—� /� I S
Other EMERGENCY VISIT ID ESTUARY Da.Released: 1 All
COLLECTORS) : HAYNES O Date Reposed: 30/5/2000
Estimated DOD Range: Starion Locmlon:BLUE RIDGE PAPER
Seed: Chlorinated: Remarks:
Stan..9 Dale Begin(j'y/mMdd) Data End(yy/mm/dd) Time Begin Time End Depth•DM,ED,DBM Value Type A,II,L Composite-T,S.B Sample Type
20000830 2300
BOD310 m /L Chlodde940 mg/L NH3 as N 610 m /L Li-Lithium 1132 ti /L
COD Ili t340 m /L Chi a:Tfi 32217 u /L TKN an N 625 m /L Mg-Magnesium 927 an /L
COD Low 335 m /L Chi.:Corr 32209 ug/L NO2 plus NO3 as N 630 m /L Mn-Man time 1055 u L
Coliform:NIF Fecal 31616 /Iw.I Plecaphytin a 32213 u /L P:Total as P 665 m L No.Sodium 929 m L
Coliform:MFTmaI 3I5N /100ml X Color.Tate 80 180 CU. PO4 as P70507 m L ArseniCTotal 1002 <10 u /L
Colirorm:rube Fecal 31615 /100m1 Color.( ill 83 pll= c.u. P:Dissolved as P 666 m /L Se.Selenium 1147 u /L
Colirorm:Fecal Strap 31673 /100ml Color.PH7.682 CU. K-Potassium m L ]JR.Mercury 71900 <0.2 u /L
Residue:Total 500 m /L Cyanide 720 m /L X Cd-Cadmium 1027 <2.0 u L Ba_Barmin u /L
Volatile 505 m L Fluodde951 m /L X Cr-Chromium:Total 1034 <25 u L OrgarrochloneFestickles
Fixed 510MM."g,"L
Formaldehyde 71880 mg/L X Cu-Copper1042 3.8 u /L Or ma hos hone Pesticides
Residue:Suspended 53 Grease and Oils 556 m L X Ni-Nickel 1067 <10 u /L
Volatile 535 Hardness Total 900 m /L X Pb.Lead 1051 <10 a /L Acid Herbicides
Fixed 540 Specific Cord.95 _ .mhos/cm2 X 2:n-Zinc 1092 36 u IL
II403 MBAS 38260 m /L V-Vanadium u /L Base/Neu.al&Acid Eatracrable Or nits �-•
Acidity pll.r,5.01, Phenols 32730 ig/l. A -Silver 1077 . /l. 'TI.11 Daascl Raw
Acidnv to it8,3435mail. Sulfate 945 m /L At.Aluminum 1105 a /L
Alkalinity to till 8.341 Sulfide 745 m L Be.Beryllium 1012 u /L Pur able Organics(VOA bottle re 'd
Alkalinity to IU.54I Brmn Ca-Calcium 916 m L TPH Gasoline Range
TOC68is Tannin&Li in u L Co-Cobalt 1037 u L TPH/BTEX Gasoline Ran V
Turbidirv7fi NTll Hesavalcm Chromium ug/L Fe-Iron 1045 u L Phymplanknor
Coliform Total Tube "/100 mis
O
COMMENTS:
D
�{l0 jp OFF{CE
1UAi.H C'..
ASHE'J 01, R

'\ we•+r.•.•• • •-•ea.✓-r.no rvrcm (Um l)
COUNTY }-laM vljoo ` Lab Number:
c PRIORITY SAMPLE TYPEU r
RIVF3t BASIN Dale Reeeivr•d• Time
/��
REPORT TO AR F50 MRO RRO WaRO WIRO WSRO TS ❑AMBIENT ❑ QA ❑ STREAM EFFLUENT Rec'd bUAW From: Bue sutler Hand Del
BM Ot ❑COMPLIANCE ❑ CHAIN ❑ LAKE Other El INFLUENT DATA ENTRY 0Y•OF CUSTODY CK:
by: Do b Bu ourie Steil, Other ❑EMERGENCY ❑ESTUARY DATE REPORTED:
COLLECTOR(S): f- t 1 r
Estimated BOD Range; 0-5/5-25/25-65/40.130 or 100 plus STATION LOCATION: \��, .� y\
Seed: yea ❑ No❑ Chlorinated: Yee❑ No❑ REMARKS:
LJ
Station ,# Date Begfn lyyyy/mm/dd)I Time Begin I Date End 2 T m ie End Depth DM DB DBM Value Type Composite Sample Type
" A H L T S H C9 G GNXX
1 HODS 310 mg/I Chloride 940 mg/I NH3 as N 610 mg/1 LI-Llthlum 1132 ug/I
2 COD High 340 mgA Chi a: Tri 32217 ug/I TKN as N 625 m9/1 Mg-Magnesium 927 mg/I
3 COD Law 335 me/l Chi a: Corr 32209 ug/I NO2 plus NO3 as N 630 mgA Mn-Manganese 1055 ug/I
4 Collform:MF Fecal 31616 /100m1 Pbeophytln a 32213 ug/I P:Total as P 665 mg/1 Na-Sodium 929 mgA
5 Colllorm:MF Total 31504 /100mi Color:True 80 Pt-Co PO4 as P 70507 mg/1 Arsenic-Total 1002 ug/1
Colllorm:Tube Fecal 31615 /100m1 Color;(pH ) 83 ADMI P:Dissolved as P 666 mg/I Se-Selenium 1147 ug/I
Coiiform:Fecal Strep 31673 /100m1 Color: pH 7.6 82 ADMI Hg-Meteury 71900 ug/1
8 Residue:Total 500 mg/l Cyanide 720 mg/l Cd-Cadmium 1027 USA Organochlorine Pesticidea
Volatile 505 mg/l
9 Fluoride 951 mg/I Cr•ChrommucTood 1034 ugA Otganopluwpiaw Pesticides
10 Fixed 510 mg/I Formaldehyde 71880 mg/l CuC pper1042 a /1 g
11 Realdue:Suspended 530 mg/I Grease and Olie 556 mg/I NI-Nlekei 1067 ug/1 Acid Herbicides
12 Volatile 535 mg/1 Hardness Total 900 mg/I Pb-Lead 1051 ug/I
13 Fixed 540 mg/1 Specific Cool 95 2 Zn-Zinc 1092
_ uMhos/em ug/1 Base/Neutral Extractable Organics
14 pH 403 - units MBAS 38260 mg/I
15 Acidity to PH 4.5 436 Actd Extractable Organics
mg/1 Phenols 32730 ug/1 A Ilver 1077
ug/1
16 Acidity to pH 8.3 435 mg/1 Sulfate 9q5 m9A AI-Aluminum 1105 ug/1 Purgeable Orgenlcs (VOA bottle r¢g'd)
17 Alkalinity to pH 8.3 415 mg/1 Sulfide 745 m9/1 Be-Beryllium 1012 ug/I
18 Alkalinity to pH 4.5 410 mg/1
Ca-Caielum 916 mg/1
..191 1 TOC 680 mgA Ca-Cobalt 1037 ug/I
. . '20 Turbidity 76 NTU Fe-Iron 1045 ug/1 Phymptankton
Sampling Point% Conductance at 25 C Water Tempemmre(C D.O.mgA PH Alkalinity Acidity Air Temperature(C)
pH 83 pH 4.5 pH 4.5 PH 8.3
2 94 10 300 1, 400 1• 02244 431 82243 182242 20
Sallnity% Precipitlon 0n/day) Claud Cover% Wmd Direction(Deg) Stream Flow Severity Turbidity Severity Wind Velocity MAI ¢an Stream Depth it Stream Width it
480 45 32 36 1351 1350 35 61 4
y- NO ( g -7Lo L.4b _ ? I ess.e C.n cn1ti 2< CO 1Vf 11 1 I 11
eV C "� (1U44 N I 't' ✓t G S QRc, fU n
%hr1 .. IC nU U
DMI/Revlsed 10/13t" —� `�

04-13-00 21 : 64 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P01/04
Making(q� r nark For you.
BLUE RIDGE PAPER PRODUCTS INC.
FACSIMILE TRANSMITTAL SWEET
TO: ` 1 FROM:
k e kti )ec-r 1 c- 24Z vZ)r%
COMPANY; DATE:
(- r 0 rJ
FAX NUMBER: TOTAL NO.OF PAGES INCLUDING COVER,
a5 ~ ��s
PHONE NUMBER: SENDER' FAX NUMBER:
[phone]
RE: SENDER'S PHONE NUMBER:
XURGENT
(828) 646- 31
❑FOR REVIEW ❑PLEASE COMMENT ❑PLEASE REPLY Cl PLEASE RECYCLE
NOTES/COMMENTS:
4
HEVIu t REGIONAL OFFICE
"The material contained in this Communication is intended only for the use of the addressee. It
may contain information that is confidential, proprietary, attorney privileged, and exempt from
disclosure under applicable law. If the reader of this communication is not the intended recipient,
you are hereby notified that any dissemination, distribution or duplication of this communication
is prohibited. If you have received this communication in error,please notify us immediately by
telephone and return,by mail,the original message to us. Thank you."
BLUE RIDGE PAPER PRODUCTS INC., 175 MAIN STREET, CANTON, NC 2371E

04-13-00 21 : 05 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P02/04
Making ur mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
f ebruary 23,2000
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfm Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products, Inc.Canton Mill
Balanced and Indigenous Species Study Plan
Dear Mr. Westall:
Attached is the Balanced and Indigenous Species Study Plan required by Part III, Section M. of
the Canton Mill's NPDES permit. This study is submitted for approval by the Division of Water
Quality and is designed to comply with 40 CFR 125 Subpart H.
We are in the process of planning this study and look forward to receiving the Division's
approval in the near future. If you have any questions in the meantime,please call me at(828)
646-2033 or Derric Brown at(828)646-2318.
Sincerely,
Bob Williams
Director-Environmental,Health and Safety
Attachment
175 Main Street • P.O.60x 4000 • Canton,North Carolina 28716 • 8284;46.2000

04-13-00 21 : 05 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P03/04
Canton bill Balanced and Indigenous Species Study Plan
Blue Ridge Paper Products,Inc.
Blue Ridge Paper Products, Inc. (BRPP) is required to submit a thermal variance report for their
Canton Mill (the Mill)that is consistent with the conditions set forth in 40 CFR 125, Subpart H.
This study plan describes the tasks that will be conducted as part of the required demonstration.
The study will consist of four basic elements:
- Selection of RIS
- Thermal Model
- Biological Study
- Preparation of 316a demonstration
Task 1 Selection of Representative hn ortant Species S)
Typically 5-10 fish species are chosen to represent a range of thermal tolerances,trophic levels,
societal values (i.e., commercially or recreationally important species), and as well as potential to
be a nuisance species. It is anticipated that one or two thermally sensitive species will be
selected,along with one species from each trophic level,one or two recreationally important
species,and one species that has the potential to become a nuisance species. Selections will be
based on the life history characteristics of the fishes inhabiting the Pigeon River. No threatened
or endangered species will be selected because none inhabit the Pigeon River.
Task 2 Prepare and Calibrate Thermal Model
In order to predict water temperatures under a variety of stream flow and thermal input
conditions, a temperature model will be constructed. Measured river temperatures for the period
1994-2000 will be used to construct the model. The model will be field verified and adjusted as
necessary.
Task 3 Field Biological Study
To verify the presence of a balanced,indigenous community, a field study will be conducted
twice(mid July and late August)during 2000. Fish and macroinvertebrates will be collected
from 11 mainstem and three tributary locations:
RM Location
64.5 Upstream of mill
63 FibervilIe
61 D.O. augmentation station
59 Upstream of Clyde

04-13-00 21 : 65 BLUE RIDGE PAPER PRODUCTS ID=8286465892 PO4/04
Carron Mill Balanced and Indigenous Species Sudv Plan Contimred
Page 2
RM Location
55.5 Downstream of Clyde
54.5 Downstream of Waynesville WWTP
52.3 Old Rt 209
48 2 Ferguson bridge
42.6 Hepco
24.7 Waterville
19.3 Groundhog Creek
trio Richland Creek
trib Jonathan Creek
trib Fines Creek
All collections will be made following standard NCDEM methodologies as has been the case
during previous assessments of the Pigeon River(EA 1988, 1996).
Task 4 Prepare 316(a) Demonstration
Mill operational data,thermal modeling results,and data from the field biology study will be
compiled into a report consistent with the guidance set forth in 40 CFR 125, Subpart H. The
report will determine whether a balanced indigenous community is present or, if not,would the
establishment of such a community be prevented by continuation of the thermal variance. This
report will be submitted by 1 June 2001.
References
EA Engineering, Science, and Technology. 1988. Synoptic survey ofphysical and biological
condition of the Pigeon River in the vicinity of Champion International's Canton Mill. EA.
Loveton, MD.
EA Engineering, Science, and Technology. 1996. A study of the aquatic resources and water
quality of the Pigeon River. EA. Deerfreld IL.

r1? + ✓ NORTH CAROLINA DEPARTMENT OF
j ENVIRONMENT AND NATURAL RESOURCES
k ' � r DIVISION OF WATER QUALITY
11 Wig . IA ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
®ER January 5, 2000
ryl`Es�-Rt;Y4F�f` I'i y •yZ�."�`
F
(jf':IAMEs e.NUNr.iR:'� Mr. D2rr1C Brown
�•1cOVERN0 :>* Blue Ridge Paper Products
=
is Post Office Box 4000
'
Canton, North Carolina 28716
6 �}
FVVAYNE�,I�mEVIT,T.'('�'Y1 Subject : Compliance Biomonitoring
b
s ST Y Inspection
Canton Mill WWTP
* ?k t NPDES Permit Number NC0000272
wood County
{�R1iS STEVEN
Dear Mr. Brown:
- _-% - Please find enclosed a copy of the Inspection Report
for the Biomonitoring Inspection which was conducted at Blue
Ridge Paper Products on December 7 and 10, 1999 .
, ? ^ The samples were collected/split for use in a 3-Brood
Ceriodaphnia dubia full range toxicity test. The test
�i
ice, I
�� ; results indicated a chronic value of >100% which is above
the 87% whole effluent toxicity limit for the facility.
Further details concerning this test are included on the
a Report.
It should be noted that an ambient sample of the Pigeon
River was also collected for use in a 3-Brood Ceriodaphnia
r' u dubia pass/fail toxicity test. The result of this test was
recorded as a "Pass" . Further details on this test are also
{ < � included in the Report.
any If you have any questions concerning this matter,
please do not hesitate to contact me at 251-6208 .
a
s arcu. L��
rnsA� rs_, Sincerel
D. Keith Ha s
h
Environmental Specialist
1 .ri a
xc: Jimmie Overton
ICE
c
M•`'.!^ �N'a INTERCHANGE EIUILDING, 58 WOODFIN PLACE, ASH EVILLE. NC 2880I-2414
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST-CONSUMER PAPER

United States Environmental Protection Agency Form Approved
Washington, D.C. 20460 OMB No. 2040-0003
PA NPDES Compliance Inspection Report Approval Expires 7-31-85
Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
I IN I 2 3 NC0000272 Ill 12 99/12/07 17 18 LJ 19 IS l 2012 u t� Remarks
I I I I I I I I I I I I I I I I I I I I I I I I I I I
r' Reserved Facility Evaluation Rating BI QA Reserved
67 LLB 69 70I_1 71 on 72 L 73 �II174 75 LLLL—LU 80
Section B:FacilityDate Name and Location of Facility Inspected Entry Time Permit Effective Date
Blue Ridge Paper Products 11:00 am 970101
Canton Plant
Canton, Haywood County Exit Time/Date Permit Expiration Date
011130
Name(s)of On-Site Representative(s)/Fitle(s) Phone No(s)
Derric Brown - Environ. Supervisor 828-646-2318
John Pryately- Lab Supervisor
Name,Address of Responsible Official Title
Mr. George Henson Vice-President/Operations Mgr.
PO Box
Canton, NC 28716 Phone No. Contacted
No
Section C:Areas Evaluated During Inspection CODES S-Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated/Not applicable
N Permit N Flow Measurement N Pretreatment
#Soth"AQUATIC
perations & Maintenance
N Records/Reports N Laboratory N Compliance Schedules udge Disposal
N Facility Site Review N Effluent/Receiving Waters N Self-Monitoring Program TOX
Section D:Summary of Findings/Comments (Attach additional sheets if necessary)
On December 8, 1999, .Division Aquatic Toxicology personnel initiated a 3-brood Ceriodaphnia dubia full-range toxicology test using composite samples of
:he subject facility's whole effluent. The samples were collected on December 6-7 and 9-10, 1999 by the facility and were split by Asheville Regional OfficE
staff.
Test concentrations were 50, 75, 87, 93.5, and 100% sample. The test resulted in a chronic value of>100%, which is above the 87% limit for the facility.
Specifically, the control exhibited 100% survival with 23.4 neonates per control organism while the test treatment survival was 100% in the 100%treatment
Nith treatment mean reproduction being 22.2% in the 100% treatment. Results of additional water quality parameter measurements follow: First Sample; p
7.95 SU, Conductivity -2600 micromhos/cm, Second Sample; pH -8.39 SU, Conductivity -2560 micromhos/cm. The result of the test Indicates that the
affluent would not be predicted to have impacts on the receiving stream.
On December 8, 1999 Division Aquatic Toxicology personnel also initiated a 3-Brood Ceriodaphnia dubia pass/fail test on an ambient sample of the Pigeon
River above Hlue Ridge Paper. The samples were collected on December 7 and 10, 1999. The test resulted in a Pass. Specifically, the control exhibited
100% survival with 24.0 neonates per control organism while the test treatment survival was 100% with treatment mean reproduction being 22.7 neonates
oer lest organism. Other measured water quality parameters were as follows: First sample: pH=6.78 SU, conductivity=28 micromhos/cm; second sample:
off=6.88 SU, conductivity=32.9 micromhos/cm.
Name(s)and Signatu e( of Inspector(s) Agency/Office/Telephone Date
Keith Haynes
DWQ/ARO 828-251-6208 cloC)
Signature evi er" Agency/Office Date
DWQ/ARO 828-251-6208 QU
Regulatory Office Use Only
Action Taken Date Compliance Status
Noncompliance
Compliance

Ur PIVVIHUNMENTAL MANAGEMENT WATER QUALITY FIELD-LAB FORM (DM1) Fo0 r Lab Use ONLY
COUNTY Lab Number: , 0/�-d l7�
PRIORITY SAMPLE TYPE �j
RIVER BASIN Date R¢eeived: q '�/ d C', me: ,l Olt
REPORT TO:ARO FRO MRO RHO WaRO WIRO WSRO TS EJAMBIENT ❑ QA ❑ STREAM ❑ EFFLUENT Rec'd b �'
AT BM y: I From: Bus-Cour(er and Del
C'
Other COMPLIANCE ❑ CHAIN ❑ LAKE El INFLUENT DATA ENTRY BY: 4—
OF CUSTODY c; CK•
Shipped by: Bus Can't. ta(f. Other ❑EMERGENCY ❑ESTUARY DATE REPORTED: / -{a -(I C)
COLLECTOR(S): �� t�
Estimated ROD Range;0-5/5-25/25-65/40.130 or 100 plus t STATION LOCATION:
Seed: Yes El No El Chlorinated.- Yee❑ No yak REMARKS:
Station /- Date Beginn (yy/mm/dd)I Time Re in Date End
Q �p 9 Time End Depth DM DB DBM Value Type CompositeI Sample Type
A H L T S B G GNXX
I BOD5 320 S+ m9/1 Chloride 940
mg/1 NH3 as N 610 mg/1 LI-Llthlum 1132 ag/1
2COD High 340 mull CFI m Tit 32217 USA 1"as N 625 0 J
mull Mg-Magnesium 927 mg/I
3 COD Low 335 mg/I
Chi a: Cori 32209 ug/1 NO2 plus NOS as N 630 m
4 Coli(orm:MF Fecal 31616 /100m1 g/I a odium 929e.e 1055 ug/I
Pheophytin a 32213 ug/1 P.Total as P 665 i
mg/] NaSodlum 929 mg/1
Coll(orm:MF Total 31504
5 /100mI Color.True 80 Pt•Co PO4 as P 70507 mgA Arsenic.-Total 1002 ug/I
6 Coli(orm:Tube Fecal 31615 /loom] Color:(pH ) 83 ADMI P:Dissolved as P 666 mil/I 9/ Se-Sefenlum 1147 ug/]
Callform:Fecal Strap 31673 /100m1
7 Color. PH 7.6 82 ADM] . Hg•Mercury 71900 URA
8 Residue:Total 500 /6,0 o m9/1 Cyanide 720 mg/IjFe-lran
admium 102J.gA
USA Grgauochlorine Pesticides
9 Volatile SOS mull fluoride 951 mg/I ppe,10 Tofa O:ganopl;ospboms Pestcides
10 Fixed 530 mull Formaldehyde 71880 mg/1
PPer 3067
11 esldue;Suspended 530 <3 mg/l Grease and Oils 556 mullckef 1067
a Avid Herbicides
12 Volatile 535 mg/1 Hardness Total 900 mg/1ad 1053
13 Fixed 540 mg/l Specific Cond.95 uMho./cm2c 1092 Base/Neutral Extractable Organics
14 PH 403 units MBAS 38260m9/I15 Acidity to PH 4.5 436 mg/] Phenols 32730 Aeld Extractable Organics
u9/Ilver 307716 Acidity to PH 8.3 I mg/I Sulfate 945 mullmina. 110 Forgeable Organics (VOA bottle reg'd)
1] Alkalinity to pH 9.3 415' mg/I Sulfide 745 mg/1ryfi]um 101Alkalinity to pif 4.5 410 mg/1Qalcium 9161TOC 680 ray/] - obalt 3037'jo Turbidity 76 NTU n 1045
Phymplankton
Sampling Pofni% Conducts.¢.at 25 C Water Temperature(C) D.O.mg" PH Alkalinity Acidity Air Temperature(C)
PH 83 PH 4.5 pH 4.5
PH 8.3
2 94 10 300 . 400 8224i 431 82243
Salinity% Pre-Ildlon ONday) Cloud Cover% WhVI Dfrectlon 82242 20
deg) Stream Flow Severity Turbidity Sederity Wind Velocity M/H ¢an Stream Depth it Stream Width f,
l
480 45 32 36
1351 3350 35 4 q _
zC,_:
DMI/H v] d jwlU, 3

DIVISION OF ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD-LAB FORM (DM1) O For Lab Use ONLYnn
COUNTY Lab Number: /�-o D N?7 7
PRIORITY SAMPLE TYPE sp
RIVER BASIN
Date Received: C) '.�/'-V O Time: .7- Ulf
AT REPORT TO:ARO FRO MRO RRO WaRO WIRO WSRO TS ❑AMBIENT ❑ QA ❑STREAM ❑ EFFLUENT Reed by: « ( F •B s-C rie d 0
BM
Other ❑COMPLIANCE ❑ CHAIN ❑ LAKE ❑ INFLUENT DATA ENTRY BY: 4— CK:
OF CUSTODY �y
Shipped by: Bus C��r.$tolt, Other ❑EMERGENCY ❑ESTUARY DATE REPORTED: / -1,2 -0 C)
Estimated BOD Range;0-5/5-25/2555/40.130 or 100 plea STATION LOCATION:
Seed: Yee ❑ No❑ Chlorinated: Yee❑ No tat REMARKS:
Station # Date r,Begin
(Yy/mm/dd) Time Begin Date Enad 4 Tlme End Depth DM DB DBM Value Typ¢ Composite Sample Type
OO - A H L T S B G GNXX
1 BODS 310 S y mg/1 Chloride 940 mg/1 NHS as N 610 mall LI•tlthlum 1132 ug/1
2COD High 340 mall Chi a:Trl 32217 USA THN es N 625 m9A Mg-Magneslum 927 mg/I
3 COD Lora MF mg/1 Chi a: Corr 32209 ug/I NO2 plus NOS ae N 630 mall Mn-Manganese 1055 ugh
4 Coillorm:MF Fecal 31616 /100ml Pheophytln a 32213 ug/l P:Total as P 665 mall NaSodlum 929 mg/i
5 Cc] arm:MF Total 31504 /100m1 Color:True 80 Pt-Co PO4 as P 70507 mg/I Arsenle Toral 1002 ug/I
6 Colliorm:Tube Fecal 31615, /100ml Color:(pH ) 83 ADMI P:Dissolved as P 666 mall Se-Selenium 1147 ug/I
7 Cultism:Fecal Strop 31673 /100m1 Color: pH 7.6 82 ADMI He-Mercury,71900 USA
B Residue:Total 500 (�0(J mg/I Cyanide 720 mg/I Cd-Cdmlum 1027 ug/l Organ0chl0rine Pesticides
9 Volatile 505 mg/1 Fluoride 951 mg/l Cr4Chramium:Tom11034 USA Oman phosplrotus Pestk:Wea
10 Fixed 510 mg/1 Formaldehyde 71880 mg/I CuCoptxn 3042 ug/I
11 esldue:Suspended 530 mg/I Grease and Oils 556 mall NI-Nlckel 1067 u
d 9n Acid Herbicides
12 Volatile 535 mg/I Hardness Teta1900 men Pb-Lead 1051 ugA
13 Fixed 540 mg/1 Specific Cond.95 2 Zn-Zino 1092 USA umhos/cm 9 Base/Neutral Extractable Organics
14 PH 403 units MBAS 38260 mg/1 Acid Extractable O rgenlcs
15 Acidity to pit 4.5 436 mall Phenols 32730 call Ag liver 1077
call
16 Acidity to PH 8.3 435 melt Sulfate 945 TO AI-Aluminum 1105 call Purgeable Organics (VOA bottle roe d)
17 Alkalinity to pH 8.3 415' mall Sulfide 745 mg/I Be-Beryllium 1012 ug/1
._ _'18 Alkalinity to pH 4.5 410 mg/1 I [)Q Ca-Calcium 916 mg/1
19 70C 680 mall Ca-Cobalt 1037 call
'.1'o Turbidity 76 NIU Fe-Iron 1045 ugA y p nkton
Sampling Point% Conductance at 25 C Water Temperature D.O.mg/I PH Alkalinity Ac LlAh Tempe lure( )
PH 8.3 PH 4.5 pH 4.5 pH .3
2 94 10 300 400 s 82294 431 82243 82242 VIATER T UrA (2 CofF(CE
Salinlly% Preetpitlon ONdny) Cloud Cover% Wind Direction p)¢g) Stream Flow Severity Turbidity Severity Wind Velocity M/H ff tre5m'Depth-IL SWam Width it
980 45 32 36 1351 1350 35 64 4
DMI/Revlsed 10/66 -

BLUE RIDGE FSt'j'EVEI
200�
PAPER PRODUCTS INC.
YECSeptember 20, 2000 ONAL OFFICE ,
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: Spill/Release Notification,NPDES Permit NC0000272
#20 Machine Lubricating Oil Spill, September 18, 2000
Dear Mr. Haynes:
Blue Ridge Paper Products,Inc. is providing written notification as a follow-up to Daryl Whitt's
telephone call to you on September 19, 2000 at approximately 4:40 PM concerning the
lubricating oil spill at the No. 20 Paper Machine. Please find the enclosed Spill Release
Notification Form.
At approximately 12:00 PM on Monday, September 18, 2000,maintenance personnel noticed an
over-flow of lubricating oil from one of the oil sumps under the No. 20 Paper Machine flowing
into the U-drain, which drains to the wastewater treatment plant(WTP). Upon investigation, it
was found that at some time over the weekend the coupling between the motor and the sump
pump had slipped loose and disconnected. This resulted in the pump not operating, even though
the motor was running, as indicated on the control panel. This was immediately repaired. The
pump and motor was last inspected on Friday afternoon, September 15, 2000. At that time the
pump was connected and working properly.
Initially, and as reported on the telephone yesterday, it was indicated that the total amount of oil
released to the WTP was approximately 800 gallons. This was the total amount added to refill
the lubricating oil reservoir on the machine. However, further investigation determined that
maintenance personnel had observed that the lubricating oil reservoir was low last Friday,prior
to the spill, and would require refilling this week. The estimated volume of oil actually lost to
the WTP was between 250 and 300 gallons. There was no observed impact of this spill on
operations at the WTP and no indication of any impact to the effluent to the Pigeon River.
If you would like additional information regarding this incident, please call me at 646-6814.
Sincerely,
D WIVVU tt P.E. ames A:Giaque
Senior Environmental Engineer Principal Enviro'nme tal Engineer
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

-UE RIDGE
P/.PEq pgOOV[LE INC.
Cc: Derric Brown
Melanie Hagar

NOTIFICATION REPORT FOR SPILL/RELEASE
CANTON MILL
175 MAIN STREET/P.O.BOX 4000
CANTON,NC 28716
Name of Chemical: Light Lubricating Oil
Is Substance an Extremely Hazardous Substance ❑ YES L✓1 NO
Caller's Name &Position: Daryl Whitt,Sr. Environmental Engineer
Media into which release occurred: ❑ Air 0 Water ❑ Land
Quantity Released: (give reasonable estimate if known or that RQ may have exceeded,and will
call back as soon as possible--do not delay reporting) 250 to 300 gallons
Date,start and stop of release : Start-after Friday afternoon,9/15/2000;Stopped around noon
9/18/2000
Cause and source of release :The coupling between the motor and sump pump slipped and
disconnected resulting in the pump not working even though the motor was operating as
indicated on the control panel. The oil overflowed the sump into the U-drain to the sewer.
Action taken to respond to release and status of actions :The coupling was reconnected,
stopping the overflow. No signs of oil were seen at the WTP
Other Notification:
National Response Center
Date: Time: Report No.
Petty Officer Name :

NCDEHNR-Asheville or NC Emergency Response-Raleigh
Date: September 18,2000 Time: Approximately 4:40 PM
Contact: Keith Haynes
Local Emergency Planning Committee
Date: Time
Contact:
Western North Carolina Regional Air Pollution Control Agency
Date: Time
Contact:
Whether any injuries occurred: ❑ YES El NO
If yes,provide detail:
Name and telephone number of person to contact for further information:
Daryl Whitt, [phone]
Action taken for clean-up:
Does release require written notification under Section 204 of Emergency Planning and
Community Right to Know Act(Title III SARA): ❑ YES NO

331330 1V 01938 3'
N01133S A801tl NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
yy��{{yy''I� e ! J39 CUUU DIVISION OF WATER QUALITY
tCDENIt
y p tember 12, 2000 U
na
198
L, � OOOZ
'JAME9 B. HUNT.JR: Mr. John J. Pryately �L'
r °YE""°R Blue Ridge Paper Products Inc.
r - LABORATJnr SECTION
P.O. Box4000 ASNEw--
uE ,
L OFFICE Canton NC 28716
=V: 1, '
y p_SECRE+Ayr SUBJECT: Laboratory Certification Maintenance Inspection
r�
,�•µ Dear Mr. Pryately:
c, KERR.T�TT6�V�,
°'"E�`°"' Enclosed is a report for the inspection performed on August 30, 2000
n rkt 4 '�
by Mr. Gary W. Francies. A response is not required if there were no
deficiencies cited. A response is not required for comments or
r recommendations unless specifically requested. We appreciate the fine job
you and your staff are doing. As a certification requirement, your laboratory
must continue to carry out the requirements set forth in 15A NCAC 2H
.0800.
Copies of the checklists completed during the inspection may be
requested from this office. Thank you for your cooperation during the
inspection. Please contact us at 919-733-3908, if you have questions or
need additional information.
.� •�; , - . Sincerely,
James W. Meyer
�-'�'' Laboratory Section
s � - Enclosure
.._. ,fin•�
E cc: Marilyn O. Deaver
Gary W. Francies
s s^ t2ahlev`illel�e Tonal®,ffice
�F l
RIM
T
3
IF 'Yih:
LABORATORY SECTION
CC:, L4 if c�F
1+XY x�ji'y'�Y--' 1623 MAIL SERVICE CENTER, RALEIG H. NORTH CAROLINA 27699-1623
LOCATION:4405 REEDY CREEK ROAD, RALEIGH, NORTH CAROLINA 27607-6445
PHONE [phone] FAX [phone]

ON-SITE INSPECTION REPORT
LABORATORY NAME: Blue Ridge Paper Products, Inc.
ADDRESS: P.O. Box 4000
Canton, NC 28716
CERTIFICATE #: 198
DATE OF INSPECTION: 8/30/00
TYPE OF INSPECTION: Maintenance
EVALUATOR (S) : Gary Francies
LOCAL PERSON (S) CONTACTED: John Pryately, Melanie Hager, Phyllis Medford, Harold
Sweitzer
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements
of 15A NCAC 2H .0800 for the analysis of environmental samples .
II. GENERAL COMMENTS:
The laboratory is spacious and well equipped. All equipment is well
maintained. Records are well kept and most data appeared accurate.
III. DEFICIENCIES, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
NO DEFICIENCIES WERE CITED DURING THE INSPECTION.
Ammonia Nitrogen
A. COMMENT: The laboratory control standard is not from a second source.
Occasionally, a second source standard is analyzed, but not daily as
required.
REQUIREMENT: Analyze one known standard in addition to calibration standards
each day samples are analyzed to document accuracy. This laboratory control
standard must be from a second source. It is recommended that this
laboratory control standard have a mid-range concentration and not vary by
more than ± 10% . If it does the analysis is out of control. The analysis
must be terminated and the problem corrected. Ref: 15A NCAC 2H . 0805 (a) (7)
(B) , (F) , and Standard Methods, 18th Edition - Method 1020 B.3 .
B. COMMENT: The distilled versus undistilled comparison study results are
unacceptable. It appears this is due to the low concentration of the samples
used. It is recommended that the samples be spiked to a concentration of at
least 1 to 5 mg/l.
REQUIREMENT: Laboratories shall analyze initially four samples distilled and
undistilled from each discharge and, thereafter, analyze two samples a year
from each effluent. Additional samples must be analyzed comparatively if the
above samples results do not indicate approximately the same values for
distilled and undistilled samples. Ref: Federal Register, July 1, 1995; 40
CFR 136; Ammonia Footnote 6. Please submit the results from the analysis of
two sets of samples.

Page 2
Color-platinum cobalt
C. COMMENT: The linearity of the curve, slope value, and y-intercept are
not maintained on file for three years . The raw data is on file and the
spectrophotometer displays all this information, but once a new curve is
established all this information from the old curve is lost except the raw
data values. It is recommended that the raw data be entered into your
computer, which then can produce the curve, and all associated information,
which can be printed and stored with the raw data. Each daily bench sheet
must document the date of the curve.
REQUIREMENT: It is required that a linear regression, slope value, and y-
intercept be calculated to document accuracy of the method and reliability
of the curve. Document the linearity of the curve on the bench sheets or
computer printouts with proper initials and dates . Reference: 15A NCAC 2H
.0805 (a) (7) (H) . Determine the absorbance against the concentrations of
standards to establish a working curve and the agreement with Beer's law.
Ref: Standard Methods, 18 Edition - Method 1070D pg. 1-28 . To establish
agreement with Beer' s law, a correlation coefficient must be calculated to
document linearity. Good laboratory procedures require a correlation
coefficient >_ 0. 995 .
BOD
D. COMMENT: The laboratory is analyzing 5 mLs of standard not 6 mLs, as
the method requires. This has been done for several years and has been
missed in prior audits, both internal and those conducted by the State. All
values obtained for the standards reviewed were in the acceptable range.
REQUIREMENT: It is required that a 2% dilution of the glucose glutamic acid
standard be analyzed. Ref: Standard Methods, 18th Edition - Method 5210
B. 4c.
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory bench
sheets and contract lab reports to DMRs submitted to this Division. Data
were reviewed for these months: February, April, and May 2000. No errors
were noted. It appears the facility is doing a good job of accurately
transcribing data.
V. CONCLUSION:
This laboratory is doing a good job overall. The staff is congratulated for
doing an excellent job of maintaining the laboratory program. Correcting the
above comments should help to produce quality data and meet certification
requirements . Implementing the recommendations will further improve the
quality of the data. A WRITTEN REPLY IS REQUIRED FOR ALL LETTERED COMMENTS.
Report prepared by: Gary Francies Date: 9/l/00

BLUE RIJDGE
PAPER PRODUCTS INC.
August 22, 2000
Keith Haynes
North Carolina of Environment
and Natural Resources
Division of Water Quality Q
59 Woodfin Place
Asheville,NC 28801
Dear Keith:
This is a follow-up to our telephone conversation on August 21, 2000 concerning preventative
maintenance and routine repair including painting of the No. 2 primary clarifier at Blue Ridge
Paper Product's Canton facility. The maintenance activity will be conducted from
approximately September 11, 2000 to October 16, 2000.
As detailed in the December 1, 1998 Low Flow Contingency Plan a primary clarifier will
normally be empty and available for outage or unplanned brown colored material storage. A
primary clarifier will not be available for material storage and managed release during this
outage. However, the mill's extensive sump and recovery system will be operational during this
period.
Please call me at [phone] if you have any questions or concerns about this planned
maintenance activity.
Sincerely,
Derric Brown
Manager, Environmental Affairs
Blue Ridge Paper Products, Inc.
xc: Forrest Westall
Regional Water Quality Supervisor
NC Department of Environment&Natural Resources
59 Woodfin Place
Asheville,NC 28801
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

NOMINATION FORM FOR THE WILBUR E. LONG Jr.
OPERATOR OF THE YEAR AWARD
This nomination form is the only method to nominate an operator for the Wilbur E. Long, Jr. Award.
Only one form per nomination will be accepted and please do not attach additional pages of comments.
The purpose is to recognize any currently certified water pollution control system operator in North
Carolina who:
• has exhibited outstanding knowledge and innovation in the continuing operation of a water pollution
control system; or.
• has contributed his/her time and efforts toward the training, education, and professionalism of water
pollution control system operators; or
• has devised, discovered or invented devices or techniques which enhance the science of system
operation.
(Water Pollution Control System: wastewater treatment system, collection system, land application
system, subsurface system, spray irrigation system,land application system,or animal waste system)
Please return by September 1, 2000 to: Technical Assistance and Certification
1618 Mail Service Center
Raleigh NC 27699-1618
Please call Dwight Lancaster at(919)733-0026 ext. 302 if you have any questions.
NAME OF NOMINEE: TYPE: GRADE:
ADDRESS OF NOMINEE:
EMPLOYER: PHONE NUMBER:
ADDRESS OF EMPLOYER:
ACCOMPLISHMENTS OF NOMINEE:
PROFESSIONAL ORGANIZATIONS THAT NOMINEE IS ACTIVE IN:
NAME OF NOMINATOR: PHONE NUMBER:
ADDRESS OF NOMINATOR:

State of North Carolina
Department of Environment
WAA
and Natural Resources 4 0 •
Division of Water Quality O &Wova
James B. Hunt, Jr., Governor NCDENR
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 23,2000
CERTIFIED MAIL \.
RETURN RECEIPT REOUESTEDy
Mr.William H.Pott 11 �" � C l•�•7(
Fletcher Warehousing Company
P.O.Box 457
Swannanoa,N.C.28778
�� O C�✓
Subject: Effluent Toxicity Testing
NPDES Permit No.NC0000094
Fletcher Warehousing Company
Henderson County
Dear Mr.Pott
This is to inform you that the Environmental Sciences Branch has not received your quarterly toxicity monitoring
report for the month of June 2000. This is in violation of Title 15A of the North Carolina Administrative Code, Chapter 2,
Subchapter 2B,Section.0506(a)(1)(E)which states that"In situations where no discharge has occurred from the facility during
the report period, the permittee is required to submit a monthly monitoring report giving all required information and indicating
'NO FLOW' unless the Director agrees to waive the reporting requirement during extended conditions of no discharge."
As I understand it Ms. Kristie Robeson,with our office, spoke with you on August 21'regarding this issue and was
then instructed to contact Mr. Tom Kilpatrick, with DDK Environmental, to discuss toxicity reporting issues. Our office
contacted Mr. Kilpatrick and instructed him to submit AT forms marked 'NO FLOW" in the event that there was no discharge
from this facility.
Mr. Kilpatrick should complete the information block located at the top of the AT form indicating the facility name,
permit number, pipe number, county and the month/year of the subject report. The AT form shall be signed, appropriately
marked"NO FLOW,"and submitted to the address cited below.
ATTN: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Attached to this Notice is a one page summary of important toxicity monitoring and reporting requirements. Please
read this summary page and if you have any questions concerning this correspondence please contact Ms. Kristie Robeson with
the Aquatic Toxicology Unit at(919)733-2136.
aWater
on
Quality Section Chief
for Environmental Sciences
cc: orrest Westall-Asheville Regional Office
e`Irh a es-A '"sue a e'gi-o'n [Offic`eSfII�.
Aquatic Toxicology Unit Files
Central Files
Mailing Address Telephone[phone] Location: .
1621 Mail Service Center Fax[phone] 4401 Reedy Creek Road
Raleigh, NC 27699.1621 State Courier#52-01-00 Raleigh, NO 27699.1621
An Equal Opportunity Affirmative Action Employer 50%recycled/10%post consumer paper

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information. Please take time to review this information. The items below do not address or include
all the toxicity testing and reporting requirements contained in vour NPDES permit. If you should have any questions
about your toxicity testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at(919) 733-
2136 or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the
appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
t� IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be riled with the Environmental Sciences Branch no later than 30 days after the end of the
reporting period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the
permit limit,then at least two multiple concentration toxicity tests(one per month)will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
. concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement
response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
December,then toxicity testing must be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January I-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not occur
during the fast six months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why the test was
invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the
information block located at the top of the AT form indicating the facility name, permit number, pipe number, county and
the month/year of the subject report. You should also write"No Flow"on the AT form,sign the form and submit following
normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities
which have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT
forth. The AT form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,You may consider submitting
your toxicity test results certified mail,return receipt requested to the Environmental Sciences Branch.

BL
UE RIDGE
PAPER PRODUCTS INC.
August 22, 2000
Keith Haynes
North Carolina Department of Environment
and Natural Resources �,f �Up`�TiNPpC
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
Dear Keith:
This is a follow-up to our telephone conversation on August 21, 2000 concerning preventative
maintenance and routine repair including painting of the No. 2 primary clarifier at Blue Ridge
Paper Product's Canton facility. The maintenance activity will be conducted from
approximately September 11,2000 to October 16, 2000.
As detailed in the December 1, 1998 Low Flow Contingency Plan a primary clarifier will
normally be empty and available for outage or unplanned brown colored material storage. A
primary clarifier will not be available for material storage and managed release during this
outage. However, the mill's extensive sump and recovery system will be operational during this
period.
Please call me at [phone] if you have any questions or concerns about this planned
maintenance activity.
Sincerely,
Derric Brown
Manager, Environmental Affairs
Blue Ridge Paper Products, Inc.
xc: Forrest Westall
Regional Water Quality Supervisor
NC Department of Environment&Natural Resources
59 Woodfm Place -
• Asheville,NC 28801 `
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
September 6, 2000 J
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources �Fo
Division of Water Quality l Foy
59 Woodfin Place
Asheville,NC 28801
RE: Sewage Spill Response Evaluaton,NPDES Permit NC0000272
Landfill Leachate Spill, September 2, 2000
Dear Mr. Haynes:
Blue Ridge Paper Products, Inc. is providing written notification as a follow-up to Daryl
Whitt's telephone call to the North Carolina Emergency Response Center on September
2, 2000 at 7:00 PM concerning the leachate spill. Please find the enclosed Sewage Spill
Response Evaluation.
At approximately 8:00 AM on Saturday, September 2, 2000,the Town of Canton
personnel noticed a potential leak in the leachate transfer line at the Blue Ridge Paper
Products landfill and subsequently notified Canton Mill wastewater treatment personnel.
By 8:15 AM, the leachate transfer pumps were turned off to minimize any additional
release. The leaking line was excavated and repairs to the line were completed by 5:00
PM.
During the initial assessment,a small amount of leachate was observed flowing into the
Storm Water Outfall 6-9 conveyance directly adjacent to the spill site. This flow stopped
and the conveyance was dry by 12:00 PM. No spilled leachate was observed to have
reached the outfall to the Pigeon River, approximately 25 to 30 yards from the spill site.
There were also no indications of any impact observed in the river.
If you would like additional information regarding this incident, do not hesitate to call me
at 646-6814.
Sincerely,
D J. Whitt P.E. James A. Giaque
Senior Environmental Engineer Principal Environm tal Engineer
Cc: - Jim Patterson, Division of Solid,Waste
Derric Brown
Melanie Hagar
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

_ JD
Sewage Spill Response Evaluation: �1 d
(page 1 of 3) �+
Permittee Blue Ridge Paper Products Inc. Permit Number NC0000272 County Haywood o
y
Incident Ended: (Date/Time) Saturday 09/02/00/5:00 PM F
Estimated Duration (Time) Less than 26 hours
First knowledge of incident: (Date/Time) Saturday. 09/02/00/8:15 AM
Estimated volume of spill/bypass: 300 gallons. Show rational for volume.
Blue Ridge personnel visited the site on Friday afternoon at approximately 3:00 PM. At that time
there was no indication of a leak or spill in the area. At 8:00 AM on Saturday, the spill was first
identified by Town of Canton personnel,who subsequently notified Blue Ridge wastewater
treatment operators at about 8:15 AM. Flow was observed into the storm water conveyance until
approximately 12:00 PM. Final repairs were made to the line at approximately 5:00 PM.
Therefore the duration was estimated to be a maximum of 26 hours.
Flow was observed in the outfall conveyance at 9:30 AM, at the rate of 3-5 gallons/hour. This
flow stopped by 12:00 PM. Assuming that the flow could have been 3 times this amount while
the pumps were still active (from 3:00 PM to 8:00 AM, pumping 4 times per hour for 2-3 minutes
each time), then the volume would be 15 gallons/hour* 17 hours+ 5 gallons/hour*5 hours = 280
gallons.
if spill is ongoing,please notify Regional Office on a daily basis until spill can be stopped.
Reported to: Jimmy Ray, N.C. Emergency Response (Date/time) 09/02/00/7:00 PM
Name of person
Weather conditions: Cloudy, high temperature 770 F, rain showers in the area, though none
occurred at the site.
Source of spill/bypass (check one): OSanitary Sewer [-]Pump Station ❑WWTP
Leak occurred in the landfill leachate transfer line leading to the sanitary sewer.
Level of treatment(check one): ZNone [-]Primary Treatment
❑Secondary Treatment ❑Chlorination Only
Did spill/bypass reach surface waters? [-]Yes ONo (If Yes, please list the following)
Volume reaching surface waters? 0 gallons
Less than 300 gallons reached the storm water conveyance. None was observed reaching the
river and none is believed to have reached the surface waters, as indicated by dry leaves in the
storm water conveyance at the point of outfall to the Pigeon River, approximately 25-30 yards
from the spill site.
Name of surface water: Pigeon River
Did spill/bypass result in a fish kill? ❑Yes QNo
If Yes, what is the estimated number of fish killed?

r
Sewage Spill Response Evaluation:
(page 2 of 3)
Permittee Blue Ridge Paper Products, Inc. Permit Number NC0000272 County Haywood
Please provide the following information:
1. Location of spill/bypass:
A leak in the leachate transfer line from the Landfill 6A leachate collection system occurred
approximately 150 yards from the leachate pump station, in the roadway directly adjacent to the
conveyance to Storm Water Outfall 6-9, at the Blue Ridge Paper Products Landfill, Canton, N.C.
2. Cause of spill/bypass:
The spill was the result of a crack in the buried transfer line.
3. Did you have personnel available to perform initial assessment 24 hours/day (including
weekends and holidays)? RlYes ❑No
4. How long did it take to make an initial assessment of the spill/overflow after first knowledge?
Hours 1 Minutes 15
How long did it take to get a repair crew onsite?
Hours 7 Minutes
Please explain the time taken to make initial assessment:
The leak was first identified by Town of Canton personnel and reported to Blue Ridge Paper
Products wastewater treatment operators. The operators then called the landfill crew to stop the
leachate transfer pumps. The EOHS staff member on duty was then called at home. This on-call
person then prepared and drove to the mill, collected equipment and drove to the spill site,
arriving by 9:15 AM. Once at the spill site, the on-call person evaluated the site, and equipment
to confirm that a spill had occurred, that the correct location had been identified, that the release
had been stopped, and what areas were potentially being or going to be impacted by the spill.
This initial assessment was completed by 9:30 AM.
5. Action taken to contain spill, clean up waste, and/or remediate the site:
The leachate transfer pumps were turned off as soon as the leak was reported. This minimized
any additional flow from the leak and stopped any indication of flow to the ground surface. When
the repair crew arrived, the area of the leak was excavated to identify the point of the leak. A
repair clamp was placed over the cracked section of pipe to prevent further leakage.
6. Were the equipment and parts needed to make repairs readily available?
QYes ❑ No If no, please explain why:
7. If the spill/overflow occurred at a pump station, or was the result of a pump station failure,
was the alarm system functional at the time of the spill? N/A
[-]Yes ❑ No If the alarm system did not function, please explain why:

Sewage Spill Response Evaluation:
(page 3 of 3)
Permittee Blue Ridge Paper Products, Inc. Permit Number NC0000272 County Haywood
8. Repairs made are: IZPermanent ❑Temporary
Please describe what repairs were made. If the repairs are temporary, please indicate a date
by which permanent repairs will be completed, and notify the Regional Office within 7 days of
the permanent repair:
A repair clamp was placed over the cracked section of pipe to prevent further leakage.
9. What actions have been made to prevent this discharge from occurring again in the future?
The area around the pipe is being backfilled with soil free of rocks to prevent re-cracking the pipe.
10.
Comments:
Other agencies notifed: None
Person reporting spill/bypass: Daryl J. Whitt Phone Number:_(828) 646-6814
Signature Date:
-------------------------------------------------------------------------
-------------------------------------------------------------------------
For DWQ Use Only:
DWQ requested additional written report? _Yes No
If yes, what additional information is needed?
Requested by

NORTH CAROLINA DEPARTMENT OF
I
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
1 'p -t"' �,L,jp. August 2, 2000
}7�a AMES��B' HUNT JR
-�3G,OVEI2NOR" 3�;tiwY '
aI 198
rgJ`r.%• r MR. JOHN PRYATELY
tHOLMAN -0' BLUE RIDGE PAPER PRODUCTS WWTP LAB
I SECRETARY
- P.O. BOX 4000
` CANTON, NC 28716
n
SUBJECT: Wastewater/Groundwater Laboratory Certification
�f
C
, g Dear Mr. Pryately:
Enclosed are inspection checklists to be used for the
upcoming inspection scheduled for August 31, 2000, at
approximately 8:45 A.M. Excluding the data review sections and any
sections that specify they are to be completed by the auditor,
L p " please complete or have your analysts complete, each checklist.
;b±• � '`. , Iv "- ,q Any checklists for parameters that - no samples have been analyzed
since the last inspection do not need to be filled out. Any
checklists that your laboratory are unable to complete, or any
specific items that you do not understand, will be completed
during the inspection.
Please submit the original checklists to the inspector(s) on
the first day of the inspection. Copies are not acceptable.
I t �
,l
Contact us at 828/251-6208 ext. 285 if you have any
1' �, - I :•_ questions.I
Sincerely,
Gary Francies
_ 41 � zai Laboratory Section
'' •� *�� Enclosures
_ cc: Marilyn Deaver
James W. Meyer .
Asheville Regional Office
a
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NORTH CAROLINA 2880 1-24 1 4
PHONE [phone] FAX [phone]
p, AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% PDST-CDNSUMER PAPER

BLUE RIDGE
PAPER PRODUCTS INC.
June 14, 2000
Attention:NDCEU
1617 Mail Service Center
Raleigh,NC 27699-1617
RE: Wastewater Spill in Excess of 15,000 Gallons—Required Public Notice and Proof of
Publication, Blue Ridge Paper Products, Inc. of Canton,North Carolina
To Whom It May Concern:
Please find the enclosed public notices and proof of their publications submitted by Blue
Ridge Paper Products,Inc. of Canton,North Carolina. The public notices,required by
North Carolina General Assembly House Bill 1160, were published in the Enterprise
Mountaineer and Newport Plain Talk in response to a wastewater spill that occurred at
Blue Ridge Paper Product's Canton Mill on May 18a'at approximately 1:20 pm.
If there are any questions,please call me at(828) 646-2318.
Sincerely,
to
yR6
Derric Brown
Manager, Environmental Affairs CP sa
175 Main Street • P.O.Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

Ep RIDGE
Cis IxC.
xe: Mr. Keith Haynes
NC Dept of Environment, Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801

JI2E &MOU.l La&2zz1L
413N.MAIN ST.
P.O.DRAWER 129
WAYNESVILLE,NC 28786
7W452-0661 -
LEGAL NO. 22063
Blue Ridge Paper Products, Inc.
Attn: Monica Dills Notice of Discharge of Untreated
P.O. Box 4000 Wastewater
Canotn, NC 28716
INVOICE AND STATEMENT
DATE FOLIO DESCRIPTION CHARGES CREDITS BALANCE
r
2000 Legal# 22063
June 07 ✓ ���G
Administrative Fee 10.00
PAYABLE UPON RECEIPT
Billing Affidavit Sent: /�IQQ

NORTH CAROLINA
CLIPPING OF LEGAL HAYWOOD COUNTY
ADVERTISEMENT
ATTACHED HERE AFFIDAVIT OF PUBLICATION
Notice of Discharge of Before the undersigned, a Notary Public of said County and
Untreated Wastewater State,duly commissioned,qualified,and authorized by law to
The Blue Ridge Paper administer oaths,personally appeared
Products ;;'Incorpporated,
Canton,t�oitll(arolino foal , �( who beingfirst
itf at 175 Main Street had a rduly a wm,a es and say=thor he(the)h
dlschorge ..of'• entreated
wastewater of approximate-
ly 1 B4O00 ga0oas due to a
power d on May 18,dis 2m0g0 (0w pa om publhhc,or oaw ol6m or anplo m autho a or mah,no slwrid
occurred on May 16, 2000
at approximately 1:19 pm. of THE ENTERPRISE MOUNTAINEER
and lasted for approximate- engaged in the publication 0172 newspaper known as
ly I mlllete.The unheated THE ENTERPRISE MOUNTAINEER
wastewater Entered the published,issued,and entered as second class mail in the City of
Pigeon River in the French WAYNESVILLE
Broad River Basin.Electrical I in said County and Scur,that he(she)is authorized to make this affidavit and
power Was re-established to sworn smtementt[hat the notice or other legal advertisement,a we copy of
the wastewater pumps to which is attached hereto, was published in THE ENTERPRISE MOUN-
prevent further disdrarge. TAINEER on the following data:
Far more.information (on-
tact the. Director of ' 7�1I)AA
Environmental, Safety and and h t the said newspaper in wh cL such notice,paper,document or legal
Health Affairs at(828)646- advertisement was published was,at the time of each and every such publia-
2033. [ion, a newspaper meeting all of the requirements and qualifications of
No.22063-June 7,2000 Section 1-597 of the General Summ of North Camlina and was a qualified
newspaper within the meaning of Section 1-597 of the General Samtes of
North Carolina.
apace rsnryr
dC" B. MCC4rG. This of� / f 20 Al-)
Gv
�y0TARv. _ s� uuvuryaou dsaa t
s
t � � t C Sworn to and subscribed before me,rhis
m '•,pUBlr\C'��
q . ; day of
rrrrr C013 My Commission atpires:_ z r�^^Lnryy ubbc
AFFIDAVIT OF PUBLICATION ,
Issued by
THE ENTERPRISE MOUNTAINEER
Waynesville, NC 28786

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P �iN TALK II
Page 8B'• Sunday,June 4, 2000 EWPOOT
T H E N E.W P` R'T PLAIN 'Iph.xl
145 EasK roadway-o Newport,T nessee 37821
MONDAY-FRIDAY 8:00 A.M.-5:00 RM.
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Publishers Note
/�ll real.teat¢adrejased -herrn fs "�
h Classified Index1. Snap Shop
Llsobjeatathe Federal FaQHousmg OFFOPTUMM' .. .. �.. -:
AcLwldrh makes itZegal to advertise . 1:Public Nodccs ui ,;; . 8:Real Estate-Sales_... _
"any preference; limibtion, or disaiminarioa" :2.-Annountnmtents•.,;7•. 9.Mobile Homes• 10 consecutive insertions k
because of race,color,religion,sex,handicap,famil- 3:.Seivices - lO.Merehandise' - transportation items with a pt
ial status,or national origin, ar intention to take - . _ " ` 20 words or less. If vehicle do
any prefermce,limimdoms ordisaimmadon', • 4..1heancial " ' . .:.. Y l l.pets/Livestock sell-the customer will receiv
We will not knowingly accept an for '5.EducationalServices 12.FarinSupplies/Equipm®t extra weeks of advertisingFB
real estate which is m violation of the law. All pet 6.Employment Services 13.Recreadonal Vehicles $16.95 with our photo or$1
sons are hereby informed that all dwe➢ings adver- Y
dsed are available'on 2Il'igal opportunity basis. .7. Real'Estate-Rent, 14.Ttattspottatioa if we take the photo at the o0
Service Directory: S lines fI
20 21 26 CHECKI
1 1Announcements I
i Happy Ads Of Interest Give-Apvays AND GF
NeppyAds 20 1 PLEASE CHECK 2 tttrreNs 10 amy to
i w u ii qP t, 22 HAPPY AD YOUR AD 0� home. 4236 3-
COW of Thanks 28 POLICY This news os16.
in Memory 24 Paper makes every.
Lost d Found All Happy Ads are payable ta .effort to avoid ertore in adver• pA�T3 TO ONE AWAY. T
10 Glvo-Alvaye advance. Owmems.Each ad is carefully Cents by The Newport Plain I
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Sska 27 nssment, any ad which in- when you handle hundreds of my,Newport TN.
29 28 cuEes-an age must not in- ads.mistakes do slip through. . I
Flow Markets�� Gude the person's full name. We ask therefore, that you WARNING
NOTICE OF You ray use Indus of first check your ad and 8 you find '
name.If no age is mentioned, an enter,report it to the Ctassl- ADS FOR -
DISCHARGE OF 20 then the full home may be fled Department Immediately GIVE AWAY PETS
UNTREATED Happy Ads used. by calling 6236171.We regret year beloved pate deserves a ,
WASTEWATER must person placing the aid that we for more will
mat not be
responsible
COR loving' caring home. The ad
The Blue Ridge Paper Prod- ATTENTION dress amend Identific verifiable ation. RECT INSERTION and onty la your free pet may drew re-
Paper Incorporated, Carrion, CLASSIFIED information is Trot for pubika. for mat portion of me ad mat will from Individuals who D I
Norm Carolina facility at 175 ADVERTISING POLICY lion in The Newport PWn may have been tendered veF Your dirihat for is.
Main Street had a discharge of All ad copy is subject to appro- Talk,but will be-made availa- ueless by such error.Each in- search or r breading purposes.
eertion is proof of publication, Please screen respondents
untreated wastewater M cop- vet prior to pubiicatlon. The ble upon request to inquiring Carefully when giving an on-
proximately 18,000 gallons Newport Plain Talk reserves parties. and it Is me responsibility of met away.Your pet will thank
live to a power failure.,The the right to add, refuse or re• The Newport Plain Talk re- the adverfisor to check each YGu ,
discharge occurred on May jec any ad at any time. The nerves me right to rejaet any insertion and Call me error to
18. 20M at approximately Newport Plain Talk reserves Happy Ad. ouradenlion. 28
1:19 p.m. and lasted for ap• the right to classilyr Index and DEADLINE FOR
proximately one minute. The position ads according to the CORRECTIONS: Yard/Garage Sales
,untreated wastewater entered policies governing the Bassi- 21
the Pigeon River in me French fled pages. a:00 A.M:12 NOON AUTO SHOI
Blood River Basin. Electri ed Thank You Of Interest CLASSIFIED
623.6171 r
power was re-established to Classified HOURS: ITS YARD
the wastewater pumps to pre- Advertising Depammam - SAMI TO 5 P.M. SALE TIMEI CARS RII
vent fuller discharge. For CLASSIFIED MONDAY THRU FRIDAY
more Information contact me CLASSIFIED ADS LINE AD Let Everyone RAGE where
rm
Director of Environmental, you oral CiARAGEnAFiD BETTEF
Safe and Heakh Afhaire at GET RESULTS DEADLINES E8 SALE KIT SPECUILI CLEANF
(�ryGEG-2033 IN THE NEWPORT Spring is hem and time to Your kit would contain:
PLAIN TALK start tamtrg all of that un- Lost&Found •6Fluoresamsgns
wanted merchandise Into -60 Price Slickers .DENTON'SAL
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LOOKING FORA NEW JOB? f Ad.let as het a with •Marking Pen
nY I;. ry of Hwy 107 Del Rio. Call ,Inventory&noSheet d9S_R9S_l'....nand letMarl el I inert ell inn�e�nnnn

BLUE RIDGE
PAPER PRODUCTS INC.
AY 2 3 20p0 ��l
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May 22, 2000 'l«f�fGIONgC pTi �`f
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
Re: Sewage Spill Response Evaluation, NPDES Permit NC0000272
Wastewater Spill, May 18, 2000, Approximately 1:19 pm
Dear Mr. Haynes:
Blue Ridge Paper Products, Inc. is providing written notification as a follow-up to Derric
Brown's telephone call to you on May 18, 2000 at approximately 3:40 pm concerning the
wastewater spill. Please find the enclosed Sewage Spill Response Evaluation.
At approximately 1:05 pm on Thursday, May 18, 2000, the Canton Mill's Wastewater
Treatment Plant lost CP&L power as well as automatic switching back-up power.
Wastewater Treatment Plant operators and mill personnel immediately responded to the
power failure and power was restored within approximately 22 minutes. The estimated
duration of the release was one minute, which was based on visual observation by the
Wastewater Treatment Plant operators.
Mill personnel monitored three downstream sites on the Pigeon River immediately
following the spill. All monitored parameters were within compliance limitations. The
data obtained is listed below.
Fiberville Thickety Above Clyde
pH 7.42 7.78 7.66
Temp. (°C) 22.4 22.6 21.5
Dissolved OZ (mg/1) 8.9 6.47 8.03
Please also find the enclosed press release and public notice as required by North
Carolina General Statutes Article 21 Chapter 143.215C. The press release was issued
to radio stations WHCC/WQNS, WPTL, and WWIT in addition to the Enterprise
Mountaineer. The public notice was issued to the Enterprise Mountaineer and the
Newport Plain Talk. Copies of the newspaper articles will be sent to the Division of
Water Quality within 30 days of their publication.
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE
If you would like additional information regarding this issue, do not hesitate to call me at
646-2318.
Sincerely,
Derric Brown
Manager, Environmental Affairs

Sewage Spill Response Evaluation:
(page 1 of 2)
Permittee Blue Ridge Paper Products, Inc. Permit Number NC0000272 County Haywood
Incident Ended: (Date rime) 5/18100/1:20 pm Estimated Duration(Time) Approximately 1
minute
First knowledge of incident: (Date/Time) 6/18/00/1:05 pm
Estimated volume of spill/bypass Approximately 18,200 gallons.
Show rational for volume:
The estimated duration of the release was based on visual observation by the Wastewater
Treatment Plant operators. The effluent flow preceding the release was approximately 18,200
gallons per minute based on parshall flume readings.
If spill is ongoing,please notify Regional Office on a daily basis until spill can be stopped.
Reported to: Mr. Keith Haynes (Date/time) 5/18/00/3:40 pm
Name of person
Weather conditions: Sunny, gusty winds from the north/northwest, temperature approximately
75°F.
Source of spill/bypass (check one):_Sanitary Sewer Pump Station _X WWTP
Level of treatment(check one): X None _Primary Treatment
_Secondary Treatment_ Chlorination Only
Did spill/bypass reach surface waters? X Yes No(If Yes, please list the following)
s_
Volume reaching surface waters? Approximately 18,200 gallons
Name of surface water Pigeon River
Did spill/bypass result in a fish kill?_X Yes No r Z�
If Yes, what is the estimated number of fish killed? Approximately 200
Please provide the following information:
S PS�
1. Location of spill/bypass: The release occurred from a manhole on the mill side df the'Pigeon
River at Blue Ridge Paper Product's facility at 175 Main Street Canton, NC.
2. Cause of spill/bypass: The release occurred due to a power failure in the wastewater
treatment plant area which shut the wastewater pumps down. The power failure occurred due to
a loss of power from the main CP&L electrical feed to the area. The fuses to the back-up
electrical power potential transformer were discovered to be blown, which prevented automatic
electrical power switching.
3. Did you have personnel available to perform initial assessment 24 hours/day (including
weekends and holidays)?
Yes X No
4. How long did it take to make an initial assessment of the spill/overflow after first knowledge?
0 Hours 22 Minutes(From first knowledge to repair)

Sewage Spill Response Evaluation:
(Page 2 of 2)
Permittee Blue Ridge Paper Products, Inc. Permit Number NC0000272 County Haywood
How long did it take to get a repair crew onsite?
0 Hours 10 Minutes
Please explain the time taken to make initial assessment:
Initial assessment activities began immediately following the power failure (within seconds).
5. Action taken to contain spill, clean up waste, and/or remediate the site: Wastewater Treatment
Plant operators immediately closed#4 manhole gate and notified electrical technicians, engineers
and management of the power outage. Electrical service was restored in approximately 22
minutes.
6. Were the equipment and parts needed to make repairs readily available?
Yes X No If no, please explain why: Repairs to re-establish power began
immediately.
7. If the spill/overflow occurred at a pump station, or was the result of a pump station failure,
was the alarm system functional at the time of the spill? Yes_X No If the alarm
system did not function, please explain why: The failure did not occur at a pump station. The
power outage was immediately detected at the wastewater treatment plant by licensed operators
who man the plant 24 hours a day. Operators immediately communicated to maintenance
personnel and began corrective action.
8. Repairs made are: Permanent X Temporary _
Please describe what repairs were made. If the repairs are temporary, please indicate a date by
which permanent repairs will be completed, and notify the Regional Office within 7 days of the
permanent repair: Repairs were made by re-establishing power to the wastewater system.
Should the incident occur again, back-up power can be obtained by manually activating the back-
up power system. Permanent back-up power automatic double-throw switching will be completed
on May 23, 2000 with the installation of a new transformer.
9. What actions have been made to prevent this discharge from occurring again in the future?
Should the incident occur again, back-up power can be obtained by manually activating the back-
up power system. Permanent back-up power automatic double-throw switching will be completed
on May 23, 2000 with the installation of a new transformer.
10.Comments:
Wastewater Treatment Plant personnel monitored three downstream sites on the Pigeon River
immediately following the spill. The following data was obtained: Fiberville, pH = 7.42, Dissolved
Oxygen (D.O.) = 8.9 mg/I, Temperature=22.4°C. Thickets, pH = 7.78, D.O. =6.47 mg/I,
Temperature=22.6°C, Above Clyde, pH =7.66, D.O = 8.03 mg/I, Temperature= 21.5°C. All
monitored parameters were within compliance limitations.
Other agencies notifed:
Person reporting spill/bypass: Derric Brown Phone Number: [phone] T Signature Lcc77 Date: 5�231 loop

PRESS RELEASE
Notification of Wastewater Spill in Haywood County
House Bill 1160, which the North Carolina General Assembly enacted in July
1999, requires that municipalities, animal operations, industries and others who
operate waste handling systems issue news releases when a waste spill of 1,000
gallons or more reaches surface waters.
In accordance with that regulation, the following news release has been prepared
and issued to media in Haywood County:
Blue Ridge Paper Products, Incorporated, of Canton, North Carolina had a
wastewater spill on May 18, 2000 of an estimated 18,000 gallons from its
wastewater collection system off 175 Main Street. The release occurred due to a
power failure. The wastewater entered the Pigeon River in the French Broad River
Basin.
The Division of Water Quality was notified of the event on May 18, 2000 and is
reviewing this matter. For information contact Blue Ridge Paper Products
Incorporated at [phone].

Notice of Discharge of Untreated Wastewater
The Blue Ridge Paper Products, Incorporated, Canton North Carolina facility at
175 Main Street had a discharge of untreated wastewater of approximately 18,000
gallons due to a power failure. The discharge occurred on May 18, 2000 at
approximately 1:19 p.m. and lasted for approximately 1 minute. The untreated
wastewater entered the Pigeon River in the French Broad River Basin. Electrical
power was re-established to the wastewater pumps to prevent further discharge.
For more information contact the Director of Environmental, Safety and Health
Affairs at [phone].

-------------------------------------------------------------------------
-------------------------------------------------------------------------
For DWQ Use Only:
DWQ requested additional written report? Yes No
If yes, what additional information is needed?
Requested by

Making ur mark for you.
BLUE. RIDGE PAPER PRODUCTS INC.
June 1, 1999
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
Re: Sewage Release, NPDES Permit NC0000272
Dear Mr. Haynes:
Enclosed is the Sewage Spill Response Evaluation report.
Per our discussion this morning, we will continue to update you daily. The status of the
temporary by-pass line and the permanent repairs will be communicated to you as
appropriate.
If you have any questions or concerns, do not hesitate to call Melanie Hager (telephone:
646-6749) or myself (telephone: [phone]).
Sincerely,
Derric Brown
Environmental Supervisor
�5,

Sewage Spill Response Evaluation
Permittee: Blue Ridge Paper Products,Inc.
Permit Number: NC0000272 County: Haywood
Incident Started: (date/time) 5/25/99 10: 00 P.M.
Incident Ended: (date/time)
(if spill is ongoing,please notify Regional Office on a daily basis until spill can be stopped)
Source of spill/bypass (check one): ❑Sanitary Sewer ❑ Pump Station ® WWTP
Level of treatment (check one): ®None ❑ Primary Treatment
❑Secondary Trt. ❑ Chlorination Only
other(i.e.,upset conditions):
Estimated volume of spill/pass (check one): ❑ 0-500 gallons ❑501-1,000 gallons
❑ 1,001-2,000 gallons ® >2,000 gallons
Estimate volume in nearest 1,000 gallon increments
Did spill/bypass reach surface waters? ❑Yes ® No (if yes,please list the following)
Volume reaching surface waters? (check one): ❑ 0-500 gallons ❑ 501-1,000 gallons
NONE ❑1,100-2,000 gallons ❑ > 2,000 gallons
Estimate volume in nearest 1,000 gallon increments: N/A
Name of surface waters:
Did spill/bypass result in a fish kill? ❑ Yes ❑No v Q\
If yes,what is the estimated number of fish killed?
Please provide the following information:
P
1). Location of spill/bypass:
The release is located on the discharge side of the WWTP low lift pumps approximately 50 feet
from the pump discharge header manifold. The material is surfacing at ground level and
flowing less than 30 feet to a concrete pad catch basin which recirculates to the low lift pump
chamber. The material is then treated in the on-site WWTP. This pipe normally carries 25-27
mgd,the entire mill flow,with periodic flows to 40 mgd during rain events.
2). Cause of spill/bypass:
Undetermined at this time. We assume this is a leaking joint or a fractured pipe.
3). Did you have personnel available to perform an initial assessment 24 hours/day (including
weekends nd holidays)? ®Yes ❑ No

4). How long did it take to make an initial assessment of the spill/overflow after first knowledge?
Less than 10 minutes.
How long did it take to get a repair crew onsite?
Immediate steps were taken to engage the services of a specialty underground utility firm in
order to develop a by-pass isolation and repair plan.
Please explain the time taken to make initial assessment:
The initial assessment entailed determining the nature of the leak, that no released material
reached the surface waters,and that the leak was effectively captured by a surface drain.
5). Action taken to contain spill,clean-up waste,and/or remediate the site:
The release is effectively captured by a surface drain and recirculated back into the sewer
system. In addition, a contract underground utility firm with expertise in sewer repair and
rehabilitation was contacted the morning of May 26. The situation was reviewed with them
and a bypass scenario was evaluated. Initial scope of work and bill of materials list was
developed on 5/27 and the contractor's industrial manager made a site visit on 5/28 to finalize
the scope of work.
6). Were the equipment and/or parts needed to make repairs readily available? ❑ Yes ® No
If no,please explain why: This is a 60 reinforced concrete pipe of 1960's vintage that requires
custom fabrication of repair materials after physical inspection and measurements.
7). If the spill/overflow occurred at a pump station or was the result of a pump station failure,
was the alarm system functional at the time of the spill? ❑Yes ❑ No
If the alarm system did not function,please explain why:
N/A
8). Repairs made are: ❑ Permanent ❑ Temporary
Please describe what repairs were made. If the repairs are temporary,please indicate by
what date a permanent repair will be completed and notify the Regional Office within 7
days of the permanent repair:
9). Comments:
It is expected that a bypass will be installed and the release terminated by June 18,1999.
Other agencies notified:
Person reporting spill/bypass: Derric Brown phone number: [phone]
Signature: Date: 6I Z 19 9
For DWQ USE Only:
Oral report taken by:
Report taken: date: time:
DWQ requested additional written report? ❑Yes ❑No
If yes,what additional information is needed?
Please send this report to: Asheville Regional Office; NCDENR-DWQ Section
Phone: [phone] Fax: [phone]
After hours,weekends,or holidays,call: 1-800-858-0368

BLUE RIDGE
PAPER PRODUCTS INC.
May 15, 2000
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
Re: Defoamer Bin Line Pluggage, NPDES Permit NC0000272
Dear Mr. Haynes:
Blue Ridge Paper Products, Inc. is providing written notification as follow•up to Melanie
Hager's voicemail message of 11:40am, Thursday, May 11, 2000.
At approximately 6:50am on May 11, 2000, the Canton Mill's Wastewater Treatment
Plant crew leader noticed a small amount of foam on the Pigeon River at the secondary
effluent outfall camera monitor. The operator detected the foam as it initially occurred
and upon immediate investigation of the area, he discovered the line from the defoamer
bin that feeds into the effluent was plugged. The operator unplugged the line in
approximately 10 minutes. A downstream survey of the river revealed that there was no
foam beyond the mill's mixing zone.
The cause of the line plugging was a hard piece of defoamer lodged in the pump feed
line. A filter system has been added to the defoamer bin supply line to eliminate line
pluggage. There are also plans to install an alarm system that will send a signal to the
Wastewater Treatment Plant's control room whenever defoamer flow to the discharge
stops or is interrupted.
If you would like additional information regarding this issue, do not hesitate to call Derric
Brown (telephone: [phone]) or myself(telephone: [phone]).
Sincerely,
cc
Melanie Hager
Environmental Engineer
s
4sfv4TFR
N4!pTTN ' Tt
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

"a jr. tC.ed
III a._ -m
��ona; =cration
May 7. 1999
Mr. Norman Good
NC Department of Environment and Natural Resources
Division of Water Quality
Water Quality Chemistry Laboratory
4405 Reedy Creek Road
Raleigh, NC _7607
RE: Change of Ownership; Laboratory Certification No. 198
Dear Mr. Good:
On Alav 13, 1999. Champion International Corporation will transfer its ownership
interest in its Canton. North Carolina (Haywood County) facility to Blue Ridge Paper
Products Inc. Champion International Corporation and Blue Ridge Paper Products Inc.
request transfer of the facility's WWTP Laboratory Certification No. 198 from Champion
International to Blue Ridge Paper Products Inc. All existing laboratory equipment will
remain after the transfer. and John Pryately will remain as Laboratory Supervisor.
Thank you for your attention to this matter.
Sincerely,
� i
Gordon Jones i Richards iforto, r. `
CEO I Senior Vi President - Environment.
Blue Ridge Paper Products Inc. Health and Safetv
Champion International Corporation

DIV WATER QUALITY Fax:[phone] Feb 11 '00 11:13 P.01
Spill Response Evaluation
(Please Print or Type - Use Attachments if Needed)
Report Number: 2111 County: Haywood
Type of Incident(Check One): lO Complaint *Spill O Other
Reporting Person: Jimmy Phone Number:733-3300
Reporting Person's Affiliation: Emergency Management
Incident Started: Date: 2/I0/00 Time: 1234 PM
RQ in Pounds
Material Category Estimated Quantity Quantity Units Chemical Name(If Applicable) (Kilograms):
Petroleum 125 *Gal. OLbs. DIESEL
O Gal. O Lbs.
O Gal. O Lbs.
Containment: yes O No Cleanup Completed: Q yes No
Location of the Spill:
Public Notice Received: Date:
I::FQ. l~S..Itntt. S'i$le..SX�.LNi,J.y.WA.,E......_........_........................................................................._.._.....—............................_......_...................__......_._..........
Did the Material reach the Surface Waters? O Yes ONO Surface Water Name:
Did the Spill result in a Fish Kill? lO yes O No Estimated Number of Fish:
Cause of the Spill:
Tractor..Trailer..M:VA.L0.ADED..WlTH.C-OAL..OVFRT.URNF..SP.ILLIN...G.AP.RQX.125.G.A.LL.QE.DlESEL1-U.EL__...
If the Spill was from a Storage Tank please indicate the type: OAST OUST
Responsible Party: Pressley Tntcking Co
Contact: Phone Number:
Address: 51 Georges Rranch Rd. D
City/State/Zip: Candler 29715
On site Contact: Phone Number:
Contact Agency: Pager Number: SyFI/!q U O
Action Taken to Contain Spill, Clean Up Waste and Remediate the Site: C/oNgFOF��
.WAS.CLF.ANED.UP.E.Y...PR.ES.SLE.X..TRUCKING.CQ.,..na.sp� ifzGs.given......................................................................................_....
..............................._.............................................................................................................................................................................................................................
Cornments:
.............................._................_.........................._.........................................................................................................................................................................................
................................................................_....................................._........................_......._.......................................................................................................................I......
.

DIV WATER QUALITY Fax:[phone] Feb 11 '00 11:14 P.02 ,
Spill Response Evaluation
(Please Print or Type - Use Attachments if Needed)
Other Agencies Notified:
Agency Name and Phone Number Contact Name,Date,and Time of Contact
DWQ Information:
Received Via:
Report Taken By: Dana Folley Date: 2/10/2000 Time: 10:15 12M 10 Phone O Fax O Mail
Regional Person Referred Via:
Report Referred To: fax machine Date:2/1 1/2000 Time: I I M am O Phone. Op Fax
O Email O Interoffice.
Regional Contact (If different than above)
DWQ Requested an Additional Written Report: Yes 0 No
If Yes,What Additional Information is Needed:
Asheville Regional Office
NCDENR-DWQ Section Phone: [phone] Fax[phone]
After hours,Weekends,or Holidays,call 1-800-858-0368
Report Number: 2111

'-`------
�.
BUOE RIDGE
PAPER PRODUCTS INC. Oil
lJ�� APR 2 7 2000
tlA i ER 0 UALITY SECTI O
ff ASHFVILLE REGIONAL OrFICE
March 20, 2000
Ms. Darlene Kucken
North Carolina Department of Environment
And Natural Resources
Division of Water Quality/Planning
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: French Broad River Basinwide Water Quality Plan -
Draft Comments
Dear Ms. Kucken:
Blue Ridge Paper Products, Inc. appreciates the opportunity to comment on the
Draft French Broad River Basinwide Water Quality Plan. We also appreciate the
Division's efforts in organizing and generating such a well-written,
comprehensive plan.
Blue Ridge Paper's Canton Mill has made significant improvements in the quality
of the secondary effluent discharge since the 1995 French Broad Basinwide
Water Quality Plan was prepared. In addition to having technology in place
(oxygen delignification followed by 100% chlorine dioxide bleaching) that
exceeds USEPA's water quality requirements for Kraft mills, the Canton mill has
invested $30 million on our Bleach Filtrate Recycle (BFRTm) process. This is a
proprietary technology on our Pine Fiberline, which improves the bleach plant
effluent quality by recycling the chemicals and water used in bleaching pulp.
Blue Ridge Paper has four general concerns with the Draft Plan as it relates to
the Pigeon River Basin:
1. Nonpoint Source Pollution
The Plan does not integrate nonpoint source pollution into the assessment to the
degree we feel it should be discussed. The data in the plan concerning nonpoint
source dischargers does not allow for appropriate evaluation of the relative
importance of such sources. If the State and the regulated community are to
make qualified allocations of their resources to address the most serious
problems in the basin, it is necessary to get a better, more current idea of the
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

Ms. Darlene Kucken
Page 2
U'' ' effect which nonpoint sources have on the water quality in the basin. This is
particularly true on the Pigeon River where the principal industrial point source
discharger, the Canton Mill, has dramatically reduced the impact of its discharge
through the application of state-of-the-art technology at great expense. It is Blue
Ridge Paper's position that it is now appropriate to focus more attention on the
multitude of nonpoint sources discharged to the Pigeon River. This is particularly
important because nonpoint sources are listed in the 303(d) list for the Pigeon
River without identifying their associated impacts or appropriate corrective action
strategies. Further, the attention focused on point source dischargers has
allowed for great progress, so to direct such focus on nonpoint source
management strategies would be prudent.
2. 303(d) Listing
As a result of a series of process improvements in the late 1980's, there have
been no measurable levels of 2,3,7,8-TCDD (dioxin) in the mill effluent since
1989. As it relates to the 303(d) list it may be necessary for the State to include
the Pigeon River for dioxin, however, the plan should clearly state that the source
of dioxin in the river has been eliminated.
3. Listing of the Pigeon River from Canton to Clyde as Impaired
On p98 of The Plan, the segment of the river considered to be impaired by the
1995 Plan is identified as the Pigeon River"below Clyde to Waterville", thereby
/ implying that the segment from Clyde to Canton was not impaired. However, on
p100, The Plan indicates that in 1995 "the entire length of the Pigeon River (38.6
mi)" was impaired. This discrepancy should be resolved. Irrespective of the
discrepancy identified above, the basis for classifying the river as impaired from
the Canton water supply intake to Clyde in the 1999 Plan is not well established.
We have concerns regarding how each of the biological communities (i.e., fish
and macroinvertebrates) was used to justify the impaired rating.
4. Fish
The Plan indicates (p40) that NCIBI scores are provided in the report but NCIBI
classes (e.g., fair, good, excellent, etc.) are not listed and the NCIBI data were
not used for use support evaluations. The Plan notes that the present NCIBI
metrics do not work as expected within the mountain portion of North Carolina
and that the metrics "will be modified to allow reference sites to reflect an
Excellent NCIBI class" (p40). Later in the report (p47), DWQ identifies five areas
in which the NCIBI needs to be modified and states that until studies are
completed "it would be premature to assign a 'final' bioclassification to this
stream and apply a use support rating to the stream based on fish community
sampling". Clearly, the NCIBI is still a work in progress. The decision to not use
NCIBI scores to support use designations is inconsistent with the table in

Ms. Darlene Kucken
Page 3
Appendix A-III (p3) in which scoring category ratings are provided. This \
discrepancy should be resolved.
To support these areas of concern, Table I is provided in order to further pinpoint
recommended revisions to the body of The Plan. Also included as Attachment
Two is a report from EA Engineering, Science and Technology on this Draft Plan.
This firm has had extensive experience in studying the Pigeon River over the
past two decades and is one of the most technically knowledgeable on the
current conditions of the Pigeon River.
Again, thank you for the opportunity to submit these comments. We respectfully
request that these comments be considered and included in the Draft revision. If
you have any questions or comments, please call me at [phone] or Derric
Brown at [phone].
Sincerely,
Melanie S. Hager
Environmental Engineer
Attachments

Table 1 - Blue Ridge Paper Products, Inc., Canton Mill
French Broad River Basinwide Water Quality Management Plan
Draft Plan Comments Including Specific Report References
1. Executive Summary
Page Paragraph Recommended Revisions
Ail Table 2 'Recommended Management Strategy"for Subbasin 05 (Pigeon River) should include
efforts to manage non-point sources of pollution in addition to the strategy
for monitoring the point source.
2.Section A: Chapter 2-FBRB Overview
/ Page Paragraph Recommended Revisions
24 Table A-12 Facility name for Permit#NCS000105 should be Blue Ridge Paper Products, Inc.
not Champion International
8 thru 32 footer Note typo in Tooter. "French Broad River Basin Basin Overview"
3.Section A: Chapter 3-Summary of Water Quality Information for the French Broad River Basin
Page Paragraph Recommended Revisions
44 2 Change sentence to say, 'The station at Clyde, downstream of the Town of Canton and
BRPP discharge, reflects the effects of these inputs and nonpoint sources on water..."
Blue Ridge Paper Products, Inc. 1 3/21/00

3.Section A: Chapter 3-Summary of Water Quality Information for the French Broad River Basin cont.
/ Page Paragraph Recommended Revisions
50 Table A-28 "Recommended Management Strategy"for Subbasin 05 (Pigeon River) should include
efforts to manage non-point sources of pollution in addition to the strategy
for monitoring the point source.
4. Section B: Chapter 5-French Broad River Subbasin 04-03-05
Page Paragraph Recommended Revisions
95 3 TVA's sampling effort did not include the 7 mile stretch from Canton's water intake to Clyde.
Also, TVA's IBI is not calibrated or tested within the Pigeon.
97 3 Delete last sentence or modify to say, "BRPP, in addition to nonpoint
sources, discharge into the headwaters of the lake."
98 4 Third sentence should say"....many facility improvements were made to eliminate dioxin
levels to the river." Followed by this additional statement: "There have been no detectable
levels of 2,3,7,8-TCDD in the mill's effluent since June, 1989."
99 3 Revise the second sentence as follows:
"The lake also receives runoff, or non-point.source contributions, from agricultural and
urban runoff."
,e Ridge Paper Products, Inc. 2 3/21/00

4. Section B: Chapter 5-French Broad River Subbasin 04-03-05 continued
Page Paragraph Recommended Revisions
99 5 Last sentence should include Pigeon:
"These actions will likely have a long-term impact on the water quality of lower Richland
Creek and the Pigeon River."
100 5 Line 8 has a typo, "iste",which should be"site"
101 1 Insert the following after the second sentence:
"Another$30 million dollars was spent to implement BFRTA4, a proprietary technology
that again has improved the quality of the mill's effluent."
101 1 Third sentence delete and replace with, "Additional process improvements have been
ongoing."
102 1 Fourth sentence should reference the$30 Million cost of implementing BFRT'A.
/ 103 2 Insert the following as the last sentence in this paragraph:
"In addition to the Joint Watershed Advisory Group, the Canton Mill has established
a Community Advisory Committee-composed of community leaders in Haywood
County, NC and Cocke County, TN."
5.Appendix 3 -Use Support Ratings Table
Page Paragraph I Recommended Revisions
ref. pg 7 6th -9th There is no possible source referenced for non-point sources, add agriculture and
of table sections I non-urban development.
Blue Ridge Paper Products, Inc. 3 3/21/00

Attachment Two
Comments on
French Broad River
Basinwide Water Quality Plan
Prepared for
Blue Ridge Paper Products
Canton Mill
Canton,North Carolina
Prepared by
EA Engineering, Science, and Technology
444 Lake Cook Road, Suite 18
Deerfield,IL 60015
March 2000 13645.01

EA Engineering, Science, and Technology reviewed the French Broad River Basinwide Water
Quality Plan (The Plan)(December, 1999) and the Basinwide Assessment Report, French
Broad River Basin (November, 1998)(The Assessment Report). Although both reports were
reviewed in their entirety, the bulk of our review concentrated on those portions dealing with
the Pigeon River. Our comments on these two reports are provided below.
We were pleased to see that the report acknowledges the significant improvement in water
quality that has taken place over the last decade. For example, on p39 of The Plan, it is
acknowledged that positive changes, primarily related to improvements in wastewater
treatment, were noted at sites on the Pigeon River (among others). Similarly, on p100, The
Plan states that "water quality conditions in the Pigeon River have unproved tremendously
since the early 1990's". Overall, our comments center on two topics, (1) the inclusion of the
Pigeon in the 303(d) list because of dioxin and (2) the classification of the segment of the river
from the Canton water intake to Clyde as impaired.
303(d) LISTING
The purposes of adding a stream to the 303(d) list are so that the source of the problem(s) with
the stream can be identified and corrective action can be initiated. However, with regard to
dioxin in the Pigeon River, the source is known and actions have already been taken to
eliminate the source. Procedurally, it may be necessary for the state to include the Pigeon
River on the 303(d) list for dioxin. However, The Plan should indicate that the source of
dioxin in the river has been eliminated and that full compliance with the state's 3 ppt dioxin
limit is only a matter of time. No TMDL is needed because dioxin effluent levels from Blue
Ridge Paper have been below the level of detection for several years and the mill's limit of 0.1
pg/L was designed to be protective of the in-stream aquatic fauna and North Carolina's water
quality standards.
The Plan indicates that dioxin concentrations in the Pigeon River and Walters Lake "have
generally declined since the early 1990's". This statement implies that there has not been a
consistent downward trend or that the trend has not been consistent among species. In fact,
dioxin concentrations have declined for all species and this decline has been consistent. The
language of the report should be revised to reflect the breadth and magnitude of the decline. It
is this consistency in decline that provides the assurance that dioxin residues in common carp
and catfishes will meet state standards in the near future, thus eliminating the need for a
TMDL study. Finally, at a minimum, the Pigeon River should be given a "low" 303(d) list
priority since action has already been taken to remove the constituent of concern.
LISTING OF THE PIGEON RIVER FROM CANTON TO CLYDE AS IMPAIRED
On p98 of The Plan, the segment of the river considered to be unpaired by the 1995 Plan is
identified as the Pigeon River "below Clyde to Waterville", thereby implying that the segment
from Clyde to Canton was not impaired. However, on p100, The Plan indicates that in 1995
"the entire length of the Pigeon River (38.6 mi)" was impaired. This discrepancy should be

resolved. Irrespective of the discrepancy identified above, the basis for classifying the river as
impaired from the Canton water supply intake to Clyde in the 1999 Plan is not well
established. We have concerns regarding how each of the biological communities (i.e., fish
and macroinvertebrates) was used to justify the impaired rating.
Fish
The Plan indicates (p40) that NCIBI scores are provided in the report but NCIBI classes (e.g.,
fair, good, excellent, etc.) are not listed and the NCIBI data were not used for use support
evaluations. The Plan notes that the present NCIBI metrics do not work as expected within
the mountain portion of North Carolina and that the metrics "will be modified to allow
reference sites to reflect an Excellent NCIBI class" (p40). Later in the report(p47), DWQ
identifies five areas in which the NCIBI needs to be modified and states that until studies are
completed "it would be premature to assign a 'final' bioclassification to this stream and apply a
use support rating to the stream based on fish community sampling". Clearly, the NCIBI is
still a work in progress. The decision to not use NCIBI scores to support use designations is
inconsistent with the table in Appendix A-III (p3) in which scoring category ratings are
provided. This discrepancy should be resolved.
Despite clear statements indicating that NCIBI scores would not be used to rate the streams,
The Plan states on p95 that "fish sampling by both DWQ and TVA biologists produced low
ratings for 8 of 10 sites in this subbasin". Aside from using NCIBI scores in a manner not
consistent with guidance established earlier in The Plan, we do not believe, the TVA IBI
should be used to rate NC streams. The TVA IBI was not developed with the Pigeon River in
mind and has not been calibrated/verified for use in this basin. It is likely that some of the
scoring problems recently identified with the NCIBI are likely present in the TVA IBI.
Furthermore, given the fact that the TVA IBI uses different metrics as well as different scoring
criteria for those metrics that the two IBI's have in common, there is no basis for "translating"
TVA IBI scores into DWQ water quality classes (i.e., fair, good, excellent, etc.). Our
contention that the TVA IBI scores may be misleading is supported by DWQ's own
interpretation. DWQ states that "overall, the TVA data suggest fish community problems
throughout the basin," which is in disagreement with DWQ benthos and other data (The
Assessment Report 1998, p120, and The Plan, pA-11-13). For example, the IBI score
generated by TVA for Jonathan Creek would be equivalent to a DWQ rating of poor.
However, DWQ rated all three sites they sampled on Jonathan Creek as excellent based on the
NC Benthic Index.
To be clear, we are not suggesting that the TVA IBI is a poorly constructed index. Rather, we
are saying that it needs to be verified or calibrated before it can be use to rate sites in the
Pigeon River basin. This is particularly true for mainstem locations where the TVA IBI
aggregates data from three gears (backpack shock, boat shock, and seine) compared to DWQ
who doesn't even conduct fish sampling in streams the size of the Pigeon River.
Macroinvertebrates

The basis by which the segment of the Pigeon River from the Canton water supply intake to
Clyde is classified as impaired is somewhat confusing and poorly supported. According to The
Plan, segments that are rated good/fair are considered to be fully supported. The 1997
assessment of the Pigeon River classified this segment as good/fair (see Appendix Table A-II,
pA-ll-7) which should result in a rating of fully supporting. The basis for classifying this
segment as impaired apparently is because of a December 1999 rating of this segment as fair
by DWQ. Since summer (June-September) is the standard sampling period (see pA-II-1), any
collections outside this time window must be adjusted to account for seasonal differences. We
wonder about the advisability of overturning the good/fair classification obtained in 1997
during the standard sampling period with the fair rating obtained using seasonally adjusted
data. Even if the change in classification is real (and that is open to debate), the fair
classification during December 1999 may be a reflection of two years of low flow, stressful
conditions in the Pigeon River and therefore not reflective of typical conditions within this
segment. We do not disagree that with the premise that this segment is borderline (see p100 of
The Plan), however, we suggest that there is as much or more basis for classifying this
segment as good/fair as there is for classifying it as fair. Based on the discussion on p100, it is
clear that DWQ considered fish data in arriving at their classification of fair for this segment.
For example, The Plan states that the fish community below the plant was assigned fair or poor
ratings in 1995-97. However, elsewhere The Plan advises against using IBI scores to assign
ratings. The Plan goes on to state that the rating of fair was supported by considering the TVA
fish community data. However, TVA did not even have a sampling station within this segment
of the mainstem Pigeon River. Thus, there are no applicable data to consider even without the
admonishment in The Plan to not classify the streams on the basis of MI scores.
Given the borderline biotic index scores noted in this segment in 1997 and 1999, we suggest
that either the rating be changed to fully supported based on the good/fair rating derived in
1997 using data collected during the normal summertime sampling period, or the segment
remain unclassified until completion of benthic sampling this summer when 3-4 locations
within this segment will be sampled by BRPP's contractor.

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
• ;,-��•S ASHEVILLE REGIONAL OFFICE
NCDEMR WATER QUALITY SECTION
JAMES S.HUNTJR.GOVERNOR _4, Mr. Robert Williams
Blue Ridge Paper Products Inc.
175 Main Street -
�'i; P.O. Box 4000
P,mAY EMCDEVIT� Y Canton, North Carolina 28716 _
$SECRETARY '�+-y�{A j
n ' L ' r Subject: Balanced and Indigenous
Species Study Plan
-.KERR T.STEVENSI1 .,; +. Blue Ridge Paper Products
. _DIRECTOR
.: NPDES Permit No. NC0000272
Haywood County
f. , 1
Dear Mr. Williams:
� r•- ��fix"``_C'
I Ewa Staff of the Division of Water Quality have reviewed
the subject Plan and offer the following comments :
Task 1) It is important to select species for modeling,
which are native to the Pigeon River Basin. It is
i •IIi .;; r? our findings that there are currently no nuisance
species in the river.
yth�:
Task 3) The NCIBI should not be used as its metrics were
not calibrated nor was it correctly designed for
streams the size of the Pigeon river.
Task 4) A definition of a "balanced and indigenous
a h_ community" should be provided up-front . As well
as the choice of the cool water reference stream
from Western North Carolina. The upper Pigeon
River would be considered a suitable reference
R1, , ^ ^< stream. Then the conditions in the portion of the
River which you have studied should then be
r compared to the reference stream.
1.
a ?R4
gsr
l(?�G`S �t I •'r''Sj� INTERCHANGE BUILDINGS 58 WOODFIN PLACE, ASHEVILLE, NC'28801-2419
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10q POST-CONSUMER PAPER

Mr. Robert Williams
Page Two
Provided that these comments are incorporated into the
study plan, the Water. Quality Section considers the plan
acceptable for the evaluation of the Mill ' s thermal impact
to the Pigeon River. Please be sure to provide us with your
study results as soon as they are available.
If you have any questions concerning this matter,
please do not hesitate to contact Keith Haynes or Forrest
Westall of our Asheville Regional Office at 828/251-6208 .
Sincerely,
een Su 1 ' s
Water Quality Section Chief
xc: Forrest Westall
4K-e--9=,-h=Hayr.es-A

y r Ir,1. NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFIC
ag 73/�,J
WATER QUALITY SECTION
NCDEN(R rk AIL - PI
a W April 25, 2000 ( �{�
k�JAME9B HUNTJR
F"GOVERNOR
MEMORA DUM
AYNE DEVI
SECRETARY
C
SEORETARY
Q L� C i •
TO: Coleen Sullins
". � Q Water Quality Section Chi f �{; ��/
THROUGH: Forrest R. Westall
KERRT.STEVEN9 illy, h u.P /
•OIRECTOR0 ` ' Water Quality Regi al Supervisor
Y
FROM: D. Keith Haynes 1
Environmental Specialist 1
orP SUBJECT: Balanced and P
Indigenous Species
1
g
d Study Plan
i Blue Ridge Paper Products
NPDES Permit No. NC0000272
Haywood County
Please find attached a letter for your signature in
which the Section provides comments and gives approval for
Blue Ridge Paper Products subject study plan proposal. Bryn
Tracy of Environmental Sciences, provided comments to this
Office on this proposal. The comments were discussed with
Bryn and Blue Ridge Paper representatives. Some of the
' = issues raised by Bryn were not incorporated into the letter,
as the ARO didn' t believe they were appropriate. The
Environmental Sciences Branch should be consulted before the
_ attached letter is signed. We have faxed Bryn a copy of
this memo and our draft letter.
,rV The facility wishes to initiate work on the study as
quickly as possible, so we need to get our comments
submitted to them as soon as we can.
If you have any questions or if you need additional
information, please advise.
rtl
14AY - 2000
INTERCHANGE BUILDING, 59 y/��O(Q�QIFIN PLACE, ASHEVILLE, NC 2BSOI-2414
UO 1, "�IYX�, %Jjr�2p/g FAX[phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - 50%rREgYFLEb W POST-CONSUMER PAPER

�10

02 : 01 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P01/02
\4a k 1111,T UY 111.1ik rOi you.
BLUE RIDGE PAPER PRODUCTS INC.
)) (r� F/ACS SHEETFACSIMILE
/TO: ���� FROM;
C.1
COMPANY: DATE:
r-FAX NUMBER; TOTAL NO,OF PAGES I�rNG COVER:
,PSI- 6�sa
PHONE NUMBER: SENDER'S FAX NUMBER:
[phone]
RE: SENDER'S PHONE NUMBER-
(828) 646 6-2y q
❑ URGENT AFOR REVIEW ❑PLEASE COMMENT ❑PLEASE REPLY ❑PLEASE RECYCLE
NOTES/COMMENTS:
MAY � 62000 ,f l
.4 11R 0Ug1/ l��
16REG1 NAECTION
"The material contained in this communicate--.is,intended only for the use of the addressee. It
may contain information that is confidential, proprietary, attorney privileged, and exempt from
disclosure under applicable laW. If the reader of this communication is not the intended recipient,
you are hereby notified that any dissemination,distribution or duplication of this communication
is prohibited. If you have received this communication in error, please notify us immediately by
telephone and return,by mail,the original message to us. Thank you."
BLUE RIDGE PAPER PRODUCTS INC., 175 MAIN STREET, CANTON, NC 28716

02 : 02 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P02/02
BLUE RIDGE
PAPER PRODUCTS INC.
May 15, 2000
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
Re: Defoamer Bin Line Pluggage, NPDES Permit NC0000272
Dear Mr- Haynes:
Blue Ridge Paper Products, Inc. is providing written notification as follow-up to Melanie
Hager's voicemail message of 11:40am, Thursday, May 11, 2000.
At approximately 6:50am on May 11, 2000, the Canton Mill's Wastewater Treatment
Plant crew leader noticed a small amount of foam on the Pigeon River at the secondary
effluent outfall camera monitor. The operator detected the foam as it initially occurred
and upon immediate investigation of the area, he discovered the line from the defoamer
bin that feeds into the effluent was plugged. The operator unplugged the line in
approximately 10 minutes. A downstream survey of the river revealed that there was no
foam beyond the mill's mixing zone_
The cause of the line plugging was a hard piece of defoamer lodged in the pump feed
line. A filter system has been added to the defoamer bin supply line to eliminate line
pluggage. There are also plans to install an alarm system that will send a signal to the
Wastewater Treatment Plant's control room whenever defoamer flow to the discharge
stops or is interrupted.
If you would like additional information regarding this issue, do not hesitate to call Derric
Brown (telephone: [phone]) or myself(telephone: [phone]).
Sincerely,
Melanie Hager
Environmental Engineer
17S Main Street • P.O. Box 4000
Canton,North Carolina 28716 • Phone:[phone]
Raising Your Expectations
I

sk �AA1��•4y NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Ma-
CDEtR DIVISION OF WATER QUALITY
...� ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
-'
May 16, 2000
A'SAMES H. HLt$T JR
. QVERN'OW•' A^1nie'.
-,.
HbLMAN• Mr. Kenny Sutton
1 9EftRETARY Post Office Box 1772
Canton, North Carolina 28716
a¢E
�RR-r TET" Subject : Pigeon River
olRec � � Joint Watershed Advisory
Committee Meeting
� Tt Dear Mr. Sutton:
Cq. F Please find attached an agenda for the initial meeting
of the Pigeon River Joint Watershed Advisory Committee for
g ry /
y ��o which you were appointed by Governor Hunt by letter dated
December 1, 1999 . The meeting is scheduled for 1 : 00 the
afternoon of May 25, 2000 in the conference room of the
Asheville Regional Office of the Department of Environment
and Natural Resources .
� rn/y SI4�
3ca S I believe that you have been to our office before,
x however, if you need directions or if you have any questions,
please do not hesitate to contact Keith Haynes, Lucy Smith or
_,• me at 251-6208 .
�h!•7. .r, :r.
4e ! Sincerely,
��` � $�..; ✓✓Forrest �11
Water Quality Regional Supervisor
T
Enclosure
xc : Paul Davis
` Mike McGhee
R Bob Williams
4 .
INTERCHANGE BUILDING, 59 WOOOFIN PLACES ASH EVILLE. NORTH CAROLINA 28 80 1-241 4
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10q POST-CONSUMER PAPER

PIGEON RIVER JOINT WATERSHED ADVISORY COMMITTEE MEETING
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801
THURSDAY, MAY 25, 2000, 1:00 PM
AGENDA
I. Introduction of Committee Members, EPA Representatives, Tennessee and North
Carolina Staff Members, Blue Ridge Paper Representatives and Other Visitors -
(1:00 - 1:10)
II. Review of Agenda and the Materials Previously Provided to Committee Members
-- Paul Davis and Forrest Westall - (1:10 - 1:25)
A. Agenda Review
B. Brief Review of the Items Provided
C. Questions/Changes From the Committee
Ill. Charge to the Committee -- Mike McGhee, EPA - (1:25 - 1:55)
A. Review of the Permit Agreement Condition that Created this Committee
(Section IV, Paragraph 32)
B. Comments on Blue Ridge Paper's NPDES Permit Renewal
C. Review of Other Pigeon River Watershed Issues
IV. Mill Status: -- Bob Williams, Blue Ridge Paper Products - (1:55 - 2:15) .
A. Mill Ownership.Issues
B. Color Effluent Discharge Levels/Removal Performance
C. Future Improvements
V. Break - (2:15 - 2:30)
VI., Mill Related Water Quality Issues -- Paul Davis, Mike McGhee and Forrest Westall
- (2:30 - 3:00)
A. Permit Agreement, NPDES and Variance Compliance
B. Dioxin Data and Trends
C. Ecological Data (Fisheries and Aquatic Insect Information)

VII. General Pigeon River Water Quality Issues/Concerns - (3:00 - 3:30)
A. Status of Permit Agreement Ecological Assessment Provision (Section V,
Paragraph 33) -- Mike McGhee
B. Tennessee and NC Watershed Planning Initiatives -- Paul Davis and
Forrest Westall
C. Recreation/Rafting Use of the Pigeon -- Paul Davis and Forrest Westall
D. Waterville Lake/CPBL Issues -- Paul Davis and Forrest Westall
Vill. Committee Discussion, Identification of Other Issues and Committee Business -
(3:30 - 4:00)
A. Reaction of Committee's Charge
B. Otherlssues
C. Establishing Committee Responsibilities -- Electing Co-Chairs
D. Setting Next Meeting Date and Location in Tennessee
IX. Adjournment - (4:00)
-2-

VII. General Pigeon River Water Quality Issues/Concerns - (3:00 - 3:30)
A. Status of Permit Agreement Ecological Assessment Provision (Section V,
Paragraph 33) -- Mike McGhee
B. Tennessee and NC Watershed Planning Initiatives -- Paul Davis and
Forrest Westall
C. Recreation/Rafting Use of the Pigeon -- Paul Davis and Forrest Westall
D. Waterville Lake/CP&L Issues -- Paul Davis and Forrest Westall
Vlll. Committee Discussion, Identification of Other Issues and Committee Business -
(3:30 - 4:00)
A. Reaction of Committee's Charge
B. Otherlssues
C. Establishing Committee Responsibilities -- Electing Co-Chairs
D. Setting Next Meeting Date and Location in Tennessee
IX. Adjournment - (4:00)
C)
Q
i
I
-2-

PIGEON 121VER JOINT WATERSHED ADVISORY COMMITTEE MEETING
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801
THURSDAY, MAY 25, 2000, 1:00 PM
AGENDA
I. Introduction of Committee Memberrs, EPA Representatives, Tennessee and North
Carolina Staff Members, Blue Ridge Paper Representatives and Other Visitors -
(1:00 - 1:10)
11. Review of Agenda and the Materials Previously Provided to Committee Members
-- Paul Davis and Forrest Westall - (1:10 - 1:25)
A. Agenda Review
B. Brief Review of the Items Provided
C. Questions/Changes From the Committee
Ill. Charge to the Committee -- Mike McGhee, EPA - (1:25 - 1:55)
A. Review of the Permit Agreement Condition that Created this Committee
(Section IV, Paragraph 32)
B. Comments on Blue Ridge Paper's NPDES Permit Renewal
C. Review of Other Pigeon River Watershed Issues
IV. Mill Status: -- Bob Williams, Blue Ridge Paper Products - (1:55 - 2:15)
A. Mill Ownership Issues
B. Color Effluent Discharge Levels/Removal Performance
C. Future Improvements
V. Break - (2:15 - 2:30)
VI. Mill Related Water Quality Issues -- Paul Davis, Mike McGhee and Forrest Westall
- (2:30 - 3:00)
A. Permit Agreement, NPDES and Variance Compliance
B. Dioxin Data and Trends
C. Ecological Data (Fisheries and Aquatic Insect Information)

Mr. Robert Williams
Page Two
Provided that these comments are incorporated into the
study plan, the Water Quality Section considers the plan
, acceptable for the evaluation of the Mill' s thermal impact
to the Pigeon River. Please be sure to provide us with your
study results as soon as they are available.
If you have any questions concerning this matter,
please do not hesitate to contact Keith Haynes or Forrest
Westall of our Asheville Regional Office at 828/251-6208 .
SincerelyV162S
e e n Su
Water Quality Section Chief
x c: •E¢rx�est- Wes ta•1 +
Keith Haynes

NORTH DEPARTMENT OF
AND NATURAL
r' ENVIRONMENT AND NATT URAL RESOURCES
•!'= Y;`u DIVISION OF WATER QUALITY
'-`, ASHEVILLE REGIONAL OFFICE
NCDENR _ WATER QUALITY SECTION
DAMES B.HUNTJR. -
h ..
GOVERNOR ".•ta� Mr. Robert Williams
Blue Ridge Paper Products Inc. p��y
;t .• ,:, 175 Main Street
P.O. Box 4000
4WAYNE MCDEVITT Canton North Carolina 28716 •�,1?'L�-� -�
--SECRETARY :'r—«I-'�i'y(�'P --
�� rr Subject : Balanced and Indigenous
Species Study Plan
, D'RE .STEVEN9 . 1;1'r.,•i Blue Ridge Paper Products
,_ - NPDES Permit No. NC0000272
Haywood County
Lre11 Dear Mr. Williams :
- 1-f f i�.• -'
4, r.-1
x Staff of the Division of Water Quality have reviewed
the subject Plan and offer the following comments :
Task 1) It is important to select species for modeling,
which are native to the Pigeon River Basin. It is
I our findings that there are currently no nuisance
species in the river.
jly,_.l . Task 3) The NCIBI should not be used as its metrics were
not calibrated nor was it correctly designed for
= -- "—= streams the size of the Pigeon river.
zT' Task 4) A definition of a "balanced and indigenous
community" should be provided up-front . As well
as the choice of the cool water reference stream
from Western North Carolina. The upper Pigeon
's E River would be considered a suitable reference
ti stream. Then the conditions in the portion of the
�µ River whicH you have studied should then be
compared to the reference stream.
- INP *
n
INTERCHANGE BUILDING, 59 WOOOFIN PLACE. ASHEVILLE. NC 28801-2414
PHONE [phone] FAX828-ZS1-6452
--' -` �Ri• AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10q POST-CONSUMER PAPER

PIGEON RIVER JOINT WATERSHED ADVISORY COMMITTEE MEETING
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801
THURSDAY, MAY 25, 2000, 1:00 PM
AGENDA
I. Introduction of Committee Members, EPA Representatives, Tennessee and North
Carolina Staff Members, Blue Ridge Paper Representatives and Other Visitors -
(1:00 - 1:10)
II. Review of Agenda and the Materials Previously Provided to Committee Members
-- Paul Davis and Forrest Westall - (1:10 - 1:25)
A. Agenda Review
B. Brief Review of the Items Provided
C. Questions/Changes From the Committee
III. Charge to the Committee -- Mike McGhee, EPA - (1:25 - 1:55)
A. Review of the Permit Agreement Condition that Created this Committee
(Section IV, Paragraph 32)
B. Comments on Blue Ridge Paper's NPDES Permit Renewal
C. Review of Other Pigeon River Watershed Issues
IV. Mill Status: -- Bob Williams, Blue Ridge Paper Products - (1:55 - 2:15)
A. Mill Ownership Issues
B. Color Effluent Discharge Levels/Removal Performance
C. Future Improvements
V. Break - (2:15 - 2:30)
VI. Mill Related Water Quality Issues -- Paul Davis, Mike McGhee and Forrest Westall
- (2:30 - 3:00)
A. Permit Agreement, NPDES and Variance Compliance
B. Dioxin Data and Trends
C. Ecological Data (Fisheries and Aquatic Insect Information)

VII. General Pigeon River Water Quality Issues/Concerns - (3:00 - 3:30)
A. Status of Permit Agreement Ecological Assessment Provision (Section V,
Paragraph 33) -- Mike McGhee
B. Tennessee and NC Watershed Planning Initiatives -- Paul Davis and
Forrest Westall
C. Recreation/Rafting Use of the Pigeon -- Paul Davis and Forrest Westall
D. Waterville Lake/CP&L Issues -- Paul Davis and Forrest Westall
Vill. Committee Discussion, Identification of Other Issues and Committee Business -
(3:30 - 4:00)
A. Reaction of Committee's Charge
B. Other Issues
C. Establishing Committee Responsibilities -- Electing Co-Chairs
D. Setting Next Meeting Date and Location in Tennessee
IX. Adjournment - (4:00)
-2-

Making ar mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
February 3,2000
1a ,es est'a
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272, Blue Ridge Paper Products,Inc. Canton Mill
Dioxin Monitoring in Fish Tissue-Report 1999
Dear Mr. Westall:
Attached is the final report detailing the results from Blue Ridge Paper Products' tenth annual
Fish Tissue Study. This study, as required by our NPEDES permit, consists of annual sampling
of fish at specific sites in the Pigeon River and analysis of those fish for dioxin. The actual fish
collection took place in August 1999. All surveys were conducted by EA Engineering Science
and Technology and the analyses conducted by Quanterra Laboratories.
Table 6-4 provides the summary of the Canton Mill's Fish Fillet Tissue Analysis Results of
2,3,7,8-TCDD from 1990 to 1999.
If you have any questions or comments,please call me at(828) 646-2318.
Sincerely,
Derric Brown
Environmental Manager
AttachmentMR
D R fnl R M R
L5 1F 617 U 15 D
ASHEVEL E REGIONAL OIOIC
N
175 Main Street P.O. Box 4000 Canton, North Carolina 28716 • 828-646-2000

xc: Mr.Keith Haynes
Water Quality Section
Asheville Regional Office
59 Woodfin Place
Asheville,NC 28802
Attn: Central Files
Division of Environmental Management
and Natural Resources
NC Division of Environment and Natural Resources
P.O. Box 29535
Raleigh,NC 27626-0535
Mr. Robert McGhee
Director,Water Management Division
USEPA Region IV
345 Courtland Street,N.E.
Atlanta, GA 30365
Ms. Coleen Sullins
Chief, Water Quality Section
Division of Environmental Management
512 N Salisbury Street
P.O. Box 27687
Raleigh,NC 27611-7687
Mr. Paul Davis,Director
TN Dept. of Environment and Conservation
Division of Water Pollution Control
6th FI. L&C Annex
401 Church Street
Nashville, TN 37243-1534
Mr. David McKinney
TN Wildlife Resources Agencies
Ellington Agricultural Agency Center
P.O.Box 40747
Nashville,TN 37204

., - •y ,�,•r � ='TL "' NORTH CAROLINA DEPARTMENT OF
.{v•. '�" ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
I��i�CDE�Ut
.t April 24, 2000
E9B HUNTJRa�.FC'
5 •.GOVERN OR
Mr. Robert Williams
Blue Ridge Paper Products Inc.
175 Main Street
K ` Tr P.O. Box 4000
Ya, r M Canton, North Carolina 28716
•4Sz ` R
v ' Subject: Causticizin Reliability
7 4 Y
Project
R'R C. Blue Ridge Paper Products
,i-- NPDES Permit No . NC0000272
:= w � Haywood County
Dear Mr. Williams :
�;• `µ� We have reviewed your letter dated April 13, 2000
concerning planned improvements to the causticizing area of
Blue Ridge Paper Products Canton Mill . Since there will be
no additional color loading or production increases, this
improvement is allowed under the -settlement agreement.
•If you have any questions concerning this matter,
p � please do not hesitate to contact Keith Haynes or me at 251-
r: 6208 .
Sincerely,
i
` orrest Westall
Water Quality Regional Supervisor
H ssr 4"✓�
xc: Don Anderson, US EPA
Keith Haynes
f,+'^ � S•,N. 4 � INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASH EV ILLE, NC 28801-2414
mi '" W'yW PHONE [phone] FAX [phone]
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ev..b�aa"�`--��y.�e.w�`-'.�•�S Via.

NORTH CAROLINA DEPAR MENT OF
J
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
v WATER QUALITY SECTION
��NCD�I�R I
April 25, 2000
.JAMESB HUNTJR: `
OVERMOR '
ya
MEMORANDUM
5i .
` Pw�YNMODEV
SECtiETARY
` gar TO: Coleen Sullins
a*. Water Quality Section Chi f
,P THROUGH: Forrest R. Westall
C'fiRTST£vt q
RI1 Water Quality Regi al Supervisor
FROM: D. Keith Haynes
Environmental Specialist
,Wi_ 3 SUBJECT: Balanced and Indigenous Species
Study Plan
s Blue Ridge Paper Products
LVOV
NPDES Permit No. NC0000272
Haywood County
14
i"
Please find attached a letter for your signature in
a .-w whi " - jes approval for
Bli Post-it'Fax Note 7671 D ges► in proposal. Bryn
Tra TG :omments to this
Off C discussed with
CoJ ept.
-.�.��.. Bra � Some of the
is.- Phone# h e# i into the letter,
y" as I Fes# Fax# date. The
Env isulted before the
att _ ______ .1ryn a copy of
firy _ this memo and our draft letter.
The facility wishes to initiate work on the study as
Ca;?°�=T�`"�,,,y„6•.G,:�. quickly as possible, so we need to get our comments
submitted to them as soon as we can.
If you have any questions or if you need additional
information, please advise.
1t,_(. ` 3"y sR•. INTERCHANGE BUILDING, 59 WOOOFIN PLACE, ASHEVILLE.FAX
8 2-251-2414
[{43••(r_•al�.v'--. " $K •' 3a.� 0% NE REC CLED/I-R20R FAX SLIME 1-6452
PAPER
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� NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
�Y-
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
i� 777♦♦♦
INCD� �R WATER QUALITY SECTION
i.
]AMPS B.Hu NTJR
GOVER NOR
*
-5I�,a;: ;� Mr. Robert Williams
arY,•�:: �? Blue Ridge Paper Products Inc.
175 Main Street
P.O. Box 4000
.weYNe'�h-1coE 41rr}4}� , Canton, North Carolina 28716
ecRrTawv ' �xT�t"�'-b
1
Subject: Balanced and Indigenous
' �c� 03Ctr Species Study Plan
"rcERas,.xT�Ey. Nsgs „a_ Blue Ridge Paper Products
IRECTQR NPDES Permit No. NC0000272
Haywood County
Dear Mr. Williams :
, w Staff of the Division of Water Quality have reviewed
the subject Plan and offer the following comments :
J
Task 1) It is important to select species for modeling,
which are native to the Pigeon River Basin. It is
t our findings that there are currently no nuisance
r species in the river.
Task 3) The NCIBI should not be used as its metrics were
not calibrated nor was it correctly designed for
-_-� streams the size of the Pigeon river.
Task 4) A definition of a "balanced and indigenous
' r z. community" should be provided up-front . As well
as the choice of the cool water reference stream
tiM-. ac from Western North Carolina. The upper Pigeon
River would be considered a suitable reference
stream. Then the conditions in the portion of the
River which you have studied should then be
compared to the reference stream.
erry L
'a
-17 may.. �.,�� C•1-.�y INTERCHANGE BUILDING, 58 WOODFIN PLACE, ASHEVILLE, NC 28801-2414
PHONE [phone] FAX[phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED110q POST-CONSUMER PAPER

Mr. Robert Williams
Page Two
Provided that these comments are incorporated into the
study plan, the Water Quality Section considers the plan
acceptable for the evaluation of the Mill' s thermal impact
to the Pigeon River. Please be sure to provide us with your
study results as soon as they are available.
If you have any questions concerning this matter,
please do not hesitate to contact Keith Haynes or Forrest
West.all of our Asheville Regional Office at 828/251-6208 .
Sincerely,
Coleen Sullins
Water Quality Section Chief
xc: Forrest Westall
Keith Haynes

State of North Carolina
Department of Environment • •
and Natural Resources —
Division of Water Quality
James B. Hunt, Jr., Governor N D R
Bill Holman, Secretary NORTH CAROLIN E OF
ENVIRONMENT AN O RGES
KerrT. Stevens, Director ';�• a`/�t^\U
April 14, 2000
Mr. Louie Justus
Blue Ridge Paper Products Inc.
P.O. Box 4000
Canton, NC 28716 j
Subject: Permit No. NCS000105 !/
Blue Ridge Paper Products
Haywood County /O
Dear Mr. Justus:
In response to your renewal application for continued coverage under NPDES stormwater
permit NCS000105 the Division of Water Quality(DWQ) is forwarding herewith the subject
state -NPDES permit. This permit is issued pursuant to the requirements of North Carolina
General Statute 143-215 .1 and the Memorandum of Agreement between North Carolina and the
US Environmental Protection agency dated December 6, 1983.
Please note that the Division has revised the analytical monitoring strategy for individual
stormwater permits. Based on a review of the permit monitoring data received to date, the
analytical monitoring measurement frequencies have been changed and cut-off concentrations
have been removed. These changes will be implemented for all second term individual
stormwater permits with analytical monitoring requirements. For those permits with analytical
monitoring requirements, Part II - Monitoring, Controls, and Limitations for Permitted
Discharges has been modified to reflect the change in monitoring strategy.
The qualitative monitoring strategy remains the same as the first term of the permit.
Please note that the semi-annual qualitative monitoring is a requirement of the permit. Failure to
complete the monitoring as required is a violation of the permit and any permit noncompliance
constitutes a violation of the Clean Water Act. Reference Part III, Section A, Item 2 'Duty to
Comply", Item 9 "Penalties for Tampering " and Item 10 'Penalties for Falsification of Reports"
of your permit for further information.
If any parts, measurement frequencies or sampling requirements contained in this permit
are unacceptable to you, you have the right to an adjudicatory hearing upon written request
within thirty (30) days following receipt of this letter. This request must be in the form of a
written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed
with the Office of Administrative Hearings,Post Office Drawer 27447, Raleigh, North Carolina
27611 -7447. Unless such demand is made, this decision shall be final and binding.
Please take notice this permit is not transferable. Part III, B.2. addresses the requirements
to be followed in case of change in ownership or control of this discharge.
1617 Mail Service Center, Raleigh, North Carolina 27699.1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10%post-consumer paper

Page 2
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Environmental Management or permits required by the Division of
Land Resources, Coastal Area Management Act or any other Federal or Local governmental
permit that may be required.
If you have any questions concerning this permit, please contact Aisha Lau at telephone
number 919/733-5083 ext. 578.
Sincerely,
ORIGINAL-SI MIDgY
forVerr T. Stevens
cc: Mr. Roger O. Pfaff, EPA
(AgheeVi le�Re tonal O`f c
Stormwater and General Permits Unit
Central Files

NCS000105
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Blue Ridge Paper Products Inc.
is hereby authorized to discharge stormwater from a facility located at
Blue Ridge Paper Products Inc. —Canton Mill
Canton, NC
Haywood County
to receiving waters designated as Pigeon River and Bowen Branch, class C streams, in the
French Broad River Basin in accordance with the discharge limitations, monitoring requirements,
and other conditions set forth in Parts I, II, III, IV, V and VI hereof.
This permit shall become effective May 1, 2000.
This permit and the authorization to discharge shall expire at midnight on April 30, 2005.
Signed this day April 14, 2000.
ORIGINAL SIGNED 8Y
%ILLIAM C.MILLS
for Kerr T. Stevens, Director
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit No.NCS000105
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B: Analytical Monitoring Requirements
Section C: Qualitative Monitoring Requirements
Section D: On-Site Vehicle Maintenance Monitoring Requirements
PART III STANDARD CONDITIONS
Section A: Compliance and Liability
1. ' Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
5. Oil and Hazardous Substance Liability
6. Property Rights
7. Severability
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
Section B: General Conditions
1. Individual Permit Expiration
2. Transfers
i

Permit No. NCS000105
3. Signatory Requirements
4. Individual Permit Modification, Revocation and Reissuance, or
Termination
5. Permit Actions
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
1. Representative Sampling
2. Recording Results
3. Flow Measurements
4. Test Procedures
5. Representative Outfall
6. Records Retention
7. Inspection and Entry
Section E: Reporting Requirements
1. Discharge Monitoring Reports
2. Submitting Reports
3. Availability of Reports
4. Non-Stormwater Discharges
5. Planned Changes
6. Anticipated Noncompliance
7. Bypass
8. Twenty-four Hour Reporting
9. Other Noncompliance
10. Other Information
PART IV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS
ii

Permit No.NCS000105
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited and monitored as specified in this permit.
SECTION B: PERMITTED ACTIVITIES
Until this permit expires or is modified or revoked, the permittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system which has
been adequately treated and managed in accordance with the terms and conditions of this
individual permit. All discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization or approval.
This permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state, or local law,rule, standard, ordinance, order,judgment, or decree.
Part 1 Page 1 of 2

Permit No.NCS000105
SECTION C: LOCATION MAP
All
IN
/ \\: `' •4i r -�� P.pti ._ - . I„ s• s�`1-_ Aza�:-,� '�
SO �.N 1 it, .�. 'll• i(.� �n� ,..1� •. >',r C t•�' .IM Ua� v..rh i °" , ,.• )�,rti• .
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( � i .may-�Jy, r_�_T�.,..:•4i�..rL -.�"iy-1>e-... .�'_
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Plat o•,. \ ,�.�``'�^•:1• \,� Iwelec
2 ib
` NC00002 er
72ge
.l' �.. - _E•,••sf,— Tel '-' `<+s�`: [_,•.. .. .-. n� i'•. ?
F? _ Mill Site
—
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a .. '=r y
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65
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Part I Page 2 of 2

Permit No.NCS000105
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this individual permit. The Plan shall include, at a
minimum, the following items:
1. Site Plan. The site plan shall provide a description of the physical facility and the
potential pollutant sources which may be expected to contribute to contamination of
stormwater discharges. The site plan shall contain the following:
(a) A general location map (USGS quadrangle map or appropriately drafted
equivalent map), showing the facility's location in relation to transportation
routes and surface waters, the name of the receiving water(s) to which the
stormwater outfall(s) discharges, or if the discharge is to a municipal separate
storm sewer system, the name of the municipality and the ultimate receiving
waters; and accurate latitude and longitude of the point(s) of discharge.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices.
(c) A site map drawn to scale with the distance legend indicating location of
industrial activities (including storage of materials, disposal areas, process areas
and loading and unloading areas), drainage structures, drainage areas for each
outfall and activities occurring in the drainage area, building locations, existing
BMPs and impervious surfaces, and the percentage of each drainage area that is
impervious. For each outfall, a narrative description of the potential pollutants
which could be expected to be present in the stormwater discharge.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the 3 previous years and any corrective actions taken to mitigate spill
impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
accordance with the requirements found in Part III, Standard Conditions, Section
B, Paragraph 3.
2. Stormwater Management Plan. The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
Part II Page I of 6

Permit No.NCS000105
nonstructural measures. The stormwater management plan, at a minimum, shall
incorporate the following:
(a) Feasibility Study. A review of the technical and economic feasibility of changing
the methods of operations and/or storage practices to eliminate or reduce exposure
of materials and processes to stormwater. Wherever practical, the permittee shall
prevent exposure of all storage areas, material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is
not practical, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
(b) Secondary Containment Schedule. A schedule to provide secondary containment
for bulk storage of liquid materials, storage of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals, or storage of hazardous substances to prevent leaks and spills from
contaminating stormwater runoff. If the secondary containment devices are
connected directly to stormwater conveyance systems, the connection shall be
controlled by manually activated valves or other similar devices [which shall be
secured with a locking mechanism] and any stormwater that accumulates in the
containment area shall be at a minimum visually observed for color, foam, outfall
staining, visible sheens and dry weather flow, prior to release of the accumulated
stormwater. Accumulated stormwater shall be released if found to be
uncontaminated by the material stored within the containment area. Records
documenting the individual making the observation, the description of the
accumulated stormwater and the date and time of the release shall be kept for a
period of five years.
(c) BMP Summary. A narrative description shall be provided of Best Management
Practices (BMPs) to be considered such as, but not limited to, oil and grease
separation, debris control, vegetative filter strips, infiltration and stormwater
detention or retention, where necessary. The need for structural BMPs shall be
based on the assessment of potential of sources to contribute significant quantities
of pollutants to stormwater discharges and data collected through monitoring of
stormwater discharges.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or team) responsible for implementing the
SPRP shall be identified. A responsible person shall be on-site at all times during facility
operations that have the potential to contaminate stormwater runoff through spills or
exposure of materials associated with the facility operations. The SPRP must be site
stormwater specific. Therefore, a SPCC plan may be a component of the SPRP, but may
not be sufficient to completely address the stormwater aspects of the SPRP. The common
elements of the SPCC with the SPRP may be incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance program shall be developed. The program shall document schedules of
inspections and maintenance activities of stormwater control systems, plant equipment
Part II Page 2 of 6

Permit No.NCS000105
and systems. Inspection of material handling areas and regular cleaning schedules of
these areas shall be incorporated into the program.
5. Employee Training. Training schedules shall be developed and training provided at a
minimum on an annual basis on proper spill response and cleanup procedures and
preventative maintenance activities for all personnel involved in any of the facility's
operations that have the potential to contaminate stormwater runoff. Facility personnel
(or team) responsible for implementing the training shall be identified.
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s) responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
7. Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance which has a significant effect on the
potential for the discharge of pollutants to surface waters. The Stormwater Pollution
Prevention Plan shall be reviewed and updated on an annual basis.
The Director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part III, Standard Conditions, Section B, Paragraph 3) to the Director that the changes
have been made.
8. Facility Inspection Program. Facilities are required to inspect all stormwater systems on
at least a semiannual schedule, once in the fall (September-November) and once in the
spring (April - June). The inspection and any subsequent maintenance activities
performed shall be documented, recording date and time of inspection, individual(s)
making the inspection and a narrative description of the facility's stormwater control
systems, plant equipment and systems. Records of these inspections shall be
incorporated into the Stormwater Pollution Prevention Plan.
Stormwater discharge characteristic monitoring as required in Part II of this permit shall
be performed in addition to facility inspections.
9. Implementation. The permittee shall document all monitoring, measurements,
inspections and maintenance activities and training provided to employees, including the
log of the sampling data and of activities taken to implement BN Ps associated with the
industrial activities, including vehicle maintenance activities. Such documentation shall
be kept on-site for a period of five years and made available to the Director or his
authorized representative immediately upon request.
Part 11 Page 3 of 6

Permit No.NCS000105
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater subject to the provisions of this permit.
Analytical monitoring of stormwater discharges shall be performed as specified below in Table
1.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 4 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO). The permittee shall complete the
minimum 4 analytical samplings in accordance with the schedule specified below in Table 2.
Table 1. Analytical Monitoring Requirements
Discharge Measurement Sample Sample
Characteristics Units Frequencyl Type2 Location3
Total Suspended Solids m /l Quarterly-4'"year Grab SDO
Fecal Coliform4 mg/l Quarterly-4"year Grab SDO
BOD 5 rn /l Quarterly-4'year Grab SDO
Total Rainfall6 inches Quarterly-4'"year _
Event Duration6 minutes Quarterly-4'year
Total Flow6 MG Quarterly-4"year _ SDO
Footnotes:
1 Measurement Frequency: Once per quarter during the 4'"year of the permit term. A year is defined as the 12
month period beginning on the month and day of issuance of the Permit.See Table 2 for schedule of monitoring
periods.
2 If the stormwater runoff is controlled by a stormwater detention pond,a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm,then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Sampling is required only at Outfalls 1,2,3,4,5,6,7,8,9,6-4,and 6-10
4 Fecal Coliform sampling is only required for outfalls 1,2,and 3.
5 BOD,sampling is only required for outfall 3.
6 For each sampled representative storm event the total precipitation, storm duration,and total flow must be
monitored. Total flow shall be either;(a)measured continuously,(b)calculated based on the amount of area
draining to the outfall,the amount of built-upon(impervious)area,and the total amount of rainfall,or(c)
estimated by the measurement of flow at 20 minute intervals during the rainfall event.
Part 11 Page 4 of 6

Permit No.NCS000105
SECTION D: ON-SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities which have any vehicle maintenance activity occurring on-site which uses more than
55 gallons of new motor oil per month when averaged over the calendar year shall perform
analytical monitoring as specified below in Table 4. This monitoring shall be performed at all
outfalls which discharge stormwater runoff from vehicle maintenance areas.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 4 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO) which discharges stormwater runoff from
vehicle maintenance areas. The permittee shall complete the minimum 4analytical samplings in
accordance with the schedule specified in Table 2 (Part II, Section B).
Table 4. Analytical Monitoring Requirements for On-Site Vehicle Maintenance
Discharge Characteristics Units Measurement Sample Sample
Frequencyl Type2 Location3
H standard Quarterly-41°year Grab SDO
Oil and Grease mg/1 Quarterly-4"year Grab SDO
Total suspended Solids mg/1 Quarterly-46 year Grab SDO
New Motor Oil Usagegallons/month Quarterly-4"year Estimate -
Total Flow4 MG Quarterly-e year Grab SDO
Footnotes:
I Measurement Frequency: Once per quarter during the 4"year of the permit term. A year is defined as the 12
month period beginning on the month and day of issuance of the Permit. See Table 2 for schedule of monitoring
periods.
2 If the stormwater runoff is controlled by a stormwater detention pond,a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm,then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO)that discharges
stormwater runoff from area(s)where vehicle maintenance activities occur.
4 Total flow shall be; (a)measured continuously,(b)calculated based on the amount of area draining to the outfall,
the amount of built-upon(impervious)area,and the total amount of rainfall,or(c)estimated by the measurement
of flow at 20 minute intervals during the rainfall event. Total precipitation and duration of the rainfall event
measured shall result from the sampled representative storm event.
Part 11 Page 6 of 6

Pemvt No.NCS000105
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL
PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater
discharges in accordance with the following schedule:
Existing Facilities: The Stormwater Pollution Prevention Plan shall be developed and
implemented within 12 months of the effective date of the initial permit and updated
thereafter on an annual basis. Secondary containment, as specified in Part 11,Section A,
Paragraph 2(b) of this permit, shall be accomplished within 12 months of the effective
date of the initial permit issuance.
Proposed Facilities: The Stormwater Pollution Prevention Plan shall be developed and
implemented prior to the beginning of discharges from the operation of the industrial
activity and be updated thereafter on an annual basis. Secondary containment, as
specified in Part H, Section A,Paragraph 2(b) of this permit shall be accomplished prior
to the beginning of discharges from the operation of the industrial activity.
2. Duty to Comply
The permittee must comply with all conditions of this individual permit. Any permit
noncompliance constitutes a violation of the Clean Water Act and is grounds for
enforcement action; for permit termination,revocation and reissuance, or modification; or
denial of a permit upon renewal application.
a. The permittee shall comply with standards or prohibitions established under
section 307(a) of the Clean Water Act for toxic pollutants within the time
provided in the regulations that establish these standards or prohibitions,even if
the permit has not yet been modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit condition is
subject to a civil penalty not to exceed $25,000 per day for each violation. Any
person who negligently violates any permit condition is subject to criminal
penalties of$2,500 to $25,000 per day of violation, or imprisonment for not more
than 1 year,or both. Any person who knowingly violates permit conditions is
subject to criminal penalties of$5,000 to$50,000 per day of violation, or
imprisonment for not more than 3 years, or both. Also,any person who violates a
permit condition may be assessed an administrative penalty not to exceed$10,000
per violation with the maximum amount not to exceed$125,000. [Ref: Section
309 of the Federal Act 33 USC 1319 and 40 CFR 122.41(a).]
Part III Page 1 of 10 Pages

Permit No.NCS000105
C. Under state law, a daily civil penalty of not more than ten thousand dollars
($10,000)per violation may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit. (Ref:
North Carolina General Statutes 143-215.6A)
d. Any person may be assessed an administrative penalty by the Director for
violating section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act. Administrative penalties for Class I violations are not to
exceed$10,000 per violation,with the maximum amount of any Class I penalty
assessed not to exceed$25,000. Penalties for Class II violations are not to exceed
$10,000 per day for each day during which the violation continues,with the
maximum amount of any Class II penalty not to exceed $125,000.
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in
violation of this individual permit which has a reasonable likelihood of adversely
affecting human health or the environment.
4. Civil and Criminal Liabilitv
Except as provided in Part III, Section C of this permit regarding bypassing of stormwater
control facilities,nothing in this individual permit shall be construed to relieve the
permittee from any responsibilities, liabilities, or penalties for noncompliance pursuant to
NCGS 143-215.3,143-215.6A, 143-215.6B, 143-215.6C or Section 309 of the Federal Act,
33 USC 1319. Furthermore,the permittee is responsible for consequential damages, such
as fish kills, even though the responsibility for effective compliance may be temporarily
suspended.
5. Oil and Hazardous Substance Liability
Nothing in this individual permit shall be construed to preclude the institution of any
legal action or relieve the penrimee from any responsibilities,liabilities,or penalties to
which the permittee is or may be subject to under NCGS 143-215.75 et seq. or Section 311
of the Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this individual permit does not convey any property rights in either real or
personal property, or any exclusive privileges,nor does it authorize any injury to private
property or any invasion of personal rights,nor any infringement of Federal, State or local
laws or regulations.
Part III Page 2 of 10 Pages

Permit No.NCS000105
7, Severability
The provisions of this individual permit are severable, and if any provision of this
individual permit, or the application of any provision of this individual permit to any
circumstances, is held invalid,the application of such provision to other circumstances,
and the remainder of this individual permit, shall not be affected thereby.
8. Duty to Provide Information
The permittee shall furnish to the Director,within a reasonable time, any information
which the Director may request to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit issued pursuant to this individual permit
or to determine compliance with this individual permit. The permittee shall also furnish
to the Director upon request,copies of records required to be kept by this individual
permit.
9. Penalties for TMerine
The Clean Water Act provides that any person who falsifies,tampers with,or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
individual permit shall,upon conviction,be punished by a fine of not more than$10,000
per violation, or by imprisonment for not more than two years per violation,or by both.
If a conviction of a person is for a violation committed after a first conviction of such
person under this paragraph,punishment is a fine of not more that$20,000 per day of
violation, or by imprisonment of not more than 4 years,or both.
10. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to
be maintained under this individual permit, including monitoring reports or reports of
compliance or noncompliance shall,upon conviction,be punished by a fine of not more
than $10,000 per violation, or by imprisonment for not more than two years per violation,
or by both.
SECTION B: GENERAL CONDITIONS
I. Individual Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expiration date,the permittee shall
submit forms and fees as are required by the agency authorized to issue permits no later
than 180 days prior to the expiration date. Any permittee that has not requested renewal
at least 180 days prior to expiration, or any permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration,will be
Part III Page 3 of 10 Pages

Permit No.NCS000105
subjected to enforcement procedures as provided in NCGS §143-2153.6 and 33 USC
1251 et. seq.
2. Transfers
This permit is not transferable to any person except after notice to and approval by the
Director. The Director may require modification or revocation and reissuance of the
permit to change the name and incorporate such other requirements as may be necessary
under the Clean Water Act. Perrnittee is required to notify the Division in writing in the
event the permitted facility is sold or closed.
3. SiQnatoryRequirements
All applications,reports, or information submitted to the Director shall be signed and
certified.
a. All applications to be covered under this individual permit shall be signed as
follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of
this Section, a responsible corporate officer means: (a) a president,
secretary,treasurer or vice president of the corporation in charge of a
principal business function, or any other person who performs similar
policy or decision making functions for the corporation, or(b)the manager
of one or more manufacturing production or operating facilities employing
more than 250 persons or having gross annual sales or expenditures
exceeding 25 million (in second quarter 1980 dollars), if authority to sign
documents has been assigned or delegated to the manager in accordance
with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the
proprietor, respectively; or
(3) For a municipality, State,Federal, or other public agency: by either a
principal executive officer or ranking elected official.
b. All reports required by the individual permit and other information requested by
the Director shall be signed by a person described above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having
responsibility for the overall operation of the regulated facility or activity,
such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or
position having overall responsibility for environmental matters for the
Part III Page 4 of 10 Pages

Permit No.NCS000105
company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Director.
C. Any person signing a document under paragraphs a. or b. of this section shall
make the following certification:
"I certify, under penalty of law, that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing
violations."
4. Individual Permit Modification, Revocation and Reissuance, or Termination
The issuance of this individual permit does not prohibit the Director from reopening and
modifying the individual permit, revoking and reissuing the individual permit, or
terminating the individual permit as allowed by the laws, rules, and regulations contained
in Title 40, Code of Federal Regulations, Parts 122 and 123;Title 15A of the North
Carolina Administrative Code, Subchapter 2H .0100; and North Carolina General Statute
143-215.1 et. al.
5. Permit Actions
The permit may be modified, revoked and reissued, or terminated for cause. The
notification of planned changes or anticipated noncompliance does not stay any
individual permit condition.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the
permittee to achieve compliance with the conditions of this individual permit. Proper
operation and maintenance also includes adequate laboratory controls and appropriate
Part III Page 5 of 10 Pages

Permit No.NCS000105
quality assurance procedures.This provision requires the operation of back-up or
auxiliary facilities or similar systems which are installed by a permittee only when the
operation is necessary to achieve compliance with the conditions of this individual
permit.
2. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with
the condition of this individual permit.
3. Bypassinv of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee
for bypass unless:
a. Bypass was unavoidable to prevent loss of life,personal injury or severe property
damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary
control facilities,retention of stormwater or maintenance during normal periods of
equipment downtime or dry weather. This condition is not satisfied if adequate
backup controls should have been installed in the exercise of reasonable
engineering judgment to prevent a bypass which occurred during normal periods
of equipment downtime or preventive maintenance; and
C. The permittee submitted notices as required under,Part III, Section E of this
permit.
If the Director determines that it will meet the three conditions listed above,the Director
may approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
1. Representative Sampline
Samples collected and measurements taken, as required herein, shall be characteristic of
the volume and nature of the permitted discharge. Analytical sampling shall be
performed during a representative storm event. Samples shall be taken on a day and time
that is characteristic of the discharge. All samples shall be taken before the discharge
joins or is diluted by any other waste stream,body of water,or substance. Monitoring
points as specified in this permit shall not be changed without notification to and
approval of the Director.
Part III Page 6 of 10 Pages

Permit No.NCS000105
2. Recordine Results
For each measurement, sample, inspection or maintenance activity performed or collected
pursuant to the requirements of this individual permit,the permittee shall record the
following information:
a. The date,exact place, and time of sampling,measurements,inspection or
maintenance activity;
b. The individual(s) who performed the sampling, measurements,inspection or
maintenance activity;
C. The date(s)analyses were performed;
d. The individual(s)who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with
accepted scientific practices shall be selected and used to ensure the accuracy and
reliability of measurements of the volume of monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations
published pursuant to NCGS 143-215.63 et. seq,the Water and Air Quality Reporting
Acts, and to regulations published pursuant to Section 304(g), 33 USC 1314, of the
Federal Water Pollution Control Act, as Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this individual permit, all test procedures
must produce minimum detection and reporting levels and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure.
5. Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater
discharges that are required to be sampled,the permittee may petition the Director for
representative outfall status. If it is established that the stormwater discharges are
substantially identical and the permittee is granted representative outfall status,then
sampling requirements may be performed at a reduced number of outfalls.
Part III Page 7 of 10 Pages

Permit No.NCS000105
6. Records
Visual monitoring shall be documented and records maintained at the facility along with
the Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall
also be maintained on-site. The permittee shall retain records of all monitoring
information,including all calibration and maintenance records and all original strip chart
recordings for continuous monitoring instrumentation, and copies of all reports required
by this individual permit for a period of at least 5 years from the date of the sample,
measurement,report or application. This period may be extended by request of the
Director at any time.
7. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an
authorized contractor acting as a representative of the Director), or in the case of a facility
which discharges through a municipal separate storm sewer system, an authorized
representative of a municipal operator or the separate storm sewer system receiving the
discharge, upon the presentation of credentials and other documents as may be required
by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located
or conducted, or where records must be kept under the conditions of this
individual permit;
b. Have access to and copy,at reasonable times, any records that must be kept under
the conditions of this individual permit;
C. Inspect at reasonable times any facilities,equipment (including monitoring and
control equipment), practices, or operations regulated or required under this
individual permit; and
d. Sample or monitor at reasonable times,for the purposes of assuring individual
permit compliance or as otherwise authorized by the Clean Water Act, any
substances or parameters at any location.
SECTION E: REPORTING REQUIREMENTS
I. Discharge Monitoring Rgports
Samples analyzed in accordance with the terms of this permit shall be submitted to the
Division on Discharge Monitoring Report forms provided by the Director. Submittals
shall be received by the Division no later than 30 days from the date the facility receives
the sampling results from the laboratory.
Part III Pages of to Pages

Permit No.NCS000105
2. Submitting Reports
Duplicate signed copies of all reports required herein, shall be submitted to the following
address:
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
3. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section
308 of the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms
shall be available for public inspection at the offices of the Division of Water Quality. As
required by the Act, analytical data shall not be considered confidential. Knowingly
making any false statement on any such report may result in the imposition of criminal
penalties as provided for in NCGS 143-215.613 or in Section 309 of the Federal Act.
4. Non-StormwaterDischaryes
If the storm event monitored in accordance with this individual permit coincides with a
non-stormwater discharge,the permittee shall separately monitor all parameters as
required under the non-stormwater discharge permit and provide this information with the
stormwater discharge monitoring report.
5. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes
at the permitted facility which could significantly alter the nature or quantity of pollutants
discharged. This notification requirement includes pollutants which are not specifically
listed in the individual permit or subject to notification requirements under 40 CFR Part
122.42 (a).
6. Anticipated Noncompliance
The permittee shall give notice to the Director as soon as possible of any planned changes
at the permitted facility which may result in noncompliance with the individual permit
requirements.
7. bass
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it
shall submit prior notice, if possible at least ten days before the date of the bypass;
including an evaluation of the anticipated quality and affect of the bypass.
Part III Page 9 of 10 Pages

Permit No.NCS000105
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of
becoming aware of an unanticipated bypass.
8. Twenty-four Hour Reportine
The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes;
the period of noncompliance, including exact dates and times, and if the noncompliance
has not been corrected, the anticipated time compliance is expected to continue; and steps
taken or planned to reduce,eliminate, and prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case-by-case basis if the oral report has
been received within 24 hours.
9. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour
reporting at the time monitoring reports are submitted.
10. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in an
application for an individual permit or in any report to-the Director, it shall promptly
submit such facts or information.
Part III Page 10 of 10 Pages

Permit No.NCS000105
PART IV LIMITATIONS REOPENER
This individual permit shall be modified or alternatively, revoked and reissued, to comply with
any applicable effluent guideline or water quality standard issued or approved under Sections
302(b) (2) (c), and (d), 304(b) (2) and 307(a) of the Clean Water Act,if the effluent guideline or
water quality standard so issued or approved:
a. Contains different conditions or is otherwise more stringent than any effluent limitation in
the individual permit; or
b. Controls any pollutant not limited in the individual permit.
The individual permit as modified or reissued under this paragraph shall also contain any other
requirements in the Act then applicable.
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days
after being billed by the Division. Failure to pay the fee in timely manner in accordance with
15A NCAC 2H .0105(b)(4) may cause this Division to initiate action to revoke the Individual
Permit.
PART VI DEFINITIONS
1. Act
See Clean Water Act.
2. Arithmetic Mean
The arithmetic mean of any set of values is the summation of the individual values
divided by the number of individual values.
3. Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Non-stormwater discharges which shall be
allowed in the stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
Parts IV,V and VI Page I of 6

Permit No.NCS000105
(b) Uncontaminated groundwater, foundation drains, air-conditioner condensate
without added chemicals, springs, discharges of uncontaminated potable water,
waterline and fire hydrant flushings, water from footing drains,flows from
riparian habitats and wetlands.
(c) Discharges resulting from fire-fighting or fire-fighting training.
4. Best Management Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters.
BMPs may take the form of a process, activity, or physical structure.
5. BBvpass
A bypass is the known diversion of stormwater from any portion of a stormwater control
facility including the collection system, which is not a designed or established operating
mode for the facility.
6. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a
single above ground storage container having a capacity of greater than 660 gallons or
with multiple above ground storage containers located in close proximity to each other
having a total combined storage capacity of greater than 1,320 gallons.
7. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as
amended, 33 USC 1251, et. seq.
8. Division orDWO
The Division of Water Quality,Department of Environment and Natural Resources.
9. Director
The Director of the Division of Water Quality,the permit issuing authority.
10. EMC
The North Carolina Environmental Management Commission.
11. Grab Sample
An individual sample collected instantaneously. Grab samples that will be directly
analyzed or qualitatively monitored must be taken within the first 30 minutes of
discharge.
Part VI Page 2 of 6 Pages

Permit No.NCS000105
12. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean
Water Act.
13. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and
which is not a land treatment facility, a surface impoundment, an injection well, a
hazardous waste long-term storage facility or a surface storage facility.
14. Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such
as a city or town.
15. Overburden
Any material of any nature,consolidated or unconsolidated,that overlies a mineral
deposit,excluding topsoil or similar naturally-occurring surface materials that are not
disturbed by mining operations.
16. Permittee
The owner or operator issued a permit pursuant to this individual permit.
17. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including,but not specifically limited
to, any pipe, ditch,channel,tunnel,conduit,well, or discrete fissure from which
stormwater is or may be discharged to waters of the state.
19. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours in which no storm event measuring greater than 0.1 inches has occurred. A single storm
event may contain up to 10 consecutive hours of no precipitation. For example,if it rains for 2
hours without producing any collectable discharge, and then stops, a sample may be collected if a
rain producing a discharge begins again within the next 10 hours.
19. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is
representative of the discharges at multiple outfalls, the DWQ may grant representative
outfall status. Representative outfall status allows the permittee to perform analytical
monitoring at a reduced number of outfalls.
Part VI Page 3 of 6 Pages

Permit No.NCS000105
• 32. Upset
Means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the permittee. An upset does not include
noncompliance to the extent caused by operational error, improperly designed treatment
or control facilities, inadequate treatment or control facilities, lack of preventive
maintenance, or careless or improper operation.
33. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs,painting,fueling, lubrication, vehicle cleaning
operations, or airport deicing operations.
34. Visible Sedimentation
Solid particulate matter,both mineral and organic,that has been or is being transported
by water, air, gravity, or ice from its site of origin which can be seen with the unaided
eye.
35. 25-year, 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the
average, once in 25 years.
Part VI Page 6 of 6 Pages

NORTH CAROLING DEPARTMEPTOF
a�„I yyC4 ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
�rINCDE�R �x
March 23, 2000
HUNTJR;
S. GOVERNOR
s, . Mr. Derric Brown
" . ,v. Blue Ridge Paper Products
, ♦� Canton Mill
we�Y�NF- -DEVIT,T: Post Office Box 4000
Ci�E RE- cs
7A Y Canton, North Carolina 28716
I t 8A�a s `sue a 7 Subject: Compliance Sampling Inspection
� ...>
ty RR�T SgTEVEN9' ;W^l
Blue Ridge Paper
`1]YRS
5 ' Canton Mill WWTP
NPDES Permit No. NC0000272
�aywood County
IN
i Dear Mr. Brown:
1 1 3
� ,�,• � ti ,� Please find attached an inspection report for the
°3 Compliance Sampling Inspection which I performed at your
E •t' .;"y facility on February 24, 2000 .
1
� - Should you have any questions concerning the Report,
y' } �� _ + please do not hesitate to contact me at 251-6208 . The.
+f t
�..•.+.�; assistance provided to me by all Mill personnel involved
during the inspection was greatly appreciated.
Sincerely,
yti»xNax y�
q4 , D. Keith Hayn s
Environmental Specialist
Attachment
t;���•;' '��.w� � xC RtIIgZ:r-�, EPA
llS � .•+h .y '} INTERCHANGE BUILDING• 59 WOODFIN PLACE, ASHEVILLE• NG 28801-2414
PHONE 828-2SI-6208 FAX 828-2S1-6452
¢¢Tr gu•f "tst'�y' •"6t'^'-•'�3" AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - SO°n' RECYCLED/10q POST-CONSUMER PAPER

United States Environmental Protection Agency Form Approved
Washington, D.C.20460 OMB No. 2040-0003
Approval Expires 7-31-85
PA NPDES Compliance Inspection Report
Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
I IN 1 2 u 3 1 NC0000272 11 12 00/02/24 117 18 IC 1 19 U 2012
u Remarks
I I I I I I I I I I I I I I I I I I I I I I I I I I I
' Reserved Facility Evaluation Rating BI QA Reserved
67 L 69 70
71 on 72 at 73 L_IW I 174 75 LLLI_]_J_]80
Section B: Facility Date
Jame and Location of Facility Inspected Entry Time Permit Effective Date
3lue Ridge Paper Products 9:30 am 970101
-anton Mill
-anton, Haywood County Exit Time/Date Permit Expiration Date
11:30 pm 011130
4ame(s)of On-Site Representative(s)/Title(s) Phone No(s)
Derric Brown -Environ. Supervisor 828-646-2318
Jame,Address of Responsible Official Title
Ar. George Henson Vice-President/Operations Mgr.
'0 Box 700
-anton, NC 28716 Phone No. Contacted
No
section C:Areas Evaluated During Inspection CODES nr S•Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated/Not applicable
S Permit S Flow Measurement $ Pretreatment $ Operations &Maintenance
$ Records/Reports $ Laboratory $ Compliance Schedules $ Sludge Disposal
$ Facility Site Review $ Effluent/Receiving Waters S Self-Monitoring Program Other:
Section D:Summary of Findings/Comments (Attach additional sheets if necessary)
:(fluent Data Permit Limits(Daily Avg/Mon Ave)
10D, — 5.3 mg/I 30.0 mg/I- 45.0 mg/I
'SS — 11.0 mg/I 30.0 mg/I- 45.0 mg/I
'rimary clarifier#1 was not in operation, it is now used as pan of the spill contention plan. Three of the four aeration basins were in operation, with the other
me in the digester mode. The remainder of the plant was in full operation. The Parshall Flume/flow meter was calibrated on the day of this inspection and is
outinely calibrated quarterly. Effluent flow at the time of sampling was 23 MGD. Maintenance records are kept by computer in the treatment maintenance shop.
All sampler refrigeration units were operating at or below the proper temperature.
4ame(s)and Signature ) of spector(s) Agency/Office/Telephone Date
). Keith Haynes
DWQ/ARO 828-251-6208 ba�3�3
signature of Rev' er Agency/Office Date
DWQ/ARO '828-251-6208 ;13 Mi✓QO
Regulatory Office Use Only
tction Taken l Date Compliance Status
Noncompliance
Compliance

NORTH CAROLINA DEPARTMItNT OF
'Y- ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY.
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
N�DE�RX 3
December 1, 1999
M:'DAMES B.HUNTJR. y3
S°:GOVERNOR
Mr. Derric Brown
Blue Ridge Paper Products Inc.
Sid ^ E DEYt^ I` 175 Main Street
�g
SEORETA Y C`+'S
.- -1 P.O. Box 4000
,. ^' Canton, North Carolina 28716
�, e Subject: Tax Certifications
�µ TCS-502 and TCS-401
yd 'Ra , Blue Ridge Paper Products
t r
NPDES Permit No . NC0000272
Haywood County
, T Dear Mr. Brown:
This letter is to advise you that the subject tax
certifications issued to Champion International on July 25,
1995 and March 31, 1992 can be transferred to Blue Ridge
t Paper Products Inc.
If you have any questions concerning this matter,
4 please do not hesitate to contact me at 251-6208 .
-' Environmental Specialist
�s xc: Haywood County Tax Collector
� I• .Y� y,. �'•M' � INTERCHANGE BUILDING, 50 WOOCFIN PLACE, ASHEVILLE, NC 28 80 1-24 1 4
PHONE [phone] FAX828-2S1-64S2
�t"'� AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/IO% POST-CONSUMER PAPER

Making(Our mark for you.
VX BLUE RIDGE PAPER PRODUCTS INC. /r/lee
November 11,1999
Mr. Forrest Westall
North Carolina Department
Environmental and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
Re: Tax Certification
Blue Ridge Paper Products Inc.
Canton,North Carolina
Dear Mr. Westall:
Attached are Tax Certifications issued to Champion International Corporation by the North
Carolina Department of Enviroiunent and Natural Resources, Division of Environmental
Management for wastewater treatment facilities. Tax Certification was issued for wastewater
treatment facilities in 1992 and 1995.
As you know, Champion International Corporation sold the Canton Mill to Blue Ridge Paper
Products Inc., on May 14, 1999. We are requesting a written confirmation that these Tax
Certifications transfer from Champion to Blue Ridge Paper Products Inc.
If you have any questions or need additional information please call me at(828) 646-2318.
Sincerely,
Derric Brown
attachments
r
1 5 1999ALITY SEOTION 175MainStreet P.O.Box4000 Canton, North Carolina 28716 828-646-2000
REGIONAI nrricr 1

LIST OF ATTACHMENTS
Attachment Description Certificate # Permit#
Attachment I Waste Treatment Plant Work TCS502 NC0000272
Attachment II Water Pollution Control Facilities TCS401 NC0000272

ATTACHMENT I
POLLLTION CONTROL
TAX CERTIFICATES
CERTIFICATE, # TCS502
PERMIT # NC0000272

State of North Carolina
Department of Environment,
Health and Natural Resources 4 •
Division of Environmental Management A&t
_
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary F1
A. Preston Howard, Jr., P.E., Director
July 25, 1995
0
, 0 1995
Mr. Derric Brown, Environmental Supervisor [
Champion International - Canton Mill
Box C-10
Canton, North Carolina 28716
Subject : Tax Certification
Champion - Canton Mill WWTP
Waste Treatment Facilities
Haywood County
Dear Mr. Brown:
Transmitted herewith is Tax Certification Number TCS502
covering the construction and operation of wastewater treatment
facilities at Champion' s Canton Mill, as described in the subject
document .
The Company may use this Certification to obtain tax benefits
in keeping with the appropriate Statutes . Detailed descriptions of
these wastewater treatment facilities are available in the files of
the Division of Environmental Management .
Sincerely, D
A. Preston Howard, Jr. , P.E.
Enclosure
c : Haywood County Tax Collector
Keith Haynes
P.O. Box 29535,Raleigh,North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 60%recycled/10%post-consumer paper

. o
LAU:G0 3 1995
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL REsdtM=V---" ..""•"°®'°�
RALEIGH
TAX CERTIFICATION
(Franchise/privilege; Amortization; Property)
In accordance with the provisions of the General Statutes of North
Carolina (G. S> 105-122 (d) , 105-130 . 10, 105-147 (13) , 105-275 (8 ) , this is
to certify that :
Champion International Corporation
Canton Mill
Haywood County
HAS BEEN ISSUED
Authorization to Construct/NPDES Permit Number NC0000272 for
installation and continued operation of wastewater treatment/disposal
equipment at the Champion International-Canton Mill as described below:
(1) grit chamber, bar screens, lowlift pumps, Carbon Dioxide pH
control, flow splitting station, one (1) 125 ' diameter clarifier,
two (2) 200 ' diameter clarifiers, Sulphuric acid pH control,
nutrient feed, Calcium Carbonate addition, two (2) 2 . 3 million
gallon aeration basins/digesters, two (2) 3. 4 million gallon
aeration basins, polymer addition, on-line respiratory system, one
(1) 150 ' diameter clarifier, two (2) 200 ' diameter clarifiers, 8"
flume, oxygen for reaeration and four (4) belt presses and
associated modifications related to the Canton Modernization
Project .
(2) Bleached Filtrate Recycle (BFRTM) demonstration project .
The Environmental Management Commission and the Department of
Environment, Health, and Natural Resources have found that the
facility:
a. has been constructed or installed;
b. complies with the requirements of the Commission;
C. is being effectively operated in accordance with the terms
and conditions of the permit, certificate of approval, or
other document of approval issued by the Commission; and
d. has as its primary rather than incidental purpose the
reduction of water pollution resulting from the discharge of
sewage and waste.

Issued at Raleigh, North Carolina, this the I "T day of
by the Director of the North Carolina Environmental Management
Commission and the North Carolina Department of Environment, Health,
and Natural Resources.
A. Preston Howard, Jr. , P. E.
Director
Division of Environmental Management

ATTACHMENT II
POLLUTION CONTROL
TAX CERTIFICATES
Water Pollution Control Facilities
CERTIFICATE # TCS-401
PERM T# NCO000272

��a RECEIVED APR 0 1 1992
Jt.
State of North Carolina
Department of Environment, Health, and Natural Resources
Asheville Regional Office
James G. Martin, Governor Ann B. Orr
William W. Cobey, Jr., Secretary Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 31, 1992
Mr. Derric Brown
Environmental Supervisor
Champion International
Canton Mill
Canton, North Carolina 28716
Subject: Tax Certification Number TCS-401
Champion International
Water Pollution Control Facilities
Haywood County, North Carolina
Dear Mr. Brown:
Transmitted herewith is one copy of a Tax Certification for water
pollution control facilities being constructed as part of the Canton
Mill Modernization project required under NPDES Permit Number NC0000272 ;
effective October 25, 1989 .
This Certification may be used to obtain tax benefits in keeping
with the General Statutes of North Carolina. Should you wish to discuss
this matter in more detail, please do not hesitate to contact me.
Sincerely,
Roy M. Davis, Regional Supervisor
Division of Environmental Management
Enclosure
xc: George Everett
Harlan Britt
Steve W. Tedder
Interchange Building, 59 Woodfin Place,Asheville, N.C. 28801 •Telephone 704-251b208
An Equal Oppommiry Affirmative Action Employer

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
T A X C E R T I F I C A T I O N
(Franchise/privilege; Amortization; Ad Valorem)
In accordance with the provisions of the General Statutes of North
Carolina (G. S. 105-122(d) , 105-130. 10, 105-147( 13 ) , 105-275(8) (a) this
is to certify that
Champion International
Canton, North Carolina
has been issued NPDES Permit Number NC0000272 for the construction and
operation of an industrial water pollution control facility. This permit
requires equipment modification to the manufacturing process to cause
the total daily wastewater flow through the treatment facility to be
reduced from 48. 5 MGD to 29 MGD, plus cause reduction in color,
chloroform, dioxin and total suspended solids. This inplant
reconstruction is also directed toward providing compliance with
effluent toxicity requirements as well as continued compliance with the
instream temperature variance issued by the North Carolina Environmental
Management Commission.
Construction approved in this Tax Certification includes ( 1) the MILL
WATER SYSTEM which provides for a new three-cell cooling tower and basin
and appurtenances (pumps, tanks, piping & distribution, pressure
controls, and electrical & instrument equipment) , (2 ) PAPER MACHINE
WATER CONSERVATION system to provide filtering and/or cleaning equipment
necessary to allow reuse of existing white water streams (primarily
machines No 11 & 12 ) and necessary equipment to reduce and control heat
loss (flow and temperature compliance) , (3 ) the CHEMICAL SYSTEM (for
color reduction) which provides for elimination of the chlorine and
hypochlorite bleaches with an oxygen delignification system and includes
all facilities necessary for handling, storage and distribution of
oxygen including oxidation of white liquor also used in the oxygen
delignification process (includes modification of the existing chlorine
dioxide generator and chilled water supply system plus construction of a
new cooling tower and mechanical chiller) , (4) the BLACK LIQUOR
EVAPORATORS (two sets rebuilt) and associated equipment including
storage and controls for prevention of chemical losses as well as color
and heat reduction, (5) the CAUSTICIZING EQUIPMENT to include
construction of a new drum-type dregs washer and associated equipment
for control of chemical loss and flow reduction and (6) Modifications to
the No. 2 FIBER LINE (PINE) and No. 1 FIBER LINE (HARDWOOD) necessary to
guarantee successful operation of the oxygen delignification system to
include reactors, pressurized screens, pulp washers, deknotters, and all
other equipment which would be necessary for flow reduction, color
removal, chloroform and dioxin minimization required by the NPDES permit
( structures or buildings, vats, bleaching towers, and equipment needed
to house and facilitate operation of the paper making process and not
exclusively for NPDES permit compliance are excluded from this Tax
Certification) .

Page 2
Tax Certification TCS-401
Wastewater from this reconstructed manufacturing process will continue
to be treated in the existing wastewater treatment facility owned by
Champion International and operated under the provisions of NPDES permit
Number NC0000272 with discharge to the Pigeon River in the French Broad
River Basin.
The Environmental Management Commission and the Department of
Environment, Health and Natural Resources have found that modifications
to the industrial water pollution control program:
1 . are presently under construction,
2 . comply with the requirements of NPDES Permit Number NC0000272
as issued by the Environmental Protection Agency with an
effective date of October 25, 1989, and requirements of the
Environmental Management Commission with respect to reduction
and/or prevention of water pollution; and
3 . has as its primary rather than incidental purpose the
prevention and reduction of water pollution from the
paper manufacturing process .
Issued at Asheville, North Carolina, this the�1yday of on 1992
By Direction of the Environmental Management Commission and the
Department of Environment, Health, and Natural Resources.
C9�
—R-a"
Roy M. Davis, Regional Supervisor
Division of Environmental Management
TCS-401

4A
Making(Our mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
October 5,1999
Mr.Forrest Westall
North Carolina Department
Environmental and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
Re: NPDES Permit NC0000272
Blue Ridge Paper Products Inc.
No.19 Paper Machine Improvement Project
Mr.Westall:
Blue Ridge Paper Products Inc., (BRPP),Canton,North Carolina Facility,NPDES Permit No. NC0000272,
is notifying you of planned improvements to No. 19 Paper Machine. The improvements will involve the
replacement of the paper machine's second press with a press of different design and the replacement of
the calendar stacks with two calendar nips. In addition, non-contact cooling towers will be installed to
minimize fresh water usage. The improvements will enhance both product quality and yield and the
paper machine will be able to process lighter weight products at maximum production rates. The No.19
Paper Machine annual calendar day production rate is projected to be less than 1,000 air dried tons of
finished product per day.
This project includes no physical or operational changes that would increase the mills current pulp
production capacity. Therefore, there will be no additional color loading resulting from this project The
current maximum annual average production capacity of the pulp mill is not sufficient to supply all four
paper machines. The Canton Mill has purchased an average of approximately 39,000 tons of dry
furnished pulp per year for each of the last six years to supplement on-site pulp production and supply
the paper machines. The pulp mill will continue to nm as efficiently as possible, but additional dry
furnish purchases will be necessary to support production at the paper machines.
Blue Ridge Paper Products Inc., is not requesting any revisions or modifications to the NPDES Permit
effluent limitations, monitoring requirements, or other conditions. Completion of the No.19 Paper
Machine Project will result in continued full compliance with the Settlement Agreement, Color Variance
and NPDES Permit
If you have any questions or need additional information please contact me at(828) 646-2033.
Sincerely,
Robert V.Williams
Director,Environmental,Health&Safety Affairs
175 Main Street • P.O.Box 4000 • Canton, North Carolina 28716 • 828-646-2000

BLUE RIDGE PAPER PRODUCTS INC.
xc: Mr. Don Anderson
U.S. Environmental Protection Agency
Mail Code 4303
Room 915A, East Tower
401 M Street,SW
Washington, D.C. 20460

Fax Message From :
Nov 1 '99 10:34
Name: DPJ WATER UJALITY
Fax Number: 9197155637
NCDENR - DIV OF WATER Planning Branch

DIV WATER QUALITY Fax:[phone] Nov 1 '99 10:34 P.01
"r a
Division of Water Quality
Water Quality PlanWng Emuch
1617 MAII.SERVICE CENTER
RaWgh,NC 27699-1617
FAX: [phone]
DATE:
TO: 6wrPSt We.l �rA FAX NUM
FROM
PHONE NKJ1VffiER:(919)733-,5083 extension:
3S i
J
No.OF PAGES(u„r ,ns this
sheet) -
CONDWENTs: V
�s� e-�A-. .,..n��, cam--• �"aa �-- �,,, l�a..c.�C
NOV _ 1 •
, 19,99 o .
ASyEV�R(QRfC10 SfCTIp
a�

DIV WATER OI.WLITY Fax:[phone] Nov 1 '99 10:34 P.02
One segment of both the Pigeon River and Richland Creek are listed as impaired based on recent
DWQ monitoring data. Both of these waters are presented and discussed below in Part 5.3.L
These waters are also on the state's year 2000(not yet EPA approved)303(d)list(see Part 5.3.2).
53.1 . Monitored Impaired Waters
Figeou]rover(7.0 miles from Canton water supply intake to Clyde to SR 1642)
This section of the Pigeon River is listed as impaired(PS)duo to both point source impacts from
the Blue Ridge Paper Products(formerly Champion International)and nonpoint sour ces-
2000 Recommendation(s)
This station has been sampled nine times since 1984. A Good-Fair rating for benthic
macroinvertebrates was recorded during the summer of 1997 for the Pigeon River for the first
time at Clyde,while the Hepco site above Walters Lake continued to have a Good-Fair
bioclassification. A Good rating at the state fine was found in 1994 and 1997. Fish sampling by
TVA biologists in the Pigeon River in 1990, 1995 and 1997 has shown some limited recovery
over time below BRPP discharge. however,the fish community below the plant was assigned
Fair or Poor ratings in 1995-1997.
Note: Most gent DWQ data indicate the hugs were on the edge between a G-F and Fair
rating. A decision was made to tall tbis streteb impaired. The river has improved
dramatically over the last 15 pears,but clearly there are still impacts from Champion. To
assure ourselves that this stretch of river should still really be called impaired,an
additional sampling effort will take place iva October at this site and possible upstream
sites. This section:of the plant will be completed after the resamplimg is dome and in time for
public review.
DWQ analyzed mercury concentrations in fish tissue at five Pigeon River sites during 1996,but
none of these samples bad levels over FDA or EPA criteria. Annual fish tissue monitoring for
dioxins in the Pigeon River is also performed by Blue Ridge Paper Products and Carolina Power
and Light. This monitoring is required as part of the Champion International NPDES permit
issued by DWQ and as a condition of the EERC license for Carolina Power and light.
By 1994,Champion completed a modernization program that included replacing chlorine as a
bleaching agent to ensure dioxin would no longer be a by-product within the effluent. Dioxin
concentrations in fish collected from the Pigeon River and Walters Lake have generally declined
since the early 1990's,although levels for certain species have fluctuated depending on sample
season,station,and the size of the fish collected Dioxin concentrations in sportfishes(redbreast
sunfish,rock bass,crappie,largemouth and smallmouth bass)have remained non-detectable or
well below the North Carolina limit for issuing a consumption advisory(3.0 ppt). Dioxin levels
in carp have decreased as much as 80%downstream of the BRPP facility.but remain above the
North Carolina limit in Walter's Lake(see Figure B-K&and B- )_
Section B: Chapter 5—French Broad River SLbbarin 04-03-05 92

DIV WATER OLPLITe Fax:[phone] Nov 1 '99 10:35 P.03
Currently,there is a limited consumption advisory for common carp and ash species(bullhead
species,channel catfish,and flathead catfish)in effect for the Pigeon River between Canton and
the North Carolina-Tennessee state line,including Walters Take. Due to declining dioxin levels,
this advisory was revised by the State health Director from a no-consumption to a limited-
consumption advisory in September 1994. Additionally, there is a limited-consumption advisory
for common carp,catfish species,and redbreast sw6sh in affect for the Pigeon River within the
State of Tennessee from the North Carolina-Tennessee state line downstream to the confluence
with the French Broad River. D WQ submitted a TMDL(see Part 53.2)for dioxins in Waterville
Lake and the Pigeon River to SPA in fall of 1999.
Figure B-XX—TCDD concentrations in carp from Pigeon River(pg 13 of ESB report)
Fgure B XXX-TCDD concentrations in carp from Walters Lake(pg 13 of ESB report)
The Champion International facility has made several improvements to manufacturing processes.
Champion(now Blue Ridge Paper Products(BRPP))has spent more than$300 million
upgrading its manufacturing process since 1990. Additional improvements were made in 1996
and 1997. These improvements in wastewater treatment at the BRPP facility are associated with
a gradual improvement in macroinvertebrate bioclassitications over the years.
A Settlement Agreement was reached in 1997 on a modified color variance and NPDES permit
between EPA,the States of NC and TN,Cocke County and the City of Newport,TN,Tennessee
Environmental Council,American Canoe Association and Champion International. The intent of
the Agreement was to resolve the Pigeon River color issue without litigation. The parties
involved in the ensuing discussions,agreed to many measures to achieve color reduction over the
life of the NFDES permit. In accordance with this agreement,Champion began installing a full-
scale BIeach Filtrate Recycle(BFR". technology on the mill's pine line. Champion also began
to evaluate the potential for additional minimization of color and report these findings on a pre-
defined schedule to DWQ and others. Opportunities for preventing and controlling measurable
leaks and spills through BMPs were also to be addressed. Champion was to achieve a true color
loading not to exceed an annual average load of 60,000 lbs/day,a monthly average true color of
69,000 lbs/day,and a maximum monthly color average of 50 true color units at the NC-TN state
line(it was further agreed that the 50 color units should be.met at Ilepco). Champion further
agreed to target annual average color loading of 48,000-52,000 lbs/day by May 1,2001.
A Technology Review Workgroup was formed to monitor Champion's achievements. To date,
this Workgroup has received reports from Champion International on the following progress:
• the(BFR")demonstration on the softwood fiber line has been installed with no problems
• all of the BMP projects as required in the agreement were completed and operational
Section B: Chapter 5—French Broad River Subbasin 04-03.05 93

DIV WATER QUWLITY Fax:[phone] Nov 1 '99 10:36 P.04
• additional color reduction measures were completed and others are ongoing
contingency'plans for low-flow periods were in place and operational
As reported to the Workgroup in January 1999,monitoring confirms the daily average of color
discharge is well below the limits set forth in the Agreement. The mill's end-of-pipe true color
report shows the facility was discharging approximately 10,000lb1aay of color below the limit
requited in the Agreement: The facility has reached the 2001 target for color loading. The color
in the Pigeon River was below the limit at Hepco for the reporting period in 1998. The
Workgroup therefore believes that Champion is mialdng substantial and continuous progress in
reducing the amount of color generated and discharged to the Pigeon River and has met the
conditions of the Agreement. Additional technologies are yet to be installed and further
operational progress is anticipated Figme B-XXX illustrates Champion's success in reducing
color discharges;to the Pigeon River since 1988,including monthly average performance for
1998.
Figure B-XXX
Forrest-Please add a short piece on the Joint Watershed Advisory Committee. I am still
not quite clear on the functions of this committee as opposed to the Workgroup.
Section B- Chapter 5—Fe-ch B.nad Juver$ubbasm 04.03-05 94

v +•��ai Cc_oration
May i. 1999
Mr. Bradic,. Bennett
State of North Carolina
Department or'Environment and Natural Resources
Division of Water Quality
Permits and Engineering Unit
P. O. Box =94 35
Raleigh. NC '7626-0535
Re: Ownership Change; Stormwater Permit No. NCS000105
Dear Mr. Bennett:
On \lay 1.3. 1999. Champion International Corporation ("Champion") will transfer
ownership of its facility in Canton. North Carolina (Haywood County) to a new owner, Blue
Ridge Paper Products Inc. Champion hereby requests a transfer of Stormwater Permit No.
NCS000105. Blue Ridge Paper Products Inc. will continue to operate the facility in the same
manner as Champion and will operate without interruption. Furthermore. Blue Ridge Paper
Products Inc. %ill continue to comply with the current permit requirements.
Please rind enclosed the following documents:
I. Water Quality Section Permit Name/Ownership Change Form
2. 5100.00 processing fee
Upon completion of the ownership transfer, Blue Ridge Paper Products Inc. will
forward a copy of the deed transferring the facility from Champion to Blue Ridge Paper
Products Inc.
Thant: you for your attention to this matter.
Sincerely,
Richa tforio, Jr.
Senior ice President - Environmental,
Health and Safety
Enclosure Champion International Corporation

Department of Environment,
Health and Natural f ai management
fllvls(on ot•Environmentaf Management
James s. Hunt, Jr., Governor s
Jonathan B. Howes, Secretary h"r
A. Preston Howard, Jr., P.E., 01rector ® � ` V �•.
WATER QUALITY SECTION
PF.Rh7IT NAM /OWNFR4HTP HANr,F FoRm
I. ('i1RRFNT PFRMTT 1NFnRMA77M-
CrR'.:C litilDCr: N e 5 0 0 0 1 0 5
I• PG-mit holder's name• 0- r- .07on Sn ern��;onc\ L'or pore fro.�
2. Permit's signing offidal's acme and title
(e=oa legally responsible for permit)
Vice- l�res',den� - Operc.�rone rnona er
(Title)
3. Mailing Address: ?• O• 4 00 0
Car, an�-on
SL=. Z8-11 to
TAP Code Phone.f a ZS 1 (0 4 (v Z8 4 0
•IL NF«• QWNFR/NA'%4F INFORMATMOEN
1. Tnis request fora name change is a result of:
�a C:'angcin ownership of PrnPerry/company
b. Name change only
_c••Other(please explain)-
2- New owner's name(name to be put on permit)-,_ e R;�4 e �c.o er Pro acts Inc.
3. New owner's or signing official's name and title: C90raon 3ones
(Poison legally resporsible for permiQ
(2.W.e� Execj�:�je O ;cec
4. Mailing address: ?- 0. -,�)0x 4000 (Idle)
City eG,n�-o n
State: —N L Tp code••?S'} 1 (c Phone: t 8IS) Gy(0- ZS 4 0

PERMIT NAME/OWNERSHIP CHANGE FORM
THIS APPLICATION PACKAGE WILL-NOT BE ACCEPTED BY THE DIVISION OF
ENVIRONMENTAL MANAGEhfENT"UNLESS ALL OF THE APPLICABLE ITEMS
LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED 17I41S:
1. This completed application
2. Proocssing fa of SI00.00 (Chce1-s to be made payable to DEHNRT
3. If an ownership change,legal doivmentation of the transfer of ownership (such as a contract,deed,
articles of incorporation)
CERTIFICATION MIST BE COMPLETED AND SIGNED BY BOTTI THE CURRENT
PERMIT HOLDER AND THE NEW APPLICANT IN THE CASE OF CHANGE OF
OWNERSHIP. FOR NAME CHANGE ONLY COMPLETE AND SIGN THE
APPLICANT'S CERTIFICATION. '
Current Permittee's Certification-.
L-121Cc�a,e0 J. D I t^orQiO J r attest that this application for name%wn=bip change has been
reviewed and is accurate an p to,to the beat of my knowledge. I understand that if all required parts
of this application are n mple that if all rcquitsd supporting info on and attachments ere not
included this S be return incomplete.
Signature• Date. ,
Applicant's Certification:
attest that this application for a name/ownership change has been
renewed and is accurate and complete to the best of my knowledge. I understand that if all requited pats
of this anplicatioh are not oPmpleted and that if all requited supporting information and ahxhments are not
included,this cal do p ge will be rutumed as incomplete.
Signatu4c- Dare: 5�11 l qq
THE COMPLETED APPLI ATION PACKAGE,INCLUDING ALL SUPPORTING INFORMATION
AND MATERIALS,SHOULD BE SENT TO THE FOLLOWING ADDRESS:
North Carolina Division of Environmental Management
Water Quality Section
Permits and Engineering Unit
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Telephone: (919) 733.5083
Fax: (919) 733-0719

=cr. -'_rnauonai Ccmc.at:or.
May 7. 1999
Mr. Charles Weaver
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
Permits and Engineering Unit
P. O. Box 29535
Raleigh, NC 27626-0535
Re: Ownership Change; NPDES Permit No. NC0000272
Dear Mr. % eaver:
On May I3. 19999 Champion International Corporation ("Champion') will transfer
ownership of its facility in Canton. North Carolina (Haywood County) to a new owner. Blue
Ridge Paper Products Inc. Champion hereby requests a transfer of NPDES Permit No.
NC0000272 including all variances previously granted. Blue Ridge Paper Products Inc. will
continue to operate the facility in the same manner as Champion and will operate without
interruption. Furthermore. Blue Ridge Paper Products Inc. will continue to comply with the
current permit requirements.
Please find enclosed the following documents:
1. Water Quality Section Permit NameiOwnership Change Form
2. S 100.00 processing fee
Upon completion of the ownership transfer. Blue Ridge Paper Products Inc. will
forward a copy of the deed transferring the facility from Champion to Blue Ridge Paper
Products Inc.
Thank you for your attention to this matter.
Sincerely.
2L��IZ
Rich iforio, Jr.
Senior ice President - Environmental,
Health and Safety
Enclosure Champion International Corporation

Department of Environment,
Health and Natural Resources � 0 a
fllvlslon of.Environmental Management
James e. Hunt, Jr., Governor .,�.��
Jonathan E. Howes, Secretary CC
A. Preston Howard, Jr., P.E., Dfrector ® C" N [ = •
WATER QUALITY SECTION
PER ITT NAM ./OWNRRSHTP CH'ANf F FnnM
I. r'[1RRF.NT PFRT.fTT YNFOR}t"0.TT{y1jt
ermitNomocr I N C a o 0 o 12 4 2
I. Permit holder's name,* 0.kc',. 0;0., =n}ernes}Iona\ eor�orc F on
I Permit's signing official's name and.title,• W'�W�c -„ R . 'M o,n 3 e.,r
(Pelson legally responsible for permit)
_ �l�C2 - �res;G2n} OperC.}ro�5 Man4ger
(Title)
3. Mailing address: O• fox 4o0o Cit}^ Title)
State: N LT+p Code. S l fo phone:
•IL NE«' QNVNFRlNAMt rucnnijA=
I. This request for a name change is a result of
X rt Changc•in ownership of property/company
`b. Name change only
_c- 'Other(please explainh
2. New owner's name (name to be put on permit):_ Plop- -P:cl$e F6,!R r 7F raLC, s Tne
3. New owner's orsigning official's nave and title: Caorclon hones
Werson legally responsible for permit)
Execjv;,Ie OJW;cer
4. Mailing address: ?• O• 'Box 4000 i� Cl+up)
City: n•4o r,
State:—N L Tp Code; a 81 S to Phone: { S 2S 1 G 4 ro- 2514 0

PERMIT NAMF/0WNFR41IP HAN F E=
TMS APPLICATION PACKAGE WILL-NOT BE ACCEPTED BY THE DIVISION OF
ENVIRONMENTAL MANAGEMENT UNLESS ALL OF THE APPLICABLE ITEMS
LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS:
L This completed application
2- Pzoccssing fcc of S100.00 (Checks to be made payable to DEHNR)
3. If as o�vership change,legal dccumcntalion cf the transfer of ownership (suds as a contract,deed,
a:[icles of incorporation)
CERTIFICATION MUST BE COMPLETED AND SIGNED By BOTH THE CURRENT
PERMIT HOLDER AND THE NEW APPLICANT IN THE CASE OF CHANGE OF
OWNERSHIP. FOR NAME CHANGE ONLY COMPLETE AND SIGN THE
APPLICANT'S CERTIFICATION. '
Current Permittee's Certification:
�;C rt AQn )• DI o attest that this application for mamelownerahip change has been
reviewed aad is acc=== com etc to the best of my knowledge. I understand that if all rewired parts
of this application are t co I d that if all requited supporting information and aff non
included, this agp be return as incomplete. ts ert not
Signaa:re: Dom. 5 7
Applicant's %crtification.-
I' attest that this application for a name%wnership change has been
rcvrewed and rs arcuratc and compiate to the best of my knowledge. I understand that if all requited parts
Of this aaplicatidn are not completed and that if all required supporting information and attachments,are not
included, t 9p4c on package ri]I be returned as incomplete
n:Stgnarc' Date-
THE COMPLETED I PLICATION PACKAGE,INCLUDING ALL SUPPORTING INFORMATION
AND N ATEPdAIS,S OULD BE SENT TO THE FOLLOWING ADDRESS:
North Carolina Division of Environmental Management
Water Quality Section
Permits and Engineering Unit
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Telephone: (919) 733.SO83
Fax: (919) 733-0719

c"7 J. vPa.Jr.
Mav 7. 1999
-=_nonat Gc.-crarcr
Mr. Day id .-1. Goodrich
Department of Environment and Natural Resources
Division of Water Quality
NPDES Unit
P. O. Box 294z35
Raleigh. NC '7626-0535
Re: Ownership Change; Certificate of Coverage # NCG500151
Dear IMr. Goodrich:
On May 13. 1999. Champion International Corporation will transfer ownership of its
facility in Dair\-pak-Waynesville. North Carolina (Havwood Countv) to Blue Ridge Paper
Products Inc. Blue Ridge Paper Products Inc. hereby requests a transfer of the Certificate of
Coverage No. NCG500151 under NPDES General Permit No. NCG500000. The Blue Ridge
Paper Products Inc. will continue to operate the facility in the same manner as Champion
International Corporation and will operate without interruption. Furthermore, the Blue Ridge
Paper Products Inc. facility will continue to comply with the current permit requirements.
Please rind enclosed the following documents:
l. Water Quality Section Permit Name/Ownership Change Form
S 100.00 processing fee
Upon completion of the ownership transfer, Blue Ridge Paper Products Inc. will
forward a cope of the deed transferring the facility from Champion International Corporation
to Blue Ridge Paper Products Inc.
Thank ou for your attention to this matter.
Sincerely,
G don Jones Rich 0ifiorio. Jr.CEO Seniorresident - Environmental,
Blue Ridge Paper Products Inc. Health and Safety
Enclosures Champion International Corporation

Department of Environment.
Health and Natural Resources�Ivislon of•Environmental Managementyr;l
James B. Hunt, Jr., Governor r
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., 01rector © E ` V �•.
WATER QUALITY SECTION
PERMIT NAM /OVVNFRSHTP H'ANr`F Fnu�• .
I. CTTRRF.NT PFRMTT TNRnRMATTrr&;
erm:[humocr: M C G 5 0 0 2 5 2 '
I. Pam- eholaet'sname C�v "o rnjErnc,' O 4\ Coroof-g•1•;on
Z Permit's signing official's name snd title:
(PersoalegallyrespoturbI forpemut)
Iwlati nes�',11e 1?\C."r 'h'\o,,,o, er
(Title)
3. Mailing address: 13 2 9 Ika ze\1 MA\ 1Z000\ City W4M negv',\\ 2
State: NL zip cc&, 28:48(o. Phone:f8281
IL LiE«' OWNFRrNdlt. F TNFORh ATTON
I. This reruest for a name change is a result of:
-La' Change n ownashiP of Propeny/company
_b. Name change only
_c- •Other(please explain).
2. New owner's name (name to be put on permit);B\.J
3. New owner's or signing official's name and titter_ t��'•\\'•o �o n
(Person legally responsible for permit)
W ci.nesd;
4. Nfailing address; l3 Q ck �oae\\ M'•\\Rc� City; Wc�
State:__ - �- Tp('-ode: 28 18 fo Phone: { 8 Z81 G4

PERMIT NAv
TIIIS APPLICATION PACKAGE WILL-NOT BE ACCEPTED BY THE DIVISION OF
ENVIRONMENTAL MANAGEMENT-UNLESS ALL OF THE APPLICABLE ITEMS
LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED nj2a:
L This completed application
2. Pro=sing fee of S100.00 (Checks to be made payable to DEHNRT
3. If an ownership change,legal documentation of the ttansfa of ownership (such as a eootract,deed,
articles of incorporation)
CERTIFICATION MUST BE COMPLETED AND SIGNED EY BOTH THE CURRENT
PERMIT HOLDER AND THE NEW APPLICANT IN THE CASE OF CHANGE OF
OWNERSHIP. FOR NAME CHANGE ONLY COMPLETE AND SIGN THE
APPLICANT'S CERTIFICATION.
Current Permittee's Certification:
attest that this application for name/ownership change his b=n
reviewed and is accuratic and complete to the best of my knowledge. I understand that if all required parts
Of this applicarion_araaot c�otapleted'and that if all required supporting information and is are not
included,this application p, a will be returned as incomplete.
Signature: Ii Date: J 7
Applicant's Cc r ICrcation:
1• attest that this application for a nameJownership change has been
renewed and is accurate and complete to the best of my knowledge. I understand that if all required parts
Of this applicariotr are not completed and that if all required supporting information and attachments are not
included this ap�lic a pac!<age will be tetumed as incomplete.
Signature / / ✓ Daum 5/11/99
l
THE COMPLETED APPLICATION PACKAGE,INCLUDING ALL SUPPORTING INFORMATION
AND MATERIALS,SHOULD BE SENT TO THE FOLLOWING ADDRESS:
North Carolina Division of Environmental Management
Water Quality Section
Permits and Engineering Unit
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Telephone: (919) 733-5083
Fax: (919) 733-0719

F!Departmer
o of North Carolina
t of Environment
Natural Resources ���
Division of Water Quality
L
James B. Hunt, Jr., Governor N �,D E N R
Bill Holman, Secretary
Kerr T. Stevens, Director
October
Mr. Gordan Jones
Blue Ridge Paper Products,Inc. N
710 Howell Mill Road tER F
Waynesville, North Carolina 28786 SNEfw�``
S Permit Modification-Name and
Ownership Change
Blue Ridge Paper Products,Inc.
Permit No. NCG500151
(formerly Champion Intl-Waynesville Plant)
Haywood County
Dear Mr. Jones:
In accordance with your request received May 18, 1999, the Division is forwarding the subject
permit. The changes in this permit are only with regard to a name and an ownership. All other terms and
conditions in the original permit remain unchanged and in full effect. This permit modification is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U. S. Environmental Protection Agency dated December 6,
1983.
This permit does not affect the legal requirement to obtain other permits which may be required by
the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area
Management Act, or any other Federal or Local government permit that may be required.
If you have any questions concerning this permit,please contact Ms. Vanessa Wiggins at telephone
number [phone], extension 520.
Sincerely,
ORIGINAL SIGNED BY
WILLIAM C. MILLS
Kerr T.'Stevens
cc: Central Files
(Asheville Regtona'Office:,Water Quality Section —1
Stormwater and General Permits Unit
Point Source Compliance Unit
1 1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10%post-consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG500000
CERTIFICATE OF COVERAGE No. NCG500151
TO DISCHARGE NON-CONTACT WATER,COOLING TOWER AND BOILER BLOWDOWN,
CONDENSATE,EXEMPT STORMWATER,COOLING WATERS ASSOCIATED WITH HYDROELECTRIC
OPERATIONS, AND SIMILAR WASTEWATERS UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act,as amended,
Blue Ridge Paper Products,Inc.
is hereby authorized to discharge(non-contact cooling water from a facility located at
Blue Ridge Paper Products,Inc.
710 Howell Mill Road
Waynesville,NC
Haywood County
to receiving waters designated as subbasin 40305 in the French Broad River Basin
in accordance with the effluent limitations,monitoring requirements,and other conditions set forth in Parts I,II,III
and IV hereof.
This Certificate of Coverage shall become effective October 11, 1999.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day October 11, 1999.
ORIGINAL SIGNED BY
WILLIAM C. MILLS
Kerr T.Stevens,Director
Division of Water Quality
By Authority of the Environmental Management Commission

Making ur mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
August 18, 1999 l
Ira
pUG 1 91
Mr. Keith Haynes g1 vi SE IM'
Environmental Specialist WpSER REGMN OFFICE
NC Department of Natural Resources pSHE1IL�
Water Quality Section
59 Woodfin Place
Asheville, NC 28801
RE: Water Quality Data
Dear Keith:
As requested,please find attached water quality data for:
1) Monthly Average COD and Color
2) Primary Influent Color Balance
3) Secondary Effluent Color
If you have any questions on this information you can contact me at(828) 646-2033.
Sincerely, 1
ufmvwjg�
Robert V. Williams
Manager
Environmental Health&Safety
175 Main Street • P.O. Box 4000 • Canton, North Carolina 28716 • 828-646-2000

EOHS Dept. [phone] 8/17/99.
Monthly Average COD and Color: Jan 1998 -July 1999
Date COD mg/L Colorlbs/day
Jan-98 144 49,812
Feb-98 136 56,295
Mar-98 113 54,450
Apr-98 139 52,770
May-98 117 42,268
Jun-98 120 43,795
Jul-98 138 62,063
Aug-98 142 50,590
Sep-98 146 51,414
Oct-98 158 50,575.
Nov-98 178 68,542
Dec-98 101 42,073
Jan-99 94.3 41,419
Feb-99 102 39,635
Mar-99 98.4 42,846
Apr-99 96.5 37,676'
May-99 118 42,608
Jun-99 78.3 36,688
Primary Influent Color Balance: January 1999 - June 1999
Lbs/day % of Total
Digesters, No. 1 FL (Hardwood) 6570 12.04%
No.1/2 Eo, No.2 FL (Pine) BSW,OZ Delig. 12222 22.41%
Paper Machines- 11 & 12 2015 3.69%
Recovery, BLO,CRP 13279 24.34%
1&2 FL's D1 + Pine D2 (Bleach Plants) 15797 28.96%
Evaporator Condensates 2786 5.10%
Unaccounted (sewer generated) 1879 3.45%
Blue Ridge Paper Products, Inc.
Canton, NC

EOHS Dept. [phone] Color Data 8117/99
Date SE Col. Ibs/day Date SE Col. Ibs/day Date SE Col. Ibs/day Date SE Col. Ibs/day
01-Jan-98 44,719 20-Feb-98 53,050 11-Apr-98 42,878 31-May-98 31,972
02-Jan-98 47,082 21-Feb-98 47,835 12-Apr-98 42,152 01-Jun-981 50,353
03-Jan-98 37,485 22-Feb-98 51,03E 13-Apr-98 37,094 02-Jun-981 24,743
04-Jan-98 38,594 23-Feb-98 63,195 14-Apr-98 35,4891 03-Jun-981 31,274
05-Jan-98 47,890 24-Feb-98 59,361 15-Apr-98 35,043 04-Jun-981 32,822
06-Jan-98 55,827 25-Feb-98 54,284 16-Apr-98 44,8441 05-Jun-981 30,607
07-Jan-98 69,034 26-Feb-98 50,852 17-Apr-98 46,622 06-Jun-98 27,431
08-Jan-96� 61,153 27-Feb-98 45,363 18-Apr-98 46,685 07-Jun-98 33,534
09-Jan-98 47,677 28-Feb-98 45,163 19-Apr-98 48,044 08-Jun-981 37,924
10-Jan-98) 46,0351 01-Mar-981 42,799 20-Apr-981 58,992 09-Jun-98 55,326
11-Jan-98 47,149 02-Mar-98 99,714 21-Apr-98( 231,862 10_Jun-981 56,859
12-Jan-98 45,758 03-Mar-981 233,853 22-Apr-981 126,3271 11-Jun-981 56,812
13-Jan-98 46,054 04-Mar-981 139,842 23-Apr-981 71,6941 12-Jun-98 45,092
14-Jan-98) 44,722 05-Mar-98 57,533 24-Apr-98 51,041 13-Jun-98 46,856
15-Jan-98 43,239 06-Mar-98 42,3391 25-Apr-98 44,853 14-Jun-98 47,964
16-Jan-98 52,810 07-Mar-98 37,266 5- PE-
37,881 15-Jun-98 47,560
17-Jan-981 49,9451 2 -Mar-98 34,101 27-Apr-98 40,5641 16-Jun-98 46,841
18-Jan-98 43,4081 09-Mar-98 39,289 28-Apr-98 42,698 17-Jun-98 55,485
19-Jan-98E 52,5071 10-Mar-98 42,681 29-Apr-98 50,539 18-Jun-98 41,362
t22-J
Jan-98f 52,9051 11-Mar-981 48,6441 30-Apr-981 44,254 19-Jun-98 33,733
Jan-981 54,765 12-Mar-98 45,380 01-May-98 44,211 20-Jun-98 34,594
an-981 61,517 13-Mar-98 46,1331 02-May-981 40,615 21-jun-981 36,166
23-Jan-981 49,925 14-Mar-981 41,807 03-May-98 40,361 22-Jun-981 46,148
24-Jan-98( 51,5501 15-Mar-98 40,130 04-May-98 45,462 23-Jun-981 42,837
25-Jan-98M 49,169 16-Mar-98 49,244 05-May-98 34,969 24-Jun-98 43,646
26-Jan-98 51,119 17-Mar-981 43,073 06-May-98) 39,269 25-Jun-98 46,082
27-Jan-98 48,952 18-Mar-98 40,296 07-May-98 45,363 26-Ju2-98 _.35,589
28-Jan-98 46,852 19-Mar-98 47,337 08-May-98 43,669 27-Jun-98 43,076
29-Jan-98{ 57,255 20-Mar-98 40,224 09-May-98 42,406 28-Jun-98 47,614
30-Jan-98! 50.644 21-Mar-98 39,602 10-May-981 64,654 29-Jun-98 54,571
31-Jan-98) 48,420 22-Mar-98 51,9611 11-May-98 54,059 30-Jun-98 80,946
01-Feb-98 46,693 23-Mar-981 51,5211 12-May-981 49,690 01-Jul-98) 51,412
02-Feb-96 50,742 24-Mar-98 49,8211 13-May-98 37,7541 02-Jul-98 44,329
03-Feb-981 62,304 25-Mar-981 43,209 14-May-98 38,6051 03-Jul-98 37,239
04-Feb-981 63,088 26-Mar-981 44,150 15-May-98) 49,680 04-Jul-98 41,723
05-Feb-98 55,696� 27-Mar-98 38,472 16-May-98 45,175 05-Jul-981 47,868
06-Feb-981 61,872 28-Mar-98 42,159 17-May-98 41,8521 06-Jul-98 56,897
07-Feb-98 55,409 29-Mar-98 37,678 18-May-981 42,214 07-Jul-98 24,475
08-Feb-981 57,930 30-Mar-98 37,565 19-May-981 43740 28-Jul-98 44,332
09-Feb-981 52,286 31-Mar-98 40,122 20-May-981 45,,294 09-Jul-98 45,039
10-Feb-981 61,544 01-Apr-98 39,366 21-May-981 36,204 10-Jul-98 45,767
11-Feb-98 58,277 02-Apr-98 _ 40.986 22-M2y-98 39,6361 11-Jul-98 61,989
12-Feb-981 50,61E 03-Apr-98 41,264 23-May-98 31,981 12-Jul-98 79,466
13-Feb-98 64,530 04-Apr-98 39,167� 24-May-98 33745 13-Jul-98 50,314
14-Feb-981 57,609 05-Apr-98 34,902 ,
25-May-98 39,739 14-Jul-98 40,227
15-Feb-981 53,557 06-Apr-98 42,6981 26-May-98 49,499 15-Jul-98 49,949
16-Feb-98 55,051 07-Apr-98 41,7971 27-May-98 42,140 16-Jul-98 50,016
17-Feb-98 54,20E O8-Apr-98 39,384 28-May-98 45,632 17-Jul-98 49,825
18-Feb-98 78,112 09-Apr-98 42,215 29-May-98 36,79E 18-Jul-98 51,498
19-Feb-981 66,592 10-Apr-98 41,766 30-May-981 33,6201 19-Jul-98 59,037
Blue Ridge Paper Products, Inc. Canton, NC

EOHS Dept. [phone] Color Data 8117/99
Date SE Col. Ibs/day Date SE Col. Ibs/day Date SE Col. Ibs/day Date SE Col. Ibs/day
20-Jul-98 57,634 08-Sep-98 56,220 28-Oct-98 58,689 17-Dec-98 41,153
21-Jul-981 59,034 09-Sep-98 51,925 29-Oct-98 49,222 18-Dec-98 36,862
22-Jul-98 59,1581 10-Sep-98 52,317 30-Oct-98 51,258 19-Dec-981 34,496
23-Jul-98 60,159 11-Sep-98 57,121 31-Oct-98 50,815 20-Dec-98 32,120
24-Jul-98 57,935 12-Sep-98 45,329 01-Nov-98 50,220 21_Dec-981 42,951
25-Jul-981 511,862 13-Sep-98 44,592 02-Nov-98 63,9981 22-Dec-98E 46,267
26-Jul-98 55,383) 14-Sep-98 48,415 03-Nov-98� 49,991 23-Dec-98 47,880
27-Jul-981 52,050 15-Sep-911 48,233 04-Nov-981 50,096 24-Dec-98 52,602
28-Jul-98 52,887 16_Se
p-98 42,224 05-Nov-98� 42,425 25-Dec-98 48,051
29-Jul-981 46,767 17-Sep-98 43,599 06-Nov-98 45,835 26-Dec-98 41,566
30-Jul-981 57,280 18-Sep-98 90,443 07-Nov-98 51,251 27-Dec-98 45,446
31-Jul-98 65,423 19-Sep-981 50,803 08-Nov-98' 53,269 28-Deo-981 49,370
01-Aug-98 57,295 20-Sep-98 52.893 09-Nov-98 60,761 29-Dec98 37,036
02-Aug-98# 50,104) 21-Sep-98 59.494 10-Nov-981 52.9631 30-Dec98 38,863
03-Aug-98 34,483 22-Sep-981 45,424 1 I-Nov-981 47,857 31-Deo-98 42,881
04-Aug-98 35,898 23-Sep-98 48,957 12-Nov-981 47,512 01-Jan-99 42,623
05-Aug-98 33,317 24-Sep-981 51,019 13-Nov-98 54,830 02-Jan-99 38,604
06-Aug-98 41,124 25-Sep-981 48,912 14-Nov-98 46,8621 03-Jan-99 39,236
07-Aug-98 55,349 26-Sep-98 55,279 15-Nov-98 47,9781 04-Jan-99 39,223
08-Aug-98 53.488 27-Sep-98 43,397 16-Nov-98 63,4951 05-Jan-99 46,803
09-Aug-98 54,756 28-Sep-98 45,209 17-Nov-98 55,352 06-J2
2
-99 43,600
10-Aug-98 54,3841 29-Sep-98 48,020 18-Nov-98� 61,506 07-Jan-99 51,858
11-Aug-98 43,799 30-Sep-98 46,243 19-Nov-98 86,227 OS-Jan-99 54,781
12-Aug-98 42,424 01-Oct-98 56,241 20-Nov-98 62,937 09-Jan-991 44,318
13-Aug-98� 41,765 02-Oct-98) 41,405 21-Nov-98� 59,173 10-Jan-991 47,284
14-Aug-98E 42,769 03-Oct-98 33,6141 22-Nov-981 60.786 11-Jan-991 42,868
15-Aug-98( 47,743) 04-Oct-98 37.045 23-Nov-981 71,742 12-Jan-991 38,475
16-Aug-981 45,283 05-Oct-98 45,6771 24-Nov-98 70,1351 13-Jan-99 39,173
17-Aug-981 45,850 06-Oct-98 36,676 25-Nov-98 68.3471 14-Jan-99 36,579
18-Aug-98 47,699 07-Oct-98 53,470 26-Nov-98 95,6471 15-Jan-99 38,093
19-Aug-981 49,651 08-Oct-98 53.1011 27-Nov-98 77,0651 16-Jan-99 33 10
20-Aug-98 51,803 09-Oct-98 41,753 28-Nov-98 53,834 17-Jan-99 38,937
21-Aug-98E 54.961 10-Oct-98 46,720 29-Nov-98 59,304 18-Jan-99 38,572
22-Aug-98 62,499 11-Oct-98 45,941 30-Nov-98 64,8681 19-Jan-99 45,948
23-Aug-98 57,428 12-Oct-98 44,817 01-Dec-98� 48,074 20-Jan-99 39,626
24-Aug-98 72,716) 13-Oct-981 47,626 02-Dec98 49,6781 21-Jan-99 42,300
25-Aug-98 64,8161 14-Oct-981 45,431 03-Dec98 44,362 22-Jan-99 47,191
26-Aug-98 52,125 15-Oct-981 56,638 04-Dec-98 40,811 23-Jan-99 42,488
27-Aug-98� 50,9361 16-Oct-98 67,156 05-Dec-98 36,657 24-Jan-99 38,1021
28-Aug-98{ 39,940 17-Oct-981 74,210 06-Dec-981 36,190 25-jan-991 37,652
29-Aug-98) 46.014 18-Oct-981 66,291 07-Dec-981 56,323 26-Jan-991 33,024
30-Aug-98 77,869 19-Oct-981 54,862 08-Dec-981 48,148 27-Jan-991 31,764
31-Aug-98 60,0111 20-Oct-98 49.704 09-Dec-981 37,5891 28-Jan-99 34,212
01-Sep-98) 56,8311 21-Oct-981 43,962 10-Dec-98 42,297) 29-Jan-99 42,034
02-Sep-98 47,085 22-Oct-98 46,3851 11-Dec-98 40,138 30-Jan-99 47,867
03-Sep-98 46,881 23-0
ct-98 43,704 12-Dee981 39,191 31-Jan-99 45,260
04-Sep-98 35,299 24-Oct-981 47,199 13-Deo-98 35,912 01-Feb-99 54,732
05-Sep-981 44,903 25-Oct-98 65.155 14-Dec-981 40,753 02-Feb-99 52.767
06-Sep-981 70,748 26-Oct-98 53,025 15-Dec-98 37,110 03-Feb-99 44,392
07-Sep-98 65,570 27-Oct-98 60,023 16-Dec-98 33,484 04-Feb-99, 40,389
Blue Ridge Paper Products, Inc. Canton, NC

EOHS Dept. [phone] Color Data 8/17/99
Date SE Col. Ibs/day Date SE Col. Ibs/day Date SE Col. Ibs/day
05-Feb-99 37,558 27-Mar-991 35,881 16-May-991 45,538
06-Feb-99 36,875 28-Mar-991 39,830 17-May-991 44,573
07-Feb-99 36,294 29-Mar-991 71,857 18-May-991 43,746
08-Feb-99 38,013 30-Mar-991 100,993 19-May-991 39,221
09-Feb-991 35,631 31-M2r-99 52,697 20-May-991 36,596
10-Feb-991 44,633 01-Apr-99 43,491 21-May-99 32,144
11-Feb-991 48,894 02-Apr-99 34,320 22-May-99 35,155
12-Feb-991 68,943 03-Apr-99 32,181 23-May-99 38,033
13-Feb-99 43,656 04-Apr-99 29,484 24-May-99 39,211
14-Feb-991 39,057 05-Apr-99 30,487 25-May-99 54,945
15-Feb-99 46,553 06-Apr-99 35,823 26-May-99 46,169
16-Feb-99 35,608 07-Apr-99 37,744 27-May-99 58,8 66
17-Feb-99 31,723 08-Apr-99) 38,910 28-May-99 69,530
18-Feb-99' 33,297 09-Apr-99 37,272 29-May-99 57,389
19-Feb-99 34,099 10-Apr-99 42,689 30-May-991 31,172
20-Feb-991 32,151 11-Apr-99 38,665 31-May-991 26,232
21-Feb-991 34,679 12-Apr-99 37,980 01-Jun-991 29,298
22-Feb-991 38,378 13-Apr-99 32,320 02-Jun-991 35,230
23-Feb-991 31,369 14-Apr-991 35,084 03-Jun-991 34,062
24-Feb-99 34,915 15-Apr-99 33,697 04-Jun-991 31,632
25-Feb-99 34,488 16-Apr-99 38,379 05-Jun-991 28,224
26-Feb-99) 36,746 17-Apr-991 40,728 06-Jun-99 27,627
27-Feb-99 31,490 18-Apr-991 41,441 07-Jun-99 22,568
28-Feb-99 32,462 19-Apr-99 39,174 08-Ju2-99 24,573
01-Mar-99 34,538 20-Apr-99 38,701 09-Jun-99 27,519
02-Mar-991 51,197 21-Apr-99 36,908 10-Jun-99 31,590
03-Mar-991 49,3561 22-Apr-99 35,6471 11-Jun-99� 30,821
04-Mar-99 42,9921 23-Apr-99 42,207 12-Jun-99 36,656
05-Mar-99 47,0931 24-Apr-99 37,397 13-Jun-991 33,555
06-Mar-99 50,9361 25-Apr-991 40,212 14-Jun-99 40,200
07-Mar-99� 45,020 26-Apr-991 38,958 15-Jun-99 41,656
11
O8-Mar-99 40,716 27-Apr-99 47,700 16-Jun-99 38,140
09-Mar-99 39,552 28-Apr-991 34,520 17-Jun-99 36,786
10-Mar-99 35,505 29-Apr-991 44,216 18-Jun-99 39,845
11-Mar-99 38,057 30-Apr-99 33,935 19-Jun-99 41,537
12-Mar-99 38,510 01-May-99 29,512 20-Jun-99 43,029
13-Mar-991 38,653 02-May-991 29,3631 21-Jun-99 38,946
14-Mar-99 35,689 03-May-99 40,542 22-Jun-99� 46,609
15-Mar-99 37,221 04-May-99 60,294 23-Jun-99 47,469
16-Mar-99� 38,983 05-May-99 67,2751 24-Jun-99 48,810
11
17-Mar-99 36,955 06-May-991 59,089 25-Jun-99 44,4451
18-Mar-991 43,311 07-May-991 34,616 26-Jun-99 41,307
19-Mar-991 41,077 08-May-99 32,1121 27-Jun-991 40,230
20-Mar-99 40,547 09-May-99 29,234 28-Jun-99 32,8861
21-Mar-99 34,050 10-May-99 31,779 29-Jun-99 38,158
22-Mar-99) 35,848 11-May-99 42,540 30-Jun-99 47,235
23-Mar-99 26,633 12-May-99 41,558
24-Mar-99 31,262 13-May-99 39,561
25-Mar-99 35,0671 14-May-99 42,399
26-Mar-991 38,192 15-May-991 39,364
Blue Ridge Paper Products, Inc. Canton, NC

Blue Ridge Paper Products, Inc. COD data
©ate Seo)Eff(GOD rng/_I Date Seg EffjGOp /Ij
02-Jan-98 138 23-Oct-98 154
09-Jan-98 163 30-Oct-98 160
16-Jan-98 146 06-Nov-98 186
23-Jan-98 130 13-Nov-98 170
30-Jan-98 142 20-Nov-98 176
06-Feb-98 136 27-Nov-98 178
13-Feb-98 184 03-Dec-98 88
20-Feb-98 114 10-Dec-98 86
27-Feb-98 109 17-Dec-98 91
06-Mar-98 130 24-Dec-98 120
13-Mar-98 103 30-Dec-98 120
20-Mar-98 90 07-Jan-99 76
27-Mar-98 129 14-Jan-99 81
03-Apr-98 122 22-Jan-99 110
10-Apr-98 136 28-Jan-99 110
17-Apr-98 150 04-Feb-99 110
24-Apr-98 149 11-Feb-99 110
01-May-98 122 18-Feb-99 98
08-May-98 133 25-Feb-99 91
15-May-98 109 04-Mar-99 100
22-May-98 112 11-Mar-99 130
29-May-98 107 18-Mar-99 140
05-Jun-98 120 25-Mar-99 68
12-Jun-98 117 31-Mar-99 54
19-Jun-98 113 08-Apr-99 81
26-Jun-98 131 15-Apr-99 110
03-Ju1-98 124 22-Apr-99 100
10-Ju1-98 121 29-Apr-99 95
17-Jul-98 142 06-May-99 120
24-Jul-98 119 13-May-99 110
31-Jul-98 170 20-May-99 110
07-Aug-98 102 27-May-99 130
14-Aug
-98 136 02-Jun-99 100
21-Aug-98 154 10-Jun-99 59
28-Aug-98 137 17-Jun-99 73
04-Sep-98 106 24-Jun-99 81
11-Sep-98 172
18-Sep-98 152
25-Sep-98 154
02-Oct-98 180
9-Oct-98 107
16-Oct-98 189
EOHS Dept. [phone] Canton, NC 8/17/99

N. C . DEPARTMENT OF ENVIRONMENT AND
e`"`�Aa NATURAL RESOURCES
H.Y 30.1�
DIVISION OF WATER QUALITY
- WATER QUALITY SECTION
o ASHEVILLE REGIONAL OFFICE
c 59 WOODFIN PLACE
��# "^' "" •� ASHEVILLE, NORTH CAROLINA 28801
PHONE : [phone] FAX: [phone]
TO : � OC�
FAX # :
FROM:
DATE:
# OF PAGES INCLUDING THIS COVER:
MESSAGE : If questions , please call 828/251-6208 .

Making(Our mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
John J. Pryately
Supervisor Laboratory & WWTP
Pulp, Recovery, & Utilities Dept.
Blue Ridge Paper Products Inc.
P.O. Box 4000
Canton,North Carolina 28716
July 19, 1999
Dwight Lancaster �9
CS Technical Assistance & Certification Unit
WPOC
P.O. Box 29535
Raleigh,North Carolina 27626-0535 AP�����``�
ps
Dear Mr. Lancaster:
This is to inform you that I have been appointed the ORC of Blue Ridge Paper Product's
Canton facility, effective July 12, 1999. I have been filing the ORC position on an
interim basis since April 4, 1999. My back-up operators are Harold Sweitzer, Gale
Goodman, and Mike Henson.
Blue Ridge Paper Products Inc. purchased the Canton mill from Champion International
Corporation on May 14, 1999.
If you require additional information, I can be contacted at 828-646-6720.
Sincerely,
J�Pryatel (Cert. No. 14109)
Harold Sweitzer(Cert.No. 15191)
Mike Henson (Cert. No. RC1371) ` �/• Give,/_
Gale Goodman (Cert.No. 9233) o •v,�
175 Main Street • P.O.Box 4000 Canton, North Carolina 28716 828-646-2000

CC:
Keith Haynes, NCDENR, Asheville
Forrest Westall,NCDENR, Asheville
Derric Brown, Blue Ridge Paper Products Inc.
Steve Single, Blue Ridge Paper Products Inc.

l
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
•^; •�' DIVISION OF WATER QUALITY
AsHEVILLE REGIONAL OFFICE
I � t leF September 7, 1999
a"-vC t
198
w':IAMES B.HUNTJR'.: �.
i..,JGPVERNoti .L�9
�- • ' ?�'� MR. STEVE SINGLE
BLUE RIDGE PAPER PRODUCTS WWTP LAB
. a 3 P.O. BOX 4000
!WAcoEv A
CANTON, NC 28716
CA
a •
SUBJECT: Wastewater/Groundwater Laboratory
Certification Laboratory Manager Requirements
Dear Mr. Single:
Our records indicate that you were named the laboratory
x Y Y
manager of the Blue Ridge Paper Products
Laboratory in a letter, dated August 27, 1999,. sent to our office
_ by the above laboratory. Enclosed is a copy of the
Wastewater/Groundwater Laboratory Certification Rules. The
•.a�. : requirements for a laboratory manager are found on page five and
six, Section .0805 (a) (4) . The most important requirements of the
laboratory manager are:
n:•.
U. (1) Notifying the State Laboratory of changes in the
laboratory supervisor within thirty days of such changes.
,U° •� tt1 (2) Insure that any new supervisors meet the requirements
' of the Laboratory Certification Rules.
.' y The requirements for a laboratory supervisor are found on
NV laboratory
page five, Section .0805 (a) (3) . Please be aware that, any time a
N-'_��ly��•� laboratory employs a new laboratory supervisor, the new employee
a. must meet the requirements in Section .0805 (a) (3) (A)or(B) .
Y Failure to meet the requirements of the Rules may result in
enforcement actions.
sSeR'.yre��
" Contact us at (828) 251-6208 extension 285 if you have
questions or need additional information.
Y At •nA.'i%a��
�,- •_'4�'°„'�"t.��, '"1' Sincerely,
Y 1 Gary Francies
9".r Laboratory Section
a0. te#err
cc: James W. Meyer
L . -d •.>"Y"-'m - Marilyn Deaver
(, .d^'W Y,.+•\ sw^'° INTERCHANGE BUILDING, 59 WOODFIN PLACE• ASHEVILLE• NC 2 880 1-24 1 4
PHONE 828-2S1-6208 FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10 POST-CONSUMER PAPER

SEP-03-1999 12:07 FROM DEM CHB115 RY LABOR4T012Y Tp RRO P.01/01
aking(17r mark for you.
SLVB RIDGE PAPER-P20DUCTS INC. ' ti
SEP S .
Certification Number 198 DtiVQ August 27, 1999'
-Mr.James W. Meyer LR$ORATQRY BEcTroN
DWQ Laboratory Section
DENR
1823 Mail Service Center
Raleigh, North Carolina 27699-1623
Subject Laboratory Certification Maintenance inspection Response to
i
August23, 1999 Letter and July 28, 1999 Inspection Report
Dear Mr.Meyer.
The laboratory inspection report from July 28, 1999 :by Mr. Gary W. Francles
contained a comment that needed a reply. This correspondence is the response to
i your letter dated August 23,1999 and received August 27, 1999 that includes the
repy to the comment.
COMMENT.On May 10,1999,we were notified thatthe facility's laboratory manager,
Mr. Mite Cody, had taken another position. We have not received notification of his
replacerneut.
REQUIREMENT: It is required that a Certified laboratory provide the State
Laboratory with written notice of laboratory manager changes within thirty days.
i
RESPONSE: The laboratory manager for Blue Ridge Paper Products Inc_ WWTP
laboratory is Mr. Steve Single. Mr. Single's title is Pulp, Recovery, & Utilities
Manager. He can be contacted by, phone at 828-626-2268 or by fax at 828f46-
2980.
If you have any questions, comments, or need additional information, I can be
contacted by phone at 828-646-6720 or by fax at 82&646-2993.
Sincemy,
' Post 'Fm rJO1B �767;1
Fn 93 94
is
ov
John J:Pryately COMML O c°
Laboratory&WWTP Supervisor Pnonei ai
301i30 IVN01938 3111A38Sr
N01133S A801tl808tl1
175 Main Street • P.O.Box 4000 Cantw_N Caro 9871R • .
TOTRL P.01
6661 6

� J
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 23, 1999 DIVISION OF WATER QUALITY
198
NC�ENR , Mr. John J. Pryately
Blue Ridge Paper Products Inc.
`a P.O. Box 4000
JAMESB.HUNTJR...:;'•r.- Canton, NC 28716
GOVERNOR
ti:: sal
SUBJECT: Laboratory Certification Maintenance Inspection
_WAYNE MCDEV1tT Dear Mr. Pryately:
.'
SECRETARY `4 ;�!
; Enclosed is a report for the inspection performed on July 28, 1999 by
' Mr. Gary W. Francies. A response is not required if there were no violations
41
cited. A response is not required for comments or recommendations unless
' KERRT.STEVENS ,v�r, specifically requested. Please reply to comments, where requested, within
,•DIRE°TDR r.A thirty days of receipt of this report. We appreciate the fine job you and your
staff are doing. As a certification requirement, your laboratory must continue
y '%1 to carry out the requirements set forth in 15A NCAC 2H .0800.
ZY
Copies of the checklists completed during the inspection may be
requested from this office. Thank you for your cooperation during the
inspection. Please contact us at 919-733-3908, if you have questions or
need additional information.
j Sincerely,
is j James W. Meyer
'` T? Laboratory Section
ys: Enclosure
cc: Marilyn O. Deaver
R�
Gary W. Francies (�S'
AUG
a. LAB SECiIy
ORATORY
ASHEVILLE REGIO� � NAL OFFICE-
LABORATORY SECTION
4405 REEDY CREEK ROAD, RALEIGH, NORTH CAROLINA 27607-6445
• ^ PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 Oq POST-CONSUMER PAPER

ON- SITE INSPECTION REPORT
LABORATORY NAME: Blue Ridge Paper Products WWTP Laboratory
ADDRESS : P.O. Box 4000
Canton, NC 28716
CERTIFICATE #: 198
DATE OF INSPECTION: 7/28/99
TYPE OF INSPECTION: Maintenance
EVALUATOR(S) : Gary Francies
LOCAL PERSON(S) CONTACTED: John Pryately, Melanie Hager
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the
requirements of 15A NCAC 2H . 0800 for the analysis of environmental
samples .
II. GENERAL COMMENTS :
The laboratory is spacious and well equipped. All equipment is well
maintained. Records are well kept and most data appeared accurate .
III . VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS :
COMMENTS : On May 10, 1999, we were notified that the facility' s
laboratory manager, Mr. Mike Cody, had taken another position. We have
not received notification of his replacement .
REQUIREMENT : It is required that a certified laboratory provide the
State Laboratory with written notice of laboratory manager changes
within thirty days . Ref : 15A NCAC 2H . 0805 (c) (5)
A written response to this item is requested.
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory
bench sheets and contract lab reports to DMRs submitted to this
Division. Data were reviewed for these months : September 1998, March
and June 1999 . The following errors were noted:
Date Parameter Location Value on Value on
Lab Report DMR
3/10/99 Hg Effluent < 0 . 2 ug/l 0 .2 ug/l
3/22/99 Hg Effluent < 0 . 2 ug/l 0 . 2 ug/l

Page 2
In order to avoid questions of legality, it is recommended that
amended DMRs be submitted to this Division.
It appears the facility is doing a good job of accurately transcribing
data .
V. CONCLUSION:
This laboratory is doing a good job overall . The staff is
congratulated for doing an excellent job of maintaining the laboratory
program.
Report prepared by: Gary Francies Date : 8/10/99

(,?
Making ur mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
John J. Pryately
Supervisor Laboratory & W WTP
Pulp, Recovery, & Utilities Dept.
Blue Ridge Paper Products Inc.
P.O. Box 4000
Canton,North Carolina 28716
July 19, 1999
Dwight Lancaster D ~~
DEHNR Technical Assistance &Certification Unit ,2�
WPCSOCC
P.O. Box 29535 QUF��ZV Sp4to�4,CE
Raleigh, North Carolina 27626-0535
Dear Mr. Lancaster:
This is to inform you that I have been appointed the ORC of Blue Ridge Paper Product's
Canton facility, effective July 12, 1999. I have been filing the ORC position on an
interim basis since April 4, 1999. My back-up operators are Harold Sweitzer, Gale
Goodman, and Mike Henson.
Blue Ridge Paper Products Inc. purchased the Canton mill from Champion International
Corporation on May 14, 1999.
If you require additional information, I can be contacted at 828-646-6720.
Sincerely,
/4
John J. el (Cert. No. 14109)
Harold Sweitzer (Cert.No. 15191)
Mike Henson (Cert.No. RC1371)
Gale Goodman (Cert. No. 9233) /I
175 Main Street • P.O.Box 4000 • Canton, North Carolina 28716 • 828-646-2000

CC:
Keith Haynes, NCDENR, Asheville
Forrest Westall,NCDENR, Asheville
Derric Brown, Blue Ridge Paper Products Inc.
Steve Single, Blue Ridge Paper Products Inc.

Making ur mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
July 9, 1999 s!r
Mr. Keith Haynes
North Carolina Department of / 219,99
!;
Environment and Natural ResourcespU,
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: July 31 Dissolved Oxygen Measurement
Dear Mr. Haynes:
Blue Ridge Paper Products, Inc. is providing written notification as follow-up to Chris
Leitsch's voicemail message of July 5, 1999 at 1:20pm. Mr. Leitsch's message was in
reference to the July 3, 1999 dissolved oxygen (D.O.) measurement of 4.80 mg/I taken
Below Clyde at river mile 55.5. The corresponding D.O. upstream of Canton was 4.96 mg/l,
which is above the minimum instantaneous limit of 4.00 mg/I but below the minimum daily
average limit of 5.00 mg/I. While the Canton mill's secondary effluent D.O. at this time was
8.76 mg/I,well above our minimum limit of 6.00 mg/I, the effluent oxygen injection was
increased as a preventive measure.
The Dissolved Oxygen Meter was recalibrated after the July 3rd measurement and, though
no quality control problems were discovered, the probe was changed before the July 41
2:55am readings. The July 41h measurements upstream of the mill and Below Clyde were
7.05 mg/I and 6.61 mg/I respectively,which were more reflective of the past month's
averages of 7.29 mg/I upstream and 7.16 mg/I Below Clyde. The average of the July 31,
9:30am measurement and the July 4'", 2:55am measurement was above 5.00 mg/I.
If you need further information regarding this issue, please contact me at 646-6749, or Derric
Brown at 646-2318.
Sincerely,
/1
Melanie S. Hager
Associate Environmental Engineer
cc: Derde Brown
John Pryately
Steve Single
Bob Williams
Blue Ridge Paper Products,Inc. •P.O.Box 4000. 175 Main Street•Canton,NC 28716 •[phone]

r � ' • „ NORTH CAROLINA DEPARTMENT OF
a;•1 '" n ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
"r WATER QUALITY SECTION
4
Fs�NCDENR a r
May 18, 1999
,II JAMESB HUNTJR..,
GOVERNOR {'
Mr. Derric Brown
Blue Ridge Paper Products Inc.
G.Y
Post Office Box 4000
fWAYNE MCDEVIT•I' Canton, North Carolina 28716
'L bECRETARY
. '•; Subject: Acceptance of Activated Sludge
R STEVENSFrom Maggie Valley WWTP
�KERT.
D1Ra NPDES Permit No. NC0000272
K
Haywood County
Y
Dear Mr. Brown:
aF : This Office does not foresee a problem with your waste
tr water treatment accepting activated sludge from the Town of
Maggie Valley. It is suggested that you maintain a record of
all sludge received including the date and number of gallons .
If you have any questions concerning this matter or if you
� , . require additional information, please do not hesitate to
.• contact me at 251-6208 .
1 � A
Sincerely,
D. Keith Haynes
Environmental Specialist
Matthews
`a 4
b v.y bluermv.let
1 4 S k- L1rty.�2
INTERCHANGE BUILDING, 59 WOOOFIN PLACES ASH EVILLE. NE 28801-# 2414
t5y. , Lh �j.'u PHONE 828-2S1-62O8 FAX[phone]S2
....�a..__...u..wr W.L� •I AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10q POST-CONSUMER PAPER

NORTH CAROLINA DEPARTMENT OF
' ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
March 29, 1999
(fir r� 4.2 w�a r• - •
W A.
^.-E5B HUNT SR A`�{' 198
GOVERNOR MR. JOHN PRYATELY
CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX 4000
. - CANTON, NC 28716
WAYNE.MCDEVITT
SECRETARY
Y_-
�,
Dear Mr. Pryately:
15
r a
Your laboratory participated in the 1998 EPA DMRQA STUDY 18
rp
�Aypi,,irEs%Howu+o.lR v; evaluation. The study did not include samples for all certified
aE�;D1RecToa �l / parameters. Those samples are enclosed.
N•1 ^ Sy °s �� Evaluation Samples
�.. (X) Residue, Total
1
(X) Residue, Dissolved 180, C
(X) Color PC
(X) Conductivity
Sample Type
(X) Required Samples
k _:k
i 6 Under provisions of the Laboratory Certification Regulation 15
_ NCAC .0807 (b) (6) , you must return a copy of the results of your
determinations for these samples within thirty days of receiving
them. Extensions beyond thirty days will not be given.
Decertification may be recommended for laboratories not meeting
the deadline for reporting results.
Please contact us at 828-251-6208 ext. 285 if you have questions
or need additional information.
Sincerely,
�ya2i/eL4s�
rr. Laboratory Section
�r� �•- Enclosure -
' cc: James W. Meyer _
*_,..xfy``-� µ•Ya,�'w .' T h - '1 rr _ ..CF:
INTERCHANGE BUILOINO,58 WOOOFIE PLACE,I-6208 LL EA NC X826801-2414
h!} - PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-50%RECYCLED/10q POST-CONSUMER PAPER

„ QJ Box C-10
Canton,North Carolina 28716
Champion
Champion International Corporation
December 15, 1998
Forrest R. Westall
Regional Water Quality Supervisor
NC Department of Environment and Natural Resources
Division of Water Quality, Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
RE: NPDES Permit No. NC0000272
Dear Mr. Westall:
Champion International Corporation's Canton Mill has an on-going process improvement
effort to reduce effluent color emissions. In support of this commitment, an additional
opportunity for color reduction has been identified for the hardwood secondary knotter
accepts tank overflow.
The control strategy for minimizing color losses from the hardwood secondary knotter
accepts tank overflow line is detailed in Section 4.6.1 of the June 1,"1998 Color Technology
Measures Report”, that was submitted to you on May 27, 1998. The current control strategy
on this tank employs a temperature probe in the overflow line. If a tank overflow occurs, the
increase in temperature is detected by the temperature probe and a process signal .
immediately alarms the hardwood brownstock operator station and appropriate action is
taken.
Planned improvements are underway to relocate the accepts tank overflow line into an
existing sump in the hardwood brownstock washing building. This will improve color
containment and the temperature probe will no longer be required for operator notification. A
sump conductivity probe will be used for operator notification in the future.
Please accept this as notification of the removal of the temperature probe and
implementation of an improvement to mill color control. If you have any questions or
concerns, please contact me at [phone] by January 6, 1999.
Sincerely,
ff / J
�Ob
Robert V. Williams
Manager
Environmental, Occupational Health and Safety � �

-, NORTH CAROLINA DEPARTMENT OF
I ' ENVIRONMENT AND NATURAL RESOURCES
M
DIVISION OF WATER QUALITY
VXASHEVILLE REGIONAL OFFICE
NCDENRr; May 26, 1999
JAMES B.HUNTJR.-'---"
GOVERNOR 198
4 MR. JOHN PRYATELY
CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX 4000
CANTON, NC 28716
WAYNE MCDEVITT. =•.(`+.[
SECRETARY
Dear Mr. Pryately:
We have evaluated results from your analysis of the wastewater
groundwater laboratory certification performance samples we
ICERR T.sTEVENs_ ; -. received May 20, 1999.
DIRECTOR
I The information from this evaluation is summarized below:
- ry_.` rived
r5ryl
Am ul ID Anal)de Units Reported True Value Lower Limit Upper Limit Performance
NC366-F; mg/I TDS 180�C T _395:0 388 350 425 Accetable
o additional follow-up isrequired as all resultsare acceptable.
Contact us at (828) 251-6208 extension 285 if you have questions.
.1
.s
Sincerely,
Gary Francies
Laboratory Section
r
r ' cc: James W. Meyer
Marilyn Deaver
>' �she�5i3-. Wa -
EVAL.LTR
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801-2414
PHONE [phone] FA%828-251-6452
-� AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10q POST-CONSUMER PAPER

' t I NORTH CAROLINA DEPARTMENT OF
re' ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
to ASHEVILLE REGIONAL OFFICE
v ion
^� ���� 'y May 10, 1999
.,.JAME9H.HUNTJR. 198
.-GOVER,xNOR a
,1t MR. JOHN PRYATELY
CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX 4000
CANTON, NC 28716 -
e AY�MODEVIT'1' � -
" ;SEDR + Dear Mr. Pryately:
p We have evaluated results from your analysis of the wastewater
/ groundwater laboratory certification performance samples we
received April 19, 1999.
Ea ENIt
wcT� • The information from this evaluation is summarized below:
Am ul ID1 Analvte Units Re o rLjmftlUooerUmRj Performance
:..E..........................a...................._t....................;..................................................(........................i.................................<
NC297-F,€_Conducti�IY.JlltlhR3/.;;Mj .893:7...<.....__859........i......_805......_} 935
NC297 F TDS 180 C i _mgA•„•,_..-6550 ,,,.,237........•......_172,,,,_,,.# ,304 Unacceptable"
o
NC298 F Color FtCo i ou 101 100 85 115 Acceptable',,,,.;,
NC299-F: Total Solids-: mg/I•...... _4200 :.-_-,_463 345 595 n Acceptable' ;........ ....... ..........._ ..................
v. *No additional follow-up is required at this time.
1
y� **Another sample is enclosed for your analysis.
Decertification may be recommended if the .results of the enclosed
sample(s) are unacceptable.
' :.• __ Under provisions of the Laboratory Certification Regulation 15 NCAC
0807 (a) (8)., you must return a copy of ' the results of your
determinations for these samples within thirty days of receiving
I
them. Extensions beyond thirty days will not be given
Decertification may be recommended for laboratories not meeting the
deadline for reporting results. -.
_ Contact us at (828) 251-6208 extension 285 if you have questions.
"M"'
Sincerely,
Gary rancies -
Laboratory Section
✓3. 7' s°
- cc: James W. Meyer
�;::^�ia:� �; ..-s:s*•`c Marilyn Deaver '
��•'•'Y �l F�T. # INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801-2414
PHONE [phone] FAX 82a-251-6452
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST-CONSUMER PAPER

Canton Mill
P.O.Box 4000
Canton,North Carolina 28716
828 646-2000
UChampion
Champion International Corporation
April 23, 1999
Mr Forrest Westall
Supervisor
Water Quality Section
Division of Environmental Mgmt.
North Carolina Dept. of Natural Resources
59 Woodfin Place
Asheville, NC 28801 91999
j
Re: NPDES Permit No.NC0000272 as Eyil� �gliry
Part III - Section F, Item 1 R����Nq�0?,
Status of Bleach Filtrate Recycle Air Permitting F�cf
Dear Forrest:
The referenced section of the Canton Mill's NPDES permit requires the following:
By March 1, 1998 the permittee will submit a status report to the Division of
Water Quality and the NPDES Committee on the analyses prepared for other
permitting agency concerning the-effects of the BFRTMtechnology on air emissions.
For your record, this is the current status of BFRTm air permitting. Preliminary information
was submitted to the Division of Water Quality as required to meet the March 1, 1998
schedule. Recently the mill has completed and submitted post-BFRTm air emission testing
information to the Western North Carolina Regional Air Pollution Agency (WNCRAPA) to
support the air permitting process. At this time all copies of both pre- and post-BFRTm air
emission testing data resides as a public record at the WNCRAPA offices. The next step
in the air permitting process is for review and approval of the air toxics modeling
protocol. The North Carolina Division of Air Quality is currently conducting this review. As
soon as an approved modeling protocol is available, the air modeling will be completed.
The modeling result will allow for a permit application to be prepared and submitted for
final approval by the WNCRAPA Board.
The Canton Mill remains committed to operating BFRTm in conformance with all
appropriate water and air regulatory.requirements. Please contact me at (828).646-2033
if you,need further information on this subject. ,
Sincerely,
Robert V. Williams
Manager
Environmental, Occupational Health and Safety

Champion International Corporation
cc: Mr. Don Anderson
U.S. Environmental Protection Agency
Mail Code -4303
Room 915A, East Tower
401 Main Street, SW
Washington, D.C. 20460
Mr. Jim Cody
Director
Western North Carolina Regional Air Pollution Agency
49 Mt. Carmel Road
Asheville, NC 28806

l
„enlon rR) it an;l 28,16
U Champion
Champion oternational Corporation.
David M. Cody ORC
Superintendent Environmental and Laboratory
Services in Recovery&Utilities
Champion International
PO 4000
Canton,North Carolina 28716
March 31, 1999
Dwight Lancaster
DEHNR Technical Assistance and Certification Unit
WPCSOCC
PO Box 29535
Raleigh,North Carolina 27626-0535
Dear Mr. Lancaster:
This is to inform you that I have resigned my position of ORC of Champion International's Canton
facility effective April 4, 1999.John Pryately will be temporally filling my position. John has a
Grade LV operator's certification and has been my back-up for the last four years. John will be
backed up by Harold Sweitzer, Gale Goodman and Mike Henson.
Champion International will appoint a permanent ORC within 120 days.
Sincerely,
e
David M. Cody ORC (Cert.No. 4024)
John Pryately(Cert.No 14109)
Harold Sweitzer(Cert.No 15191
Mike Henson(Cert.No RC1371)
Gale Goodman(Cert.No 9233) C /9

Canton Mill Box ,o D l5 L5 V Canton,North Carolina 28716
�JANpp 191999
�III ASHEVIL E REGIONAL 0�FICE
V Champion
Champion International Corporation
January 14, 1999
Mr. Keith Haynes
NCDENR
Division of Water Quality
59 Woodfin Place
Asheville,NC 28802
RE: Petroleum Release at Champion's Canton Mill on January 12, 1999.
Dear Mr. Haynes:
Champion International is providing written notification of a release of less than 100
gallons of hydraulic oil from the Number 19 Paper Machine on the morning of January
12, 1999. The release resulted from a hydraulic pump being accidentally left on while
changing out a press roll. The release began at approximately 7:50 AM and the pump
was immediately shut down, thus stopping the release approximately two minutes later at
7:52 AM.
The release flowed directly into the in-mill sewer system which flows to the mill's
wastewater treatment plant where it was removed. None of the oil was released to the
Pigeon River.
If you need further information regarding this release please contact Chad Salisbury at
828-646-2874 or Jim Giauque at 828-646-2028.
Sincerely, F
Chad Salisbury Jim Giauque
Environmental ngineer Senior Environmental Engineer
ry ,"In r; . . ... .

Canton Mill
Box C-10
Canton.North Carolina 28716
Champion
Champion International Corporation
January 5, 1999
Mr. Bradley Bennett
Supervisor, Stormwater and General Permits
North Carolina Department of Environment and Natural Resources
PO Box 27687
Raleigh, NC 27611-7687
Subject : Stormwater Permit NCS000105 �` �
Champion Internationale
Canton, North Carolina
�_. JAN 2 6 1999
Data for 4th year of permit tvArFR unur�s iio`N AS' !"' RFG;., ,C' iFO CE
Dear Mr. Bennett:
Attached is Champion International Corporation's, Canton Mill, Stormwater
Permit No. NCS000105, analytical data for the1998 reporting year. The data is
submitted by January 31 as required by Part I, Section A, 2, d.
The cut off concentration has been met for the following parameters:
Year Cut-off
Parameter Concentration Met Outfall No
BOD 1995 3
COD 1995 9
TSS 1995 5C-17
TSS 1995 6-10
TSS 1997 56-20
FECAL 1995 1
Analytical monitoring specified in Part I, Section A, 2g,(1), footnotes, will be
completed as required in 1999.
If you have questions or need additional information, please call
[phone] or 646-2255.
Sincer I _
Louie Lneer
William Ch pm r CEM Maintenance Technician

Champion International Corporation
copy: Mr. Forest Wes tall
North Carolina Department of Environment and Natural Resources
Water Quality Section
59 Woodfin Place
Asheville, NC 28801
c:\flj\doc\strwate\monrpt98.doc

STORM WATER DISCHARGE OUTFALL(SDO)
MONITORING REPORT
PERMIT NO. NCS 000105 SAMPLES COLLECTED DURING CALENDAR YEAR: 1998
(all usaamples collected during a calendar year shall be reported no later than
FACILITY NAI11R_ _CH PPION INTERNATIONAL CORPORATION ry 31 or the following year) HAYWOOD
PERSON COLLECTING SAMPLES) WILLIAM CHA MAN COUNTY
CERTIFIED LABORATORY(S) HY Lab k 47
PHONE NO. —231
crxw
Lair k (SIGNA'rUR +OF PER 1'rTEE OR DESIGNEE)
By this signatu , lify that this report is accurate
Part A: Specific Monitoring Requirements complete to the best or my knowledge
Outrall Dale 50050 Total
No. Sample Total uspended Fecal
Collected Flow Solids
ino/dd/ r' r. . MG m .l'. b
1 7— — 0 .00 0 8.0
2 -8- 8 0 . 2 0 .0 > 00
7—, — 0- 1; 1 0 .0 > 21 00
I 7- - 0 . 008 8.0
-21-9 .
7 7- -O - 0 . 0 1 0.0
7 0 .0 11 .0
9 7- - 0 . 1 .0
- 7- - 0 .002 2 2.o
n C-
w >�
a Z mx
_c
coo (n_.o CJD
Page I of 2
l:onn MRNCS

.oes this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?_yes X no '
(if yes,complete Part B) — '
Part B: Vehicle Maintenance Acliv[l Monitorin Re uircmcnts
Outfall Date 50050 0055fi iRecoverable
51 38260 00400
No. Sample Total Flow. ; Oil and Crease d, Total Delergentc pH New Motor Oil
CMecicd ) (MBAs 2 Usage
mu/dd/ r MC m m unit nVmo
No vehicle maintenance activity conducted within any stormwater drainage area
Footnotes: -
I Applies only for facilities at which fueling occurs.
1
Detergent monitoring is required only at facilities which conduct vehicle cleaning operations.
\STORM EVENT CHARACTERISTICS:
Dale 7-8-48 Mail Original and one copy to:
Total Event Precipitation (inches): 0 .21 Attn:Central Files
Event Duration(hours): 1•0 DEI INR
Division of Environmental Mgt.
D more one storm event was sampled) P.O. Box 29535
Dale —2—21-98 Raleigh, NC 27626-0535
Total Event Precipitation (inches): Q . 35
Evenl Duration(hours): 0, 17
"I certify,under penalty of law,that(his document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the Information submitted. Based on my inquiry of the person
or persons who manage the system,or those persons directly responsible for gathering the information,the informalion submitted is,to the best
of my knowledge and belief, true,accurate,and complete. I am aware[hat there arc significant penalties for submitting raise information,
including the possibility of fines and imprisonment for knowing violations."
(Signature of Perm(llee) (Dale)
Page 2 of 2
Form MRNCS

Y f�
Making(Our mark for you. GORDON L.JONES
President and Chief Executive Officer
BLUE RIDGE PAPER PRODUCTS INC.
October 11, 1999
Mr. Forrest Westall, Sr.,P.E.
Water Quality Regional Supervisor
NCDENR
59 Woodfm Place
Asheville,NC 28801
Dear Forrest:
Thank you very much for taking the time to visit our corporate office.
I enjoyed our discussion and appreciated your candid thoughts. As I
mentioned during our conversation, our organization is very
committed to the environment and we look forward to working with
yo . Please give my regards to Keith Haynes and I hope that both of
y will visit us again soon.
4dsL,
. Jones
President and CEO
GLJ/bm
cc: George Henson
Bob Williams M {�
" ` SEyOfF�
1 West Pack Square,Suite 1100 • BB&T Building
Asheville, North Carolina 28801-3425 • Phone:[phone] • Fax:[phone]

BENEFITS AND COSTS FROM THE
REDUCTION OF COLOR EFFLUENT
FROM THE CHAMPION MILL
INTO THE PIGEON RIVER
n/eirrao

ieiria
NATIONAL ECONOMIC RESEARCH ASSOCIATES,INC.
CONSULTING ECONOMISTS
BENEFITS AND COSTS FROM THE REDUCTION
OF COLOR EFFLUENT FROM THE CHAMPION MILL
INTO THE PIGEON RIVER
PREPARED BY
NATIONAL ECONOMIC RESEARCH ASSOCIATES, INC.
AT THE REQUEST OF
CHAMPION INTERNATIONAL CORPORATION
REVISED APRIL 1988
A MARSH&MCLENNAN COMPANY
WHITE PLAINS,NY•WASHINGTON•LOS ANGELES•PALM BEACH•ITHACA,NY•LONDON

TABLE OF CONTENTS
Page
I. INTRODUCTION AND SUMMARY OF RESULTS 1
A. Introduction 1
B. Summary of the Economic and Employment 2
Impacts of Discharges from the Champion Mill
C. Evaluation of the Bach and Barnett Analysis 4
D. Organization of the Report 4
II. BENEFITS 4
A. Overall Approach 5
B. Rafting and Floating 7
C. Fishing and Sightseeing 13
D. Property Values 14
E. Apportioning Benefits 16
F. Nonuse Value 18
III. COSTS 21
A. 50 Percent Reduction 21
B. 50 Units at the Tennessee Border 22
C. 50 Units at the Mill 24
IV. COSTS AND BENEFITS 25
V. EMPLOYMENT CONSEQUENCES 27
VI. EVALUATION OF THE BACH AND BARNETT REPORT 30
A. Discounting 30
B. Indirect Benefits 31
C. The Costs of Color Reduction 34
D. Financial Impact on Champion 34
International Corporation
REFERENCES 35
1Le/1'/d®

BENEFITS AND COSTS FROM THE REDUCTION
OF COLOR EFFLUENT FROM THE CHAMPION MILL
INTO THE PIGEON RIVER
I. INTRODUCTION AND SUMMARY OF RESULTS
A. Introduction
Champion International Corporation owns and operates a paper mill at
Canton, North Carolina that is sited on the Pigeon River. The mill is about 37
miles upstream of the Tennessee and North Carolina border. The United States
Environmental Protection Agency (USEPA) has proposed an NPDES permit for the
mill that would significantly reduce the amount of color allowed to be discharged
from the mill into the Pigeon River. One of many submissions in this permit
proceeding was a report by Bach and Barnett entitled, An Economic Impact Analysis
on the Recreational Benefits of a Restored Pigeon River (see Reference [1]). This
study concluded that levels of reduction consistent with the April 1987 USEPA
proposal permit would be economic. In December 1987, USEPA published a second
proposal which limited color discharges even more severely than the April proposal.
At the request of Champion, National Economic Research Associates, Inc.,
an economic consulting firm specializing in energy and environmental economics,
evaluated the economic impacts of three color reduction strategies and also reviewed
and evaluated the Bach and Barnett report. First, we estimated the benefits and
costs under three strategies proposed to reduce color discharges from the Champion
mill. One of the plans was proposed by Champion; two were proposed by USEPA.
The most stringent plan (i.e., the December proposal by USEPA) would certainly
lead to plant shutdown. The less stringent USEPA plan would likely cause plant
shutdown. All the plans had costs significantly greater than benefits, and both
USEPA plans would have substantial unemployment impacts. However, Champion's
proposal yielded benefits that were closest to cost and exhibited small net gains in
employment. Second, based on our review and evaluation of the Bach and Barnett
n/e/r/w

-2-
analysis, we have concluded that there were several fundamental errors that
completely undermine their conclusion that substantial reductions in color discharges
could be justified on economic grounds.
B. Summary of the Economic and Employment Impacts of Reducing Color
Discharges from the Champion Mill
Table I summarizes our results. This table assumes that Champion would
take all actions technologically feasible to keep the plant open. The plan proposed
by Champion would reduce color discharges from the mill by 50 percent on a long-
term average basis. The costs associated with this program would be $38.4 million.
This is the present value of the costs over a 10-year period expressed in 1988
dollars. These costs would be over three times the benefits of $11.3 million. Thus,
an expenditure of one dollar achieves only 30 cents in benefits.
The two USEPA proposals would remove more color from the effluent
discharge but at substantially higher costs. Also, costs would exceed benefits by a
far greater margin than under Champion's proposal. Under the less stringent of the
two, which would consistently achieve less than 50 color units in the Pigeon River
at the Tennessee border, the cost would be $164.5 million, with corresponding
benefits of only $18.0 million. This results in a benefit of 11 cents per dollar of
expenditure. The more stringent proposal, contained in the second draft USEPA
permit, would limit discharges at the mill to 50 units of color. This proposed
effluent limit cannot be achieved with current technology and therefore would
require that the mill be shut down. The direct cost of this proposal would then be
the cost of building and operating a new facility in a different region net of any
operating and maintenance savings attributable to the new investment. We have
estimated these costs at approximately $290.0 million. The benefits under this
program would be $18.3 million. Thus, for every dollar of expenditure, this plan
would yield benefits of about one cent. These cost estimates do not include the
Tlih/I'ra

-3-
substantial economic and social cost impacts on the city of Canton, western North
Carolina or eastern Tennessee.
There are several reasons for the striking divergence between costs and
benefits. On the benefit side, only the relatively small stretches of the Pigeon
River which are immediately downstream of the Tennessee border have good
recreational potential. The whitewater rafting run of five miles is comparatively
short. The river is usable for rafting only when the `hydroelectric electric
generation demands at the Walter's Lake plant of Carolina Power and Light (CP&L)
result in adequate releases. Also, other factors unrelated to color tend to make the
river less attractive: the most scenic part of the river in North Carolina has
virtually no water in it at all and is not affected by color discharges from the mill
because of the CP&L water diversion tunnel; and low summer river levels,
particularly in North Carolina, restrict its suitability for most recreational activity.
On the cost side, the plant is already a low color producer in terms of
pounds of color effluent per ton of product. The incremental removal of color
requires increasingly more expensive and untested methods. The low river flows
make the achievement of the lowest level of color impossible without a complete
shutdown of the mill.
Employment is another measure of the impacts of the discharge reduction
plans. The Champion proposal would increase recreational-related employment in
Tennessee by 77 jobs. The other two plans would see net recreational employment
increases of about 123 jobs. Based upon U.S. Department of Commerce figures, the
50 percent reduction plan would increase the number of jobs in North Carolina by
176 jobs. If the mill were to shut down, as would be required under the USEPA
December proposal and would be likely under the earlier proposal, the loss of
employment in North Carolina would total over 12,000 jobs, with an added loss in
nle✓rlw

4-
Tennessee of over 800 paper-related jobs. Thus, under either USEPA proposal,
Tennessee would experience a net loss of almost 700 jobs.
C. Evaluation of the Bach and Barnett Analysis
Bach and Barnett estimate the direct and indirect recreational benefits
from reducing color discharges from the Champion mill to meet 50 color units at
the state line and the costs of achieving these benefits. Based on their analysis,
they conclude that reducing the color discharges to that level is justified on
economic grounds.
We have reviewed and evaluated their analysis and found it to be
seriously flawed. There are several key errors that cause them to incorrectly
conclude that the level of color reduction they evaluated would be justified on
economic grounds. They have failed to discount benefits and have overstated and
miscalculated indirect economic benefits. In addition, they have utilized company-
wide rather than plant-specific data to evaluate local impacts.
D. Organization of the Report
The remainder of the report is divided into five sections. Section II
describes the calculation of benefits. Section III discusses the costs of each plan.
Section IV compares the costs and benefits. Section V calculates employment
impacts. Section VI evaluates the Bach and Barnett analysis.
II. BENEFITS
This section discusses how the benefits from reducing color discharges
into the Pigeon River are calculated. We begin by describing our overall approach.
This is followed by a discussion of our estimates of the benefits from greater
recreational use and improved property value on the assumption that color
discharges are eliminated entirely. We then determine the benefits associated with
each of the color discharge reduction programs we evaluated. The section concludes
ia/ea'ao

-5-
with a discussion of other possible sources of benefits--option values and existence
values.
A. Overall Aonroach
There are two issues regarding the relationship between reductions in
color discharges into the Pigeon River and improvements in recreational benefits
and property values. First, it is not clear to what extent reductions in color
discharges from the Champion mill would be perceptible in the river. It is even
less clear that incremental improvements, say from 100 to 50 units on average,
would be noticeable in the river. Second, even if these changes were noticeable,
there is no direct evidence that they would affect either recreational activity or
property values.
Bach and Barnett allege, however, that color levels in excess of 50 units
reduce the attractiveness of the Pigeon River for recreational uses (whitewater
rafting in particular) and may also reduce property values for land adjacent to the
river. It is important to note that these supposed adverse effects are entirely
hypothetical. Despite an extensive review of the literature we can find no empirical
studies which relate color to recreational activity. Indeed, we have limited evidence
for certain naturally very dark rivers (the Androscoggin River in Maine for
example) on which whitewater rafting and fishing are quite popular activities.
While there is some limited support in the economic literature for a relation
between color and property values, this may simply reflect the statistical association
between color and other unrelated aspects of water quality.
Despite our reservations about the actual impacts of reducing color
effluents, for the purposes of this study we have adopted Bach and Barnett's thesis
and have assumed that color reduction will enhance recreational activity and
rL4EV /W

-6-
property values on the Pigeon River and have attempted to quantify the maximum
possible impacts of color changes.
The time available for this study has made a direct investigation of the
Pigeon River infeasible. Consequently, we have relied on data for other rivers to
estimate the benefits from reducing color discharges into the Pigeon River. In our
effort to transfer other results to the Pigeon River we have always allowed for the
maximum benefit potential. The actual benefit levels are quite likely to be lower.
Several recreational activities are feasible on the Pigeon River, including
whitewater activities (rafting, canoeing and kayaking), floating (primarily rafting
although it includes "inncrtubing," canoeing and kayaking), fishing and general
sightseeing. To calculate the increase in usage for these activities in the absence
of color effluent we used estimates of current usage on Tennessee rivers in the
vicinity with no perceived elevated color levels, particularly the Ocoee and
Hiawassec Rivers. Adjustments must be made to these estimates since these rivers
are different from the Pigeon River in respects other than color.
To estimate the value of a visit we have utilized a variety of published
sources. For the most part, they are the results of contingent valuation studies.
In these studies participants in an activity are asked to estimate the value of that
activity to them in excess of the costs incurred. These estimates, known as
consumer surplus, serve to define the value of a day. Bach and Barnett also employ
consumer surplus valuation. Multiplying the value per day by the increased number
of days gives our estimate of benefits from reducing color discharges.
Property value benefits presumably derive from scenic advantages of being
along a river of reduced color as well as the enhanced levels of wildlife and
recreation the river can support. Several studies [2,3,4] have related color and
general water quality to property values along coastlines and lakefronts. We have
n/e/ram

-7-
calculated current values of river-front property along the impacted portion of the
Pigeon River and have used these studies to estimate the increase in property
values attributable to a river with no added non-natural color.
B. Rafting and Floating
Whitewater rafting is feasible on a 4.5 mile stretch of river about
37 miles below the Champion mill--from River Mile (RM) 26 at the CP&L
powerhouse to RM 21.5 in Hartford, Tennessee (see Figure 1). As recently as last
summer, a commercial supplier offered whitewater rafting trips on this stretch. The
river below this point has too low a gradient to support whitewater rafting, while
over the 37 miles between the mill and the power plant, both the gradient of the
river and the volume of water are insufficient to support rafting.
Rafting on the Pigeon River is further limited for two reasons. First,
the climate is conducive to rafting only from April to October. Second, during this
period rafting is limited to periods of discharge from the CP&L power plant. When
the plant is not operating (or is operating only one of its three turbines) the
depths are insufficient to support rafting. CP&L's obligation as a public utility is
to generate power so as to minimize electric generation costs without regard to
potential rafting activity. However, for the purposes of this study we have assumed
that CP&L generates electricity during as many daylight hours as water levels in
Walter's Lake permit during the rafting season.
The relatively short length of the Pigeon River run makes whitewater
rafting less attractive than it would be on longer rivers. First, no more than a
half-day trip is possible, while other rivers offer full day trips. Second, since
congestion limits the number of potential rafters per mile, shorter rivers will have
lower capacities.

. -8-
To estimate the number of potential whitewater rafting trips for the
Pigeon River we used data for the Ocoee River, which is the closest comparable
river to the Pigeon River. The whitewater rafting portion of the, Ocoee River, like
the Pigeon River, is five miles long, allowing only half-day trips. In addition, it is
also dam-constrained. Total usage on the Ocoee River for 1987 was about 120,000
visits [5]. Following Bach and Barnett, we take this figure as a limit to usage on
the Pigeon River. We assumed that there is no current recreational usage on the
Pigeon River and that over five years usage for whitewater activities would rise to
120,000 visits per year. Thus, we have assumed that all recreational use of the
Pigeon River would be attributable to reductions in color discharges. This obviously
tends to overstate the benefits from lower discharges, since there is currently
recreational usage of the river. The attached brochure (Figure 2) illustrates the
recreational benefits of the Pigeon available today. These visit estimates are
displayed in column (1) of Table II.
To estimate the value for a rafting day we used a study conducted in
Colorado in 1978 [6]. This study found that the consumer surplus from a
whitewater rafting trip averaged $10.94 per person per day. Once again, this
represents the difference between what people would be willing to pay and what
they actually had to pay for a rafting trip. The estimate was made by eliciting
from rafters the amount of money in addition to what they had paid that day that
would cause them to forego that trip on these rivers. Converting this value to 1988
dollars, we find that the benefits are $19.28 per tourist day. Other whitewater
activities, for example, kayaking and canoeing, had similar values.
The equations from which these estimates were drawn show consumers to
be quite sensitive to congestion on the river. Since congestion levels on the Ocoee
n/e✓r/W

-9-
River are much higher than those observed in Colorado, we have lowered our
estimate to $13 per trip.
In addition to the five-mile stretch of whitewater between the power
plant and Hartford, there is a more placid stretch from RM 21.5 to RM 16.5 on
which floating is feasible during periods of higher water. On this stretch the river
resembles the Hiawassee River. We have estimated floating usage for the Pigeon
River based on data for the Hiawassee River. While this activity may be expected
to be constrained somewhat by power generation, water levels further downstream
are less affected by dam activities because of the lower gradient. Nonetheless,
river levels are probably too low to achieve any significant recreational activities in
August or September. Given that these months generate 35 percent of
noncommercial activity, we have reduced the Hiawassee River floating usage of
80,000 visits [7] by 35 percent to 52,000.
Unlike whitewater rafting, which has been growing at about 6 percent per
year on the rivers for which we have visitation data over time, floating activity
seems to be on the decline. On the Hiawassee River, usage has been declining by
about five percent per year since 1978. In estimating floating usage for the Pigeon
River, we have conservatively assumed no decline. Again, we assumed growth to
capacity would occur over a five-year period. The resultant demands appear in
column (2) of Table II.
Bach and Barnett assume a value of $12.94 per tourist day for floating
activity, based on Water Resources Council criteria. These values seem quite
severely overstated. Based on our visits to the river, a score of 36 would seem to
be a better indication of the value than their assigned score of 62. In particular:
1) Bach and Barnett assign a score of 10 out of 30 for recreation
n/e/rra°

-10-
experience, which measures crowding. The large crowds projected
here should reduce this value to 5.
2) Bach and Barnett assign a score of 12 out of 18 for availability of
opportunity. A 12 would indicate no floating opportunities with one
hour, which seems to ignore the French Broad and Hiawassee Rivers.
We find 4 to be a more objective classification.
3) Bach and Barnett assign a score of 10 out of 14 for carrying
capacity. This rating reflects "optimum facilities to conduct activity
at site potential." These facilities are simply nonexistent. A 5,
representing basic facilities, seems quite generous.
4) We accept Bach and Barnett's accessibility rating of 12 out of 18.
5) Their rating of an 18 out of 20 for outstanding esthetic quality seems
highly inflated. The river would still receive municipal waste
treatment discharges and both agricultural and urban runoff. We
have lowered their rating to 10.
The score of 36 translates to a value of $8.30 in 1982 dollars, converted
to $9.76 in 1988 dollars. We have used this value in our estimate for floating
activity.
Table II describes the annual benefits and the present value of these
benefits in 1988 dollars. The present value reflects the annual benefits over the
next 10 years discounted to reflect the time value of money. We used a 10-year
time frame since that is about the expected life of the investments for color
discharge reduction. Discount rates reflect the rate at which benefits can be traded
between years. We have discounted the benefits at an annual rate of 6.79 percent
in excess of inflation. The rate used reflects the after tax cost of money to
Champion (13.2 percent) net of a presumed six percent future inflation rate. The
nm✓r/aa

. -11-
Champion rate reflects the marginal cost of capital in the private sector, since
funds spent cleaning up the Pigeon River would otherwise. earn these private sector
rates. The benefits of cleanup should consequently be discounted at the same rate.
Using this method, we derive total benefits over the next 10 years of $8.9 million
for rafting and $2.9 million for floating. The annual benefits and the present value
of the benefits for whitewater activity and floating are given in columns (5) and (6)
of Table II.
We are quite confident that these estimates overstate the actual changes
in value on the Pigeon River. There are at least six reasons why we expect the
value of additional whitewater activity and floating visits to be substantially lower.
Fib we have assumed that there is currently no recreational usage on
the Pigeon River. In fact, there is a commercial operation on the river today.
Kayaking and canoeing have also been observed on the river. However, we have
been unable to secure estimates of current usage and have therefore ignored them.
Since our goal is to calculate increases in usage, the value of all current usage
should be' subtracted from our value estimates. Our failure to do so clearly
overstates the number of trips that can be attributed to reductions in color
discharge and thereby overstates benefits.
Second the benefits per trip used for whitewater activity were estimated
on much larger and more striking rivers in Colorado. The set of rivers on which
this estimate was based includes, for example, the Yampa River, which "is among
the few rivers in the U.S. on which rafters can spend from three to five days
without encountering roads, private land, or other evidence of civilization." [6,
page 8] The rivers sampled averaged 42 miles in whitewater length, over eight
times the length of the Pigeon River run. Trips on these rivers averaged 14 miles
per day. The shortest of the rivers was almost three times the length of the
nje/Tids

12
Pigeon River. Such unique characteristics would be expected to make this set of
rivers much more valuable than the Pigeon River.
Third the $13 consumer value assumes a very modest increase in
congestion. The value of a whitewater rafting day declines sharply with the number
of people encountered on a trip. The Colorado study users encountered an average
of only forty people on a trip. With visits of 120,000 per year, Pigeon River
whitewater rafters might well encounter hundreds of people per day. In the
Colorado study, a doubling of encounters reduces the benefits per day by over
40 percent. Thus, fairly moderate increases in usage could lower the benefit per
day estimate substantially.
Fourth of the two methods traditionally used to estimate the value of
recreational activities, we relied on the contingent valuation method which usually
leads to higher values. It is subject to a number of well-known biases in which
people tend to overstate the value of services. Alternatively, travel cost models
which estimate the demand for a service by the distribution of distances people
were willing to go to participate in an activity, typically give lower values than
contingent valuation.
Fifth the current physical facilities at both the dropoff and takeout
areas are grossly inadequate to the task of accommodating the estimated number of
rafters or floaters. We assume that these facilities could be developed over time if
demand warrants but have not included the costs of developing these facilities.
These costs would properly be a subtraction from the benefits associated with these
activities.
Sixth, increased recreation visits on the Pigeon River may consist largely
of visits currently made to other rivers. Thus, in equilibrium, the total increase in
whitewater rafting trips might be much less than the 120,000 visits per year
Tl�L/Zi`d,'a

-13-
projected on the Pigeon River even if that many people do raft on the Pigeon
River. Each visit "cannibalized" from the Ocoee, Hiawassee, or any other river
represents less new value than a new trip; most of its value reflects a shifting of
value from one site to another.
For these reasons we consider our estimates of both usage and value per
trip to be quite generous and would expect to see far less rafting and floating
usage of the Pigeon River.
C. Fishing and Sightseeing
For these activities we have used both the visit estimates and value
estimates of Bach and Barnett as a base. They have scaled fishing visits to usage
estimates for the Norris Dam tailwaters put-and-take fishery. Their sightseeing
visits are scaled to estimates for the Hiawassee River. The number of visits for
these activities are given in columns (3) and (4) of Table II.
Our only adjustment is to lower fishing values to account for the costs
of the presumed put-and-take fishery. Failure to include these costs overstates
potential net benefits. One study [61 suggests that these costs can range from
$4.50 to $11.00 per visitor day depending on the length of the fishery. We have
used the average of this range to reduce Bach and Barnett's estimate of the net
benefits for a fishing day of $17.00 to $9.25.
Further, while we have used Bach and Barnett's estimates for the number
of additional fishermen expected, the source of their estimate is unclear. A proper
estimate should take into account the fact that trout are not a viable species in the
Pigeon River below the Canton Mill discharge and that put-and-take fisheries are
generally less efficient in smaller bodies of water. We have accepted their
estimates for lack of better data.

-14-
It should be noted that fishing is a viable activity on the more scenic
portions of the river only when whitewater rafting is unavailable. Excessive stream
flow and heavy boating usage are detrimental to fishing quality. We do not regard
this as a very serious constraint given the limited time available for whitewater
rafting and have therefore made no adjustment.
The annual benefits and the present values for fishing and sightseeing are
described in columns (7) and (8) of Table II. The present value of fishing benefits
is about $1.2 million over ten years, while sightseeing accounts for about
$0.7 million.
D. Proyerty Values
It has been argued that reductions in color can enhance residential
values. A 1979 study [2] in Pennsylvania, which focused on overall water quality
rather than color, indicated that a completely clean river raises adjacent residential
property values about 28 percent. Similar values were obtained for apparent color
in a 1985 Michigan study [3] on lakefront property and for a combined index of
turbidity and distance in a 1980 study [4] of beachfront property in Massachusetts.
We have used the 28 percent figure as an upper bound on residential
property improvements on the Pigeon River. We have further assumed that all
property along the Pigeon River not currently blocked by roads, public land, or
Champion property is transformed to residential use. This is obviously an extreme
assumption and causes us to overestimate the impacts of reduced color discharge on
property values.
Our calculation of increased property values had three steps: 1) an
inventory of property along the Pigeon River, 2) a calculation of its value for
residential purposes, and 3) a calculation of the maximum increase in value
attributable to reduced color.
n/e✓r/W

. -1s-
1. Much of the land adjacent to the Pigeon River is publicly owned.
Route I-40 follows one side of the river while public forest land borders the river
in many areas. The land between the dam and the powerhouse which contains no
water due to the powerhouse diversion tunnel and is, therefore, unaffected by color
was also excluded. Only about 50 percent of the river is adjacent to usable private
land. We have also excluded plots belonging to Champion and the Cocke County
School District. Since the usage of these properties cannot be expected to change
with reductions of color in the Pigeon River, we have excluded this land from our
assessment.
2. We had assessed property values for land in Tennessee only and have
assumed that similar values prevail in North Carolina. Residential land and property
was valued at $52.49 per river-foot of frontage. We have assumed that all land
along the river would have this value in residential use. In fact, nonresidential
land and property in Tennessee had a value of only $32.01 per river-foot.
To calculate increases in the value per river-foot of frontage, we used
the 28 percent figure. This increases the value of all potential residential property
by $14.64 per river-foot to $67.13. The results of this calculation are given in
Table III. Property value increases, which are assumed to be instantaneous, total
$2.52 million in North Carolina and $2.05 million in Tennessee.
Again, we feel it quite likely that this estimate overstates potential
benefits. Fi= we have applied residential-level benefits to agricultural and
commercial land. This is based on the assumption that this land may ultimately be
converted to residential use. The available studies deal exclusively with residential
values. The links between property value and color are far less obvious for land
used for agricultural, forestry, or industrial purposes. However, it is unclear that
I1�2/Y'id,�

-16-
private land along the Pigeon River currently used for agricultural or industrial
purposes will be converted to residential use.
Second the 28 percent increase cited is partly attributable to the fact
that more expensive homes are constructed on more desirable land. The net
benefit, which would subtract the cost differentials, is not included here.
Third color may not be the true measure of property desirability but may
instead be a proxy for other measures of environmental quality. A 1973 study [8]
found color much less important to property owners than the ability to sustain fish
and other wildlife. The Michigan study of lakeside property owners found that
turbidity was an important factor in value but notes that turbidity is highly
correlated with other pollution variables which decrease both fishing and swimming
uses. To the extent that these variables are not correlated here, the effects might
well be less.
Fourth we have included several plots of land currently inaccessible by
road. Several areas of vacant land doubtless have no developed residential
infrastructure--for example, sewage, telephone and water access. The costs of
providing such facilities should be subtracted from any property value increases.
Given these caveats, we find it quite likely that the combined property
value effects will be lower than what we have estimated.
E. Atmortionina Benefits
The recreational and property benefits we calculated in Sections II.B.
through II.D. total $18.3 million over 10 years. These estimates are based on the
complete elimination of color discharges from the Champion mill. The next step is
to determine the proportions of these benefits that will accrue from each of the
specific proposed reduction plans.
11�/IYc1i°

-17-
Under the most stringent reduction plan, discharges of color would be
limited to no more than 50 units at the pipe. This strategy entails a reduction of
311,000 pounds of color per day on average. We have adopted the Bach and Barnett
assumption that 50 units is the limit of color acceptability. Consequently, we have
assumed that the 50 units at the pipe strategy achieves all of the $18.3 million in
benefits.
For the other two strategies, we have assumed that the benefits achieved
are proportional to the reduction in discharges. Further, for the 50 units at the
border scenario, we have assumed that the plant remains open. Thus, the strategy
•that achieves 50 units at the border would achieve all the potential benefits in
Tennessee. This includes all of the recreational benefits as well as the increase of
$2.05 million in property values in Tennessee. In addition, since this plan also
achieves 88 percent, of the discharge reductions under the 50 units at the pipe
strategy (274,000 divided by 311,000), we assume it achieves 88 percent of the
property value benefits in North Carolina. As a result, the total benefits from the
50 units at the border strategy are $18.0 million.
The 50 percent reduction plan removes 172,000 pounds of discharge per
day on average. This achieves 63 percent (172,000 divided by 274,000) of the
Tennessee benefits and 55 percent (172,000 divided by 311,000) of the North
Carolina benefits. Thus, the total benefits from this program are $11.3 million.
This proportionality assumption is somewhat arbitrary. In the absence of
specific recreational studies on color, it is unclear whether a 50 percent reduction
in effluent will garner more or less than 50 percent of the benefits. Instead, there
might be threshold, effects. That is, below a certain color level, all benefits accrue;
above a certain level, no benefits accrue. While 50 units in the stream may
represent the lower threshold, we have no such upper threshold. Further, even the
I1�E',/ZSd�

' -1s-
50 unit lower threshold is controversial. However, we have tested several different
upper thresholds in benefits. The assumption of proportionality yields larger
incremental benefits than any other set of assumptions tested.
F. Nonuse Value
It is often asserted that there are values other than those accruing to
users of the. river. Bach and Barnett cite a study which estimates those benefits at
five times the direct benefits. We reject the notion that there are significant
nonuse benefits for the Pigeon River. Fib it is unclear whether nonuse values for
the Pigeon River are positive or negative. Second even if these benefits are
positive, they are not likely to be large.
The economics literature considers two components of nonuse values:
option values and existence values. Option value is similar to a nonrefundable
admission price that must be paid before one knows whether or not he or she will
use the river. It represents for consumers the difference between (1) the
willingness to pay to shield themselves from uncertainties about their demands for
the river and its availability and (2) the expected value of their benefits from the
river.
Substantial theoretical research indicates that option value, this
difference between willingness to pay and expected value of benefits, is as likely to
be negative as positive. Further, in some important cases where it is positive, it is
likely to be small. Whether option values are positive or negative depends on the
nature of the uncertainties confronting users and nonusers. At least five sources of
uncertainty can create option values. These include: (1) supply of the resource,
(2) income, (3) taste, (4) price of the resource and (5) prices of substitutes or
complements. Examples can be constructed where option value is positive, negative,
or zero for reasonable uncertainty assumptions. Further, V. Kerry Smith's analysis
n/e/r/W

-19-
[9] shows the importance of uniqueness and irreplaceability in assigning a positive
option value. Given that the Pigeon River has no unique characteristics (especially
given the abundance of substitutes) and that the level of color is reversible at any
time, his analysis implies that option values are unlikely to be positive.
Regarding the magnitude of the option value in the case of uncertainty
about taste, Freeman [10] points out that the conditions for a large option value
are quite stringent. Option value is unlikely to be large unless "the probability of
demand is low, the expected consumer surplus is large, and the individual is highly
risk averse." [10, p.11] For the Pigeon River, these specific conditions are unlikely
to occur. In particular, rafting on the Pigeon River is quite unlikely to have a
large expected consumer surplus relative to income given the abundant potential
substitutes in the area, both for whitewater recreation and for entertainment in
general.
Finally, the empirical evidence on option value is generally unpersuasive.
While several studies (including the one cited by Bach and Barnett) have concluded
that option values were positive and substantial, these studies have been poorly
done and cannot be used to infer large positive values. There are various reasons
for this, including the fact that the survey questions addressed the wrong issues
and were posed in a confusing manner. As Smith [11] points out:
Empirical efforts to measure option price (and option value) have not
been clear in specifying (or attempting to determine the individual's
perceptions on) the terms of access to the resource and the time
horizon for future use. . . .[T]he terms of access and the individual's
ability to adjust to demand uncertainty . . . have not been clearly
described (or elicited) from the respondents involved in the
surveys. . . .[T]his limitation is especially important when the option
price is used to measure the value of changes in either features of
the resources or in the uncertainty itself. [11, p.8]
As a result, these studies have generated estimates of surplus much too large to be
easily explained on a theoretical basis.
11/e/t'/W

_20_
Further, applying estimates taken from these other studies to the Pigeon
River would be even more tenuous. Even if the wild and scenic rivers of Colorado
may have significant option values, the transfer of those results to the Pigeon River
is unwarranted.
Considering all of these issues, we have-not included any option values in
our estimates. Our best reason for doing so is stated by Professor Richard
Schmalansee [12] of the Massachusetts Institute of Technology, one of the original
contributors to the theory of option value:
Individuals' option prices may exceed or fall short of the expected
value of the contingent surpluses they would derive from a price
change, and it is not obvious how one might judge in a real situation
which was more likely. This suggests that when tastes are the main
source of uncertainty, the expected value of consumer's surpluses
ought to be employed as the best available approximation to the sum
of their option prices . . . . Benefits will be sometimes
underestimated and sometimes overestimated by this procedure, but
there would appear to be no practical way to obtain superior
estimates. 112, p.823]
Existence values represent the utility of knowing of the existence of a
resource for a person who knows he will never use it. We believe that this does
not represent a significant source of benefits on the Pigeon River and have
excluded them from our estimates for two reasons. Fib existence value is linked
to uniqueness of the resource. A resource with features available nowhere else (for
example, the Grand Canyon) may have substantial psychic value to nonusers. We do
not believe that nonusers place a large value on the Pigeon River given the
existence of nearby alternatives.
Second a full specification of existence values would of course include
foregone opportunities for the people of Canton. Those who would place a high
utility on lower color levels in the Pigeon River should also place high disutility on
the social disruption caused by the shutting of the Canton Mill. In scenarios in
I1/evr/ad

-21-
which the mill must be closed, a positive existence value.would mean that people
put less value on the disrupted lives of Canton than for color levels; in the Pigeon
River. Thus, in this case existence value is the sum of two effects: one positive
and one negative. It is not clear a priori which effect would predominate.
Third little is known empirically about existence value. Testing for
existence value is fraught with difficulty, since people not actually called upon to
pay for improvements may systematically overstate, for any number of reasons, their
willingness to pay. The most comprehensive study of existence (and option values)
suggests that together they might increase benefit estimates by as much as
50 percent. Even these estimates have come under attack. We find that an
increase of this size at the Pigeon River to be highly unlikely. However, we note
in passing that even a tripling of all benefits in Table I still results in an
unfavorable benefit-cost ratio for all reduction plans. The benefit cost ratios for
the more stringent USEPA proposals require assumptions of option and existence
values of ten to twenty times the direct effects.
III. COSTS
Colored effluent is the byproduct of the removal of lignin from wood
chips in the pulping process. Currently, the mill is one of the lowest producers of
pounds of color per unit of output in the United States.
A. 50 Percent Reduction
The primary source of color discharge is the caustic extraction stage of
the bleach plant. Improvements proposed by Champion to cut this contribution by
90 percent would achieve an overall reduction of 50 percent. This reduction is
proposed to be accomplished by the addition of oxidation chemicals.
The costs of the 50 percent reduction proposal have been estimated by
Champion at $10 million dollars in capital cost and $4 million per year in operating

-22-
and maintenance costs. We have converted these costs into a ten year stream and
discounted them at Champion's after-tax cost of money. This yields a discounted
present value of expenses over a 10-year period that is directly comparable with the
benefit estimates. The operating and maintenance expenses were discounted using
the 6.79 percent rate. The present value of the costs of this plan is therefore
$38.4 million. The costs are summarized in Table V.
B. 50 Units at the Tennessee Border
Other technologies that would treat more than the caustic extraction
stream require far greater investments. Champion submitted to the USEPA, at the
Agency's request, seven reports detailing methods of reduction sufficient to achieve
no more than 50 color units at the border at any time. Of these, the USEPA
deemed as potentially suitable the lime, polyamine and alum removal systems. Each
technology has a different capital and operating cost, with the alum removal system
being by far the lowest cost. Further, the systems have different risks associated
with them. Champion's engineers have supplemented the estimates of probable cost
of each of these technologies with a probability distribution of costs. The proper
cost to use ex ante in comparing the plans is the expected cost of the technologies,
i.e. where the costs are weighted by the probabilities that they occur. Under this
criterion, the polyamine technology has the lowest cost. The present value of its
costs are $164.5 million, as opposed to $192.5 million for the alum reduction plan
and $209 million for the lime reduction plan. Since the polyamine system is the
least expensive of the three technologies that would achieve 50 color units of the
border at any time, we have used it in the analysis.
We should note that the polyamine removal process is likely to understate
the cost, possibly greatly so. EjEaL no polyamine process on this scale has ever
been implemented before. Large scale experiments with new technologies often have
n/esrral

-23-
substantial unexpected cost increases. Second byproducts of the polyamine process
would almost certainly violate existing environmental standards. In particular,
operation of the sludge dryer would cause air quality deterioration in particulate
matter, hydrocarbons, SOZ, and NO, The cost of meeting existing standards have
not been included in these estimates.
In calculating the results in Table I, we have assumed that the plant
'remains open at this level of expenditure. Champion has submitted to USEPA
workpapers based on the USEPA gross margin test. This test compares the ratio of
net operating revenues to annual pollution control costs. Where this ratio exceeds
the average ratio of investment returns for the industry, "the test results indicate
that pollution controls would impose severe economic impacts, [and] a more detailed
plant closure analysis would be necessary." [14, page 92] Champion's submissions
indicate that the 50 unit at the border strategy fails to pass this test. This raises
the possibility of mill shutdown even under this plan. Were this the case, the quite
substantial resource and employment costs of the more stringent December USEPA
proposal would result. Only the 50 percent reduction plan would have costs within
a factor of 50 times benefits.
We have analyzed this case from a different perspective and find a
persuasive case for shutdown. Our analysis suggests that the internal rate of
return on an investment in pollution control (combined with the $200 million
necessary to keep the plant commercially viable) is considerably less than the
20 percent hurdle rate necessary to justify an investment for Champion. Even were
the investment of average risk for the company, the project would likely not be
justified. In fact, the risks involved in both the pollution cleanup and oxygen
delignification production process are substantial, requiring internal rates of return
in excess of the hurdle rate to warrant the investment. We therefore regard the
ri/evr/ i°

_24_
50 unit at the border proposal as likely to lead to shutdown of the Canton mill.
Again, were this the case, the true costs and benefits of the 50 units at the border
plan would be identical to those from the more stringent limit of 50 units at the
pipe.
C. 50 Units at the Mill
Engineering judgment has determined that these color treatment schemes
cannot simply be scaled up to achieve a discharge level of less than 34,000 pounds
per day on the average, the amount sufficient to assure less than 50 units at
Canton. Also, the mill would not be able to operate on pulp shipped in. Thus, the
only method of achieving 50 units at the mill is the shutdown of the plant. In this
case, the real resource cost of shutdown is the cost of constructing a new mill with
replacement capacity elsewhere in the country. Champion estimates that the
creation of a new mill capable of producing 600,000 tons of pulp per year would
have capital costs of $1.4 billion. To properly characterize the total resource costs,
we should subtract from this estimate the present value of savings in operating and
maintenance provided by a new plant.
Champion has proposed a $200 million investment in an oxygen
delignification process which would allow the plant to continue operations. As a
proxy for the operating and maintenance cost savings, we have assumed that the
$1.4 billion investment creates a profit stream which yields an internal rate of
return of 13.2 percent, i.e., represents an investment of average risk for Champion.
This profit stream is then subtracted from the profit stream arising from the
$200 million switch to oxygen delignification at the Canton mill. The present value
of changed profits must represent the present value of cost savings associated with
the new technology. The present value of resource losses thus totals about
$290 million. The additional impacts of a shutdown are discussed below.
Ili/r/w

-25-
IV. COSTS AND BENEFITS
The economic criterion for undertaking any investment, including
environmental enhancement programs, is that the benefits exceed the costs. Even
where environmental benefits are themselves large, undertaking a project whose
costs exceed its benefits is a waste of society's resources. Further, the difference
between incremental costs and benefits should guide the choice between projects.
While none of the three programs pass the benefit-cost test, the
50 percent reduction plan comes the closest by a wide margin. Under the
50 percent reduction plant the present value of the costs over a 10-year period are
$38.4 million. These are $27.1 million greater than the benefits of $11.3 million.
These costs and benefits translate into a benefit-cost ratio of 0.30 (11.3 divided by
38.4). The interpretation of this benefit-cost ratio is that a one dollar of
expenditure yields 30 cents in benefits. The comparison of benefits and costs
benefits are summarized in Table I. This is substantially less than one, and
consequently would not pass the economic criterion for undertaking the investment.
The plan to reduce discharges to 50 units at the border is even less
justifiable. Its costs are $164.5 million, and they exceed the benefits of
$18.0 million by $146.5 million. This results in a benefit-cost ratio of 0.11--nearly
half of what could be achieved under the 50 percent reduction plan.
The most costly program--50 units at the mill--achieves the poorest
benefit-cost ratio. The costs would be much greater than either of the other plans
because it would involve shutting down the Champion mill in Canton and
constructing a new one. Under this program the costs would be $290 million.
These are $271.7 million more than the benefits and would yield a benefit-cost ratio
of .06.
ri/2/r'rw

-26-
A very useful way to look at the alternative programs is by comparing
the increase in costs and benefits that occurs from imposing increasingly stringent
discharge removal plans. This is a comparison of the incremental costs and benefits
and describes the additional benefits and costs that accrue from removing additional
color. If the additional costs exceed the additional benefits, then the incremental
reduction in color is uneconomic.
As we have noted above, the least stringent of the programs--the
50 percent reduction plan--increases costs by $38.4 million and benefits by
$11.3 million for a benefit-cost ratio of 0.30. The incremental cost of removing
additional color under the 50 units at the border plan is $126.1 million--the
difference between $164.5 million and $38.4 million. This added expenditure removes
an additional 102,000 pounds of color per day (274,000 minus 172,000). However,
this additional color reduction only increases benefits by $6.7 million (18.0 minus
11.3). Thus, the incremental benefit-cost ratio is 0.05 (6.7 divided by 126.1).
The incremental comparison is even more unfavorable under the 50 units
at the pipe plan as proposed by the USEPA. This program would increase costs by
$125.5 million--from $164.5 million to $290.0 million. The added expenditures would
achieve an additional reduction of color discharge of only 37,000 pounds per day.
However, this additional reduction would only increase benefits by $300,000. As a
result, the incremental benefit-cost ratio would be virtually zero.
These incremental results depend crucially on the assumption of 50 color
units as an objective perceptibility standard. If, in fact, there is no perceptible
difference between 50 and 100 color units, then the conclusions are even more
clear. Since the 50 percent reduction plan essentially achieves 100 color units or
less at the border over 95 percent of the time, this plan would achieve all benefits,

-Z7-
no matter how large. Each of the more stringent plans, therefore, has incremental
benefits of zero and cannot be justified on any rational criterion.
In estimating the benefits and costs we have discounted the annual
impacts at Champion's after-tax cost of money. Some have argued that the proper
discount rate to use for the evaluation of projects should be a riskless discount
rate. The basis for this argument is that since the benefits are spread over the
population at large, the risk premium associated with private investment should not
be included. We disagree with this argument. The reason is that funds spent on
this project will deny Champion the ability to undertake other projects capable of
earning the private rate of return. Hence the rate we have used is appropriate.
We would agree, however, were this proposal financed with new money, but that
would not be the case.
Nonetheless, we have calculated the benefits and costs using a real
discount rate of three percent, which is intended to represent a riskless rate. This
substitution does not alter the results, and therefore our conclusions remain
unchanged. Using a lower discount rate raises both the costs and benefits. For
each case, the benefit-cost ratios are slightly less favorable. Table VI compares the
results at the alternative discount rates.
V. EMPLOYMENT CONSEQUENCES
We have also estimated employment impacts from the three color
discharge reduction strategies. Employment impacts are treated separately from the
benefit-cost impacts because they represent different issues. Jobs created cannot be
examined in isolation. For example, the cost side of the benefit-cost calculations
reflects the employment impacts of the discharge reduction plans. Higher cost
levels always create more jobs, whether or not the costs were incurred efficiently.
Djevr/w

-28-
Thus, the employment consequences of a particular strategy cannot be added to
benefits. Instead, they represent an alternative perspective.
The 50 percent reduction strategy would likely have modest employment
impacts of about 250 jobs. The 50 units at the border strategy, if implemented,
would yield about 600 jobs. Given the probability that the plant would shut down,
however, both this plan and the 50 units at the pipe strategy would impose very
substantial employment losses totalling over 12,000 jobs.
Jobs created and lost can be broken down into direct and indirect
components: the direct component consists of the jobs required either to provide
recreation or to maintain color reductions. Indirect employment gains and losses
relate to the employment in other sectors required to support the direct work force.
The U.S. Department of Commerce has issued state- and industry-specific estimates
of total direct and indirect job impacts for given changes in output in various
industries [13]. For recreation in Tennessee, we have used the hotels, lodging
places and amusements multiplier. It indicates that for an increase of $1 million of
expenditure in this industry group, direct and indirect employment will increase by
60.2 jobs. For discharge reduction activities, we have used the North Carolina
values for the paper and allied products classification and the Tennessee value for
forestry and fishing products. A $1 million expenditure in North Carolina provides
30.1 jobs, while a $1 million expenditure in Tennessee provides 54.5 jobs.
The direct employment gains in Tennessee follow from the staffing
requirements of the whitewater rafting facilities. Fishing, kayaking and sightseeing
generate no direct employment gains, since they have no direct costs other than the
costs of transportation. Using Ocoee River figures which show commercial rafting
to account for about 85 percent of whitewater activity and using the Bach and
Barnett figures of $20 per trip, we derive maximum expenditures in Tennessee for
Tl/e/r/am

_29_
whitewater rafting of $2 million (20x.85x120,000). This assumes the 120,000 visits
per year associated with complete color removal. The multiplier of 60.2 direct and
indirect jobs per $1 million in expenditures implies an increase of 123 jobs.
The employment impacts are summarized in Table VII. Under either the
50 units at the border plan or the 50 units at the pipe plan, the concentration of
color will be at the minimum levels of acceptability. Consequently, under either of
these plans there will be the full employment impact of 123 jobs in Tennessee.
The 50 percent reduction plan would have less of an employment impact
because the benefits in Tennessee are less. Recall that we assumed that the
benefits are proportional to the color reduction. Since with the 50 percent
reduction plan the recreational benefits are 63 percent of those under complete
color removal, the employment impacts also would be 63 percent of 123 or 77 jobs.
The plan to provide 50 units at the pipe suggested by USEPA causes mill
shutdown. This shutdown reduces Tennessee commercial output by $15 million as
cited by the Canton Mill Operations Manager, Oliver Blackwell. This in turn causes
a loss of 816 jobs, for a net loss of 693 jobs.
For North Carolina the employment impacts depend on the annual capital
and operating costs of a discharge reduction plan. The operating costs plus an
annualized capital charge represent additional employment at the mill. Under the
50 units at the border plan, the annual capital and operating costs would be
$17.91 million. This translates into 539 increased jobs (direct plus indirect) given
the 30.1 multiplier. Under the 50 percent reduction plan the annual costs would be
$5.85 million which would result in 176 more jobs.
Shutdown of the plant under the USEPA standard would have substantial
employment effects in North Carolina. The mill currently employs over
2,100 workers and produces $400 million of paper products per year. Using the
11/G/1/W

-30-
Department of Commerce multiplier of 30.1 jobs per million dollars of output for
paper and allied products in North Carolina, a total loss of over 12,000 jobs can be
projected. The direct losses to the community include the $160, million currently
paid to local factors.
Thus, in North Carolina and Tennessee combined, the USEPA standard
would lead to a loss of over 12,000 jobs as well as widespread social costs from the
withdrawal of Champion's substantial support both directly and indirectly through its
employees and suppliers and through Champion's support of the Western North
Carolina-Eastern Tennessee infrastructure through tax payments.
VI. EVALUATION OF THE BACH AND BARNETT REPORT
We have reviewed and evaluated the Bach and Barnett analysis and found
it to be seriously flawed. There are four key conceptual errors that undermine
their conclusions that it would be economic to substantially reduce color discharges
from the mill. First they have failed to take into account the fact that benefits
occurring in different years are not of equal value. Second they have included a
category of benefits (indirect benefits) which have no place in a properly designed
benefit-cost study and which have been misestimated in any case. Third, their
examination of costs was entirely hypothetical and bears no relationship to the
benefits achieved. Fourth they have employed the wrong standard in evaluating the
possibility of mill shutdown. The appropriate way to evaluate discharge reduction
strategies is on the basis of their impacts on the Canton mill. Bach and Barnett
evaluate the strategy on a Champion-wide basis. We will address each of these
issues in the following sections.
A. Discounting
The primary distinction in direct benefits between our analysis and that
of Bach and Barnett involves discounting. Bach and Barnett simply sum the year-
nj ✓I'/w

-31-
by-year benefits to yield a total. This is obviously incorrect. A dollar of benefits
today is worth more than a dollar of benefits tomorrow, just as a dollar of income
today is worth more than a dollar of income tomorrow. Discount factors which
reflect the relative utility of current and future consumption must be applied to
accurately measure the value of future benefits.
Indeed, once appropriate discount rates are applied, the Bach and Barnett
estimates of recreational benefits are slightly lower than ours. Application of our
6.79 percent discount rate lowers the Bach and Barnett direct benefit estimates from
$18.3 million to $13.1 million. Our corresponding estimate of direct recreational
benefits is $13.72 million (see Table II).
B. Indirect Benefits
Bach and Barnett add to the recreational benefits indirect benefits
reflecting increased expenditures in the community resulting from the recreational
activity. We have strong objections to this technique. Most importantly, this type
of benefit has no place in a properly done benefit-cost study. Secondly, even were
these benefits to be included, they have overstated both the level of expenditures
to which these indirect multipliers should apply and have overstated the multiplier
to be used.
The proper standard for a benefit-cost study is the real resource costs
and the real benefits. In comparing the real resource costs and benefits of the
specific proposals mentioned here, we have a criterion which is independent of the
indirect benefits. All programs have indirect benefits. Removing those indirect
benefits can therefore have no effect 'on the analysis. Since the money spent on
this project will be spent in some other way, the indirect benefits are essentially
independent of the program undertaken.

-32-
Indirect economic multipliers represent a flawed concept taken in
aggregate. The problem is that money spent on whitewater rafting does not reflect
new income but is instead the shifting of income from another purpose. A dollar
spent on whitewater rafting is a dollar not spent on other outdoor activities or
other recreation. The economic multiplier of the dollar spent on whitewater rafting
is offset by the loss of the same multiplier from the foregone activities. In
aggregate therefore, these indirect benefits should be ignored. Each dollar of
indirect benefit represents an indirect dollar of loss to someone else.
If one is interested in the net economic benefits for a smaller region,
this can be calculated. However, we must be careful to subtract out expenditures
which cancel out within the region. To the extent that persons from outside Cocke
County are induced to spend money in Cocke County, those dollars will create
indirect benefits in Cocke County. Only expenditures by those outside Cocke
County create these spillover effects within Cocke County.
However, the number of such visitors is likely to be small. Unpublished
data on a nearby river indicate that 41 percent of all river users travelled less than
one hour to the river. Using these data, we have defined the region of direct
economic interest is that within one hour of the Pigeon river. Thus, multipliers
would apply to only 59 percent of all expenditures.
Using the average expenditure figure cited by Bach and Barnett of $20
per day, we find that a total of $8.1 million (in present value terms) should have a
multiplier attached.
This value likely overstates the benefits. For those travelling in excess of
three hours, it is highly unlikely that they would take a trip as short as those on
the Pigeon River. The abundance of alternative fishing, floating and sightseeing
areas and the comparatively low value of these activities make it unlikely that any
IL�P-✓Ifd,®

-33-
long distance visitors would use the Pigeon River for these purposes. Either the
Chattooga or French Broad on which longer trips are available should be preferred
by visitors travelling long distances, especially given the uncertainty of water
supply on the Pigeon River.
Bach and Barnett use a multiplier of three to calculate the indirect
benefits. This estimate reflects the spillover effects for the whole country, not just
the region. The correct value is much smaller. For example, assume an individual
spends $500 on a raft. If the raft was not manufactured in Tennessee, the spillover
benefits will be created wherever payment for the raft goes. By the theory
outlined above, inclusion of these benefits as a spillover is illegitimate, since these
spillovers are exactly offset elsewhere. The U.S. Department of Commerce estimates
state-by-state multipliers for hotels, lodging and amusements. For Tennessee they
have calculated the direct and indirect benefits to the region as 2.1 times the
dollars spent. Indirect benefits therefore are 1.1 times direct dollars expended.
This is the 2.1 less the 1.0 for the direct effect.
Thus, instead of using an estimate of indirect benefits equal to three
times the direct benefits, a more realistic appraisal would be indirect benefits equal
to at most 65 percent of the direct costs, which is 1.1 times 59 percent of the
costs. Total indirect benefits would therefore total about $8.9 million.
Further, these indirect benefits have offsetting indirect costs in the mill
shutdown case. Given the net output losses of $400 million based on expected 1988
mill sales and using the Department of Commerce multiplier of 2.2, we project
indirect losses of $480 million for the most stringent plan, resulting in combined
indirect losses of over $470 million for both states.
Given the importance of the mill to the local economy as the largest
employer, it is possible that these values substantially understate losses associated
I1�L✓ZYd,�

-34-
with termination of pulping facilities. For instance, the mill pays almost
$1.7 million in taxes per year to counties and municipalities over and above taxes
paid by its employees. The impacts of these local tax losses on social services and
education are not calculated here.
C. The Costs of Color Reduction
Bach and Barnett assume a capital cost of $60 million and an operating
and maintenance cost of $6 million. The present value of this expenditure,
$102.5 million, is insufficient even to achieve 50 units at the border. Further, we
note that even by their own analysis, the costs of cleanup far exceed the benefits.
D. Financial Impact on Champion International Corporation
In evaluating the impact of these expenditures on Champion rather than
on the financial viability of the mill, Bach and Barnett have used the wrong
standard. No matter how small the impact on Champion's overall balance sheet, the
economics of the Canton mill must stand on its own merits. An incremental
investment which fails to achieve a suitable rate of return is not justified.
Champion has submitted to USEPA documentation supporting the fact that
the 50 units at the border plan fails to pass the plant gross margin test. Under
this standard, plant economics do not support even this less stringent plan.
Further, our analysis indicates that the returns to this investment are insufficient
to warrant continued operation of the plant.
Tl/,/Y9d®

-35-
REFERENCES
(1] Bach, Orville E. and Barnett, William H., "An Economic Impact Analysis on
the Recreational Benefits of a Restored Pigeon River and A Financial Analysis
of Champion International Corporation's Ability to Provide for a Clean Pigeon
River", unpublished mimeo., May 9, .
[2] Epp, Donald J. and Al-Ani, K.S., "The Effect of Water Quality on Rural
Nonfarm Residential Property Values," American Journal of Agricultural
Economics 61 August 1979.
[3] Brashares, Edith Nevins, "Estimating the Instream Value of Lake Water Quality
in Southeast Michigan," Ph.D. Dissertation, University of Michigan, 1985.
[4] Feenberg, Daniel and Mills, Edwin S. Measuring the Benefits of Water
Pollution Abatement. New York: Academic Press, 1980.
[5] Data supplied in correspondence with Eastern Professional River Outfitters
and confirmed in a conversation with Bob Allen, Tennessee Department of
Conservation.
[6] Walsh, Richard G., Ericson, Ray K., Arosteguy, Daniel J., and Hansen, Michael
P., "An Empirical Application of a Model for Estimating the Recreational
Value of Instream Flow," Completion report OWRT Project No. A-036-COLD.
(Colorado Water Resources Research Institute: Fort Collins Colorado, October,
1980).
[7] Telephone Conversation with Bob Allen, Tennessee Department of
Conservation.
[8] Dornbusch, David M. and Barrager, Stephen M. Benefits of Water Pollution
Control on Prooerty Values. Prepared for the Office of Research and
Monitoring, U.S. Environmental Protection Agency, Socioeconomic
w ✓r/ao

-36-
Environmental Studies Series. EPA-600/5-73-005. (Washington: U.S.
Environmental Protection Agency, October 1973).
(9] Smith, V. Kerry, "Option Value: A Conceptual Overview," Southern Economic
Journal Volume 49, Number 3 (January, 1983).
(10] Freeman, A. Myrick, "The Sign and Size of Option Value," Land Economics
Volume 60, Number 1 (February, 1984).
[11] Smith, V. Kerry, "Nonuse Benefits in Benefit Cost Analysis," Southern
Economic Journal. Volume 54, Number 1 (July ).
[12] Schmalansee, Richard, "Option Demand and : Valuing Price Changes Under
Uncertainty," American Economic Review Volume 65, September 1975.
[13] Bureau of Economic Analysis, U.S. Department of Commerce, Regional
Multipliers: A User Handbook for the Regional Input-Output Modeling System
(RIMS II). (Washington: May 1986).
[14] Office of Analysis and Evaluation, U.S. Environmental Protection Agency,
"Workbook for Estimating the Economic Effects of Pollution Control Costs,"
(Washington: USEPA, November 1983).
rl/ev at

FIGURES
I1�P/Tfd®

FIGURE 1
DIAGRAM OF THE PIGEON RIVER
BETWEEN CANTON, NC AND NEWPORTs TN
FRENCH BROAD RIVER
•u '
MKINFORT,TN
COfaT CREEK a FIILLOTI CREEK
Tennessee
FL RM°aer-J North Carollna
ov RM 26.06.0
T
CREEK
WALTERS DA
WALTERS LAKE
CREEK
am HMO BMDGE
ROW
RREE
ramu
CIaDCE
JONATHAN Cam
FORrau
0
FaeaLANo CREEK LL OUTF
RM 63.1
CLTOE
RORFARM O
ADDmow
T

FIGURE 2
k
CGO! with the P. R.-O.S
P.O. BOX 592
GATLINBURG,
f" P1GEON TENNESSEE
° 37738
° 615,RIVEK '
i436.5008
•`
OlJ. T®OORS
• ..
S O TO
•RRA• HO
32
C 4 + PIGEON FORGE FOOTHILLS
pARXWAY
Sr --- HARTFORD
+ e COSBY
TRAFFIC N
p :r";kfG1Tq 1\
G :f - 1n(7
J ••e3 �2:' ..i�':J' �LAFITRi
a '``•f'%'�'' GREAT'SMOKY MOUNTAIN
With .;.;cNAT1ONAL PARK =:
e s.•_� ._, s.: .v: 0 CTOBER
:.� �..�tz-., �:,._ K•._ ,r._�_.. w . ., gar '`..aie •�..,APRtL-
,,.. +. ��::•.�:.�;ti:j ;t'RFSERVATIONS •�. . ....�,.u::
T•r• 'l. `y - es[ ou hone for reservations(even •:
• �: '"To U134A:I trip with us we suR Y p
:^.: "-'. •.'`.K.onl an'hour or-two aMadll• Refunds will be given if we are
P6GE0�1• _ V,: _+;,•; Y m riur•conditlons,.or if given JO or more days
Ri�E R . ...ryaMr m raft err.
.,•�`C-..:.,.:.;/_:,v�:..__�•.: T: ..Rain ed eaneailatton..
1• CLi'vWting,WNITEWATER RAFTING TRIPS am on a scenic
• 'S '•dF;•�1, ! d•`SihUr stretch of that BIG PIGEON RIVER. Trips Isere TWICE
0��� ®C • '�?_ '.DAILY from our ougoa on h E. -in ere You
Me foot of the
�ORJ ',.•: V. •r+•; sRoanWro,we.Y+uttis you m tl+s paten there You receive inatfes.
..:.y.:,.. . -i.,..,�v.•. ;_.:•; :••3 •lion in whitowuer technique and ufety procedures.With a Drofes•
w _.;;y-_ .',."`•=;-="-�-��:' .'':.._- ...u ++'�:• Clonal guide in each raft and a kayak safety boat to lead the way.we
LA through TWELVE CLASS 35 AND TWO CLASS 4'SI
. — • Sp SH E BIG PIGEON RIVER has beautiful scenery,lots of splashes.�. .. _LOCATED �N A. .and LS LOTSOF,FUN!
• 1....� Ouc trftis Ire fun for• dI•- BEGINNERS To EXPERIENCED
4,'` PADDLERS-FUN FORTHE WHOLE FAMILY!We emDhasiae...
• �i.`..' ca•MO.EXPERIENCEISNECESSARYI •ear��alm®d,and
. +'2"'•1=•' a ali safety f
t `:PIGEON RIVER OUTDOORS omvm
•:••.;-"'Bea'Iackam;Pwasr..waar Swathing m est wet in. and TENNIS
Li`C+•.:SWE51 For.iooler day wrprovidS watarpeoef lacksts.
' . •`••" �'*p&iD:SERVICE'b iialiable.with a PACKAGE DEAL�toorneor'
Pit '.:•
., bdr thr•rapids bY_We also sell hand-designed T-shire with our BIG
• IGEON RIVER RAFTING ROUTE.
3y2 HOUR TRIPS _ _
1'I�RTHER INFORMATION
'WI of ... . for fiirthsr information on our one-daY rafting MPS,
••� •• I wsrrnlghf trios, kayak and canoe lesions,group rates,v+Aat m wear,
• accommodations,and age!knits. -....

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F

TABLE I
COSTS AND BENEFITS OF PLANS TO REDUCE
COIAR DISCHARGES INTO THE PIGEON RIVER
Total Benefits and Costs Marginal Benefits and Costs
Discharge Benefit/Cost Benefit/Cost
Reduction Plan Benefitsl Costsl Ratio Benefits2 Costs2 Ratio
-(Millions of -(Millions of
1988 Dollars)- 1988 Dollars)-
(1)/(2)- (4)/(5)
(1) (2) (3) (4) (5) (6)
50 Percent Reduction $11.3 $ 38.4 0.30 $11.3 $38.4 0.30
50 Units At Border 18.0 164.5 0.11 6.7 126.1 0.05
50 Units At Pipe 18.3 290.0 0.06 0.3 125.5 0.00
Sources and Notes
1 Total benefits are taken from Table IV. Total costs are taken from
Table V.
2 Marginal benefits and costs are the difference between the figures of a
plan and the plan immediately above it.
T1h�./T'icl.'

TABLE II
Page 1 of 2
ESTIMATES OF THE MAXIM BENEFITS FROM
A PIGEON RIVER WITH NO COLOR DISCHARGES
Visits Consumer Surplus
White- WhiteJ.
-
Year water Floating FishinR3 Other3 water Floating FishinE3 Other3
--------------(Thousands)----------- --------(Thousands of Dollars)
(1) (2) (3) (4) (5) (6) (7) -(8) -
1988 24 10 13 15 $ 312 $102 $117 $ 68
1989 48 21 14 16 624 203 126 73
1990 72 31 15 18 936 305 136 79
1991 96 42 16 19 1,248 406 147 85
1992 120 52 17 21 1,560 508 159 92
1993 120 52 19 22 1,560 508 171 99
1994 120 52 20 24 1,560 508 185 107
1995 120 52 22 26 1,560 508 200 116
1996 120 52 23 28 1,560 508 216 125
1997 120 52 25 30 1,560 508 213 135
Present Value4 $8,886 $2,892 $1,226 $711
Total Recreation Value
(Millions of 1988 Dollars) $13.72
Property Enhancements5
(Millions of 1988 Dollars)
Tennessee 2.05
North Carolina 2.52
Total Benefits
(Millions of 1988 Dollars) $18.29
n/eirr

TABLE II
Page 2 of 2
ESTIMATES OF THE MAXIMUM BENEFITS FROM
A PIGEON RIVER WITH NO COLOR DISCHARGES
Sources and Notes
1 Whitewater visits are set at a capacity of 120,000. This is in line
with 1987 visits to the Ocoee River of 124,449 visits supplied in
telephone conversation with Bob Allen at the Tennessee Department of
Conservation. Value of $13 per visit derived in text.
2 Floating visits are set at a capacity of 52,000. This was set from
current usage on the Hiwassee (80,000) reduced by 35 percent to account
for low Pigeon River water levels in August and September. Value of
3 $9.76 derived in text.
Fishing and Other taken from Bach and Barnett. Fishing value derived in
text.
4 Present discounted values over 10 years at a real rate of 6.79 percent,
derived by taking Champion's 13.2 percent after-tax cost of money and
netting out an assumed 6 percent inflation rate.
5 Property value adjustment taken from Table III.
Il�/Ifd'

TABLE III
ESTIMATES OF THE MA=MDM IMPROVEMENTS IN
PROPERTY VALUE FROM A PIGEON RIVER
WITH NO COLOR DISCHARGES
(1988 DOLLARS)
Increase in
Value per Foot Total
Miles of Valuel from Reduced Increase-
Frontage Per Foot Dischar eg s� in Value
-------(D'ollars/Foot)------- --(Thousand
Dollars)-
(1) (2) (3) (4)
North Carolina:
Residential 4.33 $52.49 $14.64 $ 335
Other Private 28.32 18.78 14.64 , 2,189
Public Land3 38.614 NA 0 0
Total $2,524
Tennessee:
Residential 5.53 52.49 14.64 427
Other Private 20.96 18.78 14.64 1,620
Public Lands 14.66 NA 0 0
Total $2,047
Total of Tennessee
and North Carolina $4,100
Sources and Notes
1 Assumes same value per river foot in North Carolina as in Tennessee.
2 For residential land this value represents an increase of 27.9 percent as
estimated by Epp and Al-Ani, reference [2] . For all other private land,
the same absolute value per foot was applied.
3 North Carolina Public includes: Interstate 40, Highways 19 and 23,
forest, mapping recon, unassigned territory, and Champion property.
4
Includes 9.34 miles to estimate the distance on missing maps. The
calculation was done by noting that there are 12.5 miles /from the dam to
the powerhouse and subtracting from this the distances on maps we have
between the dam and the powerhouse.
5 Tennessee public includes: Interstate 40, Edwina Rd. , forest, Cocke
County, unassigned territory, and publicly owned property.
I1/e/I7cl7

TABLE IV
ESTIMATES OF THE BENEFITS OF PLANS TO REDUCE
COLOR DISCHARGES IN THE PIGEON RIDER
50 Percent 50 Unit Maximum
Reduction At Border At Pipe
(1) (2) (3)
Pounds Per Day Removed 172,000 274,000 311,000
Proportion of Benefitsl
Tennessee 0.63 1.00 1.00
North Carolina 0.55 0.88 1.00
Total Benefits $11.33 $17.99 $18.29
Benefits Per Pound of
Color Per Day Removed2 66 66 59
Marginal Benefit
Per Pound Per Day3 66 66 8
Sources and Notes
1 Proportion of benefits is the proportion of total state benefits which
would be observed under each plan. Tennessee benefits include all
recreation benefits in Table II.
2 Total benefits divided by pounds per day removed.
3 Difference in benefits divided by difference in pounds per day removed
from less stringent to more stringent removal.
T1�✓IYd.'

TABLE V
ESTIMATES OF THE COSTS OF PLANS TO REDUCE
COLOR DISCHARGES IN THE PIGEON RIVER
50 Percent 50 Unit Maximum
Reduction At Border At Pipe
(1) (2) (3)
Pounds Per Day Removedl 172,000 274,000 311,000
Capital Costl
(1988 Dollars) $10,000,000 $95,120,000 $290,000,000
Operating and
Maintenance Costl
(1988 Dollars Per Year) 4,000,000 9,783,000 0
Present Value of
Total Cost2
(1988 Dollars) 38,366,000 164,496,000 $290,000,000
Cost Per Pound Per Day
of Color Removed3
(1988 Dollars) 223 601 933
Marginal Cost Per Pound
Per Day of Color Removed4 223 1,244 3,392
Sources and Notes
1 Pounds removed, capital and operating costs provided by the Company. For
50 units at the border plan, capital costs have been adjusted to reflect
probability distribution of capital cost equations.
2 Total cost taken by adding capital cost to operating and maintenance cost
stream discounted at 6.79 percent real discount rate for 10 years. Real
discount rate assumes 6 percent inflation applied to Champion after-tax
cost of money of 13.2 percent.
3 Total cost divided by pounds per day removed.
4 Difference in cost divided by difference in pounds per day removed from
less stringent to more stringent removal.
Ile/T9a.'

TABLE VI
Y
COMPARISON OF COST AND BENEFITS OF
PLANS TO REDUCE COLOR DISCHARGES
IN THE PIGEON RIVER AT ALTERNATIVE DISCOUNT RATESI
6.79% Discount Rate 38 Discount Rate
Discharge Benefit/Cost Benefit/Cost
Reduction Plan Benefits Costs Ratio Benefits Costs Ratio
-(Millions of -(Millions of
1988 Dollars)- 1988 Dollars)-
(1)/(2) (4)/(5)
(1) (2) (3) (4) (5) (6)
50 Percent Reduction $11.3 $ 38.4 0.30 $13.0 $ 45.9 0.28
50 Units at Border 18.0 164.5 0.11 20.7 196.0 0.11
50 Units at Pipe 18.3 290.0 0.06 21.0 343.0 0.06
Sources and Notes
1 All calculations are as in notes to Table I.
TLp✓IPd,•

TABLE VII
ESTIMATES OF EMPIDI!MENP IMPACTS OF PLANS
TO REDUCE COIDR DISCHARGES IN THE PIGEON RIVER.
Changes in Output Changes in the Number of Jobs
Discharge North North
Reduction Plan Tennessee' Carolina2 Tennessee3 Carolina3 Total
(Millions of 1988 $) -------(Number of Jobs)--------
(3)&(4)
(1) (2) (3) (4) (5)
50 Percent Reduction 1.29 5.86 77 176 253
50 Units At Border 2.04 17.94 123 539 662
50 Units At Pie Recreation 2.04
p Forest 15.00] -385.00 -693 -12,040 12,733
Sources and Notes
' Changes in output for Tennessee are derived by multiplying increased visits per
year (120,000) , the proportion of expenditures that are commercial (.85) , the cost
per trip (20) , and the proportion of benefits achieved (from Table IV) . The loss
of $15 million of output in the last case is taken from Oliver Blackwell's
testimony before USEPA, page 27.
2 Changes in output for North Carolina are calculated as follows: for the first two
plans they are derived by adding the operating and maintenance cost of a plant and
the capital cost multiplied by the capital recovery factor (.186) . For the 50
units at the mill plan, the loss in output is equivalent to the current output of
the mill.
3 Multipliers are derived from RIMS manual, reference [131 .
Ilip./IYd'

CHRONOLOGY
CHAMPION INTERNATIONAL
CANTON, NORTH CAROLINA
June 25, 1984 EMC Public Meeting for Champion' s
Temperature Variance
October, 1984 Temperature variance issued by EMC not to
exceed temperature increase at Fiberville
Bridge ( . 4 miles downstream of discharge)
of 13 . 9 degrees Centigrade . Maximum
temperature of 29 degrees Centigrade
October thru June and 32 degrees Centigrade
July thru September
May 14 , 1985 North Carolina issued NPDES Permit Number
NC0000272 to Champion International, Canton
Mill .
November 13 , 1985 - EPA assumes control of Champion' s NPDES
Permit after determining that it (EPA)
did not have sufficient time (90 days) to
review the permit prior to N. C. issuance
and in response to color concerns of
downstream residents in Tennessee.
January 17, 1986 - Champion challenged EPA' s claim of
authority over the permit process in US
District court .
March 24 , 1986 - North Carolina filed court action to
block EPA action.
March 26, 1986 - Champion asks for temporary restraining
order to block EPA action until
existing suit is settled.
March 31, 1986 - US District Court Judge Sentelle denies
Champion request for temporary
restraining order.
April 11, 1986 - Champion requests NPDES Permit from EPA.
May 2, 1986 - Motion by EPA to dismiss Champion
suit denied.

Page 2
December 1, 1986 - US District Court Judge Sentelle ruled
that EPA had jurisdiction to assume
authority over Champion' s NPDES Permit .
March 4, 1987 - Champion appeal of Sentelle ruling.
April 9, 1987 - First EPA Draft (public notice) of
Champion NPDES Permit with 50 unit color
limit applicable to Champion immediately
downstream of discharge at Fiberville
Bridge.
May 22, 1987 - Second EPA public notice for permit
issuance .
January 14, 1988 - First Public Hearing in Asheville Civic
Center for NPDES Permit issuance.
January 21, 1988 - First Public Hearing in Knoxville,
Tennessee Civic Center.
March 9, 1988 - Tennessee, North Carolina, Champion, and
EPA agree on change in proposed permit
from 50 Apparent Color units at NC/TN
state line (proposed as applicable at
the Fiberville Bridge immediately
downstream of the Champion Mill) to 85
True Color Units at the State line.
North Carolina and Tennessee to grant
variance from color stream standard to
allow permit issuance.
May 5, 1988 - Champion formally requests water quality
color standard variance from EMC NPDES
subcommittee at public hearing in Raleigh.
June 24, 1988 - Champion appeal of Sentelle decision
denied by three judge panel of 4th US
Circuit Court of Appeals - verifying EPA
authority over Champion' s NPDES permit .
Ron Levine, Director, Division of
Health Services, NC Dept . of Human
Resources issued advisory against eating
fish from Pigeon River as per studies
showing a presence of dioxin in fish and

Page 3
sediment downstream of the mill; albeit
.not in Champion' s effluent . Dioxin not
regulated to date in the proposed NPDES
Permit .
July 13 , 1988 - EMC issues water quality variance from
North Carolina color standard allowing
NPDES Permit for 85 True Color Units to be
placed in proposed NPDES Permit.
August 18-19, 1988- Tennessee color variance hearing in
Newport, Tennessee .
December 23, 1988 - Tennessee denies Champion' s color variance
request from standard, preventing
agreement reached 3/9/88 from being
formally enacted.
March 15, 1989 - EPA Issued a draft Discharge Permit for a
reconfigured Canton Mill, allowing it to
operate during reconfiguration.
July 12, 1989 - Second draft NPDES Permit (public notice)
for Champion with color limit consistent
with EMC variance and Tennessee
limit of 50 units at State Line . Permit
also including additional requirement for
chloroform and dioxin. Permit provided
for reduction in flow from 48 . 5 MGD
to 29 MGD and three (3) year schedule for
compliance (down from 5 year schedule in
initial draft) .
August 17, 1989 - Newport, Tennessee public hearing on EPA
NPDES Draft Permit .
August 24, 1989 - Asheville public hearing on permit .
September 8, 1989 - DEM issues Section 401 Water Quality
Certification for proposed Champion Permit.
September 25, 1989- Champion NPDES Permit issued by EPA.

Page 4
October 14, 1989 - Permit appealed first by Environmental
groups and then by Champion. EPA
administrative law judge grants hearing.
Hearing to be scheduled.
March 27, 1990 - Champion announces implementation of
modernization project despite pending legal
issues . Estimated cost of project is $250
million.
1990 - 1991 - Legal issues continue to be fought before
EPA Administrative Law Judge . Champion
continues modernization project.
April, 1991 - EPA Administrative Hearing held in Atlanta,
Georgia.
Early 1992 - Administrative Law Judge issues final
decision essentially leaving permit as is .
No appeal requested.

State of North Carolina
Department of Environment
and Natural Resources A94
Asheville Regional Office
IV
AMNON �
Michael F. Easley, Governor N C D EN R
Sherri Evans-Stanton, Acting Secretary
Kerr T. Stevens, Director NORTH CAROLINA DEPARTMENT OF
Division of Water Quality ENVIRONMENT AND NATURAL RESOURCES
WATER QUALITY SECTION
January 17, 2001
Mr. Derric Brown
Blue Ridge Paper Products Inc.
Post Office Box 4000
Canton, North Carolina 28716,
Subject: Acceptance of Activated Sludge
From Maggie Valley WWTP
Blue Ridge Paper Products
NPDES Permit No . NC0000272
Haywood County
Dear Mr. Brown:
This Office does not foresee a problem with your wastewater
treatment plant accepting activated sludge from the Town of Maggie
Valley. It is suggested that you maintain a record of all sludge
received including the date and number of gallons .
If you have any questions concerning this matter or if you
require additional information, please do not hesitate to contact me
at 251-6208 .
Sincerely,
ZZ
D. Keith Haynes/
Environmental Specialist
xc: Mike Mehaffey
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-consumer paper

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
L
Michael F. Easley, Governor NCDENK
Sherri Evans-Stanton, Acting Secretary
Kerr T. Stevens, DirectorNc A CARouNA 0FP TmE of
Division of Water Quality ENV aNmE AND NA[U ResouRc�
WATER QUAL= SECTION
.January 17, 2001
Mr. Derric Brown
Blue Ridge Paper Products Inc.
Post Office Box 4000
Canton, North Carolina 28716
Subject: Acceptance. of Activated Sludge
From Maggie Valley WWTP
Blue Ridge Paper Products
NPDES Permit No. NC0000272
Haywood County
Dear Mr. Brown:
This Office does not foresee a problem with your wastewater
treatment plant accepting activated sludge from the Town of Maggie
Valley. It is suggested that you maintain a record of all sludge
received including the date and number of gallons.
If you have any questions concerning this matter or if you
require additional information, please do not hesitate to contact me
at 251-6208 .
Sincerely,
D. Keith Haynes
Environmental Specialist
xc: Mike Mehaffey
59 Woodfin Place,Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Eaual Onoortunity Affirmative Action Fmnlnver 50% reevele MM' nncf-ennsnmer naner

Making ur mark fof you. (��V
BLUE RIDGE PAPER PRODUCTS INC. - -
January 9, 2001
Mr. Forrest Westall
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,North Carolina 28801
Re: North Carolina NPDES Permit No. NC0000272
Blue Ridge Paper Products,Inc. - Canton Mill
2000 Waterville Reservoir Sampling Requirement Results
Dear Forrest:
On August 15, 2000, in accordance with Part III, Section K of the Canton Mill's NPDES
Permit, Waterville Reservoir was sampled at three locations for temperature, dissolved
oxygen, conductivity, Secchi Depth,pH,Total Nitrogen (TN),Nitrite+Nitrate (NO2 +
NO3), Ammonia(NH3-N), Total Kjeldahl Nitrogen(TKN), Total Phosphates (PO4),
Total Phosphorous (TP), and Chlorophyll-a. As stated in the permit,water samples were
collected at 0.1 meters beneath the surface of the lake prior to Laurel Branch, near
Wilkins Creek, and near the dam as stated in the permit.
Temperature, dissolved oxygen, conductivity, Secchi Depth, and pH were measured in
the field while the remaining samples were collected,preserved, and sent to a North
Carolina certified laboratory for analysis. Attached is a table summarizing the results of
the above analyses for each sampling site. This table will be attached to the mill's
December DMR,which will be mailed at the end of January.
If there are any questions or comments please contact me at(828) 646-6749.
Sincerely C
Melame S. Hager
Environmental Engineer f�. " p`�•
e'' A
nq t
175 Main Street P.O. Box 4000 Canton, North Carolina 28716 828-646-2000

Blue Ridge Paper Products, Inc. -Canton, NC
Results of 2000 Waterville Reservoir Sampling NPDES Permit Requirement
Sample Waterville Reservoir Waterville Reservoir Waterville Reservoir
Parameter Units prior to Laurel Branch near Wilkins Creek near the dam
Temperature Celsius 25.5 24.8 24.6
Dissolved Oxygen mg17 13.2 7.5 7.3
Conductivity umhos 392 351 352
pH 9 7.9 8.3
TN mg/7(ppm) 1.1 1.0 1.0
NO2 + NO3 mg/I(ppm) both ND(0.10) ND(0.10) and 0.12 ND(0.10) and 0.10
TKN mg1l(ppm) 1.1 0.9 0.9
NH3-N mg/J(ppm) ND(0.10) ND(0.10) 0.11
PO4 mgA(ppm) 0.06 ND(0.02) ND(0.02) .
TP mg/7(ppm) 0.1 0.03 0.04
Chlorphyll-a ugA(ppb) 45.39 43.44 29.75
Secchi Depth meters 0.59 0.95 0.96
Sample Notes:
Laurel Branch Site Sampled on 8/15/00 at 10:20am
Wilkins Creek Site Sampled on 8/15106 at 11:10am
Dam Site Sampled on 8/15/00 at 11:30am
2000 Waterville Lake MSH 115101

d
BLUE RIDGE ,tt11
PAPER PRODUCTS INC.
vv QOQ
December 28,2000
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
January 1,2001 Color Limit Feasibility Report
Dear Mr. Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24,
and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 99a'percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 lbs/day and an average monthly color limit of 59,796 lbs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit), Blue Ridge Paper Products recommends using a 95a'percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 95's percentile statistical review of the
limited data available from January 1998—October 31, 2000 the annual average color is 48,388 lbs/day
and the monthly average color is 55,556 lbs/day. Blue Ridge Paper Products believes the 95 s percentile
confidence interval will be appropriate with the additional color data that will be available for the June 1,
2001 analysis. The attached Table includes the summary of the 99s' and 950'percentile statistical data.
Please call me at(828) 646-2033 or Derric Brown at(828)646-2318 if you have any questions regarding
this report.
Sincerely,
Bob Williams
Director-Environmental,Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

BLUE RIDGE
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1,2001— Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000—52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III,Paragraph E 12 of the 1997
Permit provides in part, as follows:
"...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 Ibs/day
based on full implementation of the Near-Term Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits..."
This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000, Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000— 52, 000 pounds per day is feasible.
1

January 1, 2001 - Color Limit Feasibility Report
Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
400000
N
d
v
0 300000
O
V
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1,2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I1. Color Performance
The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual
average amount of color discharged, as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project, full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRTM on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average
annual color discharged was 41,048 Ibs/day. The 2000 average annual color(through
October) is 44,837 Ibs/day. All of these values are within or below the target annual
average color range of 48,000—52,000 lbs/day specified in Part III, Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion(30Q2),historical flow records, and the
January 1998—October 2000 annual average color value of 45,4581bs/day, it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
3

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
III. Recommended Color Limits
The January 1998 —October 2000 actual average annual color of 45,458 lbs/day and the
January 2000—October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000—52,000 lbs/day specified in Part
III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated, that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 lbs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998—October 2000 annual color average using a 991'percentile
distribution is 49,612 lbs/day. The January 2000—October 2000 annual color average
using a 99"i percentile distribution is 48,911 lbs/day. These values are both within the
48,000—52,000 lb/day range. Based on a statistical review of the data and the limited
data set available, Blue Ridge Paper Products, Inc. recommends an annual average
effluent limit of 49,612 lbs/day.
The January 1998 —October 2000 monthly color average using a 99`s percentile
distribution is 59,796 lbs/day. The January 2000—October 2000 monthly color average
using a 990'percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available,Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,796 lbs/day.
4

January I, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
• Canton,North Carolina
III. Conclusion
Blue Ridge Paper Products,Inc. believes it is feasible to achieve a target annual average
color limit within the range of 48,000—52, 000 lbs/day. The Canton Mill recommends
_an average-annual color limit of 49,612.1bs/day and an average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria (30Q2), historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepeo gage will be less than 50 true color units approximately 97%
of the applicable time.
5

,
TABLE
January 1, 2001 Color Limit Feasibility Report
Monthly Average Data -Max Month Calc
Data Set= 1/1/98-10/31/2000 1/112000-10/3112000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. = 34 10
xbar • 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 55556 54773
99th safe MONTH from normal dist 69796 58953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58542 58009

---.. - -. --------
UJ
Making ur mark for you.
O
BLUE RIDGE 70
PAPER PRODUCTS INC. OCr COOZ
r
LARORAT
r 1 ASREVILL ORY SECTION
Dt �v�'_' l�Jr E REGIONAL OFFCE
� �v
Certification Number 198 r OCT 9 2000 October 5, 2000
Mr. James W. Meyer . DIM
DWQ Laboratory Section LABORATORY SECTION
NCDENR
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
Subject: Laboratory Certification Maintenance Inspection Response to
September 12, 2000 Letter and August 30, 2000 Inspection Report.
Dear Mr. Meyer:
The laboratory inspection report from August 30, 2000 by Mr. Gary Francies
contained four lettered comments that required a written reply. This correspondence
is the response to your letter dated September 12, 2000 that includes the reply to the
lettered comments.
Ammonia Nitrogen
A. COMMENT: The laboratory control standard is not from a second source:
occasionally, a second source standard is analyzed, but not daily as required.
RESPONSE: Beginning October 1, 2000 a mid-range second source standard is
analyzed daily to document accuracy.
B. COMMENT: The distilled versus undistilled comparison study results are
unacceptable. It appears this is due to the low concentration of the samples used.
It is recommended that the samples be spiked to a concentration of at least 1 to 5
mg/1. Please submit the results from the analysis of two sets of samples.
RESPONSE: Two sets of spiked samples were analyzed by Pace Analytical
Services, Asheville,N.C. for the distilled versus undistilled comparison. The
sample dates and test results follow:
Date Distilled Undistilled
8-30-00 5.62 mg/I 5.2 mg/1
9-05-00 4.88 mg/1 4.3 mg/1

BLUE RIDGE PAPER PRODUCTS INC.
Color—platinum cobalt
C. COMMENT: The linearity of the curve, slope value, and y-intercept are not
maintained on file for three years. The raw data is on file and the
spectrophotometer displays all this information, but once a new curve is
established all this information from the old curve is lost except the raw data
values. It is recommended that the raw data be entered into your computer, which
then can produce the curve, and all associated information, which can be printed
and stored with the raw data. Each daily bench sheet must document the date of
the curve.
RESPONSE: The slope values, y-intercepts, and correlation coefficients for all
curves used in the past three years have been restored in our files. Daily bench
sheets now contain the date the curve in use was made.
BOD
D. COMMENT: The laboratory is analyzing 5 mLs of standard not 6 mLs, as the
method requires. This has been done for several years and has been missed in
prior audits, both internal and those conducted by the state. All values obtained
for the standards reviewed were in the acceptable range.
RESPONSE: Beginning October 1, 2000 the laboratory changed from 5 mLs to
6 mLs of glucose glutamic acid standard in the 300 mL BOD bottles. The 5 mLs
of standard was required in the Federal EPA Method.
If you have any questions, comments, or need additional information, I can be contacted
by phone at 828-646-6720 or by fax at 828-646-2993.
Sincerely,
�,
/,
John J. Pryately
Laboratory & WWTP Supervisor

ll
National
I
Environmental
Achievement Track
I
_ Application Eorin _
Blue Ridge Paper Products, Inc.
Name of facility
Name of parent company(if any)
175 Main Street
Street address
Box 4000
Street address (continued)
Canton, North Carolina 28716
City/State/Zip code
Give us information about your contact person for the
National Environmental Achievement Track Program.
Name Robert V.Williams
Title Director, Environmental, Health and Safety Affairs
Phone [phone]
Fax [phone]
E-mail [e-mail]
Page 1 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

0
Why needs
s b need this inforion on you j 1% n A
EPA needs background information on our facilityto I
evaluate your application.
What do you need to do? 1 a 9t,$+'�'r t
• Provide background information on your facility.
• Identify your environmental requirements.
1 What do you do or make at your facility? Uncoated freesheet paper and paperboard products
2 List the Standard Industrial Classification (SIC) SIC
code(s) or North American Industrial Classification 2611 2621 2631
System (NAICS) codes that you use to classify
business at your facility. NAICS
3 Does your company meet the Small Business ❑ Yes ® No
Administration definition of a small business for your
sector?
4 How many employees (full-time equivalents) ❑ Fewer than 50
currently work at your-facility?
❑ 50-99
❑ 100-499
❑ 500-1,000
® More than 1,000
Page 2 Application far the National Environmental Achievement Track
OMB Approved No.2010-0032

_ Er �I� 0buy
5 Does your facility have an EPA ID number(s)? ® Yes ❑ No
If yes, list in the right-hand column. NCD 003148889
6 Identify the environmental requirements that apply to
your facility. Use the Environmental Requirements
Checklist, at the back of the instructions,as a
reference. List your requirements to the right or
enclose a completed Checklist with your application.
7 Check the appropriate box in the right-hand column. ❑ I've listed the requirements above.
® I've enclosed the Checklist with my application.
8 Optional: Is there anything else you would like to tell The Canton Mill has been under new ownership since
us about your facility? May 1999. Along with financial investors, it is now an
employee-owned company, Blue Ridge Paper Products
Inc.The Canton Mill is still in the process of converting
many of its existing programs and documents to those
of Blue Ridge Paper Products Inc. It is also in the
process of revising or establishing new programs that
were managed by the previous corporate EHS staff.
Some long standing facility practices, such as
environmental training for all employees whose job
responsibilities can significantly impact the
environment, are now being incorporated into the
facility's formal EMS.
The Canton Mill ranks among the top pulp and paper
mills in the world for water quality. The mill is already
in compliance with the effluent guidelines portion of the
federal government's new Cluster Rules, years before
many other facilities. Canton's kraft pulp mill is
Elemental Chlorine Free (ECF), using Oxygen
Delignification with 100% chlorine dioxide bleaching
and Bleach Filtrate Recycle (BFR)technology. The
BFR process recovers naturally ocurring minerals in
wood and other chemicals used to bleach pulp white.
Because BFR technology recycles the chemicals and
Page 3 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

water used in the bleaching process, water usage,
bleach plant effluent and effluent color are reduced,
allowing the Canton Mill to dramatically reduce its
impact on the environment.
Page 4 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

'Why we need this information ( r 7 j 0,00`
'Facilities must have an operating Environmental 14f{_-�)J�f�r1.1Lf f_'UG ll1/_I (��/! f�/ )fJ
;Management System (EMS)that meets certain rmv
'requirements.
What do you need to do? ; tFtS
• Confirm that your EMS meets the Achievement L' --
Track requirements.
• Tell us if you have completed a self-assessment or ,
have had a third-party assessment:of your EMS.
1 Check yes if your EMS meets the requirements for
each element below as defined in the instructions.
a. Environmental policy ® Yes
b. Planning ® Yes
c. Implementation and operation ® Yes
d. Checking and corrective action ® Yes
e. Management review ® Yes
2 Have you completed at least one EMS cycle ®Yes
(plan-do-check-act)?
3 Did this cycle include both an EMS and a ® Yes
compliance
audit?
4 Have you completed an objective self-assessment or ®Yes
third-party assessment of your EMS?
If yes, what method of EMS assessment did you ® Self-assessment
use?
❑ GEMI ® Other
❑ CEMP
American Forest& Paper Association Corporate
Survey to Verify Compliance with EHS Principles
❑Third-party assessment
❑ ISO 14001 Certification
❑ Other
Page 5 Applicalion for the National Environmental Achievement Track
OMB Approved No.2010-0032

Why rho we need this information? � ( y�
Facilities must show that they are committed to S�3 j:_� �tl '�� n
iimproving their environmental performance. This means
that you can describe past achievements and will make
future commitments, �tstt '
What do you need to do?
;Refer to the Environmental Performance Table in the
instructions to answer questions 1 and 2.
1 Describe your past achievements for at least two
environmental aspects. If you need more space than is
provided,attach copies of this page.
Note to small facilities: If you qualify as a small facility as
defined in the instructions,you are required to report past
achievement for at least one environmental aspect.
First aspectyou've selected
What aspect have What was the previous level What is the current level?
you selected? (2 years ago)?
Quantity Units Quantity Units
COD Discharges to Water 13.86 lbs./ 1000 lbs. 8.78 lbs./ 1000 lbs.
pulp pulp
I. How is the current level an improvement over the
previous level?
This improvement is a significant reduction of COD discharge to water and is also a significant
improvement in the overall efficiency of the facility's operations.This level of performance is less than
1/3 of the proposed Cluster Rule Limitation for Bleached Papergrade Kraft Mills.
ii. How did you achieve this improvement?
As a result of substantial capital investment in BFR(Bleach Filtrate Recycle), a proprietary technology
that allows for bleach filtrates to be recycled in its softwood fiber line.The Canton Mill is the only
bleach kraft mill in the world that employs this technology.
Page 6 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

Second aspectyou've selected
What aspect have What was the previous level What is the current level?
you selected? (2 years ago)?
Quantity Units Quantity Units
Water Use 26.8 million gallons 24.3 million gallons
daily daily
i. How is the current level an improvement over the
previous level?
On average, the facility has reduced the amount of intake water by two million gallons per day.
ii. How did you achieve this improvement?
This improvement was achieved through process optimization water conservation measures
throughout the mill. Focused efforts to reduce water usage have included the optimization of non-
contact cooling water.
2 Select at least four environmental aspects (no more than
two from any one category)from the Environmental
Performance Table in the instructions and then tell us
about your future commitments. If you need more space
than is provided, attach copies of this section.
Note to small facilities: If you are a small facility, you
are required to make commitments for at least two
environmental aspects in two different categories.
First aspect you've selected
a.What is the aspect? Material Use (Purchased lime reduction)
b. Is this aspect identified as significant in your EMS? ®Yes ❑ No
c.What is the current level?You may choose to state ® Option A:
this as an absolute value or in terms of units of Absolute value 55 tons/day
production or output. (Quantity/Units)
❑ Option B:
In terms of
units of production (Quantity/Units)
or output
Page 7 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

d.What is the improvement you are committing to ® Option A:
over the next three years?You may choose to state Absolute value 40 tons/day
this as an absolute value or in terms of units of (Quantity/Units)
production or output. ❑ Option B:
In terms of
units of production (Quantity/Units)
or output
e. How will you achieve this improvement? The objective is to reduce the amount of lime
purchased by 15 tons per day. This will be
accomplished by capital investment resulting in process
improvements and equipment upgrades. This will also
reduce the amount of solid waste generated by the
facility and landfilled.
Second aspect you've selected
a.What is the aspect? Material use(Reduce influent fiber losses)
b. Is this aspect identified as significant in your EMS? ®Yes ❑ No
c.What is the current level?You may choose to state ® Option A:
this as an absolute value or in terms of units of Absolute value 28 tons/day
production or output. (Quantity/Units)
❑ Option B:
In terms of
units of production (Quantity/Units)
or output
d. What is the improvement you are committing to ® Option A:
over the next three years?You may choose to state Absolute value 20 tons/day
this as an absolute value or in terms of units of (QuantitylUnits)
production or output. ❑ Option B:
In terms of
units of production (Quantity/Units)
or output
e. How will you achieve this improvement? The objective is to increase on-site manufactured fiber
useage by 8 tons per day. This will improve the
efficiency of the facility's operations and reduce the
amount of solid waste generated and landfilled. This
objective will be achieved through process and
operating practice optimization.
Page 8 Application for the National Environmental Achievement Track
OMB Approved No.2010-0031

Third aspect you've selected
a.What is the aspect? Total Solid Waste (Recycle of depoly)
b. Is this aspect identified as significant in your EMS? ®Yes ❑ No
c.What is the current level?You may choose to state ® Option A:
this as an absolute value or in terms of units of Absolute value 350 tons/month
production or output. (Quantity/Units)
❑ Option B:
In terms of
units of production (Quantity/Units)
or output
d.What is the improvement you are committing to ® Option A:
over the next three years?You may choose to state Absolute value 1.100 tons/month
this as an absolute value or in terms of units of (Quantity/Units)
production or output. ❑ Option B:
In terms of
units of production (Quantity/Units)
or output
e. How will you achieve this improvement? The objective is to increase the amount of waste
coated paperboard material recycled by 750 tons per
month. This objective will be achieved by making
process changes and increasing uptime to the recycling
process.
Fourth aspect you've selected
a.What is the aspect? Expected Lifetime Waste of Product(Increase
paperboard packaging efficiency)
b. Is this aspect identified as significant in your EMS? ®Yes ❑ No
c. What is the current level?You may choose to state ❑ Option A:
this as an absolute value or in terms of units of Absolute value
production or output. (Quantity/Units)
® Option B:
In terms of 282 Ibs/3000 sq. ft.
units of production (Quantity/Units)
or output
d.What is the improvement you are committing to ❑ Option A:
over the next three years?You may choose to state Absolute value
this as an absolute value or in terms of units of (Quantity/Units)
production or output. ® Option B:
In terms of 265 Ibs/3000 sq. ft.
units of production (Quantity/Units)
or output
e. How will you achieve this improvement? The objective of this improvement is to reduce the total
basis weight of our product line by 5% to 6% on
average. This will result in reducing the fiber content of
our product. This change came about as a result of
applying Design for the Environment and Life Cycle
Analysis thinking. Reducing the fiber content will make
our products lighter. A lighter product will result in
Page 9 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

reduced solid waste generated by our end-users. For
example, the 23 point paperboard grade product that
we produce for milk and juice cartons is currently 282
pounds per 3000 square feet of product area, after
capital investment and equipment upgrade the weight
will be reduced to approximately 265 pounds per 3000
square feet.
Page 10 Application jar the National Environmental Achievement Track
OMB Approved No.2010-0032

Why do we need this information?
/Oozr/a IB
Facilities must demonstrate their commitment to public tS,3(10
outreach and performance reporting. You should have
appropriate mechanisms in place to identify community
concerns,to communicate with the public, and to provide LAW W1 C t �Uw a a
information on your environmental performance.
What do you need to do?
• Describe your approach to public outreach.
• List three references who are familiar with your facility.
1 How do you identify and respond to community The Canton Mill's primary means of identifying and
concerns? responding to community concerns is through the
Community Advisory Committee that normally meets
once every three months. It is made up of local
citizens, the purpose of which is to discuss their
concerns that relate to the facility and educate them
about the facility's operations.
Canton Mill management also meets periodically with
an alliance of local nonprofit organizations in order to
communicate on environmental performance and report
on different environmental initiatives.
2 How do you inform community members of Community members are informed of pertinent
important matters that affect them? information through the Community Advisory
Committee, periodic leadership forums, legislative
updates and through a regular mill tour program.
3 How will you make the Achievement Track Annual ❑Website www.
Performance Report available to the public?
❑ Newspaper
® Open Houses
® Other
The report will also be disseminated through the
existing community outreach programs.
Page I Application for the.National Environmental Achievement Track
OMB Approved No.2010-0032

4 Are there any ongoing citizen suits against your ❑ yes ® No
facility?
If yes, describe briefly in the right-hand column.
5 List references below
Organization Name Phone number
Representative of Haywood Scenic Ron Moser, Director 828-456-5195
a Communityl Waterways Assocation
Citizen Group
StatelLocal Regulator North Carolina Forrest Westall, Regional 828-251-p208
Department of Water Quality Supervisor
Environment and Natural
Resources, Division of
Environmental
Management
Other communityllocal Haywood County Jack Horton, Haywood 828-648-2363
reference
County Manager
Page 12 Application far the National Environmental Achievement Track
OMB Approved No.2010-0032

On behalf of Blue Ridge Paper Products, Inc. Canton Mill
[my facility], 1W Ing,
e�
I certify that —Ali
• I have read and agree to the terms and conditions, as specified in the National Environmental
Achievement Track Program Description and in the Application Instructions;
• I have personally examined and am familiar with the information contained in this Application (including,
if attached, the Environmental Requirements Checklist). The information contained in this Application
is, to the best of my knowledge and based on reasonable inquiry, true, accurate, and complete, and I
have no reason to believe the facility would not meet all program requirements;
• My facility has an environmental management system (EMS), as defined in the Achievement Track
EMS requirements, including systems to maintain compliance with all applicable federal, state, tribal,
and local environmental requirements, in place at the facility, and the EMS will be maintained for the
duration of the facility's participation in the program;
• My facility has conducted an objective assessment of its compliance with all applicable federal, state,
tribal, and local environmental requirements, and the facility has corrected all identified instances of
potential or actual noncompliance;
• Based on the foregoing compliance assessment and subsequent corrective actions (if any were
necessary), my facility is,to the best of my knowledge and based on reasonable inquiry, currently in
compliance with applicable federal,state,tribal, and local environmental requirements.
I agree that EPA's decision whether to accept participants into or remove them from the National Environmental
Achievement Track is wholly discretionary, and I waive any right that may exist under any law to challenge EPA's
acceptance or removal decision.
I am the senior facility manager and fully authorized to execute this statement on behalf of the corporation or
other legal entity whose facility is applying to this program.
Signature/Date
Printed Name/Title George Henson,Vice President-Mill Division
Facility Name Canton Mill
Facility Street Address 175 Main Street
Facility ID Numbers NCD 003148889
Page 13 Application for the National Environmental Achievement Dwck
OMB Approved No.2010-0032

The National Environmental Performance Track is a U.S. Environmental Protection
Agency program. Please direct inquiries to 1-888-339-PTRK or e-mail
[e-mail]. Mail completed applications to:
The Performance Track Information Center
c/o Industrial Economics Incorporated
2067 Massachusetts Avenue
Cambridge, MA 02140
Page 14 Application for the National Environmental Achievement Track
OMB Approved No.2010-0032

National Environmental Achievement Track
Environmental Requirements Checklist
The following Checklist is provided to assist facilities in answering Section A, Tell us about your
facility, " Question 6. The Checklist is given to help facilities identify the major federal, state,
tribal, and local environmental requirements applicable at their facilities. The Checklist is not
intended to be an exhaustive list of all environmental requirements that may be applicable at an
individual facility.
If you use this Checklist and choose to submit it with your application, fill in your facility
information below and enclose the completed Checklist with your application (see instructions).
Facility Name: Canton Pulp &Paper Mill
Facility Location: Canton, NC
Facility ID Number(s): NCDO0314889
(attach additional sheets if necessmy)
Check All
Air Pollution Regulations That Apply
1. National Emission Standards for Hazardous Air Pollutants (40 CFR 61)
2. Permits and Registration of Air Pollution Sources
3. General Emission Standards,Prohibitions and Restrictions
4. Control of Incinerators ❑
5. Process Industry Emission Standards
6. Control of Fuel Burning Equipment
7. Control of VOCs
8. Sampling, Testing and Reporting
9. Visible Emissions Standards
10. Control of Fugitive Dust
11. Toxic Air Pollutants Control
12. Vehicle Emissions Inspections and Testing ❑
Other Federal, State, Tribal or Local Air Pollution Regulations Not Listed Above (identify)
13. ❑
14. ❑
Page AI—Environmental Requirements Checklist Application for the National Environmental Achievement Track

Hazardous Waste Management Regulations
1. Identification and Listing of Hazardous Waste (40 CFR 261)
- Characteristic Waste
- Listed Waste
2. Standards Applicable to Generators of Hazardous Waste (40 CFR 261)
- Manifesting
- Pre-transport requirements
- Record keeping/reporting
3. Standards Applicable to Transporters of Hazardous Waste (40 CFR 262) ❑
- Transfer facility requirements ❑
- Manifest system and record-keeping ❑
- Hazardous waste discharges ❑
4. Standards for Owners and Operators of TSD Facilities (40 CFR 264) ❑
- General facility standards ❑
- Preparedness and prevention ❑
- Contingency plan and emergency procedures ❑
- Manifest system, record keeping and reporting ❑
- Groundwater protection ❑
- Financial requirements ❑
- Use and management of containers ❑
- Tanks ❑
Waste piles ❑
- Land treatment ❑
Incinerators ❑
5. Interim Status Standards for TSD Owners and Operators (40 CFR 265) ❑
6. Interim Standards for Owners and Operators of New Hazardous Waste
Land Disposal Facilities (40 CFR 267) ❑
7. Administered Permit Program (Part B) (40 CFR 270) ❑
Other Federal, State, Tribal or Local Hazardous Waste Management Regulations Not
Listed Above (identify)
8. ❑
9. ❑
Page A 2—Environmental Requirements Checklist Application for the National Environmental Achievement Track '

Hazardous Materials Management
1. Control of Pollution by Oil and Hazardous Substances (33 CFR 153)
2. Designation of Reportable Quantities and Notification of Hazardous
Materials Spill (40 CFR 302)
3. Hazardous Materials Transportation Regulations (49 CFR 172-173)
4. Worker Right-to-Know Regulations (29 CFR 1910.1200)
5. Community Right-to-Know Regulations (40 CFR 350-372)
Other Federal, State, Tribal or Local Hazardous Materials Management Regulations Not
Listed Above (identify)
6. ❑
7. ❑
Water Pollution Control Requirements
1. ' Oil Spill Prevention Control and Countermeasures (SPCC) (40 CFR 112)
2. Designation of Hazardous Substances (40 CFR 116)
3. Determination of Reportable Quantities for Hazardous Substances
4. NPDES Permit Requirements (40 CFR 122)
5. Toxic Pollutant Effluent Standards(40 CFR 129)
6. General Pretreatment Regulations for Existing and New Sources ❑
7. Organic Chemicals Manufacturing Point Source Effluent Guidelines
and Standards ❑
8. Inorganic Chemicals Manufacturing Point Source Effluent Guidelines
and Standards ❑
9. Plastics and Synthetics Point Source Effluent Guidelines and Standards
(40 CFR 416) ❑
10. Water Quality Standards
11. Effluent Limitations for Direct Dischargers
12. Permit Monitoring/Reporting Requirements
13. Classifications and Certifications of Operators and Superintendents of
Industrial Wastewater Plants
14. Collection,Handling,Processing of Sewage Sludge
15. Oil Discharge Containment, Control and Cleanup ❑
16. Standards Applicable to Indirect Discharges (Pretreatment) ❑
Other Federal, State, Tribal or Local Water Pollution Control Regulations Not Listed
Above (identify)
17. ❑
18. ❑
Page A3—Environments]Requirements Checklist Application for the National Environmental Achievement Track

Drinking Water Regulations
1. Underground Injection and Control Regulations, Criteria and Standards ❑
(40 CFR 144, 146)
2. National Primary Drinking Water Standards (40 CFR 141) ❑
3. Community Water Systems, Monitoring and Reporting Requirements ❑
(40 CFR 141)
4. Permit Requirements for Appropriation/Use of Water from Surface or
Subsurface Sources ❑
5. Underground Injection Control Requirements ❑
6. Monitoring, Reporting and Record Keeping Requirements for Community ❑
Water Systems
Other Federal, State,Tribal or Local Drinking Water Regulations Not Listed Above
(identify)
7. ❑
8. ❑
Toxic Substances
1. Manufacture and Import of Chemicals, Record Keeping and Reporting ❑
2. Import and Export of Chemicals (40 CFR 707) ❑
3. Chemical Substances Inventory Reporting Requirements (40 CFR 710) ❑
4. Chemical Information Rules (40 CFR 172) ❑
5. Health and Safety Data Reporting (40 CFR 716)
6. Pre-Manufacture Notifications (40 CFR 720) ❑
7. PCB Distribution Use, Storage and Disposal (40 CFR 761) ❑
8. Regulations on Use of Fully Halogenated Chlorofluoroalkanes (40 CFR 762) ❑
9. Storage and Disposal of Waste Material Containing TCDD (40 CFR 775) ❑
Other Federal, State, Tribal or Local Toxic Substances Regulations Not Listed Above
(identify)
10. ❑
11. ❑
Page A 4—Environmental Requirements Checklist Application for the National Environmental Achievement Track

Pesticide Regulations
1. FIFRA Pesticide Use Classification (40 CFR 162) ❑
2. Procedures for Disposal and Storage of Pesticides and Containers (40 CFR 165) ❑
3. Certification of Pesticide Applications (40 CFR 171) ❑
4. Pesticide Licensing Requirements ❑
5. Labeling of Pesticides ❑
6. Pesticide Sales, Permits, Records, Application and Disposal Requirements ❑
7. Disposal of Pesticide Containers ❑
8. Restricted Use and Prohibited Pesticides ❑
Other Federal, State, Tribal or Local Pesticides Regulations Not listed Above (identify)
9. ❑
10. ❑
Environmental Clean-Up,Restoration, Corrective Action
1. Comprehensive Environmental Response, Compensation and Liability Act (Superfund)
(identify)
El
Ej
2. RXRA Corrective Action (identify)
Other Federal, State, Tribal or Local Environmental Clean-up, Restoration, Corrective
Action Regulations Not Listed Above (identify)
3. ❑
4. ❑
Page A 5—Environmental Requirements Checklist Application for the National Environmental Achievement Track

P17 :40 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P61/02
PW
PN ,�BLUE RIDGE
PAPER pRODUC75 INC,
FACSIMILE TRANSMITTAL SHEET
TO: FROM: •
e t i�y itie s 3-1-- I� I .* e< e
COMPANY: DATE:
Nc �a1v2 11/s/00
FAX NUMBER: TOTAL NO.OF PAGES INCLUDING COVER:
asr _ � sa
PHONE NUMBER: SENDER'S FAX NUMBER:
[phone]
RE: SENDER'S PHONE NUMBER:
(828) 646- -a'o�C6
❑URGENT 11<OR REVIEW ❑PLEASE COMMENT ❑PLEASE REPLY ❑PLEASE RECYCLE
NOTES/,C/O�MJMENT)S: p 1 L
I/ CCte Ce GC �m]/��l "U TD L(ptt/
ria
NN`'6 200J
`` IC,;ECTI
"The material contained in this communication is intended only for the use of the addressee. It
may contain information that is confidential, proprietary, attorney privileged, and exempt from
disclosure under applicable law. If the reader of this communication is not the intended recipient,
you are hereby notified that any dissemination,distribution or duplication of this communication
is prohibited. If you have received this communication in error, please notify us immediately by
telephone and return,by mail,the original message to us. Thank you."
175 Main Street C P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

0 17:40 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P02/02
BLUE RIDGE
PAPER PRODUCTS INC.
November 3, 2000
Mr. Keith Haynes
North Carolina Department of Environment
And Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,North Carolina 28801
Re: Release Notification,NPDES Permit NC0000272
419 Paper Machine Lubricating Oil Release, October 30-31, 2000
Dear Mr.Haynes: .
Blue Ridge Paper Products,Inc. is providing written notification as a follow-up to Jim
CTiauque's telephone call to you on October 31,2000,at approximately 11:40 AM,
concerning a lubricating oil release at the Number 19 Paper Machine.
At approximately 6:45 AM on Tuesday,October 31, 2000,maintenance personnel
noticed a low level alarm associated with the main lubrication system day tank for the
Number 19 Paper Machine. Upon investigation, it was found that the water trap drain
valve to the tank was open allowing oil to flow from the tank into an adjacent u-drain
leading to the mill sewer system. The valve was immediately closed, stopping the
release. It is estimated that the drain had been opened at approximately 8:00-8:30 PM on
Monday, October 30,2000.
Based on the flow rate and the total capacity ofthe processing equipment,the total
release was estimated to be approximately 800 gallons. There was no oil observed
released to the Pigeon River and no impact on Wastewater Treatment Plant operations.
The cause of the release remains under investigation, however, due to the suspicious
nature of the events, the Town of Canton Police have been involved with the
investigation.
If you have questions regarding this incident, please call Tim Giauque at$28-646-2028.
Sincerely,
*aeu
que 7
Copy: Denic Brown
Bob Williams
Tilchaynes113
175 Main Street • P.O. Box 4000
Canton,North Carolina 28716 • Phone_828-646-2000
Raising Your Expectations

NORTH CAROLINA DEPARTMENT OF
�••L ENVIRONMENT AND NATURAL RESOURCES
tNCDEMR DIVISION OF WATER QUALITY
= s ASHEVILLE REGIONAL OFFICE
,'•� October 10, 2000
.JA�1E;�$rN1Y(F�Y JRq
b�i'ExtroR ' 198
` T MR. JOHN PRYATELY
BLUE RIDGE PAPER PRODUCTS WWTP LAB
P.O. BOX 4000
ILL'HOLMAN• •+� CANTON, NC 28716
ECI;EE/TART
Dear Mr. Pryately:
Tie-rkRc '�+*"+L r°EEYYVs s' Your letter, received October 9 2000 concerning corrective actions for
b3RECj'yO � ' r r • g Your
y analytical procedures has been reviewed. The quality control measures taken
in reference to the deficiencies cited in the September 12, 2000 inspection
report are acceptable. We have also reviewed the information you provided for
the ammonia nitrogen comparative results performed by your laboratory. The
results are acceptable for the requirements of your laboratory certification.
r
This report does not attempt to comprehensively address all
£«� ' certification requirements prescribed in the North Carolina Administrative
Code (15A NCAC 2H .0800) , promulgated methods, and .applicable Code of Federal
Regulations (40 CFR Part 136) . It is the responsibility of the certified
laboratory to address any required changes in Wastewater/Groundwater
}gsg• Vyr; ;SCy Laboratory Certification application information, and to correct the
� a �'i• � r . ` Laboratory Standard Operating Procedures and the Laboratory Quality Assurance
Manual when requirements of the above cited codes are not in compliance.
If a future inspection should reveal that the deficiencies cited in
11 S ' i .A_r the inspection report were not corrected, enforcement actions will be
recommended in accordance with 15A NCAC 2H .0800.
A. y..
"�- Thank you again for your cooperation during the inspection. Contact us
at 828-251-6208 ext. 285 if you have any questions or need additional
..� ,t • , ��;, � information regarding our requirements.
Sincerely,
Gary Francies
Laboratory Section
155;rye.aaTffi°>�"
-s-
b
3s 1. cc: James W. Meyer
- -, Marilyn Deaver
_ ce
k .5
y P INTERCHANGE BUILDING, S9 WOODFIN PLACE, ASHEVILLE, NORTH CAROLINA 2880 1-24 1 4
y b PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST-CONSUMER PAPER
85$4�.S.iS�c=936Se R�r°so .

DIVISION oF WATER QUA urY .
Cberahl,Labar.I.,Report I War,,Quality Lab Number YW7226
W❑ SAMPLETYPE Date Rcocired: 9/6/2000
COUNTY HAYWOOD PRIORITY Time Received: IODDAM
RISER BASIN: ❑ AMBIENT O QA STREAM X� EFFLUENT Received By : IIMW
REFORTTO : ARO Regional Ofice ❑ COMPLIANCE O CfiAIN OF.CUSTODY I LAKE INFLUENT (���/�,/[j/—� /� I S
Other EMERGENCY VISIT ID ESTUARY Da.Released: 1 All
COLLECTORS) : HAYNES O Date Reposed: 30/5/2000
Estimated DOD Range: Starion Locmlon:BLUE RIDGE PAPER
Seed: Chlorinated: Remarks:
Stan..9 Dale Begin(j'y/mMdd) Data End(yy/mm/dd) Time Begin Time End Depth•DM,ED,DBM Value Type A,II,L Composite-T,S.B Sample Type
20000830 2300
BOD310 m /L Chlodde940 mg/L NH3 as N 610 m /L Li-Lithium 1132 ti /L
COD Ili t340 m /L Chi a:Tfi 32217 u /L TKN an N 625 m /L Mg-Magnesium 927 an /L
COD Low 335 m /L Chi.:Corr 32209 ug/L NO2 plus NO3 as N 630 m /L Mn-Man time 1055 u L
Coliform:NIF Fecal 31616 /Iw.I Plecaphytin a 32213 u /L P:Total as P 665 m L No.Sodium 929 m L
Coliform:MFTmaI 3I5N /100ml X Color.Tate 80 180 CU. PO4 as P70507 m L ArseniCTotal 1002 <10 u /L
Colirorm:rube Fecal 31615 /100m1 Color.( ill 83 pll= c.u. P:Dissolved as P 666 m /L Se.Selenium 1147 u /L
Colirorm:Fecal Strap 31673 /100ml Color.PH7.682 CU. K-Potassium m L ]JR.Mercury 71900 <0.2 u /L
Residue:Total 500 m /L Cyanide 720 m /L X Cd-Cadmium 1027 <2.0 u L Ba_Barmin u /L
Volatile 505 m L Fluodde951 m /L X Cr-Chromium:Total 1034 <25 u L OrgarrochloneFestickles
Fixed 510MM."g,"L
Formaldehyde 71880 mg/L X Cu-Copper1042 3.8 u /L Or ma hos hone Pesticides
Residue:Suspended 53 Grease and Oils 556 m L X Ni-Nickel 1067 <10 u /L
Volatile 535 Hardness Total 900 m /L X Pb.Lead 1051 <10 a /L Acid Herbicides
Fixed 540 Specific Cord.95 _ .mhos/cm2 X 2:n-Zinc 1092 36 u IL
II403 MBAS 38260 m /L V-Vanadium u /L Base/Neu.al&Acid Eatracrable Or nits �-•
Acidity pll.r,5.01, Phenols 32730 ig/l. A -Silver 1077 . /l. 'TI.11 Daascl Raw
Acidnv to it8,3435mail. Sulfate 945 m /L At.Aluminum 1105 a /L
Alkalinity to till 8.341 Sulfide 745 m L Be.Beryllium 1012 u /L Pur able Organics(VOA bottle re 'd
Alkalinity to IU.54I Brmn Ca-Calcium 916 m L TPH Gasoline Range
TOC68is Tannin&Li in u L Co-Cobalt 1037 u L TPH/BTEX Gasoline Ran V
Turbidirv7fi NTll Hesavalcm Chromium ug/L Fe-Iron 1045 u L Phymplanknor
Coliform Total Tube "/100 mis
O
COMMENTS:
D
�{l0 jp OFF{CE
1UAi.H C'..
ASHE'J 01, R

'\ we•+r.•.•• • •-•ea.✓-r.no rvrcm (Um l)
COUNTY }-laM vljoo ` Lab Number:
c PRIORITY SAMPLE TYPEU r
RIVF3t BASIN Dale Reeeivr•d• Time
/��
REPORT TO AR F50 MRO RRO WaRO WIRO WSRO TS ❑AMBIENT ❑ QA ❑ STREAM EFFLUENT Rec'd bUAW From: Bue sutler Hand Del
BM Ot ❑COMPLIANCE ❑ CHAIN ❑ LAKE Other El INFLUENT DATA ENTRY 0Y•OF CUSTODY CK:
by: Do b Bu ourie Steil, Other ❑EMERGENCY ❑ESTUARY DATE REPORTED:
COLLECTOR(S): f- t 1 r
Estimated BOD Range; 0-5/5-25/25-65/40.130 or 100 plus STATION LOCATION: \��, .� y\
Seed: yea ❑ No❑ Chlorinated: Yee❑ No❑ REMARKS:
LJ
Station ,# Date Begfn lyyyy/mm/dd)I Time Begin I Date End 2 T m ie End Depth DM DB DBM Value Type Composite Sample Type
" A H L T S H C9 G GNXX
1 HODS 310 mg/I Chloride 940 mg/I NH3 as N 610 mg/1 LI-Llthlum 1132 ug/I
2 COD High 340 mgA Chi a: Tri 32217 ug/I TKN as N 625 m9/1 Mg-Magnesium 927 mg/I
3 COD Law 335 me/l Chi a: Corr 32209 ug/I NO2 plus NO3 as N 630 mgA Mn-Manganese 1055 ug/I
4 Collform:MF Fecal 31616 /100m1 Pbeophytln a 32213 ug/I P:Total as P 665 mg/1 Na-Sodium 929 mgA
5 Colllorm:MF Total 31504 /100mi Color:True 80 Pt-Co PO4 as P 70507 mg/1 Arsenic-Total 1002 ug/1
Colllorm:Tube Fecal 31615 /100m1 Color;(pH ) 83 ADMI P:Dissolved as P 666 mg/I Se-Selenium 1147 ug/I
Coiiform:Fecal Strep 31673 /100m1 Color: pH 7.6 82 ADMI Hg-Meteury 71900 ug/1
8 Residue:Total 500 mg/l Cyanide 720 mg/l Cd-Cadmium 1027 USA Organochlorine Pesticidea
Volatile 505 mg/l
9 Fluoride 951 mg/I Cr•ChrommucTood 1034 ugA Otganopluwpiaw Pesticides
10 Fixed 510 mg/I Formaldehyde 71880 mg/l CuC pper1042 a /1 g
11 Realdue:Suspended 530 mg/I Grease and Olie 556 mg/I NI-Nlekei 1067 ug/1 Acid Herbicides
12 Volatile 535 mg/1 Hardness Total 900 mg/I Pb-Lead 1051 ug/I
13 Fixed 540 mg/1 Specific Cool 95 2 Zn-Zinc 1092
_ uMhos/em ug/1 Base/Neutral Extractable Organics
14 pH 403 - units MBAS 38260 mg/I
15 Acidity to PH 4.5 436 Actd Extractable Organics
mg/1 Phenols 32730 ug/1 A Ilver 1077
ug/1
16 Acidity to pH 8.3 435 mg/1 Sulfate 9q5 m9A AI-Aluminum 1105 ug/1 Purgeable Orgenlcs (VOA bottle r¢g'd)
17 Alkalinity to pH 8.3 415 mg/1 Sulfide 745 m9/1 Be-Beryllium 1012 ug/I
18 Alkalinity to pH 4.5 410 mg/1
Ca-Caielum 916 mg/1
..191 1 TOC 680 mgA Ca-Cobalt 1037 ug/I
. . '20 Turbidity 76 NTU Fe-Iron 1045 ug/1 Phymptankton
Sampling Point% Conductance at 25 C Water Tempemmre(C D.O.mgA PH Alkalinity Acidity Air Temperature(C)
pH 83 pH 4.5 pH 4.5 PH 8.3
2 94 10 300 1, 400 1• 02244 431 82243 182242 20
Sallnity% Precipitlon 0n/day) Claud Cover% Wmd Direction(Deg) Stream Flow Severity Turbidity Severity Wind Velocity MAI ¢an Stream Depth it Stream Width it
480 45 32 36 1351 1350 35 61 4
y- NO ( g -7Lo L.4b _ ? I ess.e C.n cn1ti 2< CO 1Vf 11 1 I 11
eV C "� (1U44 N I 't' ✓t G S QRc, fU n
%hr1 .. IC nU U
DMI/Revlsed 10/13t" —� `�

04-13-00 21 : 64 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P01/04
Making(q� r nark For you.
BLUE RIDGE PAPER PRODUCTS INC.
FACSIMILE TRANSMITTAL SWEET
TO: ` 1 FROM:
k e kti )ec-r 1 c- 24Z vZ)r%
COMPANY; DATE:
(- r 0 rJ
FAX NUMBER: TOTAL NO.OF PAGES INCLUDING COVER,
a5 ~ ��s
PHONE NUMBER: SENDER' FAX NUMBER:
[phone]
RE: SENDER'S PHONE NUMBER:
XURGENT
(828) 646- 31
❑FOR REVIEW ❑PLEASE COMMENT ❑PLEASE REPLY Cl PLEASE RECYCLE
NOTES/COMMENTS:
4
HEVIu t REGIONAL OFFICE
"The material contained in this Communication is intended only for the use of the addressee. It
may contain information that is confidential, proprietary, attorney privileged, and exempt from
disclosure under applicable law. If the reader of this communication is not the intended recipient,
you are hereby notified that any dissemination, distribution or duplication of this communication
is prohibited. If you have received this communication in error,please notify us immediately by
telephone and return,by mail,the original message to us. Thank you."
BLUE RIDGE PAPER PRODUCTS INC., 175 MAIN STREET, CANTON, NC 2371E

04-13-00 21 : 05 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P02/04
Making ur mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
f ebruary 23,2000
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfm Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products, Inc.Canton Mill
Balanced and Indigenous Species Study Plan
Dear Mr. Westall:
Attached is the Balanced and Indigenous Species Study Plan required by Part III, Section M. of
the Canton Mill's NPDES permit. This study is submitted for approval by the Division of Water
Quality and is designed to comply with 40 CFR 125 Subpart H.
We are in the process of planning this study and look forward to receiving the Division's
approval in the near future. If you have any questions in the meantime,please call me at(828)
646-2033 or Derric Brown at(828)646-2318.
Sincerely,
Bob Williams
Director-Environmental,Health and Safety
Attachment
175 Main Street • P.O.60x 4000 • Canton,North Carolina 28716 • 8284;46.2000

04-13-00 21 : 05 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P03/04
Canton bill Balanced and Indigenous Species Study Plan
Blue Ridge Paper Products,Inc.
Blue Ridge Paper Products, Inc. (BRPP) is required to submit a thermal variance report for their
Canton Mill (the Mill)that is consistent with the conditions set forth in 40 CFR 125, Subpart H.
This study plan describes the tasks that will be conducted as part of the required demonstration.
The study will consist of four basic elements:
- Selection of RIS
- Thermal Model
- Biological Study
- Preparation of 316a demonstration
Task 1 Selection of Representative hn ortant Species S)
Typically 5-10 fish species are chosen to represent a range of thermal tolerances,trophic levels,
societal values (i.e., commercially or recreationally important species), and as well as potential to
be a nuisance species. It is anticipated that one or two thermally sensitive species will be
selected,along with one species from each trophic level,one or two recreationally important
species,and one species that has the potential to become a nuisance species. Selections will be
based on the life history characteristics of the fishes inhabiting the Pigeon River. No threatened
or endangered species will be selected because none inhabit the Pigeon River.
Task 2 Prepare and Calibrate Thermal Model
In order to predict water temperatures under a variety of stream flow and thermal input
conditions, a temperature model will be constructed. Measured river temperatures for the period
1994-2000 will be used to construct the model. The model will be field verified and adjusted as
necessary.
Task 3 Field Biological Study
To verify the presence of a balanced,indigenous community, a field study will be conducted
twice(mid July and late August)during 2000. Fish and macroinvertebrates will be collected
from 11 mainstem and three tributary locations:
RM Location
64.5 Upstream of mill
63 FibervilIe
61 D.O. augmentation station
59 Upstream of Clyde

04-13-00 21 : 65 BLUE RIDGE PAPER PRODUCTS ID=8286465892 PO4/04
Carron Mill Balanced and Indigenous Species Sudv Plan Contimred
Page 2
RM Location
55.5 Downstream of Clyde
54.5 Downstream of Waynesville WWTP
52.3 Old Rt 209
48 2 Ferguson bridge
42.6 Hepco
24.7 Waterville
19.3 Groundhog Creek
trio Richland Creek
trib Jonathan Creek
trib Fines Creek
All collections will be made following standard NCDEM methodologies as has been the case
during previous assessments of the Pigeon River(EA 1988, 1996).
Task 4 Prepare 316(a) Demonstration
Mill operational data,thermal modeling results,and data from the field biology study will be
compiled into a report consistent with the guidance set forth in 40 CFR 125, Subpart H. The
report will determine whether a balanced indigenous community is present or, if not,would the
establishment of such a community be prevented by continuation of the thermal variance. This
report will be submitted by 1 June 2001.
References
EA Engineering, Science, and Technology. 1988. Synoptic survey ofphysical and biological
condition of the Pigeon River in the vicinity of Champion International's Canton Mill. EA.
Loveton, MD.
EA Engineering, Science, and Technology. 1996. A study of the aquatic resources and water
quality of the Pigeon River. EA. Deerfreld IL.

r1? + ✓ NORTH CAROLINA DEPARTMENT OF
j ENVIRONMENT AND NATURAL RESOURCES
k ' � r DIVISION OF WATER QUALITY
11 Wig . IA ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
®ER January 5, 2000
ryl`Es�-Rt;Y4F�f` I'i y •yZ�."�`
F
(jf':IAMEs e.NUNr.iR:'� Mr. D2rr1C Brown
�•1cOVERN0 :>* Blue Ridge Paper Products
=
is Post Office Box 4000
'
Canton, North Carolina 28716
6 �}
FVVAYNE�,I�mEVIT,T.'('�'Y1 Subject : Compliance Biomonitoring
b
s ST Y Inspection
Canton Mill WWTP
* ?k t NPDES Permit Number NC0000272
wood County
{�R1iS STEVEN
Dear Mr. Brown:
- _-% - Please find enclosed a copy of the Inspection Report
for the Biomonitoring Inspection which was conducted at Blue
Ridge Paper Products on December 7 and 10, 1999 .
, ? ^ The samples were collected/split for use in a 3-Brood
Ceriodaphnia dubia full range toxicity test. The test
�i
ice, I
�� ; results indicated a chronic value of >100% which is above
the 87% whole effluent toxicity limit for the facility.
Further details concerning this test are included on the
a Report.
It should be noted that an ambient sample of the Pigeon
River was also collected for use in a 3-Brood Ceriodaphnia
r' u dubia pass/fail toxicity test. The result of this test was
recorded as a "Pass" . Further details on this test are also
{ < � included in the Report.
any If you have any questions concerning this matter,
please do not hesitate to contact me at 251-6208 .
a
s arcu. L��
rnsA� rs_, Sincerel
D. Keith Ha s
h
Environmental Specialist
1 .ri a
xc: Jimmie Overton
ICE
c
M•`'.!^ �N'a INTERCHANGE EIUILDING, 58 WOODFIN PLACE, ASH EVILLE. NC 2880I-2414
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST-CONSUMER PAPER

United States Environmental Protection Agency Form Approved
Washington, D.C. 20460 OMB No. 2040-0003
PA NPDES Compliance Inspection Report Approval Expires 7-31-85
Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
I IN I 2 3 NC0000272 Ill 12 99/12/07 17 18 LJ 19 IS l 2012 u t� Remarks
I I I I I I I I I I I I I I I I I I I I I I I I I I I
r' Reserved Facility Evaluation Rating BI QA Reserved
67 LLB 69 70I_1 71 on 72 L 73 �II174 75 LLLL—LU 80
Section B:FacilityDate Name and Location of Facility Inspected Entry Time Permit Effective Date
Blue Ridge Paper Products 11:00 am 970101
Canton Plant
Canton, Haywood County Exit Time/Date Permit Expiration Date
011130
Name(s)of On-Site Representative(s)/Fitle(s) Phone No(s)
Derric Brown - Environ. Supervisor 828-646-2318
John Pryately- Lab Supervisor
Name,Address of Responsible Official Title
Mr. George Henson Vice-President/Operations Mgr.
PO Box
Canton, NC 28716 Phone No. Contacted
No
Section C:Areas Evaluated During Inspection CODES S-Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated/Not applicable
N Permit N Flow Measurement N Pretreatment
#Soth"AQUATIC
perations & Maintenance
N Records/Reports N Laboratory N Compliance Schedules udge Disposal
N Facility Site Review N Effluent/Receiving Waters N Self-Monitoring Program TOX
Section D:Summary of Findings/Comments (Attach additional sheets if necessary)
On December 8, 1999, .Division Aquatic Toxicology personnel initiated a 3-brood Ceriodaphnia dubia full-range toxicology test using composite samples of
:he subject facility's whole effluent. The samples were collected on December 6-7 and 9-10, 1999 by the facility and were split by Asheville Regional OfficE
staff.
Test concentrations were 50, 75, 87, 93.5, and 100% sample. The test resulted in a chronic value of>100%, which is above the 87% limit for the facility.
Specifically, the control exhibited 100% survival with 23.4 neonates per control organism while the test treatment survival was 100% in the 100%treatment
Nith treatment mean reproduction being 22.2% in the 100% treatment. Results of additional water quality parameter measurements follow: First Sample; p
7.95 SU, Conductivity -2600 micromhos/cm, Second Sample; pH -8.39 SU, Conductivity -2560 micromhos/cm. The result of the test Indicates that the
affluent would not be predicted to have impacts on the receiving stream.
On December 8, 1999 Division Aquatic Toxicology personnel also initiated a 3-Brood Ceriodaphnia dubia pass/fail test on an ambient sample of the Pigeon
River above Hlue Ridge Paper. The samples were collected on December 7 and 10, 1999. The test resulted in a Pass. Specifically, the control exhibited
100% survival with 24.0 neonates per control organism while the test treatment survival was 100% with treatment mean reproduction being 22.7 neonates
oer lest organism. Other measured water quality parameters were as follows: First sample: pH=6.78 SU, conductivity=28 micromhos/cm; second sample:
off=6.88 SU, conductivity=32.9 micromhos/cm.
Name(s)and Signatu e( of Inspector(s) Agency/Office/Telephone Date
Keith Haynes
DWQ/ARO 828-251-6208 cloC)
Signature evi er" Agency/Office Date
DWQ/ARO 828-251-6208 QU
Regulatory Office Use Only
Action Taken Date Compliance Status
Noncompliance
Compliance

Ur PIVVIHUNMENTAL MANAGEMENT WATER QUALITY FIELD-LAB FORM (DM1) Fo0 r Lab Use ONLY
COUNTY Lab Number: , 0/�-d l7�
PRIORITY SAMPLE TYPE �j
RIVER BASIN Date R¢eeived: q '�/ d C', me: ,l Olt
REPORT TO:ARO FRO MRO RHO WaRO WIRO WSRO TS EJAMBIENT ❑ QA ❑ STREAM ❑ EFFLUENT Rec'd b �'
AT BM y: I From: Bus-Cour(er and Del
C'
Other COMPLIANCE ❑ CHAIN ❑ LAKE El INFLUENT DATA ENTRY BY: 4—
OF CUSTODY c; CK•
Shipped by: Bus Can't. ta(f. Other ❑EMERGENCY ❑ESTUARY DATE REPORTED: / -{a -(I C)
COLLECTOR(S): �� t�
Estimated ROD Range;0-5/5-25/25-65/40.130 or 100 plus t STATION LOCATION:
Seed: Yes El No El Chlorinated.- Yee❑ No yak REMARKS:
Station /- Date Beginn (yy/mm/dd)I Time Re in Date End
Q �p 9 Time End Depth DM DB DBM Value Type CompositeI Sample Type
A H L T S B G GNXX
I BOD5 320 S+ m9/1 Chloride 940
mg/1 NH3 as N 610 mg/1 LI-Llthlum 1132 ag/1
2COD High 340 mull CFI m Tit 32217 USA 1"as N 625 0 J
mull Mg-Magnesium 927 mg/I
3 COD Low 335 mg/I
Chi a: Cori 32209 ug/1 NO2 plus NOS as N 630 m
4 Coli(orm:MF Fecal 31616 /100m1 g/I a odium 929e.e 1055 ug/I
Pheophytin a 32213 ug/1 P.Total as P 665 i
mg/] NaSodlum 929 mg/1
Coll(orm:MF Total 31504
5 /100mI Color.True 80 Pt•Co PO4 as P 70507 mgA Arsenic.-Total 1002 ug/I
6 Coli(orm:Tube Fecal 31615 /loom] Color:(pH ) 83 ADMI P:Dissolved as P 666 mil/I 9/ Se-Sefenlum 1147 ug/]
Callform:Fecal Strap 31673 /100m1
7 Color. PH 7.6 82 ADM] . Hg•Mercury 71900 URA
8 Residue:Total 500 /6,0 o m9/1 Cyanide 720 mg/IjFe-lran
admium 102J.gA
USA Grgauochlorine Pesticides
9 Volatile SOS mull fluoride 951 mg/I ppe,10 Tofa O:ganopl;ospboms Pestcides
10 Fixed 530 mull Formaldehyde 71880 mg/1
PPer 3067
11 esldue;Suspended 530 <3 mg/l Grease and Oils 556 mullckef 1067
a Avid Herbicides
12 Volatile 535 mg/1 Hardness Total 900 mg/1ad 1053
13 Fixed 540 mg/l Specific Cond.95 uMho./cm2c 1092 Base/Neutral Extractable Organics
14 PH 403 units MBAS 38260m9/I15 Acidity to PH 4.5 436 mg/] Phenols 32730 Aeld Extractable Organics
u9/Ilver 307716 Acidity to PH 8.3 I mg/I Sulfate 945 mullmina. 110 Forgeable Organics (VOA bottle reg'd)
1] Alkalinity to pH 9.3 415' mg/I Sulfide 745 mg/1ryfi]um 101Alkalinity to pif 4.5 410 mg/1Qalcium 9161TOC 680 ray/] - obalt 3037'jo Turbidity 76 NTU n 1045
Phymplankton
Sampling Pofni% Conducts.¢.at 25 C Water Temperature(C) D.O.mg" PH Alkalinity Acidity Air Temperature(C)
PH 83 PH 4.5 pH 4.5
PH 8.3
2 94 10 300 . 400 8224i 431 82243
Salinity% Pre-Ildlon ONday) Cloud Cover% WhVI Dfrectlon 82242 20
deg) Stream Flow Severity Turbidity Sederity Wind Velocity M/H ¢an Stream Depth it Stream Width f,
l
480 45 32 36
1351 3350 35 4 q _
zC,_:
DMI/H v] d jwlU, 3

DIVISION OF ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD-LAB FORM (DM1) O For Lab Use ONLYnn
COUNTY Lab Number: /�-o D N?7 7
PRIORITY SAMPLE TYPE sp
RIVER BASIN
Date Received: C) '.�/'-V O Time: .7- Ulf
AT REPORT TO:ARO FRO MRO RRO WaRO WIRO WSRO TS ❑AMBIENT ❑ QA ❑STREAM ❑ EFFLUENT Reed by: « ( F •B s-C rie d 0
BM
Other ❑COMPLIANCE ❑ CHAIN ❑ LAKE ❑ INFLUENT DATA ENTRY BY: 4— CK:
OF CUSTODY �y
Shipped by: Bus C��r.$tolt, Other ❑EMERGENCY ❑ESTUARY DATE REPORTED: / -1,2 -0 C)
Estimated BOD Range;0-5/5-25/2555/40.130 or 100 plea STATION LOCATION:
Seed: Yee ❑ No❑ Chlorinated: Yee❑ No tat REMARKS:
Station # Date r,Begin
(Yy/mm/dd) Time Begin Date Enad 4 Tlme End Depth DM DB DBM Value Typ¢ Composite Sample Type
OO - A H L T S B G GNXX
1 BODS 310 S y mg/1 Chloride 940 mg/1 NHS as N 610 mall LI•tlthlum 1132 ug/1
2COD High 340 mall Chi a:Trl 32217 USA THN es N 625 m9A Mg-Magneslum 927 mg/I
3 COD Lora MF mg/1 Chi a: Corr 32209 ug/I NO2 plus NOS ae N 630 mall Mn-Manganese 1055 ugh
4 Coillorm:MF Fecal 31616 /100ml Pheophytln a 32213 ug/l P:Total as P 665 mall NaSodlum 929 mg/i
5 Cc] arm:MF Total 31504 /100m1 Color:True 80 Pt-Co PO4 as P 70507 mg/I Arsenle Toral 1002 ug/I
6 Colliorm:Tube Fecal 31615, /100ml Color:(pH ) 83 ADMI P:Dissolved as P 666 mall Se-Selenium 1147 ug/I
7 Cultism:Fecal Strop 31673 /100m1 Color: pH 7.6 82 ADMI He-Mercury,71900 USA
B Residue:Total 500 (�0(J mg/I Cyanide 720 mg/I Cd-Cdmlum 1027 ug/l Organ0chl0rine Pesticides
9 Volatile 505 mg/1 Fluoride 951 mg/l Cr4Chramium:Tom11034 USA Oman phosplrotus Pestk:Wea
10 Fixed 510 mg/1 Formaldehyde 71880 mg/I CuCoptxn 3042 ug/I
11 esldue:Suspended 530 mg/I Grease and Oils 556 mall NI-Nlckel 1067 u
d 9n Acid Herbicides
12 Volatile 535 mg/I Hardness Teta1900 men Pb-Lead 1051 ugA
13 Fixed 540 mg/1 Specific Cond.95 2 Zn-Zino 1092 USA umhos/cm 9 Base/Neutral Extractable Organics
14 PH 403 units MBAS 38260 mg/1 Acid Extractable O rgenlcs
15 Acidity to pit 4.5 436 mall Phenols 32730 call Ag liver 1077
call
16 Acidity to PH 8.3 435 melt Sulfate 945 TO AI-Aluminum 1105 call Purgeable Organics (VOA bottle roe d)
17 Alkalinity to pH 8.3 415' mall Sulfide 745 mg/I Be-Beryllium 1012 ug/1
._ _'18 Alkalinity to pH 4.5 410 mg/1 I [)Q Ca-Calcium 916 mg/1
19 70C 680 mall Ca-Cobalt 1037 call
'.1'o Turbidity 76 NIU Fe-Iron 1045 ugA y p nkton
Sampling Point% Conductance at 25 C Water Temperature D.O.mg/I PH Alkalinity Ac LlAh Tempe lure( )
PH 8.3 PH 4.5 pH 4.5 pH .3
2 94 10 300 400 s 82294 431 82243 82242 VIATER T UrA (2 CofF(CE
Salinlly% Preetpitlon ONdny) Cloud Cover% Wind Direction p)¢g) Stream Flow Severity Turbidity Severity Wind Velocity M/H ff tre5m'Depth-IL SWam Width it
980 45 32 36 1351 1350 35 64 4
DMI/Revlsed 10/66 -

BLUE RIDGE FSt'j'EVEI
200�
PAPER PRODUCTS INC.
YECSeptember 20, 2000 ONAL OFFICE ,
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: Spill/Release Notification,NPDES Permit NC0000272
#20 Machine Lubricating Oil Spill, September 18, 2000
Dear Mr. Haynes:
Blue Ridge Paper Products,Inc. is providing written notification as a follow-up to Daryl Whitt's
telephone call to you on September 19, 2000 at approximately 4:40 PM concerning the
lubricating oil spill at the No. 20 Paper Machine. Please find the enclosed Spill Release
Notification Form.
At approximately 12:00 PM on Monday, September 18, 2000,maintenance personnel noticed an
over-flow of lubricating oil from one of the oil sumps under the No. 20 Paper Machine flowing
into the U-drain, which drains to the wastewater treatment plant(WTP). Upon investigation, it
was found that at some time over the weekend the coupling between the motor and the sump
pump had slipped loose and disconnected. This resulted in the pump not operating, even though
the motor was running, as indicated on the control panel. This was immediately repaired. The
pump and motor was last inspected on Friday afternoon, September 15, 2000. At that time the
pump was connected and working properly.
Initially, and as reported on the telephone yesterday, it was indicated that the total amount of oil
released to the WTP was approximately 800 gallons. This was the total amount added to refill
the lubricating oil reservoir on the machine. However, further investigation determined that
maintenance personnel had observed that the lubricating oil reservoir was low last Friday,prior
to the spill, and would require refilling this week. The estimated volume of oil actually lost to
the WTP was between 250 and 300 gallons. There was no observed impact of this spill on
operations at the WTP and no indication of any impact to the effluent to the Pigeon River.
If you would like additional information regarding this incident, please call me at 646-6814.
Sincerely,
D WIVVU tt P.E. ames A:Giaque
Senior Environmental Engineer Principal Enviro'nme tal Engineer
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

-UE RIDGE
P/.PEq pgOOV[LE INC.
Cc: Derric Brown
Melanie Hagar

NOTIFICATION REPORT FOR SPILL/RELEASE
CANTON MILL
175 MAIN STREET/P.O.BOX 4000
CANTON,NC 28716
Name of Chemical: Light Lubricating Oil
Is Substance an Extremely Hazardous Substance ❑ YES L✓1 NO
Caller's Name &Position: Daryl Whitt,Sr. Environmental Engineer
Media into which release occurred: ❑ Air 0 Water ❑ Land
Quantity Released: (give reasonable estimate if known or that RQ may have exceeded,and will
call back as soon as possible--do not delay reporting) 250 to 300 gallons
Date,start and stop of release : Start-after Friday afternoon,9/15/2000;Stopped around noon
9/18/2000
Cause and source of release :The coupling between the motor and sump pump slipped and
disconnected resulting in the pump not working even though the motor was operating as
indicated on the control panel. The oil overflowed the sump into the U-drain to the sewer.
Action taken to respond to release and status of actions :The coupling was reconnected,
stopping the overflow. No signs of oil were seen at the WTP
Other Notification:
National Response Center
Date: Time: Report No.
Petty Officer Name :

NCDEHNR-Asheville or NC Emergency Response-Raleigh
Date: September 18,2000 Time: Approximately 4:40 PM
Contact: Keith Haynes
Local Emergency Planning Committee
Date: Time
Contact:
Western North Carolina Regional Air Pollution Control Agency
Date: Time
Contact:
Whether any injuries occurred: ❑ YES El NO
If yes,provide detail:
Name and telephone number of person to contact for further information:
Daryl Whitt, [phone]
Action taken for clean-up:
Does release require written notification under Section 204 of Emergency Planning and
Community Right to Know Act(Title III SARA): ❑ YES NO

331330 1V 01938 3'
N01133S A801tl NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
yy��{{yy''I� e ! J39 CUUU DIVISION OF WATER QUALITY
tCDENIt
y p tember 12, 2000 U
na
198
L, � OOOZ
'JAME9 B. HUNT.JR: Mr. John J. Pryately �L'
r °YE""°R Blue Ridge Paper Products Inc.
r - LABORATJnr SECTION
P.O. Box4000 ASNEw--
uE ,
L OFFICE Canton NC 28716
=V: 1, '
y p_SECRE+Ayr SUBJECT: Laboratory Certification Maintenance Inspection
r�
,�•µ Dear Mr. Pryately:
c, KERR.T�TT6�V�,
°'"E�`°"' Enclosed is a report for the inspection performed on August 30, 2000
n rkt 4 '�
by Mr. Gary W. Francies. A response is not required if there were no
deficiencies cited. A response is not required for comments or
r recommendations unless specifically requested. We appreciate the fine job
you and your staff are doing. As a certification requirement, your laboratory
must continue to carry out the requirements set forth in 15A NCAC 2H
.0800.
Copies of the checklists completed during the inspection may be
requested from this office. Thank you for your cooperation during the
inspection. Please contact us at 919-733-3908, if you have questions or
need additional information.
.� •�; , - . Sincerely,
James W. Meyer
�-'�'' Laboratory Section
s � - Enclosure
.._. ,fin•�
E cc: Marilyn O. Deaver
Gary W. Francies
s s^ t2ahlev`illel�e Tonal®,ffice
�F l
RIM
T
3
IF 'Yih:
LABORATORY SECTION
CC:, L4 if c�F
1+XY x�ji'y'�Y--' 1623 MAIL SERVICE CENTER, RALEIG H. NORTH CAROLINA 27699-1623
LOCATION:4405 REEDY CREEK ROAD, RALEIGH, NORTH CAROLINA 27607-6445
PHONE [phone] FAX [phone]

ON-SITE INSPECTION REPORT
LABORATORY NAME: Blue Ridge Paper Products, Inc.
ADDRESS: P.O. Box 4000
Canton, NC 28716
CERTIFICATE #: 198
DATE OF INSPECTION: 8/30/00
TYPE OF INSPECTION: Maintenance
EVALUATOR (S) : Gary Francies
LOCAL PERSON (S) CONTACTED: John Pryately, Melanie Hager, Phyllis Medford, Harold
Sweitzer
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements
of 15A NCAC 2H .0800 for the analysis of environmental samples .
II. GENERAL COMMENTS:
The laboratory is spacious and well equipped. All equipment is well
maintained. Records are well kept and most data appeared accurate.
III. DEFICIENCIES, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
NO DEFICIENCIES WERE CITED DURING THE INSPECTION.
Ammonia Nitrogen
A. COMMENT: The laboratory control standard is not from a second source.
Occasionally, a second source standard is analyzed, but not daily as
required.
REQUIREMENT: Analyze one known standard in addition to calibration standards
each day samples are analyzed to document accuracy. This laboratory control
standard must be from a second source. It is recommended that this
laboratory control standard have a mid-range concentration and not vary by
more than ± 10% . If it does the analysis is out of control. The analysis
must be terminated and the problem corrected. Ref: 15A NCAC 2H . 0805 (a) (7)
(B) , (F) , and Standard Methods, 18th Edition - Method 1020 B.3 .
B. COMMENT: The distilled versus undistilled comparison study results are
unacceptable. It appears this is due to the low concentration of the samples
used. It is recommended that the samples be spiked to a concentration of at
least 1 to 5 mg/l.
REQUIREMENT: Laboratories shall analyze initially four samples distilled and
undistilled from each discharge and, thereafter, analyze two samples a year
from each effluent. Additional samples must be analyzed comparatively if the
above samples results do not indicate approximately the same values for
distilled and undistilled samples. Ref: Federal Register, July 1, 1995; 40
CFR 136; Ammonia Footnote 6. Please submit the results from the analysis of
two sets of samples.

Page 2
Color-platinum cobalt
C. COMMENT: The linearity of the curve, slope value, and y-intercept are
not maintained on file for three years . The raw data is on file and the
spectrophotometer displays all this information, but once a new curve is
established all this information from the old curve is lost except the raw
data values. It is recommended that the raw data be entered into your
computer, which then can produce the curve, and all associated information,
which can be printed and stored with the raw data. Each daily bench sheet
must document the date of the curve.
REQUIREMENT: It is required that a linear regression, slope value, and y-
intercept be calculated to document accuracy of the method and reliability
of the curve. Document the linearity of the curve on the bench sheets or
computer printouts with proper initials and dates . Reference: 15A NCAC 2H
.0805 (a) (7) (H) . Determine the absorbance against the concentrations of
standards to establish a working curve and the agreement with Beer's law.
Ref: Standard Methods, 18 Edition - Method 1070D pg. 1-28 . To establish
agreement with Beer' s law, a correlation coefficient must be calculated to
document linearity. Good laboratory procedures require a correlation
coefficient >_ 0. 995 .
BOD
D. COMMENT: The laboratory is analyzing 5 mLs of standard not 6 mLs, as
the method requires. This has been done for several years and has been
missed in prior audits, both internal and those conducted by the State. All
values obtained for the standards reviewed were in the acceptable range.
REQUIREMENT: It is required that a 2% dilution of the glucose glutamic acid
standard be analyzed. Ref: Standard Methods, 18th Edition - Method 5210
B. 4c.
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory bench
sheets and contract lab reports to DMRs submitted to this Division. Data
were reviewed for these months: February, April, and May 2000. No errors
were noted. It appears the facility is doing a good job of accurately
transcribing data.
V. CONCLUSION:
This laboratory is doing a good job overall. The staff is congratulated for
doing an excellent job of maintaining the laboratory program. Correcting the
above comments should help to produce quality data and meet certification
requirements . Implementing the recommendations will further improve the
quality of the data. A WRITTEN REPLY IS REQUIRED FOR ALL LETTERED COMMENTS.
Report prepared by: Gary Francies Date: 9/l/00

BLUE RIJDGE
PAPER PRODUCTS INC.
August 22, 2000
Keith Haynes
North Carolina of Environment
and Natural Resources
Division of Water Quality Q
59 Woodfin Place
Asheville,NC 28801
Dear Keith:
This is a follow-up to our telephone conversation on August 21, 2000 concerning preventative
maintenance and routine repair including painting of the No. 2 primary clarifier at Blue Ridge
Paper Product's Canton facility. The maintenance activity will be conducted from
approximately September 11, 2000 to October 16, 2000.
As detailed in the December 1, 1998 Low Flow Contingency Plan a primary clarifier will
normally be empty and available for outage or unplanned brown colored material storage. A
primary clarifier will not be available for material storage and managed release during this
outage. However, the mill's extensive sump and recovery system will be operational during this
period.
Please call me at [phone] if you have any questions or concerns about this planned
maintenance activity.
Sincerely,
Derric Brown
Manager, Environmental Affairs
Blue Ridge Paper Products, Inc.
xc: Forrest Westall
Regional Water Quality Supervisor
NC Department of Environment&Natural Resources
59 Woodfin Place
Asheville,NC 28801
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

NOMINATION FORM FOR THE WILBUR E. LONG Jr.
OPERATOR OF THE YEAR AWARD
This nomination form is the only method to nominate an operator for the Wilbur E. Long, Jr. Award.
Only one form per nomination will be accepted and please do not attach additional pages of comments.
The purpose is to recognize any currently certified water pollution control system operator in North
Carolina who:
• has exhibited outstanding knowledge and innovation in the continuing operation of a water pollution
control system; or.
• has contributed his/her time and efforts toward the training, education, and professionalism of water
pollution control system operators; or
• has devised, discovered or invented devices or techniques which enhance the science of system
operation.
(Water Pollution Control System: wastewater treatment system, collection system, land application
system, subsurface system, spray irrigation system,land application system,or animal waste system)
Please return by September 1, 2000 to: Technical Assistance and Certification
1618 Mail Service Center
Raleigh NC 27699-1618
Please call Dwight Lancaster at(919)733-0026 ext. 302 if you have any questions.
NAME OF NOMINEE: TYPE: GRADE:
ADDRESS OF NOMINEE:
EMPLOYER: PHONE NUMBER:
ADDRESS OF EMPLOYER:
ACCOMPLISHMENTS OF NOMINEE:
PROFESSIONAL ORGANIZATIONS THAT NOMINEE IS ACTIVE IN:
NAME OF NOMINATOR: PHONE NUMBER:
ADDRESS OF NOMINATOR:

State of North Carolina
Department of Environment
WAA
and Natural Resources 4 0 •
Division of Water Quality O &Wova
James B. Hunt, Jr., Governor NCDENR
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 23,2000
CERTIFIED MAIL \.
RETURN RECEIPT REOUESTEDy
Mr.William H.Pott 11 �" � C l•�•7(
Fletcher Warehousing Company
P.O.Box 457
Swannanoa,N.C.28778
�� O C�✓
Subject: Effluent Toxicity Testing
NPDES Permit No.NC0000094
Fletcher Warehousing Company
Henderson County
Dear Mr.Pott
This is to inform you that the Environmental Sciences Branch has not received your quarterly toxicity monitoring
report for the month of June 2000. This is in violation of Title 15A of the North Carolina Administrative Code, Chapter 2,
Subchapter 2B,Section.0506(a)(1)(E)which states that"In situations where no discharge has occurred from the facility during
the report period, the permittee is required to submit a monthly monitoring report giving all required information and indicating
'NO FLOW' unless the Director agrees to waive the reporting requirement during extended conditions of no discharge."
As I understand it Ms. Kristie Robeson,with our office, spoke with you on August 21'regarding this issue and was
then instructed to contact Mr. Tom Kilpatrick, with DDK Environmental, to discuss toxicity reporting issues. Our office
contacted Mr. Kilpatrick and instructed him to submit AT forms marked 'NO FLOW" in the event that there was no discharge
from this facility.
Mr. Kilpatrick should complete the information block located at the top of the AT form indicating the facility name,
permit number, pipe number, county and the month/year of the subject report. The AT form shall be signed, appropriately
marked"NO FLOW,"and submitted to the address cited below.
ATTN: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Attached to this Notice is a one page summary of important toxicity monitoring and reporting requirements. Please
read this summary page and if you have any questions concerning this correspondence please contact Ms. Kristie Robeson with
the Aquatic Toxicology Unit at(919)733-2136.
aWater
on
Quality Section Chief
for Environmental Sciences
cc: orrest Westall-Asheville Regional Office
e`Irh a es-A '"sue a e'gi-o'n [Offic`eSfII�.
Aquatic Toxicology Unit Files
Central Files
Mailing Address Telephone[phone] Location: .
1621 Mail Service Center Fax[phone] 4401 Reedy Creek Road
Raleigh, NC 27699.1621 State Courier#52-01-00 Raleigh, NO 27699.1621
An Equal Opportunity Affirmative Action Employer 50%recycled/10%post consumer paper

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information. Please take time to review this information. The items below do not address or include
all the toxicity testing and reporting requirements contained in vour NPDES permit. If you should have any questions
about your toxicity testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at(919) 733-
2136 or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered(with the
appropriate parameter code)on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh,NC 27699-1617
t� IN ADDITION
Toxicity test data(original"AT"form)must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
➢ Toxicity test results shall be riled with the Environmental Sciences Branch no later than 30 days after the end of the
reporting period(eg,January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the
permit limit,then at least two multiple concentration toxicity tests(one per month)will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
. concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement
response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
December,then toxicity testing must be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January I-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not occur
during the fast six months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why the test was
invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs,you should complete the
information block located at the top of the AT form indicating the facility name, permit number, pipe number, county and
the month/year of the subject report. You should also write"No Flow"on the AT form,sign the form and submit following
normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge(ORC)except for facilities
which have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT
forth. The AT form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality,You may consider submitting
your toxicity test results certified mail,return receipt requested to the Environmental Sciences Branch.

BL
UE RIDGE
PAPER PRODUCTS INC.
August 22, 2000
Keith Haynes
North Carolina Department of Environment
and Natural Resources �,f �Up`�TiNPpC
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
Dear Keith:
This is a follow-up to our telephone conversation on August 21, 2000 concerning preventative
maintenance and routine repair including painting of the No. 2 primary clarifier at Blue Ridge
Paper Product's Canton facility. The maintenance activity will be conducted from
approximately September 11,2000 to October 16, 2000.
As detailed in the December 1, 1998 Low Flow Contingency Plan a primary clarifier will
normally be empty and available for outage or unplanned brown colored material storage. A
primary clarifier will not be available for material storage and managed release during this
outage. However, the mill's extensive sump and recovery system will be operational during this
period.
Please call me at [phone] if you have any questions or concerns about this planned
maintenance activity.
Sincerely,
Derric Brown
Manager, Environmental Affairs
Blue Ridge Paper Products, Inc.
xc: Forrest Westall
Regional Water Quality Supervisor
NC Department of Environment&Natural Resources
59 Woodfm Place -
• Asheville,NC 28801 `
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
September 6, 2000 J
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources �Fo
Division of Water Quality l Foy
59 Woodfin Place
Asheville,NC 28801
RE: Sewage Spill Response Evaluaton,NPDES Permit NC0000272
Landfill Leachate Spill, September 2, 2000
Dear Mr. Haynes:
Blue Ridge Paper Products, Inc. is providing written notification as a follow-up to Daryl
Whitt's telephone call to the North Carolina Emergency Response Center on September
2, 2000 at 7:00 PM concerning the leachate spill. Please find the enclosed Sewage Spill
Response Evaluation.
At approximately 8:00 AM on Saturday, September 2, 2000,the Town of Canton
personnel noticed a potential leak in the leachate transfer line at the Blue Ridge Paper
Products landfill and subsequently notified Canton Mill wastewater treatment personnel.
By 8:15 AM, the leachate transfer pumps were turned off to minimize any additional
release. The leaking line was excavated and repairs to the line were completed by 5:00
PM.
During the initial assessment,a small amount of leachate was observed flowing into the
Storm Water Outfall 6-9 conveyance directly adjacent to the spill site. This flow stopped
and the conveyance was dry by 12:00 PM. No spilled leachate was observed to have
reached the outfall to the Pigeon River, approximately 25 to 30 yards from the spill site.
There were also no indications of any impact observed in the river.
If you would like additional information regarding this incident, do not hesitate to call me
at 646-6814.
Sincerely,
D J. Whitt P.E. James A. Giaque
Senior Environmental Engineer Principal Environm tal Engineer
Cc: - Jim Patterson, Division of Solid,Waste
Derric Brown
Melanie Hagar
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

_ JD
Sewage Spill Response Evaluation: �1 d
(page 1 of 3) �+
Permittee Blue Ridge Paper Products Inc. Permit Number NC0000272 County Haywood o
y
Incident Ended: (Date/Time) Saturday 09/02/00/5:00 PM F
Estimated Duration (Time) Less than 26 hours
First knowledge of incident: (Date/Time) Saturday. 09/02/00/8:15 AM
Estimated volume of spill/bypass: 300 gallons. Show rational for volume.
Blue Ridge personnel visited the site on Friday afternoon at approximately 3:00 PM. At that time
there was no indication of a leak or spill in the area. At 8:00 AM on Saturday, the spill was first
identified by Town of Canton personnel,who subsequently notified Blue Ridge wastewater
treatment operators at about 8:15 AM. Flow was observed into the storm water conveyance until
approximately 12:00 PM. Final repairs were made to the line at approximately 5:00 PM.
Therefore the duration was estimated to be a maximum of 26 hours.
Flow was observed in the outfall conveyance at 9:30 AM, at the rate of 3-5 gallons/hour. This
flow stopped by 12:00 PM. Assuming that the flow could have been 3 times this amount while
the pumps were still active (from 3:00 PM to 8:00 AM, pumping 4 times per hour for 2-3 minutes
each time), then the volume would be 15 gallons/hour* 17 hours+ 5 gallons/hour*5 hours = 280
gallons.
if spill is ongoing,please notify Regional Office on a daily basis until spill can be stopped.
Reported to: Jimmy Ray, N.C. Emergency Response (Date/time) 09/02/00/7:00 PM
Name of person
Weather conditions: Cloudy, high temperature 770 F, rain showers in the area, though none
occurred at the site.
Source of spill/bypass (check one): OSanitary Sewer [-]Pump Station ❑WWTP
Leak occurred in the landfill leachate transfer line leading to the sanitary sewer.
Level of treatment(check one): ZNone [-]Primary Treatment
❑Secondary Treatment ❑Chlorination Only
Did spill/bypass reach surface waters? [-]Yes ONo (If Yes, please list the following)
Volume reaching surface waters? 0 gallons
Less than 300 gallons reached the storm water conveyance. None was observed reaching the
river and none is believed to have reached the surface waters, as indicated by dry leaves in the
storm water conveyance at the point of outfall to the Pigeon River, approximately 25-30 yards
from the spill site.
Name of surface water: Pigeon River
Did spill/bypass result in a fish kill? ❑Yes QNo
If Yes, what is the estimated number of fish killed?

r
Sewage Spill Response Evaluation:
(page 2 of 3)
Permittee Blue Ridge Paper Products, Inc. Permit Number NC0000272 County Haywood
Please provide the following information:
1. Location of spill/bypass:
A leak in the leachate transfer line from the Landfill 6A leachate collection system occurred
approximately 150 yards from the leachate pump station, in the roadway directly adjacent to the
conveyance to Storm Water Outfall 6-9, at the Blue Ridge Paper Products Landfill, Canton, N.C.
2. Cause of spill/bypass:
The spill was the result of a crack in the buried transfer line.
3. Did you have personnel available to perform initial assessment 24 hours/day (including
weekends and holidays)? RlYes ❑No
4. How long did it take to make an initial assessment of the spill/overflow after first knowledge?
Hours 1 Minutes 15
How long did it take to get a repair crew onsite?
Hours 7 Minutes
Please explain the time taken to make initial assessment:
The leak was first identified by Town of Canton personnel and reported to Blue Ridge Paper
Products wastewater treatment operators. The operators then called the landfill crew to stop the
leachate transfer pumps. The EOHS staff member on duty was then called at home. This on-call
person then prepared and drove to the mill, collected equipment and drove to the spill site,
arriving by 9:15 AM. Once at the spill site, the on-call person evaluated the site, and equipment
to confirm that a spill had occurred, that the correct location had been identified, that the release
had been stopped, and what areas were potentially being or going to be impacted by the spill.
This initial assessment was completed by 9:30 AM.
5. Action taken to contain spill, clean up waste, and/or remediate the site:
The leachate transfer pumps were turned off as soon as the leak was reported. This minimized
any additional flow from the leak and stopped any indication of flow to the ground surface. When
the repair crew arrived, the area of the leak was excavated to identify the point of the leak. A
repair clamp was placed over the cracked section of pipe to prevent further leakage.
6. Were the equipment and parts needed to make repairs readily available?
QYes ❑ No If no, please explain why:
7. If the spill/overflow occurred at a pump station, or was the result of a pump station failure,
was the alarm system functional at the time of the spill? N/A
[-]Yes ❑ No If the alarm system did not function, please explain why:

Sewage Spill Response Evaluation:
(page 3 of 3)
Permittee Blue Ridge Paper Products, Inc. Permit Number NC0000272 County Haywood
8. Repairs made are: IZPermanent ❑Temporary
Please describe what repairs were made. If the repairs are temporary, please indicate a date
by which permanent repairs will be completed, and notify the Regional Office within 7 days of
the permanent repair:
A repair clamp was placed over the cracked section of pipe to prevent further leakage.
9. What actions have been made to prevent this discharge from occurring again in the future?
The area around the pipe is being backfilled with soil free of rocks to prevent re-cracking the pipe.
10.
Comments:
Other agencies notifed: None
Person reporting spill/bypass: Daryl J. Whitt Phone Number:_(828) 646-6814
Signature Date:
-------------------------------------------------------------------------
-------------------------------------------------------------------------
For DWQ Use Only:
DWQ requested additional written report? _Yes No
If yes, what additional information is needed?
Requested by

NORTH CAROLINA DEPARTMENT OF
I
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
1 'p -t"' �,L,jp. August 2, 2000
}7�a AMES��B' HUNT JR
-�3G,OVEI2NOR" 3�;tiwY '
aI 198
rgJ`r.%• r MR. JOHN PRYATELY
tHOLMAN -0' BLUE RIDGE PAPER PRODUCTS WWTP LAB
I SECRETARY
- P.O. BOX 4000
` CANTON, NC 28716
n
SUBJECT: Wastewater/Groundwater Laboratory Certification
�f
C
, g Dear Mr. Pryately:
Enclosed are inspection checklists to be used for the
upcoming inspection scheduled for August 31, 2000, at
approximately 8:45 A.M. Excluding the data review sections and any
sections that specify they are to be completed by the auditor,
L p " please complete or have your analysts complete, each checklist.
;b±• � '`. , Iv "- ,q Any checklists for parameters that - no samples have been analyzed
since the last inspection do not need to be filled out. Any
checklists that your laboratory are unable to complete, or any
specific items that you do not understand, will be completed
during the inspection.
Please submit the original checklists to the inspector(s) on
the first day of the inspection. Copies are not acceptable.
I t �
,l
Contact us at 828/251-6208 ext. 285 if you have any
1' �, - I :•_ questions.I
Sincerely,
Gary Francies
_ 41 � zai Laboratory Section
'' •� *�� Enclosures
_ cc: Marilyn Deaver
James W. Meyer .
Asheville Regional Office
a
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NORTH CAROLINA 2880 1-24 1 4
PHONE [phone] FAX [phone]
p, AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% PDST-CDNSUMER PAPER

BLUE RIDGE
PAPER PRODUCTS INC.
June 14, 2000
Attention:NDCEU
1617 Mail Service Center
Raleigh,NC 27699-1617
RE: Wastewater Spill in Excess of 15,000 Gallons—Required Public Notice and Proof of
Publication, Blue Ridge Paper Products, Inc. of Canton,North Carolina
To Whom It May Concern:
Please find the enclosed public notices and proof of their publications submitted by Blue
Ridge Paper Products,Inc. of Canton,North Carolina. The public notices,required by
North Carolina General Assembly House Bill 1160, were published in the Enterprise
Mountaineer and Newport Plain Talk in response to a wastewater spill that occurred at
Blue Ridge Paper Product's Canton Mill on May 18a'at approximately 1:20 pm.
If there are any questions,please call me at(828) 646-2318.
Sincerely,
to
yR6
Derric Brown
Manager, Environmental Affairs CP sa
175 Main Street • P.O.Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

Ep RIDGE
Cis IxC.
xe: Mr. Keith Haynes
NC Dept of Environment, Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801

JI2E &MOU.l La&2zz1L
413N.MAIN ST.
P.O.DRAWER 129
WAYNESVILLE,NC 28786
7W452-0661 -
LEGAL NO. 22063
Blue Ridge Paper Products, Inc.
Attn: Monica Dills Notice of Discharge of Untreated
P.O. Box 4000 Wastewater
Canotn, NC 28716
INVOICE AND STATEMENT
DATE FOLIO DESCRIPTION CHARGES CREDITS BALANCE
r
2000 Legal# 22063
June 07 ✓ ���G
Administrative Fee 10.00
PAYABLE UPON RECEIPT
Billing Affidavit Sent: /�IQQ

NORTH CAROLINA
CLIPPING OF LEGAL HAYWOOD COUNTY
ADVERTISEMENT
ATTACHED HERE AFFIDAVIT OF PUBLICATION
Notice of Discharge of Before the undersigned, a Notary Public of said County and
Untreated Wastewater State,duly commissioned,qualified,and authorized by law to
The Blue Ridge Paper administer oaths,personally appeared
Products ;;'Incorpporated,
Canton,t�oitll(arolino foal , �( who beingfirst
itf at 175 Main Street had a rduly a wm,a es and say=thor he(the)h
dlschorge ..of'• entreated
wastewater of approximate-
ly 1 B4O00 ga0oas due to a
power d on May 18,dis 2m0g0 (0w pa om publhhc,or oaw ol6m or anplo m autho a or mah,no slwrid
occurred on May 16, 2000
at approximately 1:19 pm. of THE ENTERPRISE MOUNTAINEER
and lasted for approximate- engaged in the publication 0172 newspaper known as
ly I mlllete.The unheated THE ENTERPRISE MOUNTAINEER
wastewater Entered the published,issued,and entered as second class mail in the City of
Pigeon River in the French WAYNESVILLE
Broad River Basin.Electrical I in said County and Scur,that he(she)is authorized to make this affidavit and
power Was re-established to sworn smtementt[hat the notice or other legal advertisement,a we copy of
the wastewater pumps to which is attached hereto, was published in THE ENTERPRISE MOUN-
prevent further disdrarge. TAINEER on the following data:
Far more.information (on-
tact the. Director of ' 7�1I)AA
Environmental, Safety and and h t the said newspaper in wh cL such notice,paper,document or legal
Health Affairs at(828)646- advertisement was published was,at the time of each and every such publia-
2033. [ion, a newspaper meeting all of the requirements and qualifications of
No.22063-June 7,2000 Section 1-597 of the General Summ of North Camlina and was a qualified
newspaper within the meaning of Section 1-597 of the General Samtes of
North Carolina.
apace rsnryr
dC" B. MCC4rG. This of� / f 20 Al-)
Gv
�y0TARv. _ s� uuvuryaou dsaa t
s
t � � t C Sworn to and subscribed before me,rhis
m '•,pUBlr\C'��
q . ; day of
rrrrr C013 My Commission atpires:_ z r�^^Lnryy ubbc
AFFIDAVIT OF PUBLICATION ,
Issued by
THE ENTERPRISE MOUNTAINEER
Waynesville, NC 28786

u THEN
P �iN TALK II
Page 8B'• Sunday,June 4, 2000 EWPOOT
T H E N E.W P` R'T PLAIN 'Iph.xl
145 EasK roadway-o Newport,T nessee 37821
MONDAY-FRIDAY 8:00 A.M.-5:00 RM.
`�CI.OSE&SIATLJRIf11Y62$UNDAY^
',F
r� •\•�
Publishers Note
/�ll real.teat¢adrejased -herrn fs "�
h Classified Index1. Snap Shop
Llsobjeatathe Federal FaQHousmg OFFOPTUMM' .. .. �.. -:
AcLwldrh makes itZegal to advertise . 1:Public Nodccs ui ,;; . 8:Real Estate-Sales_... _
"any preference; limibtion, or disaiminarioa" :2.-Annountnmtents•.,;7•. 9.Mobile Homes• 10 consecutive insertions k
because of race,color,religion,sex,handicap,famil- 3:.Seivices - lO.Merehandise' - transportation items with a pt
ial status,or national origin, ar intention to take - . _ " ` 20 words or less. If vehicle do
any prefermce,limimdoms ordisaimmadon', • 4..1heancial " ' . .:.. Y l l.pets/Livestock sell-the customer will receiv
We will not knowingly accept an for '5.EducationalServices 12.FarinSupplies/Equipm®t extra weeks of advertisingFB
real estate which is m violation of the law. All pet 6.Employment Services 13.Recreadonal Vehicles $16.95 with our photo or$1
sons are hereby informed that all dwe➢ings adver- Y
dsed are available'on 2Il'igal opportunity basis. .7. Real'Estate-Rent, 14.Ttattspottatioa if we take the photo at the o0
Service Directory: S lines fI
20 21 26 CHECKI
1 1Announcements I
i Happy Ads Of Interest Give-Apvays AND GF
NeppyAds 20 1 PLEASE CHECK 2 tttrreNs 10 amy to
i w u ii qP t, 22 HAPPY AD YOUR AD 0� home. 4236 3-
COW of Thanks 28 POLICY This news os16.
in Memory 24 Paper makes every.
Lost d Found All Happy Ads are payable ta .effort to avoid ertore in adver• pA�T3 TO ONE AWAY. T
10 Glvo-Alvaye advance. Owmems.Each ad is carefully Cents by The Newport Plain I
Le al Notices To avoid any possible ember. cheesed and proofread, but Talk GHim at 145. Broad-
Legal Ye�ort s hl
Sska 27 nssment, any ad which in- when you handle hundreds of my,Newport TN.
29 28 cuEes-an age must not in- ads.mistakes do slip through. . I
Flow Markets�� Gude the person's full name. We ask therefore, that you WARNING
NOTICE OF You ray use Indus of first check your ad and 8 you find '
name.If no age is mentioned, an enter,report it to the Ctassl- ADS FOR -
DISCHARGE OF 20 then the full home may be fled Department Immediately GIVE AWAY PETS
UNTREATED Happy Ads used. by calling 6236171.We regret year beloved pate deserves a ,
WASTEWATER must person placing the aid that we for more will
mat not be
responsible
COR loving' caring home. The ad
The Blue Ridge Paper Prod- ATTENTION dress amend Identific verifiable ation. RECT INSERTION and onty la your free pet may drew re-
Paper Incorporated, Carrion, CLASSIFIED information is Trot for pubika. for mat portion of me ad mat will from Individuals who D I
Norm Carolina facility at 175 ADVERTISING POLICY lion in The Newport PWn may have been tendered veF Your dirihat for is.
Main Street had a discharge of All ad copy is subject to appro- Talk,but will be-made availa- ueless by such error.Each in- search or r breading purposes.
eertion is proof of publication, Please screen respondents
untreated wastewater M cop- vet prior to pubiicatlon. The ble upon request to inquiring Carefully when giving an on-
proximately 18,000 gallons Newport Plain Talk reserves parties. and it Is me responsibility of met away.Your pet will thank
live to a power failure.,The the right to add, refuse or re• The Newport Plain Talk re- the adverfisor to check each YGu ,
discharge occurred on May jec any ad at any time. The nerves me right to rejaet any insertion and Call me error to
18. 20M at approximately Newport Plain Talk reserves Happy Ad. ouradenlion. 28
1:19 p.m. and lasted for ap• the right to classilyr Index and DEADLINE FOR
proximately one minute. The position ads according to the CORRECTIONS: Yard/Garage Sales
,untreated wastewater entered policies governing the Bassi- 21
the Pigeon River in me French fled pages. a:00 A.M:12 NOON AUTO SHOI
Blood River Basin. Electri ed Thank You Of Interest CLASSIFIED
623.6171 r
power was re-established to Classified HOURS: ITS YARD
the wastewater pumps to pre- Advertising Depammam - SAMI TO 5 P.M. SALE TIMEI CARS RII
vent fuller discharge. For CLASSIFIED MONDAY THRU FRIDAY
more Information contact me CLASSIFIED ADS LINE AD Let Everyone RAGE where
rm
Director of Environmental, you oral CiARAGEnAFiD BETTEF
Safe and Heakh Afhaire at GET RESULTS DEADLINES E8 SALE KIT SPECUILI CLEANF
(�ryGEG-2033 IN THE NEWPORT Spring is hem and time to Your kit would contain:
PLAIN TALK start tamtrg all of that un- Lost&Found •6Fluoresamsgns
wanted merchandise Into -60 Price Slickers .DENTON'SAL
P__ ____ _ d CASHg Call Brenda or San- FOUND:SMALL DOG.Vitlni- '6 DIMCWhal Arrows. DETAILING
LOOKING FORA NEW JOB? f Ad.let as het a with •Marking Pen
nY I;. ry of Hwy 107 Del Rio. Call ,Inventory&noSheet d9S_R9S_l'....nand letMarl el I inert ell inn�e�nnnn

BLUE RIDGE
PAPER PRODUCTS INC.
AY 2 3 20p0 ��l
ivFlr ���
�.'-?SH fVFR qUn qp
May 22, 2000 'l«f�fGIONgC pTi �`f
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
Re: Sewage Spill Response Evaluation, NPDES Permit NC0000272
Wastewater Spill, May 18, 2000, Approximately 1:19 pm
Dear Mr. Haynes:
Blue Ridge Paper Products, Inc. is providing written notification as a follow-up to Derric
Brown's telephone call to you on May 18, 2000 at approximately 3:40 pm concerning the
wastewater spill. Please find the enclosed Sewage Spill Response Evaluation.
At approximately 1:05 pm on Thursday, May 18, 2000, the Canton Mill's Wastewater
Treatment Plant lost CP&L power as well as automatic switching back-up power.
Wastewater Treatment Plant operators and mill personnel immediately responded to the
power failure and power was restored within approximately 22 minutes. The estimated
duration of the release was one minute, which was based on visual observation by the
Wastewater Treatment Plant operators.
Mill personnel monitored three downstream sites on the Pigeon River immediately
following the spill. All monitored parameters were within compliance limitations. The
data obtained is listed below.
Fiberville Thickety Above Clyde
pH 7.42 7.78 7.66
Temp. (°C) 22.4 22.6 21.5
Dissolved OZ (mg/1) 8.9 6.47 8.03
Please also find the enclosed press release and public notice as required by North
Carolina General Statutes Article 21 Chapter 143.215C. The press release was issued
to radio stations WHCC/WQNS, WPTL, and WWIT in addition to the Enterprise
Mountaineer. The public notice was issued to the Enterprise Mountaineer and the
Newport Plain Talk. Copies of the newspaper articles will be sent to the Division of
Water Quality within 30 days of their publication.
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE
If you would like additional information regarding this issue, do not hesitate to call me at
646-2318.
Sincerely,
Derric Brown
Manager, Environmental Affairs

Sewage Spill Response Evaluation:
(page 1 of 2)
Permittee Blue Ridge Paper Products, Inc. Permit Number NC0000272 County Haywood
Incident Ended: (Date rime) 5/18100/1:20 pm Estimated Duration(Time) Approximately 1
minute
First knowledge of incident: (Date/Time) 6/18/00/1:05 pm
Estimated volume of spill/bypass Approximately 18,200 gallons.
Show rational for volume:
The estimated duration of the release was based on visual observation by the Wastewater
Treatment Plant operators. The effluent flow preceding the release was approximately 18,200
gallons per minute based on parshall flume readings.
If spill is ongoing,please notify Regional Office on a daily basis until spill can be stopped.
Reported to: Mr. Keith Haynes (Date/time) 5/18/00/3:40 pm
Name of person
Weather conditions: Sunny, gusty winds from the north/northwest, temperature approximately
75°F.
Source of spill/bypass (check one):_Sanitary Sewer Pump Station _X WWTP
Level of treatment(check one): X None _Primary Treatment
_Secondary Treatment_ Chlorination Only
Did spill/bypass reach surface waters? X Yes No(If Yes, please list the following)
s_
Volume reaching surface waters? Approximately 18,200 gallons
Name of surface water Pigeon River
Did spill/bypass result in a fish kill?_X Yes No r Z�
If Yes, what is the estimated number of fish killed? Approximately 200
Please provide the following information:
S PS�
1. Location of spill/bypass: The release occurred from a manhole on the mill side df the'Pigeon
River at Blue Ridge Paper Product's facility at 175 Main Street Canton, NC.
2. Cause of spill/bypass: The release occurred due to a power failure in the wastewater
treatment plant area which shut the wastewater pumps down. The power failure occurred due to
a loss of power from the main CP&L electrical feed to the area. The fuses to the back-up
electrical power potential transformer were discovered to be blown, which prevented automatic
electrical power switching.
3. Did you have personnel available to perform initial assessment 24 hours/day (including
weekends and holidays)?
Yes X No
4. How long did it take to make an initial assessment of the spill/overflow after first knowledge?
0 Hours 22 Minutes(From first knowledge to repair)

Sewage Spill Response Evaluation:
(Page 2 of 2)
Permittee Blue Ridge Paper Products, Inc. Permit Number NC0000272 County Haywood
How long did it take to get a repair crew onsite?
0 Hours 10 Minutes
Please explain the time taken to make initial assessment:
Initial assessment activities began immediately following the power failure (within seconds).
5. Action taken to contain spill, clean up waste, and/or remediate the site: Wastewater Treatment
Plant operators immediately closed#4 manhole gate and notified electrical technicians, engineers
and management of the power outage. Electrical service was restored in approximately 22
minutes.
6. Were the equipment and parts needed to make repairs readily available?
Yes X No If no, please explain why: Repairs to re-establish power began
immediately.
7. If the spill/overflow occurred at a pump station, or was the result of a pump station failure,
was the alarm system functional at the time of the spill? Yes_X No If the alarm
system did not function, please explain why: The failure did not occur at a pump station. The
power outage was immediately detected at the wastewater treatment plant by licensed operators
who man the plant 24 hours a day. Operators immediately communicated to maintenance
personnel and began corrective action.
8. Repairs made are: Permanent X Temporary _
Please describe what repairs were made. If the repairs are temporary, please indicate a date by
which permanent repairs will be completed, and notify the Regional Office within 7 days of the
permanent repair: Repairs were made by re-establishing power to the wastewater system.
Should the incident occur again, back-up power can be obtained by manually activating the back-
up power system. Permanent back-up power automatic double-throw switching will be completed
on May 23, 2000 with the installation of a new transformer.
9. What actions have been made to prevent this discharge from occurring again in the future?
Should the incident occur again, back-up power can be obtained by manually activating the back-
up power system. Permanent back-up power automatic double-throw switching will be completed
on May 23, 2000 with the installation of a new transformer.
10.Comments:
Wastewater Treatment Plant personnel monitored three downstream sites on the Pigeon River
immediately following the spill. The following data was obtained: Fiberville, pH = 7.42, Dissolved
Oxygen (D.O.) = 8.9 mg/I, Temperature=22.4°C. Thickets, pH = 7.78, D.O. =6.47 mg/I,
Temperature=22.6°C, Above Clyde, pH =7.66, D.O = 8.03 mg/I, Temperature= 21.5°C. All
monitored parameters were within compliance limitations.
Other agencies notifed:
Person reporting spill/bypass: Derric Brown Phone Number: [phone] T Signature Lcc77 Date: 5�231 loop

PRESS RELEASE
Notification of Wastewater Spill in Haywood County
House Bill 1160, which the North Carolina General Assembly enacted in July
1999, requires that municipalities, animal operations, industries and others who
operate waste handling systems issue news releases when a waste spill of 1,000
gallons or more reaches surface waters.
In accordance with that regulation, the following news release has been prepared
and issued to media in Haywood County:
Blue Ridge Paper Products, Incorporated, of Canton, North Carolina had a
wastewater spill on May 18, 2000 of an estimated 18,000 gallons from its
wastewater collection system off 175 Main Street. The release occurred due to a
power failure. The wastewater entered the Pigeon River in the French Broad River
Basin.
The Division of Water Quality was notified of the event on May 18, 2000 and is
reviewing this matter. For information contact Blue Ridge Paper Products
Incorporated at [phone].

Notice of Discharge of Untreated Wastewater
The Blue Ridge Paper Products, Incorporated, Canton North Carolina facility at
175 Main Street had a discharge of untreated wastewater of approximately 18,000
gallons due to a power failure. The discharge occurred on May 18, 2000 at
approximately 1:19 p.m. and lasted for approximately 1 minute. The untreated
wastewater entered the Pigeon River in the French Broad River Basin. Electrical
power was re-established to the wastewater pumps to prevent further discharge.
For more information contact the Director of Environmental, Safety and Health
Affairs at [phone].

-------------------------------------------------------------------------
-------------------------------------------------------------------------
For DWQ Use Only:
DWQ requested additional written report? Yes No
If yes, what additional information is needed?
Requested by

Making ur mark for you.
BLUE. RIDGE PAPER PRODUCTS INC.
June 1, 1999
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
Re: Sewage Release, NPDES Permit NC0000272
Dear Mr. Haynes:
Enclosed is the Sewage Spill Response Evaluation report.
Per our discussion this morning, we will continue to update you daily. The status of the
temporary by-pass line and the permanent repairs will be communicated to you as
appropriate.
If you have any questions or concerns, do not hesitate to call Melanie Hager (telephone:
646-6749) or myself (telephone: [phone]).
Sincerely,
Derric Brown
Environmental Supervisor
�5,

Sewage Spill Response Evaluation
Permittee: Blue Ridge Paper Products,Inc.
Permit Number: NC0000272 County: Haywood
Incident Started: (date/time) 5/25/99 10: 00 P.M.
Incident Ended: (date/time)
(if spill is ongoing,please notify Regional Office on a daily basis until spill can be stopped)
Source of spill/bypass (check one): ❑Sanitary Sewer ❑ Pump Station ® WWTP
Level of treatment (check one): ®None ❑ Primary Treatment
❑Secondary Trt. ❑ Chlorination Only
other(i.e.,upset conditions):
Estimated volume of spill/pass (check one): ❑ 0-500 gallons ❑501-1,000 gallons
❑ 1,001-2,000 gallons ® >2,000 gallons
Estimate volume in nearest 1,000 gallon increments
Did spill/bypass reach surface waters? ❑Yes ® No (if yes,please list the following)
Volume reaching surface waters? (check one): ❑ 0-500 gallons ❑ 501-1,000 gallons
NONE ❑1,100-2,000 gallons ❑ > 2,000 gallons
Estimate volume in nearest 1,000 gallon increments: N/A
Name of surface waters:
Did spill/bypass result in a fish kill? ❑ Yes ❑No v Q\
If yes,what is the estimated number of fish killed?
Please provide the following information:
P
1). Location of spill/bypass:
The release is located on the discharge side of the WWTP low lift pumps approximately 50 feet
from the pump discharge header manifold. The material is surfacing at ground level and
flowing less than 30 feet to a concrete pad catch basin which recirculates to the low lift pump
chamber. The material is then treated in the on-site WWTP. This pipe normally carries 25-27
mgd,the entire mill flow,with periodic flows to 40 mgd during rain events.
2). Cause of spill/bypass:
Undetermined at this time. We assume this is a leaking joint or a fractured pipe.
3). Did you have personnel available to perform an initial assessment 24 hours/day (including
weekends nd holidays)? ®Yes ❑ No

4). How long did it take to make an initial assessment of the spill/overflow after first knowledge?
Less than 10 minutes.
How long did it take to get a repair crew onsite?
Immediate steps were taken to engage the services of a specialty underground utility firm in
order to develop a by-pass isolation and repair plan.
Please explain the time taken to make initial assessment:
The initial assessment entailed determining the nature of the leak, that no released material
reached the surface waters,and that the leak was effectively captured by a surface drain.
5). Action taken to contain spill,clean-up waste,and/or remediate the site:
The release is effectively captured by a surface drain and recirculated back into the sewer
system. In addition, a contract underground utility firm with expertise in sewer repair and
rehabilitation was contacted the morning of May 26. The situation was reviewed with them
and a bypass scenario was evaluated. Initial scope of work and bill of materials list was
developed on 5/27 and the contractor's industrial manager made a site visit on 5/28 to finalize
the scope of work.
6). Were the equipment and/or parts needed to make repairs readily available? ❑ Yes ® No
If no,please explain why: This is a 60 reinforced concrete pipe of 1960's vintage that requires
custom fabrication of repair materials after physical inspection and measurements.
7). If the spill/overflow occurred at a pump station or was the result of a pump station failure,
was the alarm system functional at the time of the spill? ❑Yes ❑ No
If the alarm system did not function,please explain why:
N/A
8). Repairs made are: ❑ Permanent ❑ Temporary
Please describe what repairs were made. If the repairs are temporary,please indicate by
what date a permanent repair will be completed and notify the Regional Office within 7
days of the permanent repair:
9). Comments:
It is expected that a bypass will be installed and the release terminated by June 18,1999.
Other agencies notified:
Person reporting spill/bypass: Derric Brown phone number: [phone]
Signature: Date: 6I Z 19 9
For DWQ USE Only:
Oral report taken by:
Report taken: date: time:
DWQ requested additional written report? ❑Yes ❑No
If yes,what additional information is needed?
Please send this report to: Asheville Regional Office; NCDENR-DWQ Section
Phone: [phone] Fax: [phone]
After hours,weekends,or holidays,call: 1-800-858-0368

BLUE RIDGE
PAPER PRODUCTS INC.
May 15, 2000
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
Re: Defoamer Bin Line Pluggage, NPDES Permit NC0000272
Dear Mr. Haynes:
Blue Ridge Paper Products, Inc. is providing written notification as follow•up to Melanie
Hager's voicemail message of 11:40am, Thursday, May 11, 2000.
At approximately 6:50am on May 11, 2000, the Canton Mill's Wastewater Treatment
Plant crew leader noticed a small amount of foam on the Pigeon River at the secondary
effluent outfall camera monitor. The operator detected the foam as it initially occurred
and upon immediate investigation of the area, he discovered the line from the defoamer
bin that feeds into the effluent was plugged. The operator unplugged the line in
approximately 10 minutes. A downstream survey of the river revealed that there was no
foam beyond the mill's mixing zone.
The cause of the line plugging was a hard piece of defoamer lodged in the pump feed
line. A filter system has been added to the defoamer bin supply line to eliminate line
pluggage. There are also plans to install an alarm system that will send a signal to the
Wastewater Treatment Plant's control room whenever defoamer flow to the discharge
stops or is interrupted.
If you would like additional information regarding this issue, do not hesitate to call Derric
Brown (telephone: [phone]) or myself(telephone: [phone]).
Sincerely,
cc
Melanie Hager
Environmental Engineer
s
4sfv4TFR
N4!pTTN ' Tt
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

"a jr. tC.ed
III a._ -m
��ona; =cration
May 7. 1999
Mr. Norman Good
NC Department of Environment and Natural Resources
Division of Water Quality
Water Quality Chemistry Laboratory
4405 Reedy Creek Road
Raleigh, NC _7607
RE: Change of Ownership; Laboratory Certification No. 198
Dear Mr. Good:
On Alav 13, 1999. Champion International Corporation will transfer its ownership
interest in its Canton. North Carolina (Haywood County) facility to Blue Ridge Paper
Products Inc. Champion International Corporation and Blue Ridge Paper Products Inc.
request transfer of the facility's WWTP Laboratory Certification No. 198 from Champion
International to Blue Ridge Paper Products Inc. All existing laboratory equipment will
remain after the transfer. and John Pryately will remain as Laboratory Supervisor.
Thank you for your attention to this matter.
Sincerely,
� i
Gordon Jones i Richards iforto, r. `
CEO I Senior Vi President - Environment.
Blue Ridge Paper Products Inc. Health and Safetv
Champion International Corporation

DIV WATER QUALITY Fax:[phone] Feb 11 '00 11:13 P.01
Spill Response Evaluation
(Please Print or Type - Use Attachments if Needed)
Report Number: 2111 County: Haywood
Type of Incident(Check One): lO Complaint *Spill O Other
Reporting Person: Jimmy Phone Number:733-3300
Reporting Person's Affiliation: Emergency Management
Incident Started: Date: 2/I0/00 Time: 1234 PM
RQ in Pounds
Material Category Estimated Quantity Quantity Units Chemical Name(If Applicable) (Kilograms):
Petroleum 125 *Gal. OLbs. DIESEL
O Gal. O Lbs.
O Gal. O Lbs.
Containment: yes O No Cleanup Completed: Q yes No
Location of the Spill:
Public Notice Received: Date:
I::FQ. l~S..Itntt. S'i$le..SX�.LNi,J.y.WA.,E......_........_........................................................................._.._.....—............................_......_...................__......_._..........
Did the Material reach the Surface Waters? O Yes ONO Surface Water Name:
Did the Spill result in a Fish Kill? lO yes O No Estimated Number of Fish:
Cause of the Spill:
Tractor..Trailer..M:VA.L0.ADED..WlTH.C-OAL..OVFRT.URNF..SP.ILLIN...G.AP.RQX.125.G.A.LL.QE.DlESEL1-U.EL__...
If the Spill was from a Storage Tank please indicate the type: OAST OUST
Responsible Party: Pressley Tntcking Co
Contact: Phone Number:
Address: 51 Georges Rranch Rd. D
City/State/Zip: Candler 29715
On site Contact: Phone Number:
Contact Agency: Pager Number: SyFI/!q U O
Action Taken to Contain Spill, Clean Up Waste and Remediate the Site: C/oNgFOF��
.WAS.CLF.ANED.UP.E.Y...PR.ES.SLE.X..TRUCKING.CQ.,..na.sp� ifzGs.given......................................................................................_....
..............................._.............................................................................................................................................................................................................................
Cornments:
.............................._................_.........................._.........................................................................................................................................................................................
................................................................_....................................._........................_......._.......................................................................................................................I......
.

DIV WATER QUALITY Fax:[phone] Feb 11 '00 11:14 P.02 ,
Spill Response Evaluation
(Please Print or Type - Use Attachments if Needed)
Other Agencies Notified:
Agency Name and Phone Number Contact Name,Date,and Time of Contact
DWQ Information:
Received Via:
Report Taken By: Dana Folley Date: 2/10/2000 Time: 10:15 12M 10 Phone O Fax O Mail
Regional Person Referred Via:
Report Referred To: fax machine Date:2/1 1/2000 Time: I I M am O Phone. Op Fax
O Email O Interoffice.
Regional Contact (If different than above)
DWQ Requested an Additional Written Report: Yes 0 No
If Yes,What Additional Information is Needed:
Asheville Regional Office
NCDENR-DWQ Section Phone: [phone] Fax[phone]
After hours,Weekends,or Holidays,call 1-800-858-0368
Report Number: 2111

'-`------
�.
BUOE RIDGE
PAPER PRODUCTS INC. Oil
lJ�� APR 2 7 2000
tlA i ER 0 UALITY SECTI O
ff ASHFVILLE REGIONAL OrFICE
March 20, 2000
Ms. Darlene Kucken
North Carolina Department of Environment
And Natural Resources
Division of Water Quality/Planning
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: French Broad River Basinwide Water Quality Plan -
Draft Comments
Dear Ms. Kucken:
Blue Ridge Paper Products, Inc. appreciates the opportunity to comment on the
Draft French Broad River Basinwide Water Quality Plan. We also appreciate the
Division's efforts in organizing and generating such a well-written,
comprehensive plan.
Blue Ridge Paper's Canton Mill has made significant improvements in the quality
of the secondary effluent discharge since the 1995 French Broad Basinwide
Water Quality Plan was prepared. In addition to having technology in place
(oxygen delignification followed by 100% chlorine dioxide bleaching) that
exceeds USEPA's water quality requirements for Kraft mills, the Canton mill has
invested $30 million on our Bleach Filtrate Recycle (BFRTm) process. This is a
proprietary technology on our Pine Fiberline, which improves the bleach plant
effluent quality by recycling the chemicals and water used in bleaching pulp.
Blue Ridge Paper has four general concerns with the Draft Plan as it relates to
the Pigeon River Basin:
1. Nonpoint Source Pollution
The Plan does not integrate nonpoint source pollution into the assessment to the
degree we feel it should be discussed. The data in the plan concerning nonpoint
source dischargers does not allow for appropriate evaluation of the relative
importance of such sources. If the State and the regulated community are to
make qualified allocations of their resources to address the most serious
problems in the basin, it is necessary to get a better, more current idea of the
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

Ms. Darlene Kucken
Page 2
U'' ' effect which nonpoint sources have on the water quality in the basin. This is
particularly true on the Pigeon River where the principal industrial point source
discharger, the Canton Mill, has dramatically reduced the impact of its discharge
through the application of state-of-the-art technology at great expense. It is Blue
Ridge Paper's position that it is now appropriate to focus more attention on the
multitude of nonpoint sources discharged to the Pigeon River. This is particularly
important because nonpoint sources are listed in the 303(d) list for the Pigeon
River without identifying their associated impacts or appropriate corrective action
strategies. Further, the attention focused on point source dischargers has
allowed for great progress, so to direct such focus on nonpoint source
management strategies would be prudent.
2. 303(d) Listing
As a result of a series of process improvements in the late 1980's, there have
been no measurable levels of 2,3,7,8-TCDD (dioxin) in the mill effluent since
1989. As it relates to the 303(d) list it may be necessary for the State to include
the Pigeon River for dioxin, however, the plan should clearly state that the source
of dioxin in the river has been eliminated.
3. Listing of the Pigeon River from Canton to Clyde as Impaired
On p98 of The Plan, the segment of the river considered to be impaired by the
1995 Plan is identified as the Pigeon River"below Clyde to Waterville", thereby
/ implying that the segment from Clyde to Canton was not impaired. However, on
p100, The Plan indicates that in 1995 "the entire length of the Pigeon River (38.6
mi)" was impaired. This discrepancy should be resolved. Irrespective of the
discrepancy identified above, the basis for classifying the river as impaired from
the Canton water supply intake to Clyde in the 1999 Plan is not well established.
We have concerns regarding how each of the biological communities (i.e., fish
and macroinvertebrates) was used to justify the impaired rating.
4. Fish
The Plan indicates (p40) that NCIBI scores are provided in the report but NCIBI
classes (e.g., fair, good, excellent, etc.) are not listed and the NCIBI data were
not used for use support evaluations. The Plan notes that the present NCIBI
metrics do not work as expected within the mountain portion of North Carolina
and that the metrics "will be modified to allow reference sites to reflect an
Excellent NCIBI class" (p40). Later in the report (p47), DWQ identifies five areas
in which the NCIBI needs to be modified and states that until studies are
completed "it would be premature to assign a 'final' bioclassification to this
stream and apply a use support rating to the stream based on fish community
sampling". Clearly, the NCIBI is still a work in progress. The decision to not use
NCIBI scores to support use designations is inconsistent with the table in

Ms. Darlene Kucken
Page 3
Appendix A-III (p3) in which scoring category ratings are provided. This \
discrepancy should be resolved.
To support these areas of concern, Table I is provided in order to further pinpoint
recommended revisions to the body of The Plan. Also included as Attachment
Two is a report from EA Engineering, Science and Technology on this Draft Plan.
This firm has had extensive experience in studying the Pigeon River over the
past two decades and is one of the most technically knowledgeable on the
current conditions of the Pigeon River.
Again, thank you for the opportunity to submit these comments. We respectfully
request that these comments be considered and included in the Draft revision. If
you have any questions or comments, please call me at [phone] or Derric
Brown at [phone].
Sincerely,
Melanie S. Hager
Environmental Engineer
Attachments

Table 1 - Blue Ridge Paper Products, Inc., Canton Mill
French Broad River Basinwide Water Quality Management Plan
Draft Plan Comments Including Specific Report References
1. Executive Summary
Page Paragraph Recommended Revisions
Ail Table 2 'Recommended Management Strategy"for Subbasin 05 (Pigeon River) should include
efforts to manage non-point sources of pollution in addition to the strategy
for monitoring the point source.
2.Section A: Chapter 2-FBRB Overview
/ Page Paragraph Recommended Revisions
24 Table A-12 Facility name for Permit#NCS000105 should be Blue Ridge Paper Products, Inc.
not Champion International
8 thru 32 footer Note typo in Tooter. "French Broad River Basin Basin Overview"
3.Section A: Chapter 3-Summary of Water Quality Information for the French Broad River Basin
Page Paragraph Recommended Revisions
44 2 Change sentence to say, 'The station at Clyde, downstream of the Town of Canton and
BRPP discharge, reflects the effects of these inputs and nonpoint sources on water..."
Blue Ridge Paper Products, Inc. 1 3/21/00

3.Section A: Chapter 3-Summary of Water Quality Information for the French Broad River Basin cont.
/ Page Paragraph Recommended Revisions
50 Table A-28 "Recommended Management Strategy"for Subbasin 05 (Pigeon River) should include
efforts to manage non-point sources of pollution in addition to the strategy
for monitoring the point source.
4. Section B: Chapter 5-French Broad River Subbasin 04-03-05
Page Paragraph Recommended Revisions
95 3 TVA's sampling effort did not include the 7 mile stretch from Canton's water intake to Clyde.
Also, TVA's IBI is not calibrated or tested within the Pigeon.
97 3 Delete last sentence or modify to say, "BRPP, in addition to nonpoint
sources, discharge into the headwaters of the lake."
98 4 Third sentence should say"....many facility improvements were made to eliminate dioxin
levels to the river." Followed by this additional statement: "There have been no detectable
levels of 2,3,7,8-TCDD in the mill's effluent since June, 1989."
99 3 Revise the second sentence as follows:
"The lake also receives runoff, or non-point.source contributions, from agricultural and
urban runoff."
,e Ridge Paper Products, Inc. 2 3/21/00

4. Section B: Chapter 5-French Broad River Subbasin 04-03-05 continued
Page Paragraph Recommended Revisions
99 5 Last sentence should include Pigeon:
"These actions will likely have a long-term impact on the water quality of lower Richland
Creek and the Pigeon River."
100 5 Line 8 has a typo, "iste",which should be"site"
101 1 Insert the following after the second sentence:
"Another$30 million dollars was spent to implement BFRTA4, a proprietary technology
that again has improved the quality of the mill's effluent."
101 1 Third sentence delete and replace with, "Additional process improvements have been
ongoing."
102 1 Fourth sentence should reference the$30 Million cost of implementing BFRT'A.
/ 103 2 Insert the following as the last sentence in this paragraph:
"In addition to the Joint Watershed Advisory Group, the Canton Mill has established
a Community Advisory Committee-composed of community leaders in Haywood
County, NC and Cocke County, TN."
5.Appendix 3 -Use Support Ratings Table
Page Paragraph I Recommended Revisions
ref. pg 7 6th -9th There is no possible source referenced for non-point sources, add agriculture and
of table sections I non-urban development.
Blue Ridge Paper Products, Inc. 3 3/21/00

Attachment Two
Comments on
French Broad River
Basinwide Water Quality Plan
Prepared for
Blue Ridge Paper Products
Canton Mill
Canton,North Carolina
Prepared by
EA Engineering, Science, and Technology
444 Lake Cook Road, Suite 18
Deerfield,IL 60015
March 2000 13645.01

EA Engineering, Science, and Technology reviewed the French Broad River Basinwide Water
Quality Plan (The Plan)(December, 1999) and the Basinwide Assessment Report, French
Broad River Basin (November, 1998)(The Assessment Report). Although both reports were
reviewed in their entirety, the bulk of our review concentrated on those portions dealing with
the Pigeon River. Our comments on these two reports are provided below.
We were pleased to see that the report acknowledges the significant improvement in water
quality that has taken place over the last decade. For example, on p39 of The Plan, it is
acknowledged that positive changes, primarily related to improvements in wastewater
treatment, were noted at sites on the Pigeon River (among others). Similarly, on p100, The
Plan states that "water quality conditions in the Pigeon River have unproved tremendously
since the early 1990's". Overall, our comments center on two topics, (1) the inclusion of the
Pigeon in the 303(d) list because of dioxin and (2) the classification of the segment of the river
from the Canton water intake to Clyde as impaired.
303(d) LISTING
The purposes of adding a stream to the 303(d) list are so that the source of the problem(s) with
the stream can be identified and corrective action can be initiated. However, with regard to
dioxin in the Pigeon River, the source is known and actions have already been taken to
eliminate the source. Procedurally, it may be necessary for the state to include the Pigeon
River on the 303(d) list for dioxin. However, The Plan should indicate that the source of
dioxin in the river has been eliminated and that full compliance with the state's 3 ppt dioxin
limit is only a matter of time. No TMDL is needed because dioxin effluent levels from Blue
Ridge Paper have been below the level of detection for several years and the mill's limit of 0.1
pg/L was designed to be protective of the in-stream aquatic fauna and North Carolina's water
quality standards.
The Plan indicates that dioxin concentrations in the Pigeon River and Walters Lake "have
generally declined since the early 1990's". This statement implies that there has not been a
consistent downward trend or that the trend has not been consistent among species. In fact,
dioxin concentrations have declined for all species and this decline has been consistent. The
language of the report should be revised to reflect the breadth and magnitude of the decline. It
is this consistency in decline that provides the assurance that dioxin residues in common carp
and catfishes will meet state standards in the near future, thus eliminating the need for a
TMDL study. Finally, at a minimum, the Pigeon River should be given a "low" 303(d) list
priority since action has already been taken to remove the constituent of concern.
LISTING OF THE PIGEON RIVER FROM CANTON TO CLYDE AS IMPAIRED
On p98 of The Plan, the segment of the river considered to be unpaired by the 1995 Plan is
identified as the Pigeon River "below Clyde to Waterville", thereby implying that the segment
from Clyde to Canton was not impaired. However, on p100, The Plan indicates that in 1995
"the entire length of the Pigeon River (38.6 mi)" was impaired. This discrepancy should be

resolved. Irrespective of the discrepancy identified above, the basis for classifying the river as
impaired from the Canton water supply intake to Clyde in the 1999 Plan is not well
established. We have concerns regarding how each of the biological communities (i.e., fish
and macroinvertebrates) was used to justify the impaired rating.
Fish
The Plan indicates (p40) that NCIBI scores are provided in the report but NCIBI classes (e.g.,
fair, good, excellent, etc.) are not listed and the NCIBI data were not used for use support
evaluations. The Plan notes that the present NCIBI metrics do not work as expected within
the mountain portion of North Carolina and that the metrics "will be modified to allow
reference sites to reflect an Excellent NCIBI class" (p40). Later in the report(p47), DWQ
identifies five areas in which the NCIBI needs to be modified and states that until studies are
completed "it would be premature to assign a 'final' bioclassification to this stream and apply a
use support rating to the stream based on fish community sampling". Clearly, the NCIBI is
still a work in progress. The decision to not use NCIBI scores to support use designations is
inconsistent with the table in Appendix A-III (p3) in which scoring category ratings are
provided. This discrepancy should be resolved.
Despite clear statements indicating that NCIBI scores would not be used to rate the streams,
The Plan states on p95 that "fish sampling by both DWQ and TVA biologists produced low
ratings for 8 of 10 sites in this subbasin". Aside from using NCIBI scores in a manner not
consistent with guidance established earlier in The Plan, we do not believe, the TVA IBI
should be used to rate NC streams. The TVA IBI was not developed with the Pigeon River in
mind and has not been calibrated/verified for use in this basin. It is likely that some of the
scoring problems recently identified with the NCIBI are likely present in the TVA IBI.
Furthermore, given the fact that the TVA IBI uses different metrics as well as different scoring
criteria for those metrics that the two IBI's have in common, there is no basis for "translating"
TVA IBI scores into DWQ water quality classes (i.e., fair, good, excellent, etc.). Our
contention that the TVA IBI scores may be misleading is supported by DWQ's own
interpretation. DWQ states that "overall, the TVA data suggest fish community problems
throughout the basin," which is in disagreement with DWQ benthos and other data (The
Assessment Report 1998, p120, and The Plan, pA-11-13). For example, the IBI score
generated by TVA for Jonathan Creek would be equivalent to a DWQ rating of poor.
However, DWQ rated all three sites they sampled on Jonathan Creek as excellent based on the
NC Benthic Index.
To be clear, we are not suggesting that the TVA IBI is a poorly constructed index. Rather, we
are saying that it needs to be verified or calibrated before it can be use to rate sites in the
Pigeon River basin. This is particularly true for mainstem locations where the TVA IBI
aggregates data from three gears (backpack shock, boat shock, and seine) compared to DWQ
who doesn't even conduct fish sampling in streams the size of the Pigeon River.
Macroinvertebrates

The basis by which the segment of the Pigeon River from the Canton water supply intake to
Clyde is classified as impaired is somewhat confusing and poorly supported. According to The
Plan, segments that are rated good/fair are considered to be fully supported. The 1997
assessment of the Pigeon River classified this segment as good/fair (see Appendix Table A-II,
pA-ll-7) which should result in a rating of fully supporting. The basis for classifying this
segment as impaired apparently is because of a December 1999 rating of this segment as fair
by DWQ. Since summer (June-September) is the standard sampling period (see pA-II-1), any
collections outside this time window must be adjusted to account for seasonal differences. We
wonder about the advisability of overturning the good/fair classification obtained in 1997
during the standard sampling period with the fair rating obtained using seasonally adjusted
data. Even if the change in classification is real (and that is open to debate), the fair
classification during December 1999 may be a reflection of two years of low flow, stressful
conditions in the Pigeon River and therefore not reflective of typical conditions within this
segment. We do not disagree that with the premise that this segment is borderline (see p100 of
The Plan), however, we suggest that there is as much or more basis for classifying this
segment as good/fair as there is for classifying it as fair. Based on the discussion on p100, it is
clear that DWQ considered fish data in arriving at their classification of fair for this segment.
For example, The Plan states that the fish community below the plant was assigned fair or poor
ratings in 1995-97. However, elsewhere The Plan advises against using IBI scores to assign
ratings. The Plan goes on to state that the rating of fair was supported by considering the TVA
fish community data. However, TVA did not even have a sampling station within this segment
of the mainstem Pigeon River. Thus, there are no applicable data to consider even without the
admonishment in The Plan to not classify the streams on the basis of MI scores.
Given the borderline biotic index scores noted in this segment in 1997 and 1999, we suggest
that either the rating be changed to fully supported based on the good/fair rating derived in
1997 using data collected during the normal summertime sampling period, or the segment
remain unclassified until completion of benthic sampling this summer when 3-4 locations
within this segment will be sampled by BRPP's contractor.

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
• ;,-��•S ASHEVILLE REGIONAL OFFICE
NCDEMR WATER QUALITY SECTION
JAMES S.HUNTJR.GOVERNOR _4, Mr. Robert Williams
Blue Ridge Paper Products Inc.
175 Main Street -
�'i; P.O. Box 4000
P,mAY EMCDEVIT� Y Canton, North Carolina 28716 _
$SECRETARY '�+-y�{A j
n ' L ' r Subject: Balanced and Indigenous
Species Study Plan
-.KERR T.STEVENSI1 .,; +. Blue Ridge Paper Products
. _DIRECTOR
.: NPDES Permit No. NC0000272
Haywood County
f. , 1
Dear Mr. Williams:
� r•- ��fix"``_C'
I Ewa Staff of the Division of Water Quality have reviewed
the subject Plan and offer the following comments :
Task 1) It is important to select species for modeling,
which are native to the Pigeon River Basin. It is
i •IIi .;; r? our findings that there are currently no nuisance
species in the river.
yth�:
Task 3) The NCIBI should not be used as its metrics were
not calibrated nor was it correctly designed for
streams the size of the Pigeon river.
Task 4) A definition of a "balanced and indigenous
a h_ community" should be provided up-front . As well
as the choice of the cool water reference stream
from Western North Carolina. The upper Pigeon
River would be considered a suitable reference
R1, , ^ ^< stream. Then the conditions in the portion of the
River which you have studied should then be
r compared to the reference stream.
1.
a ?R4
gsr
l(?�G`S �t I •'r''Sj� INTERCHANGE BUILDINGS 58 WOODFIN PLACE, ASHEVILLE, NC'28801-2419
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10q POST-CONSUMER PAPER

Mr. Robert Williams
Page Two
Provided that these comments are incorporated into the
study plan, the Water. Quality Section considers the plan
acceptable for the evaluation of the Mill ' s thermal impact
to the Pigeon River. Please be sure to provide us with your
study results as soon as they are available.
If you have any questions concerning this matter,
please do not hesitate to contact Keith Haynes or Forrest
Westall of our Asheville Regional Office at 828/251-6208 .
Sincerely,
een Su 1 ' s
Water Quality Section Chief
xc: Forrest Westall
4K-e--9=,-h=Hayr.es-A

y r Ir,1. NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFIC
ag 73/�,J
WATER QUALITY SECTION
NCDEN(R rk AIL - PI
a W April 25, 2000 ( �{�
k�JAME9B HUNTJR
F"GOVERNOR
MEMORA DUM
AYNE DEVI
SECRETARY
C
SEORETARY
Q L� C i •
TO: Coleen Sullins
". � Q Water Quality Section Chi f �{; ��/
THROUGH: Forrest R. Westall
KERRT.STEVEN9 illy, h u.P /
•OIRECTOR0 ` ' Water Quality Regi al Supervisor
Y
FROM: D. Keith Haynes 1
Environmental Specialist 1
orP SUBJECT: Balanced and P
Indigenous Species
1
g
d Study Plan
i Blue Ridge Paper Products
NPDES Permit No. NC0000272
Haywood County
Please find attached a letter for your signature in
which the Section provides comments and gives approval for
Blue Ridge Paper Products subject study plan proposal. Bryn
Tracy of Environmental Sciences, provided comments to this
Office on this proposal. The comments were discussed with
Bryn and Blue Ridge Paper representatives. Some of the
' = issues raised by Bryn were not incorporated into the letter,
as the ARO didn' t believe they were appropriate. The
Environmental Sciences Branch should be consulted before the
_ attached letter is signed. We have faxed Bryn a copy of
this memo and our draft letter.
,rV The facility wishes to initiate work on the study as
quickly as possible, so we need to get our comments
submitted to them as soon as we can.
If you have any questions or if you need additional
information, please advise.
rtl
14AY - 2000
INTERCHANGE BUILDING, 59 y/��O(Q�QIFIN PLACE, ASHEVILLE, NC 2BSOI-2414
UO 1, "�IYX�, %Jjr�2p/g FAX[phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - 50%rREgYFLEb W POST-CONSUMER PAPER

�10

02 : 01 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P01/02
\4a k 1111,T UY 111.1ik rOi you.
BLUE RIDGE PAPER PRODUCTS INC.
)) (r� F/ACS SHEETFACSIMILE
/TO: ���� FROM;
C.1
COMPANY: DATE:
r-FAX NUMBER; TOTAL NO,OF PAGES I�rNG COVER:
,PSI- 6�sa
PHONE NUMBER: SENDER'S FAX NUMBER:
[phone]
RE: SENDER'S PHONE NUMBER-
(828) 646 6-2y q
❑ URGENT AFOR REVIEW ❑PLEASE COMMENT ❑PLEASE REPLY ❑PLEASE RECYCLE
NOTES/COMMENTS:
MAY � 62000 ,f l
.4 11R 0Ug1/ l��
16REG1 NAECTION
"The material contained in this communicate--.is,intended only for the use of the addressee. It
may contain information that is confidential, proprietary, attorney privileged, and exempt from
disclosure under applicable laW. If the reader of this communication is not the intended recipient,
you are hereby notified that any dissemination,distribution or duplication of this communication
is prohibited. If you have received this communication in error, please notify us immediately by
telephone and return,by mail,the original message to us. Thank you."
BLUE RIDGE PAPER PRODUCTS INC., 175 MAIN STREET, CANTON, NC 28716

02 : 02 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P02/02
BLUE RIDGE
PAPER PRODUCTS INC.
May 15, 2000
Mr. Keith Haynes
North Carolina Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
Re: Defoamer Bin Line Pluggage, NPDES Permit NC0000272
Dear Mr- Haynes:
Blue Ridge Paper Products, Inc. is providing written notification as follow-up to Melanie
Hager's voicemail message of 11:40am, Thursday, May 11, 2000.
At approximately 6:50am on May 11, 2000, the Canton Mill's Wastewater Treatment
Plant crew leader noticed a small amount of foam on the Pigeon River at the secondary
effluent outfall camera monitor. The operator detected the foam as it initially occurred
and upon immediate investigation of the area, he discovered the line from the defoamer
bin that feeds into the effluent was plugged. The operator unplugged the line in
approximately 10 minutes. A downstream survey of the river revealed that there was no
foam beyond the mill's mixing zone_
The cause of the line plugging was a hard piece of defoamer lodged in the pump feed
line. A filter system has been added to the defoamer bin supply line to eliminate line
pluggage. There are also plans to install an alarm system that will send a signal to the
Wastewater Treatment Plant's control room whenever defoamer flow to the discharge
stops or is interrupted.
If you would like additional information regarding this issue, do not hesitate to call Derric
Brown (telephone: [phone]) or myself(telephone: [phone]).
Sincerely,
Melanie Hager
Environmental Engineer
17S Main Street • P.O. Box 4000
Canton,North Carolina 28716 • Phone:[phone]
Raising Your Expectations
I

sk �AA1��•4y NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Ma-
CDEtR DIVISION OF WATER QUALITY
...� ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
-'
May 16, 2000
A'SAMES H. HLt$T JR
. QVERN'OW•' A^1nie'.
-,.
HbLMAN• Mr. Kenny Sutton
1 9EftRETARY Post Office Box 1772
Canton, North Carolina 28716
a¢E
�RR-r TET" Subject : Pigeon River
olRec � � Joint Watershed Advisory
Committee Meeting
� Tt Dear Mr. Sutton:
Cq. F Please find attached an agenda for the initial meeting
of the Pigeon River Joint Watershed Advisory Committee for
g ry /
y ��o which you were appointed by Governor Hunt by letter dated
December 1, 1999 . The meeting is scheduled for 1 : 00 the
afternoon of May 25, 2000 in the conference room of the
Asheville Regional Office of the Department of Environment
and Natural Resources .
� rn/y SI4�
3ca S I believe that you have been to our office before,
x however, if you need directions or if you have any questions,
please do not hesitate to contact Keith Haynes, Lucy Smith or
_,• me at 251-6208 .
�h!•7. .r, :r.
4e ! Sincerely,
��` � $�..; ✓✓Forrest �11
Water Quality Regional Supervisor
T
Enclosure
xc : Paul Davis
` Mike McGhee
R Bob Williams
4 .
INTERCHANGE BUILDING, 59 WOOOFIN PLACES ASH EVILLE. NORTH CAROLINA 28 80 1-241 4
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10q POST-CONSUMER PAPER

PIGEON RIVER JOINT WATERSHED ADVISORY COMMITTEE MEETING
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801
THURSDAY, MAY 25, 2000, 1:00 PM
AGENDA
I. Introduction of Committee Members, EPA Representatives, Tennessee and North
Carolina Staff Members, Blue Ridge Paper Representatives and Other Visitors -
(1:00 - 1:10)
II. Review of Agenda and the Materials Previously Provided to Committee Members
-- Paul Davis and Forrest Westall - (1:10 - 1:25)
A. Agenda Review
B. Brief Review of the Items Provided
C. Questions/Changes From the Committee
Ill. Charge to the Committee -- Mike McGhee, EPA - (1:25 - 1:55)
A. Review of the Permit Agreement Condition that Created this Committee
(Section IV, Paragraph 32)
B. Comments on Blue Ridge Paper's NPDES Permit Renewal
C. Review of Other Pigeon River Watershed Issues
IV. Mill Status: -- Bob Williams, Blue Ridge Paper Products - (1:55 - 2:15) .
A. Mill Ownership.Issues
B. Color Effluent Discharge Levels/Removal Performance
C. Future Improvements
V. Break - (2:15 - 2:30)
VI., Mill Related Water Quality Issues -- Paul Davis, Mike McGhee and Forrest Westall
- (2:30 - 3:00)
A. Permit Agreement, NPDES and Variance Compliance
B. Dioxin Data and Trends
C. Ecological Data (Fisheries and Aquatic Insect Information)

VII. General Pigeon River Water Quality Issues/Concerns - (3:00 - 3:30)
A. Status of Permit Agreement Ecological Assessment Provision (Section V,
Paragraph 33) -- Mike McGhee
B. Tennessee and NC Watershed Planning Initiatives -- Paul Davis and
Forrest Westall
C. Recreation/Rafting Use of the Pigeon -- Paul Davis and Forrest Westall
D. Waterville Lake/CPBL Issues -- Paul Davis and Forrest Westall
Vill. Committee Discussion, Identification of Other Issues and Committee Business -
(3:30 - 4:00)
A. Reaction of Committee's Charge
B. Otherlssues
C. Establishing Committee Responsibilities -- Electing Co-Chairs
D. Setting Next Meeting Date and Location in Tennessee
IX. Adjournment - (4:00)
-2-

VII. General Pigeon River Water Quality Issues/Concerns - (3:00 - 3:30)
A. Status of Permit Agreement Ecological Assessment Provision (Section V,
Paragraph 33) -- Mike McGhee
B. Tennessee and NC Watershed Planning Initiatives -- Paul Davis and
Forrest Westall
C. Recreation/Rafting Use of the Pigeon -- Paul Davis and Forrest Westall
D. Waterville Lake/CP&L Issues -- Paul Davis and Forrest Westall
Vlll. Committee Discussion, Identification of Other Issues and Committee Business -
(3:30 - 4:00)
A. Reaction of Committee's Charge
B. Otherlssues
C. Establishing Committee Responsibilities -- Electing Co-Chairs
D. Setting Next Meeting Date and Location in Tennessee
IX. Adjournment - (4:00)
C)
Q
i
I
-2-

PIGEON 121VER JOINT WATERSHED ADVISORY COMMITTEE MEETING
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801
THURSDAY, MAY 25, 2000, 1:00 PM
AGENDA
I. Introduction of Committee Memberrs, EPA Representatives, Tennessee and North
Carolina Staff Members, Blue Ridge Paper Representatives and Other Visitors -
(1:00 - 1:10)
11. Review of Agenda and the Materials Previously Provided to Committee Members
-- Paul Davis and Forrest Westall - (1:10 - 1:25)
A. Agenda Review
B. Brief Review of the Items Provided
C. Questions/Changes From the Committee
Ill. Charge to the Committee -- Mike McGhee, EPA - (1:25 - 1:55)
A. Review of the Permit Agreement Condition that Created this Committee
(Section IV, Paragraph 32)
B. Comments on Blue Ridge Paper's NPDES Permit Renewal
C. Review of Other Pigeon River Watershed Issues
IV. Mill Status: -- Bob Williams, Blue Ridge Paper Products - (1:55 - 2:15)
A. Mill Ownership Issues
B. Color Effluent Discharge Levels/Removal Performance
C. Future Improvements
V. Break - (2:15 - 2:30)
VI. Mill Related Water Quality Issues -- Paul Davis, Mike McGhee and Forrest Westall
- (2:30 - 3:00)
A. Permit Agreement, NPDES and Variance Compliance
B. Dioxin Data and Trends
C. Ecological Data (Fisheries and Aquatic Insect Information)

Mr. Robert Williams
Page Two
Provided that these comments are incorporated into the
study plan, the Water Quality Section considers the plan
, acceptable for the evaluation of the Mill' s thermal impact
to the Pigeon River. Please be sure to provide us with your
study results as soon as they are available.
If you have any questions concerning this matter,
please do not hesitate to contact Keith Haynes or Forrest
Westall of our Asheville Regional Office at 828/251-6208 .
SincerelyV162S
e e n Su
Water Quality Section Chief
x c: •E¢rx�est- Wes ta•1 +
Keith Haynes

NORTH DEPARTMENT OF
AND NATURAL
r' ENVIRONMENT AND NATT URAL RESOURCES
•!'= Y;`u DIVISION OF WATER QUALITY
'-`, ASHEVILLE REGIONAL OFFICE
NCDENR _ WATER QUALITY SECTION
DAMES B.HUNTJR. -
h ..
GOVERNOR ".•ta� Mr. Robert Williams
Blue Ridge Paper Products Inc. p��y
;t .• ,:, 175 Main Street
P.O. Box 4000
4WAYNE MCDEVITT Canton North Carolina 28716 •�,1?'L�-� -�
--SECRETARY :'r—«I-'�i'y(�'P --
�� rr Subject : Balanced and Indigenous
Species Study Plan
, D'RE .STEVEN9 . 1;1'r.,•i Blue Ridge Paper Products
,_ - NPDES Permit No. NC0000272
Haywood County
Lre11 Dear Mr. Williams :
- 1-f f i�.• -'
4, r.-1
x Staff of the Division of Water Quality have reviewed
the subject Plan and offer the following comments :
Task 1) It is important to select species for modeling,
which are native to the Pigeon River Basin. It is
I our findings that there are currently no nuisance
species in the river.
jly,_.l . Task 3) The NCIBI should not be used as its metrics were
not calibrated nor was it correctly designed for
= -- "—= streams the size of the Pigeon river.
zT' Task 4) A definition of a "balanced and indigenous
community" should be provided up-front . As well
as the choice of the cool water reference stream
from Western North Carolina. The upper Pigeon
's E River would be considered a suitable reference
ti stream. Then the conditions in the portion of the
�µ River whicH you have studied should then be
compared to the reference stream.
- INP *
n
INTERCHANGE BUILDING, 59 WOOOFIN PLACE. ASHEVILLE. NC 28801-2414
PHONE [phone] FAX828-ZS1-6452
--' -` �Ri• AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10q POST-CONSUMER PAPER

PIGEON RIVER JOINT WATERSHED ADVISORY COMMITTEE MEETING
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801
THURSDAY, MAY 25, 2000, 1:00 PM
AGENDA
I. Introduction of Committee Members, EPA Representatives, Tennessee and North
Carolina Staff Members, Blue Ridge Paper Representatives and Other Visitors -
(1:00 - 1:10)
II. Review of Agenda and the Materials Previously Provided to Committee Members
-- Paul Davis and Forrest Westall - (1:10 - 1:25)
A. Agenda Review
B. Brief Review of the Items Provided
C. Questions/Changes From the Committee
III. Charge to the Committee -- Mike McGhee, EPA - (1:25 - 1:55)
A. Review of the Permit Agreement Condition that Created this Committee
(Section IV, Paragraph 32)
B. Comments on Blue Ridge Paper's NPDES Permit Renewal
C. Review of Other Pigeon River Watershed Issues
IV. Mill Status: -- Bob Williams, Blue Ridge Paper Products - (1:55 - 2:15)
A. Mill Ownership Issues
B. Color Effluent Discharge Levels/Removal Performance
C. Future Improvements
V. Break - (2:15 - 2:30)
VI. Mill Related Water Quality Issues -- Paul Davis, Mike McGhee and Forrest Westall
- (2:30 - 3:00)
A. Permit Agreement, NPDES and Variance Compliance
B. Dioxin Data and Trends
C. Ecological Data (Fisheries and Aquatic Insect Information)

VII. General Pigeon River Water Quality Issues/Concerns - (3:00 - 3:30)
A. Status of Permit Agreement Ecological Assessment Provision (Section V,
Paragraph 33) -- Mike McGhee
B. Tennessee and NC Watershed Planning Initiatives -- Paul Davis and
Forrest Westall
C. Recreation/Rafting Use of the Pigeon -- Paul Davis and Forrest Westall
D. Waterville Lake/CP&L Issues -- Paul Davis and Forrest Westall
Vill. Committee Discussion, Identification of Other Issues and Committee Business -
(3:30 - 4:00)
A. Reaction of Committee's Charge
B. Other Issues
C. Establishing Committee Responsibilities -- Electing Co-Chairs
D. Setting Next Meeting Date and Location in Tennessee
IX. Adjournment - (4:00)
-2-

Making ar mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
February 3,2000
1a ,es est'a
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272, Blue Ridge Paper Products,Inc. Canton Mill
Dioxin Monitoring in Fish Tissue-Report 1999
Dear Mr. Westall:
Attached is the final report detailing the results from Blue Ridge Paper Products' tenth annual
Fish Tissue Study. This study, as required by our NPEDES permit, consists of annual sampling
of fish at specific sites in the Pigeon River and analysis of those fish for dioxin. The actual fish
collection took place in August 1999. All surveys were conducted by EA Engineering Science
and Technology and the analyses conducted by Quanterra Laboratories.
Table 6-4 provides the summary of the Canton Mill's Fish Fillet Tissue Analysis Results of
2,3,7,8-TCDD from 1990 to 1999.
If you have any questions or comments,please call me at(828) 646-2318.
Sincerely,
Derric Brown
Environmental Manager
AttachmentMR
D R fnl R M R
L5 1F 617 U 15 D
ASHEVEL E REGIONAL OIOIC
N
175 Main Street P.O. Box 4000 Canton, North Carolina 28716 • 828-646-2000

xc: Mr.Keith Haynes
Water Quality Section
Asheville Regional Office
59 Woodfin Place
Asheville,NC 28802
Attn: Central Files
Division of Environmental Management
and Natural Resources
NC Division of Environment and Natural Resources
P.O. Box 29535
Raleigh,NC 27626-0535
Mr. Robert McGhee
Director,Water Management Division
USEPA Region IV
345 Courtland Street,N.E.
Atlanta, GA 30365
Ms. Coleen Sullins
Chief, Water Quality Section
Division of Environmental Management
512 N Salisbury Street
P.O. Box 27687
Raleigh,NC 27611-7687
Mr. Paul Davis,Director
TN Dept. of Environment and Conservation
Division of Water Pollution Control
6th FI. L&C Annex
401 Church Street
Nashville, TN 37243-1534
Mr. David McKinney
TN Wildlife Resources Agencies
Ellington Agricultural Agency Center
P.O.Box 40747
Nashville,TN 37204

., - •y ,�,•r � ='TL "' NORTH CAROLINA DEPARTMENT OF
.{v•. '�" ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
I��i�CDE�Ut
.t April 24, 2000
E9B HUNTJRa�.FC'
5 •.GOVERN OR
Mr. Robert Williams
Blue Ridge Paper Products Inc.
175 Main Street
K ` Tr P.O. Box 4000
Ya, r M Canton, North Carolina 28716
•4Sz ` R
v ' Subject: Causticizin Reliability
7 4 Y
Project
R'R C. Blue Ridge Paper Products
,i-- NPDES Permit No . NC0000272
:= w � Haywood County
Dear Mr. Williams :
�;• `µ� We have reviewed your letter dated April 13, 2000
concerning planned improvements to the causticizing area of
Blue Ridge Paper Products Canton Mill . Since there will be
no additional color loading or production increases, this
improvement is allowed under the -settlement agreement.
•If you have any questions concerning this matter,
p � please do not hesitate to contact Keith Haynes or me at 251-
r: 6208 .
Sincerely,
i
` orrest Westall
Water Quality Regional Supervisor
H ssr 4"✓�
xc: Don Anderson, US EPA
Keith Haynes
f,+'^ � S•,N. 4 � INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASH EV ILLE, NC 28801-2414
mi '" W'yW PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10q POST-CONSUMER PAPER
ev..b�aa"�`--��y.�e.w�`-'.�•�S Via.

NORTH CAROLINA DEPAR MENT OF
J
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
v WATER QUALITY SECTION
��NCD�I�R I
April 25, 2000
.JAMESB HUNTJR: `
OVERMOR '
ya
MEMORANDUM
5i .
` Pw�YNMODEV
SECtiETARY
` gar TO: Coleen Sullins
a*. Water Quality Section Chi f
,P THROUGH: Forrest R. Westall
C'fiRTST£vt q
RI1 Water Quality Regi al Supervisor
FROM: D. Keith Haynes
Environmental Specialist
,Wi_ 3 SUBJECT: Balanced and Indigenous Species
Study Plan
s Blue Ridge Paper Products
LVOV
NPDES Permit No. NC0000272
Haywood County
14
i"
Please find attached a letter for your signature in
a .-w whi " - jes approval for
Bli Post-it'Fax Note 7671 D ges► in proposal. Bryn
Tra TG :omments to this
Off C discussed with
CoJ ept.
-.�.��.. Bra � Some of the
is.- Phone# h e# i into the letter,
y" as I Fes# Fax# date. The
Env isulted before the
att _ ______ .1ryn a copy of
firy _ this memo and our draft letter.
The facility wishes to initiate work on the study as
Ca;?°�=T�`"�,,,y„6•.G,:�. quickly as possible, so we need to get our comments
submitted to them as soon as we can.
If you have any questions or if you need additional
information, please advise.
1t,_(. ` 3"y sR•. INTERCHANGE BUILDING, 59 WOOOFIN PLACE, ASHEVILLE.FAX
8 2-251-2414
[{43••(r_•al�.v'--. " $K •' 3a.� 0% NE REC CLED/I-R20R FAX SLIME 1-6452
PAPER
q AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - EOYo RECYCLED/10q POST-CONSUMER PAPER

� NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
�Y-
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
i� 777♦♦♦
INCD� �R WATER QUALITY SECTION
i.
]AMPS B.Hu NTJR
GOVER NOR
*
-5I�,a;: ;� Mr. Robert Williams
arY,•�:: �? Blue Ridge Paper Products Inc.
175 Main Street
P.O. Box 4000
.weYNe'�h-1coE 41rr}4}� , Canton, North Carolina 28716
ecRrTawv ' �xT�t"�'-b
1
Subject: Balanced and Indigenous
' �c� 03Ctr Species Study Plan
"rcERas,.xT�Ey. Nsgs „a_ Blue Ridge Paper Products
IRECTQR NPDES Permit No. NC0000272
Haywood County
Dear Mr. Williams :
, w Staff of the Division of Water Quality have reviewed
the subject Plan and offer the following comments :
J
Task 1) It is important to select species for modeling,
which are native to the Pigeon River Basin. It is
t our findings that there are currently no nuisance
r species in the river.
Task 3) The NCIBI should not be used as its metrics were
not calibrated nor was it correctly designed for
-_-� streams the size of the Pigeon river.
Task 4) A definition of a "balanced and indigenous
' r z. community" should be provided up-front . As well
as the choice of the cool water reference stream
tiM-. ac from Western North Carolina. The upper Pigeon
River would be considered a suitable reference
stream. Then the conditions in the portion of the
River which you have studied should then be
compared to the reference stream.
erry L
'a
-17 may.. �.,�� C•1-.�y INTERCHANGE BUILDING, 58 WOODFIN PLACE, ASHEVILLE, NC 28801-2414
PHONE [phone] FAX[phone]
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED110q POST-CONSUMER PAPER

Mr. Robert Williams
Page Two
Provided that these comments are incorporated into the
study plan, the Water Quality Section considers the plan
acceptable for the evaluation of the Mill' s thermal impact
to the Pigeon River. Please be sure to provide us with your
study results as soon as they are available.
If you have any questions concerning this matter,
please do not hesitate to contact Keith Haynes or Forrest
West.all of our Asheville Regional Office at 828/251-6208 .
Sincerely,
Coleen Sullins
Water Quality Section Chief
xc: Forrest Westall
Keith Haynes

State of North Carolina
Department of Environment • •
and Natural Resources —
Division of Water Quality
James B. Hunt, Jr., Governor N D R
Bill Holman, Secretary NORTH CAROLIN E OF
ENVIRONMENT AN O RGES
KerrT. Stevens, Director ';�• a`/�t^\U
April 14, 2000
Mr. Louie Justus
Blue Ridge Paper Products Inc.
P.O. Box 4000
Canton, NC 28716 j
Subject: Permit No. NCS000105 !/
Blue Ridge Paper Products
Haywood County /O
Dear Mr. Justus:
In response to your renewal application for continued coverage under NPDES stormwater
permit NCS000105 the Division of Water Quality(DWQ) is forwarding herewith the subject
state -NPDES permit. This permit is issued pursuant to the requirements of North Carolina
General Statute 143-215 .1 and the Memorandum of Agreement between North Carolina and the
US Environmental Protection agency dated December 6, 1983.
Please note that the Division has revised the analytical monitoring strategy for individual
stormwater permits. Based on a review of the permit monitoring data received to date, the
analytical monitoring measurement frequencies have been changed and cut-off concentrations
have been removed. These changes will be implemented for all second term individual
stormwater permits with analytical monitoring requirements. For those permits with analytical
monitoring requirements, Part II - Monitoring, Controls, and Limitations for Permitted
Discharges has been modified to reflect the change in monitoring strategy.
The qualitative monitoring strategy remains the same as the first term of the permit.
Please note that the semi-annual qualitative monitoring is a requirement of the permit. Failure to
complete the monitoring as required is a violation of the permit and any permit noncompliance
constitutes a violation of the Clean Water Act. Reference Part III, Section A, Item 2 'Duty to
Comply", Item 9 "Penalties for Tampering " and Item 10 'Penalties for Falsification of Reports"
of your permit for further information.
If any parts, measurement frequencies or sampling requirements contained in this permit
are unacceptable to you, you have the right to an adjudicatory hearing upon written request
within thirty (30) days following receipt of this letter. This request must be in the form of a
written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed
with the Office of Administrative Hearings,Post Office Drawer 27447, Raleigh, North Carolina
27611 -7447. Unless such demand is made, this decision shall be final and binding.
Please take notice this permit is not transferable. Part III, B.2. addresses the requirements
to be followed in case of change in ownership or control of this discharge.
1617 Mail Service Center, Raleigh, North Carolina 27699.1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10%post-consumer paper

Page 2
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Environmental Management or permits required by the Division of
Land Resources, Coastal Area Management Act or any other Federal or Local governmental
permit that may be required.
If you have any questions concerning this permit, please contact Aisha Lau at telephone
number 919/733-5083 ext. 578.
Sincerely,
ORIGINAL-SI MIDgY
forVerr T. Stevens
cc: Mr. Roger O. Pfaff, EPA
(AgheeVi le�Re tonal O`f c
Stormwater and General Permits Unit
Central Files

NCS000105
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Blue Ridge Paper Products Inc.
is hereby authorized to discharge stormwater from a facility located at
Blue Ridge Paper Products Inc. —Canton Mill
Canton, NC
Haywood County
to receiving waters designated as Pigeon River and Bowen Branch, class C streams, in the
French Broad River Basin in accordance with the discharge limitations, monitoring requirements,
and other conditions set forth in Parts I, II, III, IV, V and VI hereof.
This permit shall become effective May 1, 2000.
This permit and the authorization to discharge shall expire at midnight on April 30, 2005.
Signed this day April 14, 2000.
ORIGINAL SIGNED 8Y
%ILLIAM C.MILLS
for Kerr T. Stevens, Director
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit No.NCS000105
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B: Analytical Monitoring Requirements
Section C: Qualitative Monitoring Requirements
Section D: On-Site Vehicle Maintenance Monitoring Requirements
PART III STANDARD CONDITIONS
Section A: Compliance and Liability
1. ' Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
5. Oil and Hazardous Substance Liability
6. Property Rights
7. Severability
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
Section B: General Conditions
1. Individual Permit Expiration
2. Transfers
i

Permit No. NCS000105
3. Signatory Requirements
4. Individual Permit Modification, Revocation and Reissuance, or
Termination
5. Permit Actions
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
1. Representative Sampling
2. Recording Results
3. Flow Measurements
4. Test Procedures
5. Representative Outfall
6. Records Retention
7. Inspection and Entry
Section E: Reporting Requirements
1. Discharge Monitoring Reports
2. Submitting Reports
3. Availability of Reports
4. Non-Stormwater Discharges
5. Planned Changes
6. Anticipated Noncompliance
7. Bypass
8. Twenty-four Hour Reporting
9. Other Noncompliance
10. Other Information
PART IV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS
ii

Permit No.NCS000105
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited and monitored as specified in this permit.
SECTION B: PERMITTED ACTIVITIES
Until this permit expires or is modified or revoked, the permittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system which has
been adequately treated and managed in accordance with the terms and conditions of this
individual permit. All discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stormwater discharge or is covered by another permit, authorization or approval.
This permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state, or local law,rule, standard, ordinance, order,judgment, or decree.
Part 1 Page 1 of 2

Permit No.NCS000105
SECTION C: LOCATION MAP
All
IN
/ \\: `' •4i r -�� P.pti ._ - . I„ s• s�`1-_ Aza�:-,� '�
SO �.N 1 it, .�. 'll• i(.� �n� ,..1� •. >',r C t•�' .IM Ua� v..rh i °" , ,.• )�,rti• .
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Plat o•,. \ ,�.�``'�^•:1• \,� Iwelec
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` NC00002 er
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.l' �.. - _E•,••sf,— Tel '-' `<+s�`: [_,•.. .. .-. n� i'•. ?
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65
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Part I Page 2 of 2

Permit No.NCS000105
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this individual permit. The Plan shall include, at a
minimum, the following items:
1. Site Plan. The site plan shall provide a description of the physical facility and the
potential pollutant sources which may be expected to contribute to contamination of
stormwater discharges. The site plan shall contain the following:
(a) A general location map (USGS quadrangle map or appropriately drafted
equivalent map), showing the facility's location in relation to transportation
routes and surface waters, the name of the receiving water(s) to which the
stormwater outfall(s) discharges, or if the discharge is to a municipal separate
storm sewer system, the name of the municipality and the ultimate receiving
waters; and accurate latitude and longitude of the point(s) of discharge.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices.
(c) A site map drawn to scale with the distance legend indicating location of
industrial activities (including storage of materials, disposal areas, process areas
and loading and unloading areas), drainage structures, drainage areas for each
outfall and activities occurring in the drainage area, building locations, existing
BMPs and impervious surfaces, and the percentage of each drainage area that is
impervious. For each outfall, a narrative description of the potential pollutants
which could be expected to be present in the stormwater discharge.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the 3 previous years and any corrective actions taken to mitigate spill
impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
accordance with the requirements found in Part III, Standard Conditions, Section
B, Paragraph 3.
2. Stormwater Management Plan. The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
Part II Page I of 6

Permit No.NCS000105
nonstructural measures. The stormwater management plan, at a minimum, shall
incorporate the following:
(a) Feasibility Study. A review of the technical and economic feasibility of changing
the methods of operations and/or storage practices to eliminate or reduce exposure
of materials and processes to stormwater. Wherever practical, the permittee shall
prevent exposure of all storage areas, material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is
not practical, the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
(b) Secondary Containment Schedule. A schedule to provide secondary containment
for bulk storage of liquid materials, storage of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals, or storage of hazardous substances to prevent leaks and spills from
contaminating stormwater runoff. If the secondary containment devices are
connected directly to stormwater conveyance systems, the connection shall be
controlled by manually activated valves or other similar devices [which shall be
secured with a locking mechanism] and any stormwater that accumulates in the
containment area shall be at a minimum visually observed for color, foam, outfall
staining, visible sheens and dry weather flow, prior to release of the accumulated
stormwater. Accumulated stormwater shall be released if found to be
uncontaminated by the material stored within the containment area. Records
documenting the individual making the observation, the description of the
accumulated stormwater and the date and time of the release shall be kept for a
period of five years.
(c) BMP Summary. A narrative description shall be provided of Best Management
Practices (BMPs) to be considered such as, but not limited to, oil and grease
separation, debris control, vegetative filter strips, infiltration and stormwater
detention or retention, where necessary. The need for structural BMPs shall be
based on the assessment of potential of sources to contribute significant quantities
of pollutants to stormwater discharges and data collected through monitoring of
stormwater discharges.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or team) responsible for implementing the
SPRP shall be identified. A responsible person shall be on-site at all times during facility
operations that have the potential to contaminate stormwater runoff through spills or
exposure of materials associated with the facility operations. The SPRP must be site
stormwater specific. Therefore, a SPCC plan may be a component of the SPRP, but may
not be sufficient to completely address the stormwater aspects of the SPRP. The common
elements of the SPCC with the SPRP may be incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance program shall be developed. The program shall document schedules of
inspections and maintenance activities of stormwater control systems, plant equipment
Part II Page 2 of 6

Permit No.NCS000105
and systems. Inspection of material handling areas and regular cleaning schedules of
these areas shall be incorporated into the program.
5. Employee Training. Training schedules shall be developed and training provided at a
minimum on an annual basis on proper spill response and cleanup procedures and
preventative maintenance activities for all personnel involved in any of the facility's
operations that have the potential to contaminate stormwater runoff. Facility personnel
(or team) responsible for implementing the training shall be identified.
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s) responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
7. Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction, operation, or maintenance which has a significant effect on the
potential for the discharge of pollutants to surface waters. The Stormwater Pollution
Prevention Plan shall be reviewed and updated on an annual basis.
The Director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part III, Standard Conditions, Section B, Paragraph 3) to the Director that the changes
have been made.
8. Facility Inspection Program. Facilities are required to inspect all stormwater systems on
at least a semiannual schedule, once in the fall (September-November) and once in the
spring (April - June). The inspection and any subsequent maintenance activities
performed shall be documented, recording date and time of inspection, individual(s)
making the inspection and a narrative description of the facility's stormwater control
systems, plant equipment and systems. Records of these inspections shall be
incorporated into the Stormwater Pollution Prevention Plan.
Stormwater discharge characteristic monitoring as required in Part II of this permit shall
be performed in addition to facility inspections.
9. Implementation. The permittee shall document all monitoring, measurements,
inspections and maintenance activities and training provided to employees, including the
log of the sampling data and of activities taken to implement BN Ps associated with the
industrial activities, including vehicle maintenance activities. Such documentation shall
be kept on-site for a period of five years and made available to the Director or his
authorized representative immediately upon request.
Part 11 Page 3 of 6

Permit No.NCS000105
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater subject to the provisions of this permit.
Analytical monitoring of stormwater discharges shall be performed as specified below in Table
1.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 4 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO). The permittee shall complete the
minimum 4 analytical samplings in accordance with the schedule specified below in Table 2.
Table 1. Analytical Monitoring Requirements
Discharge Measurement Sample Sample
Characteristics Units Frequencyl Type2 Location3
Total Suspended Solids m /l Quarterly-4'"year Grab SDO
Fecal Coliform4 mg/l Quarterly-4"year Grab SDO
BOD 5 rn /l Quarterly-4'year Grab SDO
Total Rainfall6 inches Quarterly-4'"year _
Event Duration6 minutes Quarterly-4'year
Total Flow6 MG Quarterly-4"year _ SDO
Footnotes:
1 Measurement Frequency: Once per quarter during the 4'"year of the permit term. A year is defined as the 12
month period beginning on the month and day of issuance of the Permit.See Table 2 for schedule of monitoring
periods.
2 If the stormwater runoff is controlled by a stormwater detention pond,a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm,then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Sampling is required only at Outfalls 1,2,3,4,5,6,7,8,9,6-4,and 6-10
4 Fecal Coliform sampling is only required for outfalls 1,2,and 3.
5 BOD,sampling is only required for outfall 3.
6 For each sampled representative storm event the total precipitation, storm duration,and total flow must be
monitored. Total flow shall be either;(a)measured continuously,(b)calculated based on the amount of area
draining to the outfall,the amount of built-upon(impervious)area,and the total amount of rainfall,or(c)
estimated by the measurement of flow at 20 minute intervals during the rainfall event.
Part 11 Page 4 of 6

Permit No.NCS000105
SECTION D: ON-SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities which have any vehicle maintenance activity occurring on-site which uses more than
55 gallons of new motor oil per month when averaged over the calendar year shall perform
analytical monitoring as specified below in Table 4. This monitoring shall be performed at all
outfalls which discharge stormwater runoff from vehicle maintenance areas.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 4 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO) which discharges stormwater runoff from
vehicle maintenance areas. The permittee shall complete the minimum 4analytical samplings in
accordance with the schedule specified in Table 2 (Part II, Section B).
Table 4. Analytical Monitoring Requirements for On-Site Vehicle Maintenance
Discharge Characteristics Units Measurement Sample Sample
Frequencyl Type2 Location3
H standard Quarterly-41°year Grab SDO
Oil and Grease mg/1 Quarterly-4"year Grab SDO
Total suspended Solids mg/1 Quarterly-46 year Grab SDO
New Motor Oil Usagegallons/month Quarterly-4"year Estimate -
Total Flow4 MG Quarterly-e year Grab SDO
Footnotes:
I Measurement Frequency: Once per quarter during the 4"year of the permit term. A year is defined as the 12
month period beginning on the month and day of issuance of the Permit. See Table 2 for schedule of monitoring
periods.
2 If the stormwater runoff is controlled by a stormwater detention pond,a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm,then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO)that discharges
stormwater runoff from area(s)where vehicle maintenance activities occur.
4 Total flow shall be; (a)measured continuously,(b)calculated based on the amount of area draining to the outfall,
the amount of built-upon(impervious)area,and the total amount of rainfall,or(c)estimated by the measurement
of flow at 20 minute intervals during the rainfall event. Total precipitation and duration of the rainfall event
measured shall result from the sampled representative storm event.
Part 11 Page 6 of 6

Pemvt No.NCS000105
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL
PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater
discharges in accordance with the following schedule:
Existing Facilities: The Stormwater Pollution Prevention Plan shall be developed and
implemented within 12 months of the effective date of the initial permit and updated
thereafter on an annual basis. Secondary containment, as specified in Part 11,Section A,
Paragraph 2(b) of this permit, shall be accomplished within 12 months of the effective
date of the initial permit issuance.
Proposed Facilities: The Stormwater Pollution Prevention Plan shall be developed and
implemented prior to the beginning of discharges from the operation of the industrial
activity and be updated thereafter on an annual basis. Secondary containment, as
specified in Part H, Section A,Paragraph 2(b) of this permit shall be accomplished prior
to the beginning of discharges from the operation of the industrial activity.
2. Duty to Comply
The permittee must comply with all conditions of this individual permit. Any permit
noncompliance constitutes a violation of the Clean Water Act and is grounds for
enforcement action; for permit termination,revocation and reissuance, or modification; or
denial of a permit upon renewal application.
a. The permittee shall comply with standards or prohibitions established under
section 307(a) of the Clean Water Act for toxic pollutants within the time
provided in the regulations that establish these standards or prohibitions,even if
the permit has not yet been modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit condition is
subject to a civil penalty not to exceed $25,000 per day for each violation. Any
person who negligently violates any permit condition is subject to criminal
penalties of$2,500 to $25,000 per day of violation, or imprisonment for not more
than 1 year,or both. Any person who knowingly violates permit conditions is
subject to criminal penalties of$5,000 to$50,000 per day of violation, or
imprisonment for not more than 3 years, or both. Also,any person who violates a
permit condition may be assessed an administrative penalty not to exceed$10,000
per violation with the maximum amount not to exceed$125,000. [Ref: Section
309 of the Federal Act 33 USC 1319 and 40 CFR 122.41(a).]
Part III Page 1 of 10 Pages

Permit No.NCS000105
C. Under state law, a daily civil penalty of not more than ten thousand dollars
($10,000)per violation may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit. (Ref:
North Carolina General Statutes 143-215.6A)
d. Any person may be assessed an administrative penalty by the Director for
violating section 301, 302, 306, 307, 308, 318, or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act. Administrative penalties for Class I violations are not to
exceed$10,000 per violation,with the maximum amount of any Class I penalty
assessed not to exceed$25,000. Penalties for Class II violations are not to exceed
$10,000 per day for each day during which the violation continues,with the
maximum amount of any Class II penalty not to exceed $125,000.
3. Duty to Mitigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in
violation of this individual permit which has a reasonable likelihood of adversely
affecting human health or the environment.
4. Civil and Criminal Liabilitv
Except as provided in Part III, Section C of this permit regarding bypassing of stormwater
control facilities,nothing in this individual permit shall be construed to relieve the
permittee from any responsibilities, liabilities, or penalties for noncompliance pursuant to
NCGS 143-215.3,143-215.6A, 143-215.6B, 143-215.6C or Section 309 of the Federal Act,
33 USC 1319. Furthermore,the permittee is responsible for consequential damages, such
as fish kills, even though the responsibility for effective compliance may be temporarily
suspended.
5. Oil and Hazardous Substance Liability
Nothing in this individual permit shall be construed to preclude the institution of any
legal action or relieve the penrimee from any responsibilities,liabilities,or penalties to
which the permittee is or may be subject to under NCGS 143-215.75 et seq. or Section 311
of the Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this individual permit does not convey any property rights in either real or
personal property, or any exclusive privileges,nor does it authorize any injury to private
property or any invasion of personal rights,nor any infringement of Federal, State or local
laws or regulations.
Part III Page 2 of 10 Pages

Permit No.NCS000105
7, Severability
The provisions of this individual permit are severable, and if any provision of this
individual permit, or the application of any provision of this individual permit to any
circumstances, is held invalid,the application of such provision to other circumstances,
and the remainder of this individual permit, shall not be affected thereby.
8. Duty to Provide Information
The permittee shall furnish to the Director,within a reasonable time, any information
which the Director may request to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit issued pursuant to this individual permit
or to determine compliance with this individual permit. The permittee shall also furnish
to the Director upon request,copies of records required to be kept by this individual
permit.
9. Penalties for TMerine
The Clean Water Act provides that any person who falsifies,tampers with,or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
individual permit shall,upon conviction,be punished by a fine of not more than$10,000
per violation, or by imprisonment for not more than two years per violation,or by both.
If a conviction of a person is for a violation committed after a first conviction of such
person under this paragraph,punishment is a fine of not more that$20,000 per day of
violation, or by imprisonment of not more than 4 years,or both.
10. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to
be maintained under this individual permit, including monitoring reports or reports of
compliance or noncompliance shall,upon conviction,be punished by a fine of not more
than $10,000 per violation, or by imprisonment for not more than two years per violation,
or by both.
SECTION B: GENERAL CONDITIONS
I. Individual Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expiration date,the permittee shall
submit forms and fees as are required by the agency authorized to issue permits no later
than 180 days prior to the expiration date. Any permittee that has not requested renewal
at least 180 days prior to expiration, or any permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration,will be
Part III Page 3 of 10 Pages

Permit No.NCS000105
subjected to enforcement procedures as provided in NCGS §143-2153.6 and 33 USC
1251 et. seq.
2. Transfers
This permit is not transferable to any person except after notice to and approval by the
Director. The Director may require modification or revocation and reissuance of the
permit to change the name and incorporate such other requirements as may be necessary
under the Clean Water Act. Perrnittee is required to notify the Division in writing in the
event the permitted facility is sold or closed.
3. SiQnatoryRequirements
All applications,reports, or information submitted to the Director shall be signed and
certified.
a. All applications to be covered under this individual permit shall be signed as
follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of
this Section, a responsible corporate officer means: (a) a president,
secretary,treasurer or vice president of the corporation in charge of a
principal business function, or any other person who performs similar
policy or decision making functions for the corporation, or(b)the manager
of one or more manufacturing production or operating facilities employing
more than 250 persons or having gross annual sales or expenditures
exceeding 25 million (in second quarter 1980 dollars), if authority to sign
documents has been assigned or delegated to the manager in accordance
with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the
proprietor, respectively; or
(3) For a municipality, State,Federal, or other public agency: by either a
principal executive officer or ranking elected official.
b. All reports required by the individual permit and other information requested by
the Director shall be signed by a person described above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having
responsibility for the overall operation of the regulated facility or activity,
such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or
position having overall responsibility for environmental matters for the
Part III Page 4 of 10 Pages

Permit No.NCS000105
company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Director.
C. Any person signing a document under paragraphs a. or b. of this section shall
make the following certification:
"I certify, under penalty of law, that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing
violations."
4. Individual Permit Modification, Revocation and Reissuance, or Termination
The issuance of this individual permit does not prohibit the Director from reopening and
modifying the individual permit, revoking and reissuing the individual permit, or
terminating the individual permit as allowed by the laws, rules, and regulations contained
in Title 40, Code of Federal Regulations, Parts 122 and 123;Title 15A of the North
Carolina Administrative Code, Subchapter 2H .0100; and North Carolina General Statute
143-215.1 et. al.
5. Permit Actions
The permit may be modified, revoked and reissued, or terminated for cause. The
notification of planned changes or anticipated noncompliance does not stay any
individual permit condition.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the
permittee to achieve compliance with the conditions of this individual permit. Proper
operation and maintenance also includes adequate laboratory controls and appropriate
Part III Page 5 of 10 Pages

Permit No.NCS000105
quality assurance procedures.This provision requires the operation of back-up or
auxiliary facilities or similar systems which are installed by a permittee only when the
operation is necessary to achieve compliance with the conditions of this individual
permit.
2. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with
the condition of this individual permit.
3. Bypassinv of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee
for bypass unless:
a. Bypass was unavoidable to prevent loss of life,personal injury or severe property
damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary
control facilities,retention of stormwater or maintenance during normal periods of
equipment downtime or dry weather. This condition is not satisfied if adequate
backup controls should have been installed in the exercise of reasonable
engineering judgment to prevent a bypass which occurred during normal periods
of equipment downtime or preventive maintenance; and
C. The permittee submitted notices as required under,Part III, Section E of this
permit.
If the Director determines that it will meet the three conditions listed above,the Director
may approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
1. Representative Sampline
Samples collected and measurements taken, as required herein, shall be characteristic of
the volume and nature of the permitted discharge. Analytical sampling shall be
performed during a representative storm event. Samples shall be taken on a day and time
that is characteristic of the discharge. All samples shall be taken before the discharge
joins or is diluted by any other waste stream,body of water,or substance. Monitoring
points as specified in this permit shall not be changed without notification to and
approval of the Director.
Part III Page 6 of 10 Pages

Permit No.NCS000105
2. Recordine Results
For each measurement, sample, inspection or maintenance activity performed or collected
pursuant to the requirements of this individual permit,the permittee shall record the
following information:
a. The date,exact place, and time of sampling,measurements,inspection or
maintenance activity;
b. The individual(s) who performed the sampling, measurements,inspection or
maintenance activity;
C. The date(s)analyses were performed;
d. The individual(s)who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with
accepted scientific practices shall be selected and used to ensure the accuracy and
reliability of measurements of the volume of monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations
published pursuant to NCGS 143-215.63 et. seq,the Water and Air Quality Reporting
Acts, and to regulations published pursuant to Section 304(g), 33 USC 1314, of the
Federal Water Pollution Control Act, as Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this individual permit, all test procedures
must produce minimum detection and reporting levels and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure.
5. Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater
discharges that are required to be sampled,the permittee may petition the Director for
representative outfall status. If it is established that the stormwater discharges are
substantially identical and the permittee is granted representative outfall status,then
sampling requirements may be performed at a reduced number of outfalls.
Part III Page 7 of 10 Pages

Permit No.NCS000105
6. Records
Visual monitoring shall be documented and records maintained at the facility along with
the Stormwater Pollution Prevention Plan. Copies of analytical monitoring results shall
also be maintained on-site. The permittee shall retain records of all monitoring
information,including all calibration and maintenance records and all original strip chart
recordings for continuous monitoring instrumentation, and copies of all reports required
by this individual permit for a period of at least 5 years from the date of the sample,
measurement,report or application. This period may be extended by request of the
Director at any time.
7. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an
authorized contractor acting as a representative of the Director), or in the case of a facility
which discharges through a municipal separate storm sewer system, an authorized
representative of a municipal operator or the separate storm sewer system receiving the
discharge, upon the presentation of credentials and other documents as may be required
by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located
or conducted, or where records must be kept under the conditions of this
individual permit;
b. Have access to and copy,at reasonable times, any records that must be kept under
the conditions of this individual permit;
C. Inspect at reasonable times any facilities,equipment (including monitoring and
control equipment), practices, or operations regulated or required under this
individual permit; and
d. Sample or monitor at reasonable times,for the purposes of assuring individual
permit compliance or as otherwise authorized by the Clean Water Act, any
substances or parameters at any location.
SECTION E: REPORTING REQUIREMENTS
I. Discharge Monitoring Rgports
Samples analyzed in accordance with the terms of this permit shall be submitted to the
Division on Discharge Monitoring Report forms provided by the Director. Submittals
shall be received by the Division no later than 30 days from the date the facility receives
the sampling results from the laboratory.
Part III Pages of to Pages

Permit No.NCS000105
2. Submitting Reports
Duplicate signed copies of all reports required herein, shall be submitted to the following
address:
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
3. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section
308 of the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms
shall be available for public inspection at the offices of the Division of Water Quality. As
required by the Act, analytical data shall not be considered confidential. Knowingly
making any false statement on any such report may result in the imposition of criminal
penalties as provided for in NCGS 143-215.613 or in Section 309 of the Federal Act.
4. Non-StormwaterDischaryes
If the storm event monitored in accordance with this individual permit coincides with a
non-stormwater discharge,the permittee shall separately monitor all parameters as
required under the non-stormwater discharge permit and provide this information with the
stormwater discharge monitoring report.
5. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes
at the permitted facility which could significantly alter the nature or quantity of pollutants
discharged. This notification requirement includes pollutants which are not specifically
listed in the individual permit or subject to notification requirements under 40 CFR Part
122.42 (a).
6. Anticipated Noncompliance
The permittee shall give notice to the Director as soon as possible of any planned changes
at the permitted facility which may result in noncompliance with the individual permit
requirements.
7. bass
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass, it
shall submit prior notice, if possible at least ten days before the date of the bypass;
including an evaluation of the anticipated quality and affect of the bypass.
Part III Page 9 of 10 Pages

Permit No.NCS000105
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of
becoming aware of an unanticipated bypass.
8. Twenty-four Hour Reportine
The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes;
the period of noncompliance, including exact dates and times, and if the noncompliance
has not been corrected, the anticipated time compliance is expected to continue; and steps
taken or planned to reduce,eliminate, and prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case-by-case basis if the oral report has
been received within 24 hours.
9. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour
reporting at the time monitoring reports are submitted.
10. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in an
application for an individual permit or in any report to-the Director, it shall promptly
submit such facts or information.
Part III Page 10 of 10 Pages

Permit No.NCS000105
PART IV LIMITATIONS REOPENER
This individual permit shall be modified or alternatively, revoked and reissued, to comply with
any applicable effluent guideline or water quality standard issued or approved under Sections
302(b) (2) (c), and (d), 304(b) (2) and 307(a) of the Clean Water Act,if the effluent guideline or
water quality standard so issued or approved:
a. Contains different conditions or is otherwise more stringent than any effluent limitation in
the individual permit; or
b. Controls any pollutant not limited in the individual permit.
The individual permit as modified or reissued under this paragraph shall also contain any other
requirements in the Act then applicable.
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days
after being billed by the Division. Failure to pay the fee in timely manner in accordance with
15A NCAC 2H .0105(b)(4) may cause this Division to initiate action to revoke the Individual
Permit.
PART VI DEFINITIONS
1. Act
See Clean Water Act.
2. Arithmetic Mean
The arithmetic mean of any set of values is the summation of the individual values
divided by the number of individual values.
3. Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Non-stormwater discharges which shall be
allowed in the stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
Parts IV,V and VI Page I of 6

Permit No.NCS000105
(b) Uncontaminated groundwater, foundation drains, air-conditioner condensate
without added chemicals, springs, discharges of uncontaminated potable water,
waterline and fire hydrant flushings, water from footing drains,flows from
riparian habitats and wetlands.
(c) Discharges resulting from fire-fighting or fire-fighting training.
4. Best Management Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters.
BMPs may take the form of a process, activity, or physical structure.
5. BBvpass
A bypass is the known diversion of stormwater from any portion of a stormwater control
facility including the collection system, which is not a designed or established operating
mode for the facility.
6. Bulk Storage of Liquid Products
Liquid raw materials, manufactured products, waste materials or by-products with a
single above ground storage container having a capacity of greater than 660 gallons or
with multiple above ground storage containers located in close proximity to each other
having a total combined storage capacity of greater than 1,320 gallons.
7. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as
amended, 33 USC 1251, et. seq.
8. Division orDWO
The Division of Water Quality,Department of Environment and Natural Resources.
9. Director
The Director of the Division of Water Quality,the permit issuing authority.
10. EMC
The North Carolina Environmental Management Commission.
11. Grab Sample
An individual sample collected instantaneously. Grab samples that will be directly
analyzed or qualitatively monitored must be taken within the first 30 minutes of
discharge.
Part VI Page 2 of 6 Pages

Permit No.NCS000105
12. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean
Water Act.
13. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and
which is not a land treatment facility, a surface impoundment, an injection well, a
hazardous waste long-term storage facility or a surface storage facility.
14. Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such
as a city or town.
15. Overburden
Any material of any nature,consolidated or unconsolidated,that overlies a mineral
deposit,excluding topsoil or similar naturally-occurring surface materials that are not
disturbed by mining operations.
16. Permittee
The owner or operator issued a permit pursuant to this individual permit.
17. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including,but not specifically limited
to, any pipe, ditch,channel,tunnel,conduit,well, or discrete fissure from which
stormwater is or may be discharged to waters of the state.
19. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours in which no storm event measuring greater than 0.1 inches has occurred. A single storm
event may contain up to 10 consecutive hours of no precipitation. For example,if it rains for 2
hours without producing any collectable discharge, and then stops, a sample may be collected if a
rain producing a discharge begins again within the next 10 hours.
19. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is
representative of the discharges at multiple outfalls, the DWQ may grant representative
outfall status. Representative outfall status allows the permittee to perform analytical
monitoring at a reduced number of outfalls.
Part VI Page 3 of 6 Pages

Permit No.NCS000105
• 32. Upset
Means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the permittee. An upset does not include
noncompliance to the extent caused by operational error, improperly designed treatment
or control facilities, inadequate treatment or control facilities, lack of preventive
maintenance, or careless or improper operation.
33. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs,painting,fueling, lubrication, vehicle cleaning
operations, or airport deicing operations.
34. Visible Sedimentation
Solid particulate matter,both mineral and organic,that has been or is being transported
by water, air, gravity, or ice from its site of origin which can be seen with the unaided
eye.
35. 25-year, 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the
average, once in 25 years.
Part VI Page 6 of 6 Pages

NORTH CAROLING DEPARTMEPTOF
a�„I yyC4 ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
�rINCDE�R �x
March 23, 2000
HUNTJR;
S. GOVERNOR
s, . Mr. Derric Brown
" . ,v. Blue Ridge Paper Products
, ♦� Canton Mill
we�Y�NF- -DEVIT,T: Post Office Box 4000
Ci�E RE- cs
7A Y Canton, North Carolina 28716
I t 8A�a s `sue a 7 Subject: Compliance Sampling Inspection
� ...>
ty RR�T SgTEVEN9' ;W^l
Blue Ridge Paper
`1]YRS
5 ' Canton Mill WWTP
NPDES Permit No. NC0000272
�aywood County
IN
i Dear Mr. Brown:
1 1 3
� ,�,• � ti ,� Please find attached an inspection report for the
°3 Compliance Sampling Inspection which I performed at your
E •t' .;"y facility on February 24, 2000 .
1
� - Should you have any questions concerning the Report,
y' } �� _ + please do not hesitate to contact me at 251-6208 . The.
+f t
�..•.+.�; assistance provided to me by all Mill personnel involved
during the inspection was greatly appreciated.
Sincerely,
yti»xNax y�
q4 , D. Keith Hayn s
Environmental Specialist
Attachment
t;���•;' '��.w� � xC RtIIgZ:r-�, EPA
llS � .•+h .y '} INTERCHANGE BUILDING• 59 WOODFIN PLACE, ASHEVILLE• NG 28801-2414
PHONE 828-2SI-6208 FAX 828-2S1-6452
¢¢Tr gu•f "tst'�y' •"6t'^'-•'�3" AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - SO°n' RECYCLED/10q POST-CONSUMER PAPER

United States Environmental Protection Agency Form Approved
Washington, D.C.20460 OMB No. 2040-0003
Approval Expires 7-31-85
PA NPDES Compliance Inspection Report
Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
I IN 1 2 u 3 1 NC0000272 11 12 00/02/24 117 18 IC 1 19 U 2012
u Remarks
I I I I I I I I I I I I I I I I I I I I I I I I I I I
' Reserved Facility Evaluation Rating BI QA Reserved
67 L 69 70
71 on 72 at 73 L_IW I 174 75 LLLI_]_J_]80
Section B: Facility Date
Jame and Location of Facility Inspected Entry Time Permit Effective Date
3lue Ridge Paper Products 9:30 am 970101
-anton Mill
-anton, Haywood County Exit Time/Date Permit Expiration Date
11:30 pm 011130
4ame(s)of On-Site Representative(s)/Title(s) Phone No(s)
Derric Brown -Environ. Supervisor 828-646-2318
Jame,Address of Responsible Official Title
Ar. George Henson Vice-President/Operations Mgr.
'0 Box 700
-anton, NC 28716 Phone No. Contacted
No
section C:Areas Evaluated During Inspection CODES nr S•Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated/Not applicable
S Permit S Flow Measurement $ Pretreatment $ Operations &Maintenance
$ Records/Reports $ Laboratory $ Compliance Schedules $ Sludge Disposal
$ Facility Site Review $ Effluent/Receiving Waters S Self-Monitoring Program Other:
Section D:Summary of Findings/Comments (Attach additional sheets if necessary)
:(fluent Data Permit Limits(Daily Avg/Mon Ave)
10D, — 5.3 mg/I 30.0 mg/I- 45.0 mg/I
'SS — 11.0 mg/I 30.0 mg/I- 45.0 mg/I
'rimary clarifier#1 was not in operation, it is now used as pan of the spill contention plan. Three of the four aeration basins were in operation, with the other
me in the digester mode. The remainder of the plant was in full operation. The Parshall Flume/flow meter was calibrated on the day of this inspection and is
outinely calibrated quarterly. Effluent flow at the time of sampling was 23 MGD. Maintenance records are kept by computer in the treatment maintenance shop.
All sampler refrigeration units were operating at or below the proper temperature.
4ame(s)and Signature ) of spector(s) Agency/Office/Telephone Date
). Keith Haynes
DWQ/ARO 828-251-6208 ba�3�3
signature of Rev' er Agency/Office Date
DWQ/ARO '828-251-6208 ;13 Mi✓QO
Regulatory Office Use Only
tction Taken l Date Compliance Status
Noncompliance
Compliance

NORTH CAROLINA DEPARTMItNT OF
'Y- ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY.
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
N�DE�RX 3
December 1, 1999
M:'DAMES B.HUNTJR. y3
S°:GOVERNOR
Mr. Derric Brown
Blue Ridge Paper Products Inc.
Sid ^ E DEYt^ I` 175 Main Street
�g
SEORETA Y C`+'S
.- -1 P.O. Box 4000
,. ^' Canton, North Carolina 28716
�, e Subject: Tax Certifications
�µ TCS-502 and TCS-401
yd 'Ra , Blue Ridge Paper Products
t r
NPDES Permit No . NC0000272
Haywood County
, T Dear Mr. Brown:
This letter is to advise you that the subject tax
certifications issued to Champion International on July 25,
1995 and March 31, 1992 can be transferred to Blue Ridge
t Paper Products Inc.
If you have any questions concerning this matter,
4 please do not hesitate to contact me at 251-6208 .
-' Environmental Specialist
�s xc: Haywood County Tax Collector
� I• .Y� y,. �'•M' � INTERCHANGE BUILDING, 50 WOOCFIN PLACE, ASHEVILLE, NC 28 80 1-24 1 4
PHONE [phone] FAX828-2S1-64S2
�t"'� AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/IO% POST-CONSUMER PAPER

Making(Our mark for you.
VX BLUE RIDGE PAPER PRODUCTS INC. /r/lee
November 11,1999
Mr. Forrest Westall
North Carolina Department
Environmental and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
Re: Tax Certification
Blue Ridge Paper Products Inc.
Canton,North Carolina
Dear Mr. Westall:
Attached are Tax Certifications issued to Champion International Corporation by the North
Carolina Department of Enviroiunent and Natural Resources, Division of Environmental
Management for wastewater treatment facilities. Tax Certification was issued for wastewater
treatment facilities in 1992 and 1995.
As you know, Champion International Corporation sold the Canton Mill to Blue Ridge Paper
Products Inc., on May 14, 1999. We are requesting a written confirmation that these Tax
Certifications transfer from Champion to Blue Ridge Paper Products Inc.
If you have any questions or need additional information please call me at(828) 646-2318.
Sincerely,
Derric Brown
attachments
r
1 5 1999ALITY SEOTION 175MainStreet P.O.Box4000 Canton, North Carolina 28716 828-646-2000
REGIONAI nrricr 1

LIST OF ATTACHMENTS
Attachment Description Certificate # Permit#
Attachment I Waste Treatment Plant Work TCS502 NC0000272
Attachment II Water Pollution Control Facilities TCS401 NC0000272

ATTACHMENT I
POLLLTION CONTROL
TAX CERTIFICATES
CERTIFICATE, # TCS502
PERMIT # NC0000272

State of North Carolina
Department of Environment,
Health and Natural Resources 4 •
Division of Environmental Management A&t
_
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary F1
A. Preston Howard, Jr., P.E., Director
July 25, 1995
0
, 0 1995
Mr. Derric Brown, Environmental Supervisor [
Champion International - Canton Mill
Box C-10
Canton, North Carolina 28716
Subject : Tax Certification
Champion - Canton Mill WWTP
Waste Treatment Facilities
Haywood County
Dear Mr. Brown:
Transmitted herewith is Tax Certification Number TCS502
covering the construction and operation of wastewater treatment
facilities at Champion' s Canton Mill, as described in the subject
document .
The Company may use this Certification to obtain tax benefits
in keeping with the appropriate Statutes . Detailed descriptions of
these wastewater treatment facilities are available in the files of
the Division of Environmental Management .
Sincerely, D
A. Preston Howard, Jr. , P.E.
Enclosure
c : Haywood County Tax Collector
Keith Haynes
P.O. Box 29535,Raleigh,North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 60%recycled/10%post-consumer paper

. o
LAU:G0 3 1995
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL REsdtM=V---" ..""•"°®'°�
RALEIGH
TAX CERTIFICATION
(Franchise/privilege; Amortization; Property)
In accordance with the provisions of the General Statutes of North
Carolina (G. S> 105-122 (d) , 105-130 . 10, 105-147 (13) , 105-275 (8 ) , this is
to certify that :
Champion International Corporation
Canton Mill
Haywood County
HAS BEEN ISSUED
Authorization to Construct/NPDES Permit Number NC0000272 for
installation and continued operation of wastewater treatment/disposal
equipment at the Champion International-Canton Mill as described below:
(1) grit chamber, bar screens, lowlift pumps, Carbon Dioxide pH
control, flow splitting station, one (1) 125 ' diameter clarifier,
two (2) 200 ' diameter clarifiers, Sulphuric acid pH control,
nutrient feed, Calcium Carbonate addition, two (2) 2 . 3 million
gallon aeration basins/digesters, two (2) 3. 4 million gallon
aeration basins, polymer addition, on-line respiratory system, one
(1) 150 ' diameter clarifier, two (2) 200 ' diameter clarifiers, 8"
flume, oxygen for reaeration and four (4) belt presses and
associated modifications related to the Canton Modernization
Project .
(2) Bleached Filtrate Recycle (BFRTM) demonstration project .
The Environmental Management Commission and the Department of
Environment, Health, and Natural Resources have found that the
facility:
a. has been constructed or installed;
b. complies with the requirements of the Commission;
C. is being effectively operated in accordance with the terms
and conditions of the permit, certificate of approval, or
other document of approval issued by the Commission; and
d. has as its primary rather than incidental purpose the
reduction of water pollution resulting from the discharge of
sewage and waste.

Issued at Raleigh, North Carolina, this the I "T day of
by the Director of the North Carolina Environmental Management
Commission and the North Carolina Department of Environment, Health,
and Natural Resources.
A. Preston Howard, Jr. , P. E.
Director
Division of Environmental Management

ATTACHMENT II
POLLUTION CONTROL
TAX CERTIFICATES
Water Pollution Control Facilities
CERTIFICATE # TCS-401
PERM T# NCO000272

��a RECEIVED APR 0 1 1992
Jt.
State of North Carolina
Department of Environment, Health, and Natural Resources
Asheville Regional Office
James G. Martin, Governor Ann B. Orr
William W. Cobey, Jr., Secretary Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 31, 1992
Mr. Derric Brown
Environmental Supervisor
Champion International
Canton Mill
Canton, North Carolina 28716
Subject: Tax Certification Number TCS-401
Champion International
Water Pollution Control Facilities
Haywood County, North Carolina
Dear Mr. Brown:
Transmitted herewith is one copy of a Tax Certification for water
pollution control facilities being constructed as part of the Canton
Mill Modernization project required under NPDES Permit Number NC0000272 ;
effective October 25, 1989 .
This Certification may be used to obtain tax benefits in keeping
with the General Statutes of North Carolina. Should you wish to discuss
this matter in more detail, please do not hesitate to contact me.
Sincerely,
Roy M. Davis, Regional Supervisor
Division of Environmental Management
Enclosure
xc: George Everett
Harlan Britt
Steve W. Tedder
Interchange Building, 59 Woodfin Place,Asheville, N.C. 28801 •Telephone 704-251b208
An Equal Oppommiry Affirmative Action Employer

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
T A X C E R T I F I C A T I O N
(Franchise/privilege; Amortization; Ad Valorem)
In accordance with the provisions of the General Statutes of North
Carolina (G. S. 105-122(d) , 105-130. 10, 105-147( 13 ) , 105-275(8) (a) this
is to certify that
Champion International
Canton, North Carolina
has been issued NPDES Permit Number NC0000272 for the construction and
operation of an industrial water pollution control facility. This permit
requires equipment modification to the manufacturing process to cause
the total daily wastewater flow through the treatment facility to be
reduced from 48. 5 MGD to 29 MGD, plus cause reduction in color,
chloroform, dioxin and total suspended solids. This inplant
reconstruction is also directed toward providing compliance with
effluent toxicity requirements as well as continued compliance with the
instream temperature variance issued by the North Carolina Environmental
Management Commission.
Construction approved in this Tax Certification includes ( 1) the MILL
WATER SYSTEM which provides for a new three-cell cooling tower and basin
and appurtenances (pumps, tanks, piping & distribution, pressure
controls, and electrical & instrument equipment) , (2 ) PAPER MACHINE
WATER CONSERVATION system to provide filtering and/or cleaning equipment
necessary to allow reuse of existing white water streams (primarily
machines No 11 & 12 ) and necessary equipment to reduce and control heat
loss (flow and temperature compliance) , (3 ) the CHEMICAL SYSTEM (for
color reduction) which provides for elimination of the chlorine and
hypochlorite bleaches with an oxygen delignification system and includes
all facilities necessary for handling, storage and distribution of
oxygen including oxidation of white liquor also used in the oxygen
delignification process (includes modification of the existing chlorine
dioxide generator and chilled water supply system plus construction of a
new cooling tower and mechanical chiller) , (4) the BLACK LIQUOR
EVAPORATORS (two sets rebuilt) and associated equipment including
storage and controls for prevention of chemical losses as well as color
and heat reduction, (5) the CAUSTICIZING EQUIPMENT to include
construction of a new drum-type dregs washer and associated equipment
for control of chemical loss and flow reduction and (6) Modifications to
the No. 2 FIBER LINE (PINE) and No. 1 FIBER LINE (HARDWOOD) necessary to
guarantee successful operation of the oxygen delignification system to
include reactors, pressurized screens, pulp washers, deknotters, and all
other equipment which would be necessary for flow reduction, color
removal, chloroform and dioxin minimization required by the NPDES permit
( structures or buildings, vats, bleaching towers, and equipment needed
to house and facilitate operation of the paper making process and not
exclusively for NPDES permit compliance are excluded from this Tax
Certification) .

Page 2
Tax Certification TCS-401
Wastewater from this reconstructed manufacturing process will continue
to be treated in the existing wastewater treatment facility owned by
Champion International and operated under the provisions of NPDES permit
Number NC0000272 with discharge to the Pigeon River in the French Broad
River Basin.
The Environmental Management Commission and the Department of
Environment, Health and Natural Resources have found that modifications
to the industrial water pollution control program:
1 . are presently under construction,
2 . comply with the requirements of NPDES Permit Number NC0000272
as issued by the Environmental Protection Agency with an
effective date of October 25, 1989, and requirements of the
Environmental Management Commission with respect to reduction
and/or prevention of water pollution; and
3 . has as its primary rather than incidental purpose the
prevention and reduction of water pollution from the
paper manufacturing process .
Issued at Asheville, North Carolina, this the�1yday of on 1992
By Direction of the Environmental Management Commission and the
Department of Environment, Health, and Natural Resources.
C9�
—R-a"
Roy M. Davis, Regional Supervisor
Division of Environmental Management
TCS-401

4A
Making(Our mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
October 5,1999
Mr.Forrest Westall
North Carolina Department
Environmental and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
Re: NPDES Permit NC0000272
Blue Ridge Paper Products Inc.
No.19 Paper Machine Improvement Project
Mr.Westall:
Blue Ridge Paper Products Inc., (BRPP),Canton,North Carolina Facility,NPDES Permit No. NC0000272,
is notifying you of planned improvements to No. 19 Paper Machine. The improvements will involve the
replacement of the paper machine's second press with a press of different design and the replacement of
the calendar stacks with two calendar nips. In addition, non-contact cooling towers will be installed to
minimize fresh water usage. The improvements will enhance both product quality and yield and the
paper machine will be able to process lighter weight products at maximum production rates. The No.19
Paper Machine annual calendar day production rate is projected to be less than 1,000 air dried tons of
finished product per day.
This project includes no physical or operational changes that would increase the mills current pulp
production capacity. Therefore, there will be no additional color loading resulting from this project The
current maximum annual average production capacity of the pulp mill is not sufficient to supply all four
paper machines. The Canton Mill has purchased an average of approximately 39,000 tons of dry
furnished pulp per year for each of the last six years to supplement on-site pulp production and supply
the paper machines. The pulp mill will continue to nm as efficiently as possible, but additional dry
furnish purchases will be necessary to support production at the paper machines.
Blue Ridge Paper Products Inc., is not requesting any revisions or modifications to the NPDES Permit
effluent limitations, monitoring requirements, or other conditions. Completion of the No.19 Paper
Machine Project will result in continued full compliance with the Settlement Agreement, Color Variance
and NPDES Permit
If you have any questions or need additional information please contact me at(828) 646-2033.
Sincerely,
Robert V.Williams
Director,Environmental,Health&Safety Affairs
175 Main Street • P.O.Box 4000 • Canton, North Carolina 28716 • 828-646-2000

BLUE RIDGE PAPER PRODUCTS INC.
xc: Mr. Don Anderson
U.S. Environmental Protection Agency
Mail Code 4303
Room 915A, East Tower
401 M Street,SW
Washington, D.C. 20460

Fax Message From :
Nov 1 '99 10:34
Name: DPJ WATER UJALITY
Fax Number: 9197155637
NCDENR - DIV OF WATER Planning Branch

DIV WATER QUALITY Fax:[phone] Nov 1 '99 10:34 P.01
"r a
Division of Water Quality
Water Quality PlanWng Emuch
1617 MAII.SERVICE CENTER
RaWgh,NC 27699-1617
FAX: [phone]
DATE:
TO: 6wrPSt We.l �rA FAX NUM
FROM
PHONE NKJ1VffiER:(919)733-,5083 extension:
3S i
J
No.OF PAGES(u„r ,ns this
sheet) -
CONDWENTs: V
�s� e-�A-. .,..n��, cam--• �"aa �-- �,,, l�a..c.�C
NOV _ 1 •
, 19,99 o .
ASyEV�R(QRfC10 SfCTIp
a�

DIV WATER OI.WLITY Fax:[phone] Nov 1 '99 10:34 P.02
One segment of both the Pigeon River and Richland Creek are listed as impaired based on recent
DWQ monitoring data. Both of these waters are presented and discussed below in Part 5.3.L
These waters are also on the state's year 2000(not yet EPA approved)303(d)list(see Part 5.3.2).
53.1 . Monitored Impaired Waters
Figeou]rover(7.0 miles from Canton water supply intake to Clyde to SR 1642)
This section of the Pigeon River is listed as impaired(PS)duo to both point source impacts from
the Blue Ridge Paper Products(formerly Champion International)and nonpoint sour ces-
2000 Recommendation(s)
This station has been sampled nine times since 1984. A Good-Fair rating for benthic
macroinvertebrates was recorded during the summer of 1997 for the Pigeon River for the first
time at Clyde,while the Hepco site above Walters Lake continued to have a Good-Fair
bioclassification. A Good rating at the state fine was found in 1994 and 1997. Fish sampling by
TVA biologists in the Pigeon River in 1990, 1995 and 1997 has shown some limited recovery
over time below BRPP discharge. however,the fish community below the plant was assigned
Fair or Poor ratings in 1995-1997.
Note: Most gent DWQ data indicate the hugs were on the edge between a G-F and Fair
rating. A decision was made to tall tbis streteb impaired. The river has improved
dramatically over the last 15 pears,but clearly there are still impacts from Champion. To
assure ourselves that this stretch of river should still really be called impaired,an
additional sampling effort will take place iva October at this site and possible upstream
sites. This section:of the plant will be completed after the resamplimg is dome and in time for
public review.
DWQ analyzed mercury concentrations in fish tissue at five Pigeon River sites during 1996,but
none of these samples bad levels over FDA or EPA criteria. Annual fish tissue monitoring for
dioxins in the Pigeon River is also performed by Blue Ridge Paper Products and Carolina Power
and Light. This monitoring is required as part of the Champion International NPDES permit
issued by DWQ and as a condition of the EERC license for Carolina Power and light.
By 1994,Champion completed a modernization program that included replacing chlorine as a
bleaching agent to ensure dioxin would no longer be a by-product within the effluent. Dioxin
concentrations in fish collected from the Pigeon River and Walters Lake have generally declined
since the early 1990's,although levels for certain species have fluctuated depending on sample
season,station,and the size of the fish collected Dioxin concentrations in sportfishes(redbreast
sunfish,rock bass,crappie,largemouth and smallmouth bass)have remained non-detectable or
well below the North Carolina limit for issuing a consumption advisory(3.0 ppt). Dioxin levels
in carp have decreased as much as 80%downstream of the BRPP facility.but remain above the
North Carolina limit in Walter's Lake(see Figure B-K&and B- )_
Section B: Chapter 5—French Broad River SLbbarin 04-03-05 92

DIV WATER OLPLITe Fax:[phone] Nov 1 '99 10:35 P.03
Currently,there is a limited consumption advisory for common carp and ash species(bullhead
species,channel catfish,and flathead catfish)in effect for the Pigeon River between Canton and
the North Carolina-Tennessee state line,including Walters Take. Due to declining dioxin levels,
this advisory was revised by the State health Director from a no-consumption to a limited-
consumption advisory in September 1994. Additionally, there is a limited-consumption advisory
for common carp,catfish species,and redbreast sw6sh in affect for the Pigeon River within the
State of Tennessee from the North Carolina-Tennessee state line downstream to the confluence
with the French Broad River. D WQ submitted a TMDL(see Part 53.2)for dioxins in Waterville
Lake and the Pigeon River to SPA in fall of 1999.
Figure B-XX—TCDD concentrations in carp from Pigeon River(pg 13 of ESB report)
Fgure B XXX-TCDD concentrations in carp from Walters Lake(pg 13 of ESB report)
The Champion International facility has made several improvements to manufacturing processes.
Champion(now Blue Ridge Paper Products(BRPP))has spent more than$300 million
upgrading its manufacturing process since 1990. Additional improvements were made in 1996
and 1997. These improvements in wastewater treatment at the BRPP facility are associated with
a gradual improvement in macroinvertebrate bioclassitications over the years.
A Settlement Agreement was reached in 1997 on a modified color variance and NPDES permit
between EPA,the States of NC and TN,Cocke County and the City of Newport,TN,Tennessee
Environmental Council,American Canoe Association and Champion International. The intent of
the Agreement was to resolve the Pigeon River color issue without litigation. The parties
involved in the ensuing discussions,agreed to many measures to achieve color reduction over the
life of the NFDES permit. In accordance with this agreement,Champion began installing a full-
scale BIeach Filtrate Recycle(BFR". technology on the mill's pine line. Champion also began
to evaluate the potential for additional minimization of color and report these findings on a pre-
defined schedule to DWQ and others. Opportunities for preventing and controlling measurable
leaks and spills through BMPs were also to be addressed. Champion was to achieve a true color
loading not to exceed an annual average load of 60,000 lbs/day,a monthly average true color of
69,000 lbs/day,and a maximum monthly color average of 50 true color units at the NC-TN state
line(it was further agreed that the 50 color units should be.met at Ilepco). Champion further
agreed to target annual average color loading of 48,000-52,000 lbs/day by May 1,2001.
A Technology Review Workgroup was formed to monitor Champion's achievements. To date,
this Workgroup has received reports from Champion International on the following progress:
• the(BFR")demonstration on the softwood fiber line has been installed with no problems
• all of the BMP projects as required in the agreement were completed and operational
Section B: Chapter 5—French Broad River Subbasin 04-03.05 93

DIV WATER QUWLITY Fax:[phone] Nov 1 '99 10:36 P.04
• additional color reduction measures were completed and others are ongoing
contingency'plans for low-flow periods were in place and operational
As reported to the Workgroup in January 1999,monitoring confirms the daily average of color
discharge is well below the limits set forth in the Agreement. The mill's end-of-pipe true color
report shows the facility was discharging approximately 10,000lb1aay of color below the limit
requited in the Agreement: The facility has reached the 2001 target for color loading. The color
in the Pigeon River was below the limit at Hepco for the reporting period in 1998. The
Workgroup therefore believes that Champion is mialdng substantial and continuous progress in
reducing the amount of color generated and discharged to the Pigeon River and has met the
conditions of the Agreement. Additional technologies are yet to be installed and further
operational progress is anticipated Figme B-XXX illustrates Champion's success in reducing
color discharges;to the Pigeon River since 1988,including monthly average performance for
1998.
Figure B-XXX
Forrest-Please add a short piece on the Joint Watershed Advisory Committee. I am still
not quite clear on the functions of this committee as opposed to the Workgroup.
Section B- Chapter 5—Fe-ch B.nad Juver$ubbasm 04.03-05 94

v +•��ai Cc_oration
May i. 1999
Mr. Bradic,. Bennett
State of North Carolina
Department or'Environment and Natural Resources
Division of Water Quality
Permits and Engineering Unit
P. O. Box =94 35
Raleigh. NC '7626-0535
Re: Ownership Change; Stormwater Permit No. NCS000105
Dear Mr. Bennett:
On \lay 1.3. 1999. Champion International Corporation ("Champion") will transfer
ownership of its facility in Canton. North Carolina (Haywood County) to a new owner, Blue
Ridge Paper Products Inc. Champion hereby requests a transfer of Stormwater Permit No.
NCS000105. Blue Ridge Paper Products Inc. will continue to operate the facility in the same
manner as Champion and will operate without interruption. Furthermore. Blue Ridge Paper
Products Inc. %ill continue to comply with the current permit requirements.
Please rind enclosed the following documents:
I. Water Quality Section Permit Name/Ownership Change Form
2. 5100.00 processing fee
Upon completion of the ownership transfer, Blue Ridge Paper Products Inc. will
forward a copy of the deed transferring the facility from Champion to Blue Ridge Paper
Products Inc.
Thant: you for your attention to this matter.
Sincerely,
Richa tforio, Jr.
Senior ice President - Environmental,
Health and Safety
Enclosure Champion International Corporation

Department of Environment,
Health and Natural f ai management
fllvls(on ot•Environmentaf Management
James s. Hunt, Jr., Governor s
Jonathan B. Howes, Secretary h"r
A. Preston Howard, Jr., P.E., 01rector ® � ` V �•.
WATER QUALITY SECTION
PF.Rh7IT NAM /OWNFR4HTP HANr,F FoRm
I. ('i1RRFNT PFRMTT 1NFnRMA77M-
CrR'.:C litilDCr: N e 5 0 0 0 1 0 5
I• PG-mit holder's name• 0- r- .07on Sn ern��;onc\ L'or pore fro.�
2. Permit's signing offidal's acme and title
(e=oa legally responsible for permit)
Vice- l�res',den� - Operc.�rone rnona er
(Title)
3. Mailing Address: ?• O• 4 00 0
Car, an�-on
SL=. Z8-11 to
TAP Code Phone.f a ZS 1 (0 4 (v Z8 4 0
•IL NF«• QWNFR/NA'%4F INFORMATMOEN
1. Tnis request fora name change is a result of:
�a C:'angcin ownership of PrnPerry/company
b. Name change only
_c••Other(please explain)-
2- New owner's name(name to be put on permit)-,_ e R;�4 e �c.o er Pro acts Inc.
3. New owner's or signing official's name and title: C90raon 3ones
(Poison legally resporsible for permiQ
(2.W.e� Execj�:�je O ;cec
4. Mailing address: ?- 0. -,�)0x 4000 (Idle)
City eG,n�-o n
State: —N L Tp code••?S'} 1 (c Phone: t 8IS) Gy(0- ZS 4 0

PERMIT NAME/OWNERSHIP CHANGE FORM
THIS APPLICATION PACKAGE WILL-NOT BE ACCEPTED BY THE DIVISION OF
ENVIRONMENTAL MANAGEhfENT"UNLESS ALL OF THE APPLICABLE ITEMS
LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED 17I41S:
1. This completed application
2. Proocssing fa of SI00.00 (Chce1-s to be made payable to DEHNRT
3. If an ownership change,legal doivmentation of the transfer of ownership (such as a contract,deed,
articles of incorporation)
CERTIFICATION MIST BE COMPLETED AND SIGNED BY BOTTI THE CURRENT
PERMIT HOLDER AND THE NEW APPLICANT IN THE CASE OF CHANGE OF
OWNERSHIP. FOR NAME CHANGE ONLY COMPLETE AND SIGN THE
APPLICANT'S CERTIFICATION. '
Current Permittee's Certification-.
L-121Cc�a,e0 J. D I t^orQiO J r attest that this application for name%wn=bip change has been
reviewed and is accurate an p to,to the beat of my knowledge. I understand that if all required parts
of this application are n mple that if all rcquitsd supporting info on and attachments ere not
included this S be return incomplete.
Signature• Date. ,
Applicant's Certification:
attest that this application for a name/ownership change has been
renewed and is accurate and complete to the best of my knowledge. I understand that if all requited pats
of this anplicatioh are not oPmpleted and that if all requited supporting information and ahxhments are not
included,this cal do p ge will be rutumed as incomplete.
Signatu4c- Dare: 5�11 l qq
THE COMPLETED APPLI ATION PACKAGE,INCLUDING ALL SUPPORTING INFORMATION
AND MATERIALS,SHOULD BE SENT TO THE FOLLOWING ADDRESS:
North Carolina Division of Environmental Management
Water Quality Section
Permits and Engineering Unit
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Telephone: (919) 733.5083
Fax: (919) 733-0719

=cr. -'_rnauonai Ccmc.at:or.
May 7. 1999
Mr. Charles Weaver
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
Permits and Engineering Unit
P. O. Box 29535
Raleigh, NC 27626-0535
Re: Ownership Change; NPDES Permit No. NC0000272
Dear Mr. % eaver:
On May I3. 19999 Champion International Corporation ("Champion') will transfer
ownership of its facility in Canton. North Carolina (Haywood County) to a new owner. Blue
Ridge Paper Products Inc. Champion hereby requests a transfer of NPDES Permit No.
NC0000272 including all variances previously granted. Blue Ridge Paper Products Inc. will
continue to operate the facility in the same manner as Champion and will operate without
interruption. Furthermore. Blue Ridge Paper Products Inc. will continue to comply with the
current permit requirements.
Please find enclosed the following documents:
1. Water Quality Section Permit NameiOwnership Change Form
2. S 100.00 processing fee
Upon completion of the ownership transfer. Blue Ridge Paper Products Inc. will
forward a copy of the deed transferring the facility from Champion to Blue Ridge Paper
Products Inc.
Thank you for your attention to this matter.
Sincerely.
2L��IZ
Rich iforio, Jr.
Senior ice President - Environmental,
Health and Safety
Enclosure Champion International Corporation

Department of Environment,
Health and Natural Resources � 0 a
fllvlslon of.Environmental Management
James e. Hunt, Jr., Governor .,�.��
Jonathan E. Howes, Secretary CC
A. Preston Howard, Jr., P.E., Dfrector ® C" N [ = •
WATER QUALITY SECTION
PER ITT NAM ./OWNRRSHTP CH'ANf F FnnM
I. r'[1RRF.NT PFRT.fTT YNFOR}t"0.TT{y1jt
ermitNomocr I N C a o 0 o 12 4 2
I. Permit holder's name,* 0.kc',. 0;0., =n}ernes}Iona\ eor�orc F on
I Permit's signing official's name and.title,• W'�W�c -„ R . 'M o,n 3 e.,r
(Pelson legally responsible for permit)
_ �l�C2 - �res;G2n} OperC.}ro�5 Man4ger
(Title)
3. Mailing address: O• fox 4o0o Cit}^ Title)
State: N LT+p Code. S l fo phone:
•IL NE«' QNVNFRlNAMt rucnnijA=
I. This request for a name change is a result of
X rt Changc•in ownership of property/company
`b. Name change only
_c- 'Other(please explainh
2. New owner's name (name to be put on permit):_ Plop- -P:cl$e F6,!R r 7F raLC, s Tne
3. New owner's orsigning official's nave and title: Caorclon hones
Werson legally responsible for permit)
Execjv;,Ie OJW;cer
4. Mailing address: ?• O• 'Box 4000 i� Cl+up)
City: n•4o r,
State:—N L Tp Code; a 81 S to Phone: { S 2S 1 G 4 ro- 2514 0

PERMIT NAMF/0WNFR41IP HAN F E=
TMS APPLICATION PACKAGE WILL-NOT BE ACCEPTED BY THE DIVISION OF
ENVIRONMENTAL MANAGEMENT UNLESS ALL OF THE APPLICABLE ITEMS
LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS:
L This completed application
2- Pzoccssing fcc of S100.00 (Checks to be made payable to DEHNR)
3. If as o�vership change,legal dccumcntalion cf the transfer of ownership (suds as a contract,deed,
a:[icles of incorporation)
CERTIFICATION MUST BE COMPLETED AND SIGNED By BOTH THE CURRENT
PERMIT HOLDER AND THE NEW APPLICANT IN THE CASE OF CHANGE OF
OWNERSHIP. FOR NAME CHANGE ONLY COMPLETE AND SIGN THE
APPLICANT'S CERTIFICATION. '
Current Permittee's Certification:
�;C rt AQn )• DI o attest that this application for mamelownerahip change has been
reviewed aad is acc=== com etc to the best of my knowledge. I understand that if all rewired parts
of this application are t co I d that if all requited supporting information and aff non
included, this agp be return as incomplete. ts ert not
Signaa:re: Dom. 5 7
Applicant's %crtification.-
I' attest that this application for a name%wnership change has been
rcvrewed and rs arcuratc and compiate to the best of my knowledge. I understand that if all requited parts
Of this aaplicatidn are not completed and that if all required supporting information and attachments,are not
included, t 9p4c on package ri]I be returned as incomplete
n:Stgnarc' Date-
THE COMPLETED I PLICATION PACKAGE,INCLUDING ALL SUPPORTING INFORMATION
AND N ATEPdAIS,S OULD BE SENT TO THE FOLLOWING ADDRESS:
North Carolina Division of Environmental Management
Water Quality Section
Permits and Engineering Unit
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Telephone: (919) 733.SO83
Fax: (919) 733-0719

c"7 J. vPa.Jr.
Mav 7. 1999
-=_nonat Gc.-crarcr
Mr. Day id .-1. Goodrich
Department of Environment and Natural Resources
Division of Water Quality
NPDES Unit
P. O. Box 294z35
Raleigh. NC '7626-0535
Re: Ownership Change; Certificate of Coverage # NCG500151
Dear IMr. Goodrich:
On May 13. 1999. Champion International Corporation will transfer ownership of its
facility in Dair\-pak-Waynesville. North Carolina (Havwood Countv) to Blue Ridge Paper
Products Inc. Blue Ridge Paper Products Inc. hereby requests a transfer of the Certificate of
Coverage No. NCG500151 under NPDES General Permit No. NCG500000. The Blue Ridge
Paper Products Inc. will continue to operate the facility in the same manner as Champion
International Corporation and will operate without interruption. Furthermore, the Blue Ridge
Paper Products Inc. facility will continue to comply with the current permit requirements.
Please rind enclosed the following documents:
l. Water Quality Section Permit Name/Ownership Change Form
S 100.00 processing fee
Upon completion of the ownership transfer, Blue Ridge Paper Products Inc. will
forward a cope of the deed transferring the facility from Champion International Corporation
to Blue Ridge Paper Products Inc.
Thank ou for your attention to this matter.
Sincerely,
G don Jones Rich 0ifiorio. Jr.CEO Seniorresident - Environmental,
Blue Ridge Paper Products Inc. Health and Safety
Enclosures Champion International Corporation

Department of Environment.
Health and Natural Resources�Ivislon of•Environmental Managementyr;l
James B. Hunt, Jr., Governor r
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., 01rector © E ` V �•.
WATER QUALITY SECTION
PERMIT NAM /OVVNFRSHTP H'ANr`F Fnu�• .
I. CTTRRF.NT PFRMTT TNRnRMATTrr&;
erm:[humocr: M C G 5 0 0 2 5 2 '
I. Pam- eholaet'sname C�v "o rnjErnc,' O 4\ Coroof-g•1•;on
Z Permit's signing official's name snd title:
(PersoalegallyrespoturbI forpemut)
Iwlati nes�',11e 1?\C."r 'h'\o,,,o, er
(Title)
3. Mailing address: 13 2 9 Ika ze\1 MA\ 1Z000\ City W4M negv',\\ 2
State: NL zip cc&, 28:48(o. Phone:f8281
IL LiE«' OWNFRrNdlt. F TNFORh ATTON
I. This reruest for a name change is a result of:
-La' Change n ownashiP of Propeny/company
_b. Name change only
_c- •Other(please explain).
2. New owner's name (name to be put on permit);B\.J
3. New owner's or signing official's name and titter_ t��'•\\'•o �o n
(Person legally responsible for permit)
W ci.nesd;
4. Nfailing address; l3 Q ck �oae\\ M'•\\Rc� City; Wc�
State:__ - �- Tp('-ode: 28 18 fo Phone: { 8 Z81 G4

PERMIT NAv
TIIIS APPLICATION PACKAGE WILL-NOT BE ACCEPTED BY THE DIVISION OF
ENVIRONMENTAL MANAGEMENT-UNLESS ALL OF THE APPLICABLE ITEMS
LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED nj2a:
L This completed application
2. Pro=sing fee of S100.00 (Checks to be made payable to DEHNRT
3. If an ownership change,legal documentation of the ttansfa of ownership (such as a eootract,deed,
articles of incorporation)
CERTIFICATION MUST BE COMPLETED AND SIGNED EY BOTH THE CURRENT
PERMIT HOLDER AND THE NEW APPLICANT IN THE CASE OF CHANGE OF
OWNERSHIP. FOR NAME CHANGE ONLY COMPLETE AND SIGN THE
APPLICANT'S CERTIFICATION.
Current Permittee's Certification:
attest that this application for name/ownership change his b=n
reviewed and is accuratic and complete to the best of my knowledge. I understand that if all required parts
Of this applicarion_araaot c�otapleted'and that if all required supporting information and is are not
included,this application p, a will be returned as incomplete.
Signature: Ii Date: J 7
Applicant's Cc r ICrcation:
1• attest that this application for a nameJownership change has been
renewed and is accurate and complete to the best of my knowledge. I understand that if all required parts
Of this applicariotr are not completed and that if all required supporting information and attachments are not
included this ap�lic a pac!<age will be tetumed as incomplete.
Signature / / ✓ Daum 5/11/99
l
THE COMPLETED APPLICATION PACKAGE,INCLUDING ALL SUPPORTING INFORMATION
AND MATERIALS,SHOULD BE SENT TO THE FOLLOWING ADDRESS:
North Carolina Division of Environmental Management
Water Quality Section
Permits and Engineering Unit
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Telephone: (919) 733-5083
Fax: (919) 733-0719

F!Departmer
o of North Carolina
t of Environment
Natural Resources ���
Division of Water Quality
L
James B. Hunt, Jr., Governor N �,D E N R
Bill Holman, Secretary
Kerr T. Stevens, Director
October
Mr. Gordan Jones
Blue Ridge Paper Products,Inc. N
710 Howell Mill Road tER F
Waynesville, North Carolina 28786 SNEfw�``
S Permit Modification-Name and
Ownership Change
Blue Ridge Paper Products,Inc.
Permit No. NCG500151
(formerly Champion Intl-Waynesville Plant)
Haywood County
Dear Mr. Jones:
In accordance with your request received May 18, 1999, the Division is forwarding the subject
permit. The changes in this permit are only with regard to a name and an ownership. All other terms and
conditions in the original permit remain unchanged and in full effect. This permit modification is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U. S. Environmental Protection Agency dated December 6,
1983.
This permit does not affect the legal requirement to obtain other permits which may be required by
the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area
Management Act, or any other Federal or Local government permit that may be required.
If you have any questions concerning this permit,please contact Ms. Vanessa Wiggins at telephone
number [phone], extension 520.
Sincerely,
ORIGINAL SIGNED BY
WILLIAM C. MILLS
Kerr T.'Stevens
cc: Central Files
(Asheville Regtona'Office:,Water Quality Section —1
Stormwater and General Permits Unit
Point Source Compliance Unit
1 1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10%post-consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG500000
CERTIFICATE OF COVERAGE No. NCG500151
TO DISCHARGE NON-CONTACT WATER,COOLING TOWER AND BOILER BLOWDOWN,
CONDENSATE,EXEMPT STORMWATER,COOLING WATERS ASSOCIATED WITH HYDROELECTRIC
OPERATIONS, AND SIMILAR WASTEWATERS UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1,other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act,as amended,
Blue Ridge Paper Products,Inc.
is hereby authorized to discharge(non-contact cooling water from a facility located at
Blue Ridge Paper Products,Inc.
710 Howell Mill Road
Waynesville,NC
Haywood County
to receiving waters designated as subbasin 40305 in the French Broad River Basin
in accordance with the effluent limitations,monitoring requirements,and other conditions set forth in Parts I,II,III
and IV hereof.
This Certificate of Coverage shall become effective October 11, 1999.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day October 11, 1999.
ORIGINAL SIGNED BY
WILLIAM C. MILLS
Kerr T.Stevens,Director
Division of Water Quality
By Authority of the Environmental Management Commission

Making ur mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
August 18, 1999 l
Ira
pUG 1 91
Mr. Keith Haynes g1 vi SE IM'
Environmental Specialist WpSER REGMN OFFICE
NC Department of Natural Resources pSHE1IL�
Water Quality Section
59 Woodfin Place
Asheville, NC 28801
RE: Water Quality Data
Dear Keith:
As requested,please find attached water quality data for:
1) Monthly Average COD and Color
2) Primary Influent Color Balance
3) Secondary Effluent Color
If you have any questions on this information you can contact me at(828) 646-2033.
Sincerely, 1
ufmvwjg�
Robert V. Williams
Manager
Environmental Health&Safety
175 Main Street • P.O. Box 4000 • Canton, North Carolina 28716 • 828-646-2000

EOHS Dept. [phone] 8/17/99.
Monthly Average COD and Color: Jan 1998 -July 1999
Date COD mg/L Colorlbs/day
Jan-98 144 49,812
Feb-98 136 56,295
Mar-98 113 54,450
Apr-98 139 52,770
May-98 117 42,268
Jun-98 120 43,795
Jul-98 138 62,063
Aug-98 142 50,590
Sep-98 146 51,414
Oct-98 158 50,575.
Nov-98 178 68,542
Dec-98 101 42,073
Jan-99 94.3 41,419
Feb-99 102 39,635
Mar-99 98.4 42,846
Apr-99 96.5 37,676'
May-99 118 42,608
Jun-99 78.3 36,688
Primary Influent Color Balance: January 1999 - June 1999
Lbs/day % of Total
Digesters, No. 1 FL (Hardwood) 6570 12.04%
No.1/2 Eo, No.2 FL (Pine) BSW,OZ Delig. 12222 22.41%
Paper Machines- 11 & 12 2015 3.69%
Recovery, BLO,CRP 13279 24.34%
1&2 FL's D1 + Pine D2 (Bleach Plants) 15797 28.96%
Evaporator Condensates 2786 5.10%
Unaccounted (sewer generated) 1879 3.45%
Blue Ridge Paper Products, Inc.
Canton, NC

EOHS Dept. [phone] Color Data 8117/99
Date SE Col. Ibs/day Date SE Col. Ibs/day Date SE Col. Ibs/day Date SE Col. Ibs/day
01-Jan-98 44,719 20-Feb-98 53,050 11-Apr-98 42,878 31-May-98 31,972
02-Jan-98 47,082 21-Feb-98 47,835 12-Apr-98 42,152 01-Jun-981 50,353
03-Jan-98 37,485 22-Feb-98 51,03E 13-Apr-98 37,094 02-Jun-981 24,743
04-Jan-98 38,594 23-Feb-98 63,195 14-Apr-98 35,4891 03-Jun-981 31,274
05-Jan-98 47,890 24-Feb-98 59,361 15-Apr-98 35,043 04-Jun-981 32,822
06-Jan-98 55,827 25-Feb-98 54,284 16-Apr-98 44,8441 05-Jun-981 30,607
07-Jan-98 69,034 26-Feb-98 50,852 17-Apr-98 46,622 06-Jun-98 27,431
08-Jan-96� 61,153 27-Feb-98 45,363 18-Apr-98 46,685 07-Jun-98 33,534
09-Jan-98 47,677 28-Feb-98 45,163 19-Apr-98 48,044 08-Jun-981 37,924
10-Jan-98) 46,0351 01-Mar-981 42,799 20-Apr-981 58,992 09-Jun-98 55,326
11-Jan-98 47,149 02-Mar-98 99,714 21-Apr-98( 231,862 10_Jun-981 56,859
12-Jan-98 45,758 03-Mar-981 233,853 22-Apr-981 126,3271 11-Jun-981 56,812
13-Jan-98 46,054 04-Mar-981 139,842 23-Apr-981 71,6941 12-Jun-98 45,092
14-Jan-98) 44,722 05-Mar-98 57,533 24-Apr-98 51,041 13-Jun-98 46,856
15-Jan-98 43,239 06-Mar-98 42,3391 25-Apr-98 44,853 14-Jun-98 47,964
16-Jan-98 52,810 07-Mar-98 37,266 5- PE-
37,881 15-Jun-98 47,560
17-Jan-981 49,9451 2 -Mar-98 34,101 27-Apr-98 40,5641 16-Jun-98 46,841
18-Jan-98 43,4081 09-Mar-98 39,289 28-Apr-98 42,698 17-Jun-98 55,485
19-Jan-98E 52,5071 10-Mar-98 42,681 29-Apr-98 50,539 18-Jun-98 41,362
t22-J
Jan-98f 52,9051 11-Mar-981 48,6441 30-Apr-981 44,254 19-Jun-98 33,733
Jan-981 54,765 12-Mar-98 45,380 01-May-98 44,211 20-Jun-98 34,594
an-981 61,517 13-Mar-98 46,1331 02-May-981 40,615 21-jun-981 36,166
23-Jan-981 49,925 14-Mar-981 41,807 03-May-98 40,361 22-Jun-981 46,148
24-Jan-98( 51,5501 15-Mar-98 40,130 04-May-98 45,462 23-Jun-981 42,837
25-Jan-98M 49,169 16-Mar-98 49,244 05-May-98 34,969 24-Jun-98 43,646
26-Jan-98 51,119 17-Mar-981 43,073 06-May-98) 39,269 25-Jun-98 46,082
27-Jan-98 48,952 18-Mar-98 40,296 07-May-98 45,363 26-Ju2-98 _.35,589
28-Jan-98 46,852 19-Mar-98 47,337 08-May-98 43,669 27-Jun-98 43,076
29-Jan-98{ 57,255 20-Mar-98 40,224 09-May-98 42,406 28-Jun-98 47,614
30-Jan-98! 50.644 21-Mar-98 39,602 10-May-981 64,654 29-Jun-98 54,571
31-Jan-98) 48,420 22-Mar-98 51,9611 11-May-98 54,059 30-Jun-98 80,946
01-Feb-98 46,693 23-Mar-981 51,5211 12-May-981 49,690 01-Jul-98) 51,412
02-Feb-96 50,742 24-Mar-98 49,8211 13-May-98 37,7541 02-Jul-98 44,329
03-Feb-981 62,304 25-Mar-981 43,209 14-May-98 38,6051 03-Jul-98 37,239
04-Feb-981 63,088 26-Mar-981 44,150 15-May-98) 49,680 04-Jul-98 41,723
05-Feb-98 55,696� 27-Mar-98 38,472 16-May-98 45,175 05-Jul-981 47,868
06-Feb-981 61,872 28-Mar-98 42,159 17-May-98 41,8521 06-Jul-98 56,897
07-Feb-98 55,409 29-Mar-98 37,678 18-May-981 42,214 07-Jul-98 24,475
08-Feb-981 57,930 30-Mar-98 37,565 19-May-981 43740 28-Jul-98 44,332
09-Feb-981 52,286 31-Mar-98 40,122 20-May-981 45,,294 09-Jul-98 45,039
10-Feb-981 61,544 01-Apr-98 39,366 21-May-981 36,204 10-Jul-98 45,767
11-Feb-98 58,277 02-Apr-98 _ 40.986 22-M2y-98 39,6361 11-Jul-98 61,989
12-Feb-981 50,61E 03-Apr-98 41,264 23-May-98 31,981 12-Jul-98 79,466
13-Feb-98 64,530 04-Apr-98 39,167� 24-May-98 33745 13-Jul-98 50,314
14-Feb-981 57,609 05-Apr-98 34,902 ,
25-May-98 39,739 14-Jul-98 40,227
15-Feb-981 53,557 06-Apr-98 42,6981 26-May-98 49,499 15-Jul-98 49,949
16-Feb-98 55,051 07-Apr-98 41,7971 27-May-98 42,140 16-Jul-98 50,016
17-Feb-98 54,20E O8-Apr-98 39,384 28-May-98 45,632 17-Jul-98 49,825
18-Feb-98 78,112 09-Apr-98 42,215 29-May-98 36,79E 18-Jul-98 51,498
19-Feb-981 66,592 10-Apr-98 41,766 30-May-981 33,6201 19-Jul-98 59,037
Blue Ridge Paper Products, Inc. Canton, NC

EOHS Dept. [phone] Color Data 8117/99
Date SE Col. Ibs/day Date SE Col. Ibs/day Date SE Col. Ibs/day Date SE Col. Ibs/day
20-Jul-98 57,634 08-Sep-98 56,220 28-Oct-98 58,689 17-Dec-98 41,153
21-Jul-981 59,034 09-Sep-98 51,925 29-Oct-98 49,222 18-Dec-98 36,862
22-Jul-98 59,1581 10-Sep-98 52,317 30-Oct-98 51,258 19-Dec-981 34,496
23-Jul-98 60,159 11-Sep-98 57,121 31-Oct-98 50,815 20-Dec-98 32,120
24-Jul-98 57,935 12-Sep-98 45,329 01-Nov-98 50,220 21_Dec-981 42,951
25-Jul-981 511,862 13-Sep-98 44,592 02-Nov-98 63,9981 22-Dec-98E 46,267
26-Jul-98 55,383) 14-Sep-98 48,415 03-Nov-98� 49,991 23-Dec-98 47,880
27-Jul-981 52,050 15-Sep-911 48,233 04-Nov-981 50,096 24-Dec-98 52,602
28-Jul-98 52,887 16_Se
p-98 42,224 05-Nov-98� 42,425 25-Dec-98 48,051
29-Jul-981 46,767 17-Sep-98 43,599 06-Nov-98 45,835 26-Dec-98 41,566
30-Jul-981 57,280 18-Sep-98 90,443 07-Nov-98 51,251 27-Dec-98 45,446
31-Jul-98 65,423 19-Sep-981 50,803 08-Nov-98' 53,269 28-Deo-981 49,370
01-Aug-98 57,295 20-Sep-98 52.893 09-Nov-98 60,761 29-Dec98 37,036
02-Aug-98# 50,104) 21-Sep-98 59.494 10-Nov-981 52.9631 30-Dec98 38,863
03-Aug-98 34,483 22-Sep-981 45,424 1 I-Nov-981 47,857 31-Deo-98 42,881
04-Aug-98 35,898 23-Sep-98 48,957 12-Nov-981 47,512 01-Jan-99 42,623
05-Aug-98 33,317 24-Sep-981 51,019 13-Nov-98 54,830 02-Jan-99 38,604
06-Aug-98 41,124 25-Sep-981 48,912 14-Nov-98 46,8621 03-Jan-99 39,236
07-Aug-98 55,349 26-Sep-98 55,279 15-Nov-98 47,9781 04-Jan-99 39,223
08-Aug-98 53.488 27-Sep-98 43,397 16-Nov-98 63,4951 05-Jan-99 46,803
09-Aug-98 54,756 28-Sep-98 45,209 17-Nov-98 55,352 06-J2
2
-99 43,600
10-Aug-98 54,3841 29-Sep-98 48,020 18-Nov-98� 61,506 07-Jan-99 51,858
11-Aug-98 43,799 30-Sep-98 46,243 19-Nov-98 86,227 OS-Jan-99 54,781
12-Aug-98 42,424 01-Oct-98 56,241 20-Nov-98 62,937 09-Jan-991 44,318
13-Aug-98� 41,765 02-Oct-98) 41,405 21-Nov-98� 59,173 10-Jan-991 47,284
14-Aug-98E 42,769 03-Oct-98 33,6141 22-Nov-981 60.786 11-Jan-991 42,868
15-Aug-98( 47,743) 04-Oct-98 37.045 23-Nov-981 71,742 12-Jan-991 38,475
16-Aug-981 45,283 05-Oct-98 45,6771 24-Nov-98 70,1351 13-Jan-99 39,173
17-Aug-981 45,850 06-Oct-98 36,676 25-Nov-98 68.3471 14-Jan-99 36,579
18-Aug-98 47,699 07-Oct-98 53,470 26-Nov-98 95,6471 15-Jan-99 38,093
19-Aug-981 49,651 08-Oct-98 53.1011 27-Nov-98 77,0651 16-Jan-99 33 10
20-Aug-98 51,803 09-Oct-98 41,753 28-Nov-98 53,834 17-Jan-99 38,937
21-Aug-98E 54.961 10-Oct-98 46,720 29-Nov-98 59,304 18-Jan-99 38,572
22-Aug-98 62,499 11-Oct-98 45,941 30-Nov-98 64,8681 19-Jan-99 45,948
23-Aug-98 57,428 12-Oct-98 44,817 01-Dec-98� 48,074 20-Jan-99 39,626
24-Aug-98 72,716) 13-Oct-981 47,626 02-Dec98 49,6781 21-Jan-99 42,300
25-Aug-98 64,8161 14-Oct-981 45,431 03-Dec98 44,362 22-Jan-99 47,191
26-Aug-98 52,125 15-Oct-981 56,638 04-Dec-98 40,811 23-Jan-99 42,488
27-Aug-98� 50,9361 16-Oct-98 67,156 05-Dec-98 36,657 24-Jan-99 38,1021
28-Aug-98{ 39,940 17-Oct-981 74,210 06-Dec-981 36,190 25-jan-991 37,652
29-Aug-98) 46.014 18-Oct-981 66,291 07-Dec-981 56,323 26-Jan-991 33,024
30-Aug-98 77,869 19-Oct-981 54,862 08-Dec-981 48,148 27-Jan-991 31,764
31-Aug-98 60,0111 20-Oct-98 49.704 09-Dec-981 37,5891 28-Jan-99 34,212
01-Sep-98) 56,8311 21-Oct-981 43,962 10-Dec-98 42,297) 29-Jan-99 42,034
02-Sep-98 47,085 22-Oct-98 46,3851 11-Dec-98 40,138 30-Jan-99 47,867
03-Sep-98 46,881 23-0
ct-98 43,704 12-Dee981 39,191 31-Jan-99 45,260
04-Sep-98 35,299 24-Oct-981 47,199 13-Deo-98 35,912 01-Feb-99 54,732
05-Sep-981 44,903 25-Oct-98 65.155 14-Dec-981 40,753 02-Feb-99 52.767
06-Sep-981 70,748 26-Oct-98 53,025 15-Dec-98 37,110 03-Feb-99 44,392
07-Sep-98 65,570 27-Oct-98 60,023 16-Dec-98 33,484 04-Feb-99, 40,389
Blue Ridge Paper Products, Inc. Canton, NC

EOHS Dept. [phone] Color Data 8/17/99
Date SE Col. Ibs/day Date SE Col. Ibs/day Date SE Col. Ibs/day
05-Feb-99 37,558 27-Mar-991 35,881 16-May-991 45,538
06-Feb-99 36,875 28-Mar-991 39,830 17-May-991 44,573
07-Feb-99 36,294 29-Mar-991 71,857 18-May-991 43,746
08-Feb-99 38,013 30-Mar-991 100,993 19-May-991 39,221
09-Feb-991 35,631 31-M2r-99 52,697 20-May-991 36,596
10-Feb-991 44,633 01-Apr-99 43,491 21-May-99 32,144
11-Feb-991 48,894 02-Apr-99 34,320 22-May-99 35,155
12-Feb-991 68,943 03-Apr-99 32,181 23-May-99 38,033
13-Feb-99 43,656 04-Apr-99 29,484 24-May-99 39,211
14-Feb-991 39,057 05-Apr-99 30,487 25-May-99 54,945
15-Feb-99 46,553 06-Apr-99 35,823 26-May-99 46,169
16-Feb-99 35,608 07-Apr-99 37,744 27-May-99 58,8 66
17-Feb-99 31,723 08-Apr-99) 38,910 28-May-99 69,530
18-Feb-99' 33,297 09-Apr-99 37,272 29-May-99 57,389
19-Feb-99 34,099 10-Apr-99 42,689 30-May-991 31,172
20-Feb-991 32,151 11-Apr-99 38,665 31-May-991 26,232
21-Feb-991 34,679 12-Apr-99 37,980 01-Jun-991 29,298
22-Feb-991 38,378 13-Apr-99 32,320 02-Jun-991 35,230
23-Feb-991 31,369 14-Apr-991 35,084 03-Jun-991 34,062
24-Feb-99 34,915 15-Apr-99 33,697 04-Jun-991 31,632
25-Feb-99 34,488 16-Apr-99 38,379 05-Jun-991 28,224
26-Feb-99) 36,746 17-Apr-991 40,728 06-Jun-99 27,627
27-Feb-99 31,490 18-Apr-991 41,441 07-Jun-99 22,568
28-Feb-99 32,462 19-Apr-99 39,174 08-Ju2-99 24,573
01-Mar-99 34,538 20-Apr-99 38,701 09-Jun-99 27,519
02-Mar-991 51,197 21-Apr-99 36,908 10-Jun-99 31,590
03-Mar-991 49,3561 22-Apr-99 35,6471 11-Jun-99� 30,821
04-Mar-99 42,9921 23-Apr-99 42,207 12-Jun-99 36,656
05-Mar-99 47,0931 24-Apr-99 37,397 13-Jun-991 33,555
06-Mar-99 50,9361 25-Apr-991 40,212 14-Jun-99 40,200
07-Mar-99� 45,020 26-Apr-991 38,958 15-Jun-99 41,656
11
O8-Mar-99 40,716 27-Apr-99 47,700 16-Jun-99 38,140
09-Mar-99 39,552 28-Apr-991 34,520 17-Jun-99 36,786
10-Mar-99 35,505 29-Apr-991 44,216 18-Jun-99 39,845
11-Mar-99 38,057 30-Apr-99 33,935 19-Jun-99 41,537
12-Mar-99 38,510 01-May-99 29,512 20-Jun-99 43,029
13-Mar-991 38,653 02-May-991 29,3631 21-Jun-99 38,946
14-Mar-99 35,689 03-May-99 40,542 22-Jun-99� 46,609
15-Mar-99 37,221 04-May-99 60,294 23-Jun-99 47,469
16-Mar-99� 38,983 05-May-99 67,2751 24-Jun-99 48,810
11
17-Mar-99 36,955 06-May-991 59,089 25-Jun-99 44,4451
18-Mar-991 43,311 07-May-991 34,616 26-Jun-99 41,307
19-Mar-991 41,077 08-May-99 32,1121 27-Jun-991 40,230
20-Mar-99 40,547 09-May-99 29,234 28-Jun-99 32,8861
21-Mar-99 34,050 10-May-99 31,779 29-Jun-99 38,158
22-Mar-99) 35,848 11-May-99 42,540 30-Jun-99 47,235
23-Mar-99 26,633 12-May-99 41,558
24-Mar-99 31,262 13-May-99 39,561
25-Mar-99 35,0671 14-May-99 42,399
26-Mar-991 38,192 15-May-991 39,364
Blue Ridge Paper Products, Inc. Canton, NC

Blue Ridge Paper Products, Inc. COD data
©ate Seo)Eff(GOD rng/_I Date Seg EffjGOp /Ij
02-Jan-98 138 23-Oct-98 154
09-Jan-98 163 30-Oct-98 160
16-Jan-98 146 06-Nov-98 186
23-Jan-98 130 13-Nov-98 170
30-Jan-98 142 20-Nov-98 176
06-Feb-98 136 27-Nov-98 178
13-Feb-98 184 03-Dec-98 88
20-Feb-98 114 10-Dec-98 86
27-Feb-98 109 17-Dec-98 91
06-Mar-98 130 24-Dec-98 120
13-Mar-98 103 30-Dec-98 120
20-Mar-98 90 07-Jan-99 76
27-Mar-98 129 14-Jan-99 81
03-Apr-98 122 22-Jan-99 110
10-Apr-98 136 28-Jan-99 110
17-Apr-98 150 04-Feb-99 110
24-Apr-98 149 11-Feb-99 110
01-May-98 122 18-Feb-99 98
08-May-98 133 25-Feb-99 91
15-May-98 109 04-Mar-99 100
22-May-98 112 11-Mar-99 130
29-May-98 107 18-Mar-99 140
05-Jun-98 120 25-Mar-99 68
12-Jun-98 117 31-Mar-99 54
19-Jun-98 113 08-Apr-99 81
26-Jun-98 131 15-Apr-99 110
03-Ju1-98 124 22-Apr-99 100
10-Ju1-98 121 29-Apr-99 95
17-Jul-98 142 06-May-99 120
24-Jul-98 119 13-May-99 110
31-Jul-98 170 20-May-99 110
07-Aug-98 102 27-May-99 130
14-Aug
-98 136 02-Jun-99 100
21-Aug-98 154 10-Jun-99 59
28-Aug-98 137 17-Jun-99 73
04-Sep-98 106 24-Jun-99 81
11-Sep-98 172
18-Sep-98 152
25-Sep-98 154
02-Oct-98 180
9-Oct-98 107
16-Oct-98 189
EOHS Dept. [phone] Canton, NC 8/17/99

N. C . DEPARTMENT OF ENVIRONMENT AND
e`"`�Aa NATURAL RESOURCES
H.Y 30.1�
DIVISION OF WATER QUALITY
- WATER QUALITY SECTION
o ASHEVILLE REGIONAL OFFICE
c 59 WOODFIN PLACE
��# "^' "" •� ASHEVILLE, NORTH CAROLINA 28801
PHONE : [phone] FAX: [phone]
TO : � OC�
FAX # :
FROM:
DATE:
# OF PAGES INCLUDING THIS COVER:
MESSAGE : If questions , please call 828/251-6208 .

Making(Our mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
John J. Pryately
Supervisor Laboratory & WWTP
Pulp, Recovery, & Utilities Dept.
Blue Ridge Paper Products Inc.
P.O. Box 4000
Canton,North Carolina 28716
July 19, 1999
Dwight Lancaster �9
CS Technical Assistance & Certification Unit
WPOC
P.O. Box 29535
Raleigh,North Carolina 27626-0535 AP�����``�
ps
Dear Mr. Lancaster:
This is to inform you that I have been appointed the ORC of Blue Ridge Paper Product's
Canton facility, effective July 12, 1999. I have been filing the ORC position on an
interim basis since April 4, 1999. My back-up operators are Harold Sweitzer, Gale
Goodman, and Mike Henson.
Blue Ridge Paper Products Inc. purchased the Canton mill from Champion International
Corporation on May 14, 1999.
If you require additional information, I can be contacted at 828-646-6720.
Sincerely,
J�Pryatel (Cert. No. 14109)
Harold Sweitzer(Cert.No. 15191)
Mike Henson (Cert. No. RC1371) ` �/• Give,/_
Gale Goodman (Cert.No. 9233) o •v,�
175 Main Street • P.O.Box 4000 Canton, North Carolina 28716 828-646-2000

CC:
Keith Haynes, NCDENR, Asheville
Forrest Westall,NCDENR, Asheville
Derric Brown, Blue Ridge Paper Products Inc.
Steve Single, Blue Ridge Paper Products Inc.

l
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
•^; •�' DIVISION OF WATER QUALITY
AsHEVILLE REGIONAL OFFICE
I � t leF September 7, 1999
a"-vC t
198
w':IAMES B.HUNTJR'.: �.
i..,JGPVERNoti .L�9
�- • ' ?�'� MR. STEVE SINGLE
BLUE RIDGE PAPER PRODUCTS WWTP LAB
. a 3 P.O. BOX 4000
!WAcoEv A
CANTON, NC 28716
CA
a •
SUBJECT: Wastewater/Groundwater Laboratory
Certification Laboratory Manager Requirements
Dear Mr. Single:
Our records indicate that you were named the laboratory
x Y Y
manager of the Blue Ridge Paper Products
Laboratory in a letter, dated August 27, 1999,. sent to our office
_ by the above laboratory. Enclosed is a copy of the
Wastewater/Groundwater Laboratory Certification Rules. The
•.a�. : requirements for a laboratory manager are found on page five and
six, Section .0805 (a) (4) . The most important requirements of the
laboratory manager are:
n:•.
U. (1) Notifying the State Laboratory of changes in the
laboratory supervisor within thirty days of such changes.
,U° •� tt1 (2) Insure that any new supervisors meet the requirements
' of the Laboratory Certification Rules.
.' y The requirements for a laboratory supervisor are found on
NV laboratory
page five, Section .0805 (a) (3) . Please be aware that, any time a
N-'_��ly��•� laboratory employs a new laboratory supervisor, the new employee
a. must meet the requirements in Section .0805 (a) (3) (A)or(B) .
Y Failure to meet the requirements of the Rules may result in
enforcement actions.
sSeR'.yre��
" Contact us at (828) 251-6208 extension 285 if you have
questions or need additional information.
Y At •nA.'i%a��
�,- •_'4�'°„'�"t.��, '"1' Sincerely,
Y 1 Gary Francies
9".r Laboratory Section
a0. te#err
cc: James W. Meyer
L . -d •.>"Y"-'m - Marilyn Deaver
(, .d^'W Y,.+•\ sw^'° INTERCHANGE BUILDING, 59 WOODFIN PLACE• ASHEVILLE• NC 2 880 1-24 1 4
PHONE 828-2S1-6208 FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10 POST-CONSUMER PAPER

SEP-03-1999 12:07 FROM DEM CHB115 RY LABOR4T012Y Tp RRO P.01/01
aking(17r mark for you.
SLVB RIDGE PAPER-P20DUCTS INC. ' ti
SEP S .
Certification Number 198 DtiVQ August 27, 1999'
-Mr.James W. Meyer LR$ORATQRY BEcTroN
DWQ Laboratory Section
DENR
1823 Mail Service Center
Raleigh, North Carolina 27699-1623
Subject Laboratory Certification Maintenance inspection Response to
i
August23, 1999 Letter and July 28, 1999 Inspection Report
Dear Mr.Meyer.
The laboratory inspection report from July 28, 1999 :by Mr. Gary W. Francles
contained a comment that needed a reply. This correspondence is the response to
i your letter dated August 23,1999 and received August 27, 1999 that includes the
repy to the comment.
COMMENT.On May 10,1999,we were notified thatthe facility's laboratory manager,
Mr. Mite Cody, had taken another position. We have not received notification of his
replacerneut.
REQUIREMENT: It is required that a Certified laboratory provide the State
Laboratory with written notice of laboratory manager changes within thirty days.
i
RESPONSE: The laboratory manager for Blue Ridge Paper Products Inc_ WWTP
laboratory is Mr. Steve Single. Mr. Single's title is Pulp, Recovery, & Utilities
Manager. He can be contacted by, phone at 828-626-2268 or by fax at 828f46-
2980.
If you have any questions, comments, or need additional information, I can be
contacted by phone at 828-646-6720 or by fax at 82&646-2993.
Sincemy,
' Post 'Fm rJO1B �767;1
Fn 93 94
is
ov
John J:Pryately COMML O c°
Laboratory&WWTP Supervisor Pnonei ai
301i30 IVN01938 3111A38Sr
N01133S A801tl808tl1
175 Main Street • P.O.Box 4000 Cantw_N Caro 9871R • .
TOTRL P.01
6661 6

� J
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 23, 1999 DIVISION OF WATER QUALITY
198
NC�ENR , Mr. John J. Pryately
Blue Ridge Paper Products Inc.
`a P.O. Box 4000
JAMESB.HUNTJR...:;'•r.- Canton, NC 28716
GOVERNOR
ti:: sal
SUBJECT: Laboratory Certification Maintenance Inspection
_WAYNE MCDEV1tT Dear Mr. Pryately:
.'
SECRETARY `4 ;�!
; Enclosed is a report for the inspection performed on July 28, 1999 by
' Mr. Gary W. Francies. A response is not required if there were no violations
41
cited. A response is not required for comments or recommendations unless
' KERRT.STEVENS ,v�r, specifically requested. Please reply to comments, where requested, within
,•DIRE°TDR r.A thirty days of receipt of this report. We appreciate the fine job you and your
staff are doing. As a certification requirement, your laboratory must continue
y '%1 to carry out the requirements set forth in 15A NCAC 2H .0800.
ZY
Copies of the checklists completed during the inspection may be
requested from this office. Thank you for your cooperation during the
inspection. Please contact us at 919-733-3908, if you have questions or
need additional information.
j Sincerely,
is j James W. Meyer
'` T? Laboratory Section
ys: Enclosure
cc: Marilyn O. Deaver
R�
Gary W. Francies (�S'
AUG
a. LAB SECiIy
ORATORY
ASHEVILLE REGIO� � NAL OFFICE-
LABORATORY SECTION
4405 REEDY CREEK ROAD, RALEIGH, NORTH CAROLINA 27607-6445
• ^ PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 Oq POST-CONSUMER PAPER

ON- SITE INSPECTION REPORT
LABORATORY NAME: Blue Ridge Paper Products WWTP Laboratory
ADDRESS : P.O. Box 4000
Canton, NC 28716
CERTIFICATE #: 198
DATE OF INSPECTION: 7/28/99
TYPE OF INSPECTION: Maintenance
EVALUATOR(S) : Gary Francies
LOCAL PERSON(S) CONTACTED: John Pryately, Melanie Hager
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the
requirements of 15A NCAC 2H . 0800 for the analysis of environmental
samples .
II. GENERAL COMMENTS :
The laboratory is spacious and well equipped. All equipment is well
maintained. Records are well kept and most data appeared accurate .
III . VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS :
COMMENTS : On May 10, 1999, we were notified that the facility' s
laboratory manager, Mr. Mike Cody, had taken another position. We have
not received notification of his replacement .
REQUIREMENT : It is required that a certified laboratory provide the
State Laboratory with written notice of laboratory manager changes
within thirty days . Ref : 15A NCAC 2H . 0805 (c) (5)
A written response to this item is requested.
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory
bench sheets and contract lab reports to DMRs submitted to this
Division. Data were reviewed for these months : September 1998, March
and June 1999 . The following errors were noted:
Date Parameter Location Value on Value on
Lab Report DMR
3/10/99 Hg Effluent < 0 . 2 ug/l 0 .2 ug/l
3/22/99 Hg Effluent < 0 . 2 ug/l 0 . 2 ug/l

Page 2
In order to avoid questions of legality, it is recommended that
amended DMRs be submitted to this Division.
It appears the facility is doing a good job of accurately transcribing
data .
V. CONCLUSION:
This laboratory is doing a good job overall . The staff is
congratulated for doing an excellent job of maintaining the laboratory
program.
Report prepared by: Gary Francies Date : 8/10/99

(,?
Making ur mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
John J. Pryately
Supervisor Laboratory & W WTP
Pulp, Recovery, & Utilities Dept.
Blue Ridge Paper Products Inc.
P.O. Box 4000
Canton,North Carolina 28716
July 19, 1999
Dwight Lancaster D ~~
DEHNR Technical Assistance &Certification Unit ,2�
WPCSOCC
P.O. Box 29535 QUF��ZV Sp4to�4,CE
Raleigh, North Carolina 27626-0535
Dear Mr. Lancaster:
This is to inform you that I have been appointed the ORC of Blue Ridge Paper Product's
Canton facility, effective July 12, 1999. I have been filing the ORC position on an
interim basis since April 4, 1999. My back-up operators are Harold Sweitzer, Gale
Goodman, and Mike Henson.
Blue Ridge Paper Products Inc. purchased the Canton mill from Champion International
Corporation on May 14, 1999.
If you require additional information, I can be contacted at 828-646-6720.
Sincerely,
/4
John J. el (Cert. No. 14109)
Harold Sweitzer (Cert.No. 15191)
Mike Henson (Cert.No. RC1371)
Gale Goodman (Cert. No. 9233) /I
175 Main Street • P.O.Box 4000 • Canton, North Carolina 28716 • 828-646-2000

CC:
Keith Haynes, NCDENR, Asheville
Forrest Westall,NCDENR, Asheville
Derric Brown, Blue Ridge Paper Products Inc.
Steve Single, Blue Ridge Paper Products Inc.

Making ur mark for you.
BLUE RIDGE PAPER PRODUCTS INC.
July 9, 1999 s!r
Mr. Keith Haynes
North Carolina Department of / 219,99
!;
Environment and Natural ResourcespU,
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: July 31 Dissolved Oxygen Measurement
Dear Mr. Haynes:
Blue Ridge Paper Products, Inc. is providing written notification as follow-up to Chris
Leitsch's voicemail message of July 5, 1999 at 1:20pm. Mr. Leitsch's message was in
reference to the July 3, 1999 dissolved oxygen (D.O.) measurement of 4.80 mg/I taken
Below Clyde at river mile 55.5. The corresponding D.O. upstream of Canton was 4.96 mg/l,
which is above the minimum instantaneous limit of 4.00 mg/I but below the minimum daily
average limit of 5.00 mg/I. While the Canton mill's secondary effluent D.O. at this time was
8.76 mg/I,well above our minimum limit of 6.00 mg/I, the effluent oxygen injection was
increased as a preventive measure.
The Dissolved Oxygen Meter was recalibrated after the July 3rd measurement and, though
no quality control problems were discovered, the probe was changed before the July 41
2:55am readings. The July 41h measurements upstream of the mill and Below Clyde were
7.05 mg/I and 6.61 mg/I respectively,which were more reflective of the past month's
averages of 7.29 mg/I upstream and 7.16 mg/I Below Clyde. The average of the July 31,
9:30am measurement and the July 4'", 2:55am measurement was above 5.00 mg/I.
If you need further information regarding this issue, please contact me at 646-6749, or Derric
Brown at 646-2318.
Sincerely,
/1
Melanie S. Hager
Associate Environmental Engineer
cc: Derde Brown
John Pryately
Steve Single
Bob Williams
Blue Ridge Paper Products,Inc. •P.O.Box 4000. 175 Main Street•Canton,NC 28716 •[phone]

r � ' • „ NORTH CAROLINA DEPARTMENT OF
a;•1 '" n ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
"r WATER QUALITY SECTION
4
Fs�NCDENR a r
May 18, 1999
,II JAMESB HUNTJR..,
GOVERNOR {'
Mr. Derric Brown
Blue Ridge Paper Products Inc.
G.Y
Post Office Box 4000
fWAYNE MCDEVIT•I' Canton, North Carolina 28716
'L bECRETARY
. '•; Subject: Acceptance of Activated Sludge
R STEVENSFrom Maggie Valley WWTP
�KERT.
D1Ra NPDES Permit No. NC0000272
K
Haywood County
Y
Dear Mr. Brown:
aF : This Office does not foresee a problem with your waste
tr water treatment accepting activated sludge from the Town of
Maggie Valley. It is suggested that you maintain a record of
all sludge received including the date and number of gallons .
If you have any questions concerning this matter or if you
� , . require additional information, please do not hesitate to
.• contact me at 251-6208 .
1 � A
Sincerely,
D. Keith Haynes
Environmental Specialist
Matthews
`a 4
b v.y bluermv.let
1 4 S k- L1rty.�2
INTERCHANGE BUILDING, 59 WOOOFIN PLACES ASH EVILLE. NE 28801-# 2414
t5y. , Lh �j.'u PHONE 828-2S1-62O8 FAX[phone]S2
....�a..__...u..wr W.L� •I AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10q POST-CONSUMER PAPER

NORTH CAROLINA DEPARTMENT OF
' ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
March 29, 1999
(fir r� 4.2 w�a r• - •
W A.
^.-E5B HUNT SR A`�{' 198
GOVERNOR MR. JOHN PRYATELY
CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX 4000
. - CANTON, NC 28716
WAYNE.MCDEVITT
SECRETARY
Y_-
�,
Dear Mr. Pryately:
15
r a
Your laboratory participated in the 1998 EPA DMRQA STUDY 18
rp
�Aypi,,irEs%Howu+o.lR v; evaluation. The study did not include samples for all certified
aE�;D1RecToa �l / parameters. Those samples are enclosed.
N•1 ^ Sy °s �� Evaluation Samples
�.. (X) Residue, Total
1
(X) Residue, Dissolved 180, C
(X) Color PC
(X) Conductivity
Sample Type
(X) Required Samples
k _:k
i 6 Under provisions of the Laboratory Certification Regulation 15
_ NCAC .0807 (b) (6) , you must return a copy of the results of your
determinations for these samples within thirty days of receiving
them. Extensions beyond thirty days will not be given.
Decertification may be recommended for laboratories not meeting
the deadline for reporting results.
Please contact us at 828-251-6208 ext. 285 if you have questions
or need additional information.
Sincerely,
�ya2i/eL4s�
rr. Laboratory Section
�r� �•- Enclosure -
' cc: James W. Meyer _
*_,..xfy``-� µ•Ya,�'w .' T h - '1 rr _ ..CF:
INTERCHANGE BUILOINO,58 WOOOFIE PLACE,I-6208 LL EA NC X826801-2414
h!} - PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-50%RECYCLED/10q POST-CONSUMER PAPER

„ QJ Box C-10
Canton,North Carolina 28716
Champion
Champion International Corporation
December 15, 1998
Forrest R. Westall
Regional Water Quality Supervisor
NC Department of Environment and Natural Resources
Division of Water Quality, Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
RE: NPDES Permit No. NC0000272
Dear Mr. Westall:
Champion International Corporation's Canton Mill has an on-going process improvement
effort to reduce effluent color emissions. In support of this commitment, an additional
opportunity for color reduction has been identified for the hardwood secondary knotter
accepts tank overflow.
The control strategy for minimizing color losses from the hardwood secondary knotter
accepts tank overflow line is detailed in Section 4.6.1 of the June 1,"1998 Color Technology
Measures Report”, that was submitted to you on May 27, 1998. The current control strategy
on this tank employs a temperature probe in the overflow line. If a tank overflow occurs, the
increase in temperature is detected by the temperature probe and a process signal .
immediately alarms the hardwood brownstock operator station and appropriate action is
taken.
Planned improvements are underway to relocate the accepts tank overflow line into an
existing sump in the hardwood brownstock washing building. This will improve color
containment and the temperature probe will no longer be required for operator notification. A
sump conductivity probe will be used for operator notification in the future.
Please accept this as notification of the removal of the temperature probe and
implementation of an improvement to mill color control. If you have any questions or
concerns, please contact me at [phone] by January 6, 1999.
Sincerely,
ff / J
�Ob
Robert V. Williams
Manager
Environmental, Occupational Health and Safety � �

-, NORTH CAROLINA DEPARTMENT OF
I ' ENVIRONMENT AND NATURAL RESOURCES
M
DIVISION OF WATER QUALITY
VXASHEVILLE REGIONAL OFFICE
NCDENRr; May 26, 1999
JAMES B.HUNTJR.-'---"
GOVERNOR 198
4 MR. JOHN PRYATELY
CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX 4000
CANTON, NC 28716
WAYNE MCDEVITT. =•.(`+.[
SECRETARY
Dear Mr. Pryately:
We have evaluated results from your analysis of the wastewater
groundwater laboratory certification performance samples we
ICERR T.sTEVENs_ ; -. received May 20, 1999.
DIRECTOR
I The information from this evaluation is summarized below:
- ry_.` rived
r5ryl
Am ul ID Anal)de Units Reported True Value Lower Limit Upper Limit Performance
NC366-F; mg/I TDS 180�C T _395:0 388 350 425 Accetable
o additional follow-up isrequired as all resultsare acceptable.
Contact us at (828) 251-6208 extension 285 if you have questions.
.1
.s
Sincerely,
Gary Francies
Laboratory Section
r
r ' cc: James W. Meyer
Marilyn Deaver
>' �she�5i3-. Wa -
EVAL.LTR
INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801-2414
PHONE [phone] FA%828-251-6452
-� AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10q POST-CONSUMER PAPER

' t I NORTH CAROLINA DEPARTMENT OF
re' ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
to ASHEVILLE REGIONAL OFFICE
v ion
^� ���� 'y May 10, 1999
.,.JAME9H.HUNTJR. 198
.-GOVER,xNOR a
,1t MR. JOHN PRYATELY
CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX 4000
CANTON, NC 28716 -
e AY�MODEVIT'1' � -
" ;SEDR + Dear Mr. Pryately:
p We have evaluated results from your analysis of the wastewater
/ groundwater laboratory certification performance samples we
received April 19, 1999.
Ea ENIt
wcT� • The information from this evaluation is summarized below:
Am ul ID1 Analvte Units Re o rLjmftlUooerUmRj Performance
:..E..........................a...................._t....................;..................................................(........................i.................................<
NC297-F,€_Conducti�IY.JlltlhR3/.;;Mj .893:7...<.....__859........i......_805......_} 935
NC297 F TDS 180 C i _mgA•„•,_..-6550 ,,,.,237........•......_172,,,,_,,.# ,304 Unacceptable"
o
NC298 F Color FtCo i ou 101 100 85 115 Acceptable',,,,.;,
NC299-F: Total Solids-: mg/I•...... _4200 :.-_-,_463 345 595 n Acceptable' ;........ ....... ..........._ ..................
v. *No additional follow-up is required at this time.
1
y� **Another sample is enclosed for your analysis.
Decertification may be recommended if the .results of the enclosed
sample(s) are unacceptable.
' :.• __ Under provisions of the Laboratory Certification Regulation 15 NCAC
0807 (a) (8)., you must return a copy of ' the results of your
determinations for these samples within thirty days of receiving
I
them. Extensions beyond thirty days will not be given
Decertification may be recommended for laboratories not meeting the
deadline for reporting results. -.
_ Contact us at (828) 251-6208 extension 285 if you have questions.
"M"'
Sincerely,
Gary rancies -
Laboratory Section
✓3. 7' s°
- cc: James W. Meyer
�;::^�ia:� �; ..-s:s*•`c Marilyn Deaver '
��•'•'Y �l F�T. # INTERCHANGE BUILDING, 59 WOODFIN PLACE, ASHEVILLE, NC 28801-2414
PHONE [phone] FAX 82a-251-6452
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST-CONSUMER PAPER

Canton Mill
P.O.Box 4000
Canton,North Carolina 28716
828 646-2000
UChampion
Champion International Corporation
April 23, 1999
Mr Forrest Westall
Supervisor
Water Quality Section
Division of Environmental Mgmt.
North Carolina Dept. of Natural Resources
59 Woodfin Place
Asheville, NC 28801 91999
j
Re: NPDES Permit No.NC0000272 as Eyil� �gliry
Part III - Section F, Item 1 R����Nq�0?,
Status of Bleach Filtrate Recycle Air Permitting F�cf
Dear Forrest:
The referenced section of the Canton Mill's NPDES permit requires the following:
By March 1, 1998 the permittee will submit a status report to the Division of
Water Quality and the NPDES Committee on the analyses prepared for other
permitting agency concerning the-effects of the BFRTMtechnology on air emissions.
For your record, this is the current status of BFRTm air permitting. Preliminary information
was submitted to the Division of Water Quality as required to meet the March 1, 1998
schedule. Recently the mill has completed and submitted post-BFRTm air emission testing
information to the Western North Carolina Regional Air Pollution Agency (WNCRAPA) to
support the air permitting process. At this time all copies of both pre- and post-BFRTm air
emission testing data resides as a public record at the WNCRAPA offices. The next step
in the air permitting process is for review and approval of the air toxics modeling
protocol. The North Carolina Division of Air Quality is currently conducting this review. As
soon as an approved modeling protocol is available, the air modeling will be completed.
The modeling result will allow for a permit application to be prepared and submitted for
final approval by the WNCRAPA Board.
The Canton Mill remains committed to operating BFRTm in conformance with all
appropriate water and air regulatory.requirements. Please contact me at (828).646-2033
if you,need further information on this subject. ,
Sincerely,
Robert V. Williams
Manager
Environmental, Occupational Health and Safety

Champion International Corporation
cc: Mr. Don Anderson
U.S. Environmental Protection Agency
Mail Code -4303
Room 915A, East Tower
401 Main Street, SW
Washington, D.C. 20460
Mr. Jim Cody
Director
Western North Carolina Regional Air Pollution Agency
49 Mt. Carmel Road
Asheville, NC 28806

l
„enlon rR) it an;l 28,16
U Champion
Champion oternational Corporation.
David M. Cody ORC
Superintendent Environmental and Laboratory
Services in Recovery&Utilities
Champion International
PO 4000
Canton,North Carolina 28716
March 31, 1999
Dwight Lancaster
DEHNR Technical Assistance and Certification Unit
WPCSOCC
PO Box 29535
Raleigh,North Carolina 27626-0535
Dear Mr. Lancaster:
This is to inform you that I have resigned my position of ORC of Champion International's Canton
facility effective April 4, 1999.John Pryately will be temporally filling my position. John has a
Grade LV operator's certification and has been my back-up for the last four years. John will be
backed up by Harold Sweitzer, Gale Goodman and Mike Henson.
Champion International will appoint a permanent ORC within 120 days.
Sincerely,
e
David M. Cody ORC (Cert.No. 4024)
John Pryately(Cert.No 14109)
Harold Sweitzer(Cert.No 15191
Mike Henson(Cert.No RC1371)
Gale Goodman(Cert.No 9233) C /9

Canton Mill Box ,o D l5 L5 V Canton,North Carolina 28716
�JANpp 191999
�III ASHEVIL E REGIONAL 0�FICE
V Champion
Champion International Corporation
January 14, 1999
Mr. Keith Haynes
NCDENR
Division of Water Quality
59 Woodfin Place
Asheville,NC 28802
RE: Petroleum Release at Champion's Canton Mill on January 12, 1999.
Dear Mr. Haynes:
Champion International is providing written notification of a release of less than 100
gallons of hydraulic oil from the Number 19 Paper Machine on the morning of January
12, 1999. The release resulted from a hydraulic pump being accidentally left on while
changing out a press roll. The release began at approximately 7:50 AM and the pump
was immediately shut down, thus stopping the release approximately two minutes later at
7:52 AM.
The release flowed directly into the in-mill sewer system which flows to the mill's
wastewater treatment plant where it was removed. None of the oil was released to the
Pigeon River.
If you need further information regarding this release please contact Chad Salisbury at
828-646-2874 or Jim Giauque at 828-646-2028.
Sincerely, F
Chad Salisbury Jim Giauque
Environmental ngineer Senior Environmental Engineer
ry ,"In r; . . ... .

Canton Mill
Box C-10
Canton.North Carolina 28716
Champion
Champion International Corporation
January 5, 1999
Mr. Bradley Bennett
Supervisor, Stormwater and General Permits
North Carolina Department of Environment and Natural Resources
PO Box 27687
Raleigh, NC 27611-7687
Subject : Stormwater Permit NCS000105 �` �
Champion Internationale
Canton, North Carolina
�_. JAN 2 6 1999
Data for 4th year of permit tvArFR unur�s iio`N AS' !"' RFG;., ,C' iFO CE
Dear Mr. Bennett:
Attached is Champion International Corporation's, Canton Mill, Stormwater
Permit No. NCS000105, analytical data for the1998 reporting year. The data is
submitted by January 31 as required by Part I, Section A, 2, d.
The cut off concentration has been met for the following parameters:
Year Cut-off
Parameter Concentration Met Outfall No
BOD 1995 3
COD 1995 9
TSS 1995 5C-17
TSS 1995 6-10
TSS 1997 56-20
FECAL 1995 1
Analytical monitoring specified in Part I, Section A, 2g,(1), footnotes, will be
completed as required in 1999.
If you have questions or need additional information, please call
[phone] or 646-2255.
Sincer I _
Louie Lneer
William Ch pm r CEM Maintenance Technician

Champion International Corporation
copy: Mr. Forest Wes tall
North Carolina Department of Environment and Natural Resources
Water Quality Section
59 Woodfin Place
Asheville, NC 28801
c:\flj\doc\strwate\monrpt98.doc

STORM WATER DISCHARGE OUTFALL(SDO)
MONITORING REPORT
PERMIT NO. NCS 000105 SAMPLES COLLECTED DURING CALENDAR YEAR: 1998
(all usaamples collected during a calendar year shall be reported no later than
FACILITY NAI11R_ _CH PPION INTERNATIONAL CORPORATION ry 31 or the following year) HAYWOOD
PERSON COLLECTING SAMPLES) WILLIAM CHA MAN COUNTY
CERTIFIED LABORATORY(S) HY Lab k 47
PHONE NO. —231
crxw
Lair k (SIGNA'rUR +OF PER 1'rTEE OR DESIGNEE)
By this signatu , lify that this report is accurate
Part A: Specific Monitoring Requirements complete to the best or my knowledge
Outrall Dale 50050 Total
No. Sample Total uspended Fecal
Collected Flow Solids
ino/dd/ r' r. . MG m .l'. b
1 7— — 0 .00 0 8.0
2 -8- 8 0 . 2 0 .0 > 00
7—, — 0- 1; 1 0 .0 > 21 00
I 7- - 0 . 008 8.0
-21-9 .
7 7- -O - 0 . 0 1 0.0
7 0 .0 11 .0
9 7- - 0 . 1 .0
- 7- - 0 .002 2 2.o
n C-
w >�
a Z mx
_c
coo (n_.o CJD
Page I of 2
l:onn MRNCS

.oes this facility perform Vehicle Maintenance Activities using more than 55 gallons of new motor oil per month?_yes X no '
(if yes,complete Part B) — '
Part B: Vehicle Maintenance Acliv[l Monitorin Re uircmcnts
Outfall Date 50050 0055fi iRecoverable
51 38260 00400
No. Sample Total Flow. ; Oil and Crease d, Total Delergentc pH New Motor Oil
CMecicd ) (MBAs 2 Usage
mu/dd/ r MC m m unit nVmo
No vehicle maintenance activity conducted within any stormwater drainage area
Footnotes: -
I Applies only for facilities at which fueling occurs.
1
Detergent monitoring is required only at facilities which conduct vehicle cleaning operations.
\STORM EVENT CHARACTERISTICS:
Dale 7-8-48 Mail Original and one copy to:
Total Event Precipitation (inches): 0 .21 Attn:Central Files
Event Duration(hours): 1•0 DEI INR
Division of Environmental Mgt.
D more one storm event was sampled) P.O. Box 29535
Dale —2—21-98 Raleigh, NC 27626-0535
Total Event Precipitation (inches): Q . 35
Evenl Duration(hours): 0, 17
"I certify,under penalty of law,that(his document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the Information submitted. Based on my inquiry of the person
or persons who manage the system,or those persons directly responsible for gathering the information,the informalion submitted is,to the best
of my knowledge and belief, true,accurate,and complete. I am aware[hat there arc significant penalties for submitting raise information,
including the possibility of fines and imprisonment for knowing violations."
(Signature of Perm(llee) (Dale)
Page 2 of 2
Form MRNCS

RECEIVED APR 0 1 1992
State of North Carolina
Department of Environment, Health, and Natural Resources
Asheville Regional Office
James G. Martin, Governor Ann B. On'
William W. Cobey, Jr., Secretary Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 31, 1992
Mr. Derric Brown
Environmental Supervisor
Champion International
Canton ,Mill
Canton, North Carolina 28716
Subject: Tax Certification Number TCS-401
Champion International
Water Pollution Control Facilities
Haywood County, North Carolina
Dear Mr. Brown:
Transmitted herewith is one copy of a Tax Certification for water
pollution control facilities being constructed as part of the Canton
Mill Modernization project required under NPDES Permit Number NC0000272 ;
effective October 25, 1989 .
This Certification may be used to obtain tax benefits in keeping
with the General Statutes of North Carolina. Should you wish to discuss
this matter in more detail , please do not hesitate to contact me.
Sincerely,
Roy M. Davis, Regional Supervisor
Division of Environmental Management
Enclosure
xc: George Everett
Harlan Britt
Steve W. Tedder
Interchange Building, 59 Woodfin Place, Asheville, N.C. 28801 •Telephone [phone]
An Equal Opportunity Affirmative Action Employer

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
T A X C E R T I F I C A T I O N
(Franchise/privilege; Amortization; Ad Valorem)
In accordance with the provisions of the General Statutes of North
Carolina (G. S. 105-122(d) , 105-130 . 10, 105-147( 13 ) , 105-275(8) ( a) this
is to certify that
Champion International
Canton, North Carolina
has been issued NPDES Permit Number NC0000272 for the construction and
operation of an industrial water pollution control facility. This permit
requires equipment modification to the manufacturing process to cause
the total daily wastewater flow through the treatment facility to be
reduced from 48. 5 MGD to 29 MGD, plus cause reduction in color,
chloroform, dioxin and total suspended solids. This inplant
reconstruction is also directed toward providing compliance with
effluent toxicity requirements as well as continued compliance with the
instream temperature variance issued by the North Carolina Environmental
Management Commission.
Construction approved in this Tax Certification includes ( 1 ) the MILL
WATER SYSTEM which provides for a new three-cell cooling tower and basin
and appurtenances (pumps, tanks, piping & distribution, pressure
controls, and electrical & instrument equipment) , (2 ) PAPER MACHINE
WATER CONSERVATION system to provide filtering and/or cleaning equipment
necessary to allow reuse of existing white water streams (primarily
machines No 11 & 12 ) and necessary equipment to reduce and control heat
loss (flow and temperature compliance) , (3 ) the CHEMICAL SYSTEM (for
color reduction) which provides for elimination of the chlorine and
hypochlorite bleaches with an oxygen delignification system and includes
all facilities necessary for handling, storage and distribution of
oxygen including oxidation of white liquor also used in the oxygen
delignification process (includes modification of the existing chlorine
dioxide generator and chilled water supply system plus construction of a
new cooling tower and mechanical chiller) , (4) the BLACK LIQUOR
EVAPORATORS (two sets rebuilt) and associated equipment including
storage and controls for prevention of chemical losses as well as color
and heat reduction, (5 ) the CAUSTICIZING EQUIPMENT to include
construction of a new drum-type dregs washer and associated equipment
for control of chemical loss and flow reduction and (6) Modifications to
the No .2 FIBER LINE (PINE) and No. 1 FIBER LINE (HARDWOOD) necessary to
guarantee successful operation of the oxygen delignification system to
include reactors, pressurized screens, pulp washers, deknotters, and all
other equipment which would be necessary for flow reduction, color
removal, chloroform and dioxin minimization required by the NPDES permit
( structures or buildings, vats, bleaching towers, and equipment needed
to house and facilitate operation of the paper making process and not
exclusively for NPDES permit compliance are excluded from this Tax
Certification) .

Page 2
Tax Certification TCS-401
Wastewater from this reconstructed manufacturing process will continue ,
to be treated in the existing wastewater treatment facility owned by
Champion International and operated under the provisions of NPDES permit
Number NC0000272 with discharge to the Pigeon River in the French Broad
River Basin.
The Environmental Management Commission and the Department of
Environment, Health and Natural Resources have found that modifications
to the industrial water pollution control program:
1 . are presently under construction,
2 . comply with the requirements of NPDES Permit Number NC0000272
as issued by the Environmental Protection Agency with an
effective date of October 25, 1989, and requirements of the
Environmental Management Commission with respect to reduction
and/or prevention of water pollution; and
3 . has as its primary rather than incidental purpose the
prevention and reduction of water pollution from the
paper manufacturing process .
Issued at Asheville, North Carolina, this the�1q�day of i�uu�, 1992
By Direction of the Environmental Management Commission and the
Department of Environment, Health, and Natural Resources.
Roy M. Davis, Regional Supervisor
Division of Environmental Management
TCS-401

State of North Carolina
Department of Environment •
and Natural Resources ;k �
Division of Water Quality
Michael F. Easley, Governor NCDENR
William G. Ross Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT-AND NATTU IAL, ES,OLI C ES1
Il L 11
11/26/2001 f` I I�—
DEC
GORDAN JONES CJi 3 2()�� /
BLUE RIDGE PAPER PRODUCTS INC _ SlJ
710 HOWELL MU-L RD -L1101!,,1 l iY S:.0 I;'!;J
Sti:
WAYNESVILLE, NC 28786 L'II!C I; Jl ;+, ;;Mr.. _
Subject: NPDES Wastewater Permit Coverage Renewal
Blue Ridge Paper Products Inc
COC Number NCG500151
Haywood County
Dear Permittee:
Your facility is currently covered for wastewater discharge under General Permit NCG500000. This permit expires
on July 31,2002. Division of Water Quality(DWQ)staff is in the process of rewriting this permit with a
scheduled reissue in the summer of 2002. Once the permit is reissued,your facility would be eligible for continued
coverage under the reissued permit.
In order to assure your continued coverage under the general permit,you must apply to the DWQ for renewal of
your permit coverage. To make this renewal process easier,we are informing you in advance that your permit
coverage will be expiring. Enclosed you will find a general permit coverage renewal application form. This
will serve as your application for renewal of your permit coverage. The application must be completed and
returned with the required information by February 01,2002 in order to assure continued coverage under the
general permit.There is no renewal fee associated with this process. Your facility will be invoiced for the annual
permit fee at a later date.
Failure to request renewal within this time period may result in a civil assessment of at least$250.00. Larger
penalties may be assessed depending on the delinquency of the request. Discharge of wastewater from your facility
without coverage under a valid wastewater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments of civil penalties of up to$10,000 per day.
If the subject wastewater discharge to waters of the state has been terminated,please complete the enclosed
rescission request form. Mailing instructions are listed on the bottom of the form. You will be notified when the
rescission process has been completed.
If you have any questions regarding the permit coverage renewal procedures please contact the Asheville Regional
Office at 828-251-6208 or Delonda Alexander of the Central Office Stormwater Unit at(919)733-5083,ext.584
Sincerely,
Bradley Bennett,Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater and General Permits Unit Files
Asheville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/10%post-consumer paper

BLUE RIDGE
PAPER PRODUCTS INC.
NOV 3 0 2001 D
November 28, 2001 VJATER QUALITY SECTION
ASHEVILLF-REGIONAL OFFICE c
Mr. Michael Myers
North Carolina Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh,N.C. 27699-1617
Dear Mr. Myers:
Blue Ridge Paper Products Inc. is providing certification that the Canton Mill's Best
Management Practices Plan has been prepared in accordance with the regulations stated
in 40 CFR 430.03. This letter is submitted in accordance with the Canton Mill NPDES
Permit NC0000272, A6 Section Fl, effective December 1, 2001.
Please find the attached certification, signed by the mill manager and the manager of the
Pulp and Recovery areas, as required by the regulation.
Please call Derric Brown at [phone] or myself at [phone] if you have any
questions or need additional information.
Sincerely,
��/��
Melanie Hager
Environmental Engineer
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone: [phone] • Fax: [phone]
Raising Your Expectations

Section 1
Review and Certification
1.1 Regulatory Requirements
Section§430.03(f),review and certification of BMP plan,states,
The BMP plan,and any amendments thereto, must be reviewed by the senior technical manager
at the mill and approved and signed by the mill manager. Any person signing the BMP plan or
its amendments must certify to the permitting or pretreatment control authority under penalty of
law that the BMP plan (or its amendments)has been prepared in accordance with good
engineering practices and in accordance with this regulation. The mill is not required to obtain
approval from the permitting or pretreatment control authority of the BMP plan or any
amendments thereto.
I,the mill manager,certify under penalty of law that this plan has been reviewed by the senior
technical manager and prepared in accordance with good engineering practices,in accordance
with 40 CFR 430.03.
Signs 'o 'ral Manager Date
ita
signature,Vice President-Mill Manager Date
BMP Plan 1-1 Blue Ridge Paper Products Inc.
1:%WPGVLIPMM71160%02UW71tsoo2-0sLnoc November 2001

BLUE RIDGE PAPER PRODUCTS INC.
copy: Mr. Keith Haynes
NC Department of Environmental,
Health &Natural Resources
59 Woodfrn Place
Asheville,NC 28801

Division of Water Quality
November 29,2001
MEMOFANDUv fi
To: Forrest Westall, ARO Supervisor NO
r Matthews V`1r
Through: Matt 1VATER
1Q SNn,•
From: Jennifer Everett
Aquatic Toxicology Unit
Subject: Toxicity testing schedule for 2nd quarter FFY 2001-2002
Aquatic toxicity testing goals for the entire Federal Fiscal Year(FFY)2001-2002 are provided in Table 2.
The requested numbers reflect our capacity to do the tests and the types of tests employed by the facilities
in your region. Our baseline goal is to evaluate 20%of the major dischargers per year so each will be
evaluated at least once during each permit cycle. The numbers of other test types may be adjusted on an as
ir testing goals by scheduling tests throughout the quarters that
needed basis. Regions may accomplish the
best accommodates their schedules and/or other constraints.
Test schedule restrictions for FFY 2001-2002 are listed in Table 1. This list reflects holidays and other
current scheduling conflicts. We are available to schedule for the entire year; however,this is not required.
ATU encourages planning as far ahead as possible and will schedule on a first request-first filled basis.
ATU will accommodate emergency response or additional testing requests on an as needed basis.
Table 3 indicates your region's total number of valid and completed tests and test types to date for FFY
2001-2002. This will help keep an accurate running tally of the toxicity testing goals.
Please be reminded:
1. To increase the probability of the split being identified and properly evaluated please indicate split
tests on the sample logs,along with the identity of the lab to receive the split. ATU uses only"true"
splits for certified laboratory evaluations. True splits are from a single grab or composite sample split
into 2 representative aliquots for analysis by ATU and the other laboratory.
2. Samples should not be collected before 10 AM,and preferably 11 AM. This is to allow adequate time
for sample delivery to ATU and preparation of samples for test initiation. The maximum holding time
for samples (prior to initiation of the toxicity test)is 36 hours for acute test samples and 72 hours for
chronic test samples. The holding time for composite samples begins at the time of collection of the
last aliquot.
3. All samples should be iced during collection and transport. Completely fill coolers with ice. This is
particularly critical for the second sample collected for chronic tests, which remain in the cooler until
delivered to ATU on Monday mornings.
I may be reached to schedule tests,or answer questions,by telephone or voice mail at(919)733-2136
x234,by fax at(919) 733-9959,or by e-mail at jennifer.ei,er'[e-mail]. Thank you for your
assistance. As always, if there is anything that ATU can do to assist with your efforts, please do not
hesitate to contact us.
cc. I€eith Haynes, AR.M

Table 1. Test schedule restrictions for FFY 2001-2002'.
Week
of: Restrictions• comments:
Nov.5,2001 No chronic tests.
Nov. 12,2001 No composite chronic tests. Grabs OK.
Nov. 19,2001 No tests.
Dec. 17,2001 No chronic tests. Fathead&Cerio acute tests only.
Dec.24,2001 No tests.
Dec.31,2001 No chronic tests.Fathead&Cerio 24hr acute grab
tests only.
Jan. 14,2002 No chronic tests.
Jan.21,2002 No composite tests. Grabs OK
Mar.25,2002 No chronic tests. 24hr acute tests only for 3/27.
May 20,2002 No chronic tests.
May 27,2002 No composite sample tests.
Aug.26,2002 No chronic tests.
Sept.2,2002 No composite chronic tests.
There are no test restrictions for weeks not listed above.
Table 2. Requested test numbers and types for the entire FFY 2001-2002'.
Facility Facility Facility Facility
Cerio Cerio Cerio Fathead Ambient
Acute Acute Chronics Acute Tests Splits
Pass/Fail LC50 Pass/Fail
ARO 1 3 10 0 2 2
FRO 0 3 8 1 3 2
MRO 0 1 14 2 2 2
RRO 0 1 10 3 3 2
WaRO 0 0 8 4 2 2
WiRO 1 0 5 4 2 3
WSRO 0 1 11 0 2 3
'October 2001-September 2002.
Table 3.Total number of com leted and valid tests to date.
Facility Facility Facility Cerio Facility
Cerio Cerio Chronics Fathead Ambient Splits
Acute Acute Acute Tests
Pass/Fail LC50 Pass/Fail
ARO 0 0 3 0 3 0
(1 in progress) (1 in-progress)

State of North Carolina
Department of Environment `
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor NCDENR
� Wim llia G. Ross, Jr., Secretary
Gregory J. Thorpe, Acting Director
August 3,2001 n
Mr. Robert Shanahan
Vice President-Mill Manager
P Blue Ridge
Paper Products
O.Box 4 00 gs9F`lFn, 9<0c2
Canton,North Carolina 28716
Subject: NPDES Draft Permit
Permit No.NC0000272
Blue Ridge Paper Products Inc.
Haywood County
Dear Mr. Shanahan:
Blue Ridge Paper Products Inc,applied for an NPDES permit renewal on February 26,2001. The Division
of Water Quality's original schedule for conducting a public hearing prior to July 31,2001 was postponed in order
to allow the EPA Tech Team and the Technology Review Workgroup the necessary time to incorporate the findings
of a third party evaluation of the Canton Mill, sponsored by the Clean Water Fund of North Carolina,American
Canoe Association,Western North Carolina Alliance,Dead Pigeon River Council,Appalachian Voices,Tennessee
Environmental Council, Southern Appalachian Biodiversity Project,Dogwood Alliance and the National Forest
Protection Council. The EPA Tech Team has completed their report and provided the Technology Review
Workgroup with the `potential' color reductions available through the application of the identified process
improvements. Based on this report,the Technology Review Workgroup developed the `regulatory'basis for
additional color reductions in this permit cycle. Now that the EPA Tech Team and the Technology Review
Workgroup's color recommendations are final,the Division of Water Quality has prepared this draft permit and
scheduled a public hearing for September 6,2001 (additional details below).
After issuing a"pre-draft"permit,the Division of Water Quality prepared this draft permit and is once
again soliciting comments from the Environmental Protection Agency,the State of Tennessee,the City of Newport,
Cocke County, and other concerned stakeholders. The Division reviewed and considered all comments received
during the"pre-draft"comment period and modified the"pre-draft"permit and fact sheet accordingly. The
modifications reflected in this draft permit include the following:
➢ The dioxin monitoring special condition has been modified. The dioxin monitoring special condition in the pre-
draft permit allowed the permittee to split samples. If the analysis of either sample was below the minimum
level,then the quality was considered zero for compliance purposes. The Division received concerns over this
allowance and has modified the condition accordingly. The decision to split samples is at the discretion of the
permittee,if samples are split,the permittee must report both values and compliance shall be judge on each
sample independently.
➢ Dates that have passed have been deleted from the Best Management Practices Special Condition.
➢ Special Condition A. (8.)Requirements for Color Analysis and Compliance have been added. Based on the
recommendations of the Technology Review Workgroup and the EPA Tech Team Report,the Division of
Water Quality has developed the recommendations for additional color removal over the term of the permit.
The color reductions contained in this condition represent a 19%to 29%reduction in the current permitted color
load. After Blue Ridge Paper has implemented the process improvements necessary to achieve color reductions
within the targeted range,Blue Ridge Paper will evaluate the feasibility of complying with North Carolina's
1617 MAIL SERVICE CENTER,RALEIGH,NORTH CAROLINA 27699-1617-TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER-50%RECYCLED/10%POST-CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Permit Number: NC000O272
color standard. Then during permit renewal process in 2006,the Division of Water Quality and the NPDES
Committee will evaluate what additional reduction,if any, are required in order to achieve compliance with
North Carolina's color standard.
Below are the Division's responses to comments received on the pre-draft permit.
➢ There were concerns over the language in the Best Management Practices Special Condition,these include:
- Special Condition A. (6.)Section A. 1,the wording"to the maximum extent possible as determined by
the mill. The language and conditions set forth in the Best Management Practices Special Condition
were developed by the EPA as part of the new Effluent Guidelines for the Pulp and Paper Industry.
After extensive research and gathering of public comment,the EPA stipulated an industry standard for
Best Management Practices. The language contained in Special Condition A.(6.)is consistent with
the industry standard as published in the Code of Federal Regulations. Since Blue Ridge Paper meets
or exceeds the Best Management Practices standards,the Division does not feel that requiring a higher
standard is justified at this time.
- Special Condition A. (6.)Section E.3,the language"failure to take the actions required by Section E.2
as soon as practicable will be a permit violation". The comment was made that this language is
unenforceable. In addition to the comment made for Special Condition A.(6)Section E.3,it is the
Division's understanding that the language in Section A. (6.)E.3 "failure to take the actions required
by Section E.2 as soon as practicable will be a permit violation", is a`good faith' condition and that
any gross violations of this condition are enforceable.
- Monthly reporting of`action' level exceedence was recommended. In addition,to the comment made
for Special Condition A. (6.) Section E.3,please refer to the Best Management Practices Special
Condition Paragraph E. This condition requires that Blue Ridge Paper submit an annual report to the
Division of Water Quality that summarizes Best Management Practices monitoring and action levels.
The longer time frame(annual as opposed to monthly)associated with the annual submittal required in
Special Condition A. (7.)provides the Division with a more representative analysis of operations at the
mill and is better suited for analysis and conclusions. Therefore,the Division feels that annual
reporting is appropriate.
➢ Comments were made regarding the daily maximum BOD5 limit proposed in the pre-draft permit. The
Division's review of the instream dissolved oxygen data indicates that the limits and conditions in the permit
are protecting the dissolved oxygen standard in the River. Additionally,the Division's model predicts and
actual data supports that the lowest dissolved oxygen concentrations occur at river mile 57.7,which is above
Hepco.
➢ The Division received comments regarding the need for nutrient limits in permits above the lake. The Division
has no evidence that nutrients are a concern in this watershed. Additionally,Blue Ridge Paper's nutrient
loading is relatively low,however,nutrient monitoring will continue as a condition for this permit in order to
assess Blue Ridge Paper's nutrient loading to the River.
➢ The Division received comments regarding the removal of the monitoring station at river mile 53.5. Blue Ridge
Paper currently is monitoring color,temperature,and dissolved oxygen at river mile 53.5. Temperature and
dissolved oxygen monitoring at this point is required according to the NPDES permit issued to the City of
Waynesville. Since Waynesville is already required to monitor this station, it is the Division's recommendation
that additional monitoring of temperature and dissolved oxygen by Blue Ridge Paper is not appropriate.
The color monitoring at this station was originally implemented in order to assess the impacts from Clyde's,the
Waynesville and Richland Creek. With the removal of Clyde's discharge,the Division feels that the continued
monitoring of color at river mile 62.9 (Fiberville)and river mile 42.6(Hepco)is sufficient.
➢ The Division received a request to require dioxin isomer monitoring of the octachlorinated dioxin isomers at the
internal outfalls,sludge and landfill leachate. The Division also received opposing comments suggesting that
the dioxin and furan monitoring proposed in the pre-draft unnecessary. During the previous permit cycle,Blue
Ridge Paper was required to monitor 15 isomers of dioxin and furans. Based on a review of this data and the

Permit Number: NC0000272
public comments received,the Division recommends continued monitoring of 2,3,7,8,TCDD and 2,3,7,8 TCDF
on the effluent,sludge,landfill leachate, and the influent to the wastewater treatment plant.
Please review the draft permit and fact sheet carefully and submit comments to DENR-DWQ NPDES
Unit. This draft permit should not be interpreted as the Division and NPDES Committee's final decision. A 30-day
public comment period follows the release of this draft permit and will close at the discretion of the hearing officer
and will be announced at the beginning of the public hearing to be held on September 6,2001. The details on where
and when the hearing will be held is listed below:
Public Hearing on regarding the Blue Ridge Paper Products Canton Mill's NPDES discharge will be held:
September 6,2001 @ 7:00 pm
at the
Tuscola High School Auditorium
564 Tuscola School Road
Waynesville,North Carolina
Haywood County
If you have any questions concerning the draft permit for your facility,please call me at(919)733-5083,
extension 508.
Sincerely,/
Michael J. Myers, EIT
NPDES Unit
cc: Central Files
NPDES Files
Aquatic Toxicology Unit
Marion Deerhake - North Carolina Environmental Management Commission, NPDES Committee
Jerry Wilde- Dead Pigeon River Council
402 W. Broadway
Newport, Tennessee 37821
Forrest Westall -Asheville Regional Office/Water Quality Section
Dan Oakley- North Carolina Attorney General, Environmental Division
Keith-Haynes -Asheville Regional Office/Water Quality Section
Rob Lang - Compliance and Enforcement Unit
Diane Reid- Classification and Standards Unit
Roosevelt Childress Jr. - Environmental Protection Agency, Region IV
Karrie-Jo Shell - Environmental Protection Agency, Region IV
Don Anderson-Environmental Protection Agency, Headquarters
Mark Perez- Environmental Protection Agency, Headquarters
Justin P. Wilson- Deputy to the Governor
Tennessee State Capital, Suite G10
Nashville, Tennessee 37243
Paul Davis -Tennessee Division of Water Pollution Control
6th Floor, L&C Annex
401 Church Street
Nashville, TN 37243-1534
Charles Lewis Moore- County Executive Cocke County
360 Main Street, East
Newport, Tennessee 37821
David Jenkins-American Canoe Association
7432 Alban Station Boulevard,Suite B-232
Springfield,Virginia 22150-23 11

Permit Number: NC0000272
Hope Taylor- Clean Water Fund of North Carolina
29 iA Page Ave
Asheville, North Carolina 28801
David McKinney —Tennessee Wildlife Resources
Ellington Agricultural Center
P.O. Box 40747
Nashville, Tennessee 37204
Jonathon E. Burr—Tennessee Division of Water Pollution Control
Regional Environmental Assistance Center
2700 Middlebrook Pike, Suite 220
Knoxville, Tennessee 37921
Robert Williams—Blue Ridge Paper
175 Main Street
P.O.Box 4000
Canton,North Carolina 28716
Derric Brown—Blue Ridge Paper
175 Main Street
P.O.Box 4000
Canton,North Carolina 28716
Patsy R.Williams—Chairman Newport/Cocke County Tourism Council
360 East Main Street
Court House Annex,Suite 141
Newport,Tennessee 37821
Dianne Keys—Newport/Cock County Tourism Council
360 East Main Street
Court House Annex, Suite 141
Newport,Tennessee 37821
Timothy L.Dockery—Director
City of Newport
Parks and Recreation Department
433 Prospect Avenue
Newport,Tennessee 37821
A.Dean Williams—Coordinator
Newport/Cocke County Economic Development Commission
433 Prospect Avenue
Newport,Tennessee 37821
Ray Sunder—News Director
WNPC Radio AM/PM
377 Graham Street
Newport,Tennessee 27821

Permit Number: NC0000272
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANTDISCHARGE ELIMINATION SYSTEM
F
In compliiththe prov sion of Norj�Carolina�Gel\Statute 43�215.1, other lawfuld
regulations promulgated land adopted by the North darbli a Envir nmental Management on mission,
and the Federal Vlkate Po lu�ion-Control Act as ameded\
�1 Blue 72�idge �Paper�Products Inc.
is ereb authorize to discharge was\w\er from a fac' ility lc c\ed at
� u �u u
Blue Ridge Paper Products Inc.
Canton Mill Wastewater Treatment Plant
Off Highway 215
Canton
Haywood County
to receiving waters designated as the Pigeon River in the French Broad River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, III and IV hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on November 30, 2006.
Signed this day D
-A-
Gregory J.Thorpe,Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Number: NC0000272
SUPPLEMENT TO PERMIT COVER SHEET
Blue Ridge Paper Products,Inc.
is hereby authorized to:
1. Continue operation of a 29.9 MGD wastewater treatment plant for the treatment of wastewater
associated with the Blue Paper Products Inc. pulp and paper mill, the Town of Canton's
chlorinated domestic wastewater and landfill leachate. The treatment system consists of the
following treatment units:
Grit Chamber
• BaY creen
Lift
• Poly er��addtio
• pH contrbl ( C injection r 2SO4 bac up)
Threelpri a c ari iers
• Nutrient
Aeratio basins
Three s2con I clarifiers
Resi al beltrsses
uent flov+Lmeasurement
• Cascade post aeration with oxygen injection
• Instream oxygen injection facilities
The facility is located at the Blue Ridge Paper Products WWTP, off Highway 215, Canton,
Haywood County, and;
2. Discharge treated wastewater from said treatment works at the location specified on the attached
map through outfall 001 into the Pigeon River, which is classified C water, in the French Broad
River Basin.
DD �
D

.` f1 y� ��J _ l J� `� _LII• 1 _ �.
IL
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• Blue Ndge Paper's Outfall Facility Information
French Broad Hydrography Blue Ridge Paper Products Inc. State Grid: E 7 SE
/�/FS USGS Quad: Canton
/V NR NC0000272 Subbasin: oa• M5
�,PS Haywood County '
/\iMu
. �d Munidpal Boundaries �sR 3
County Boundary
N 0.5 0 0.5 1 Miles BLUE RIDGE PAPER PRODUCTS INC.
A

Permit Number: NC0000272
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge treated industrial,municipal,stormwater and landfill wastewater through
outfall(s) 001. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics Effluet Limits Monitoring Requirements
Monthly Daily _ Measurement Sample Type Sample
Average Mazimutu Frequency Locationi
Flow 29.9 MGD Continuous Recording I or El
BOD, 5-day,20°C 3205 lb/day 10897 lb/day Daily Composite I,El
Total Suspended Residue 12549 lb/day 49560 lb/day Daily Composite I,E,
NH;-N Daily Composite Et
AQX r 1-556 9-Ib/day 2822.2 lb/,days Daily,—Composite. Er—
Co)or \ / , \ Dailyl -__QompA itelL
Di;solvedOxygdr \ \ / J\ Daily) I Grab I El
WCrature \ \ J / \ \ Dailyl I Grab I El
Dailyl L Grab i EI
Coitddctivity f / J I \ Daily Grab F El
Fecal Coliform I ( 200h100\mI 4007 100-m \Weekly I Grab EI
CQD I / / \ \ / r- — Weekly I Composite I El
Sirier� / ! \ \ / j \Quarterly I Composite El
Zinc / ( \ / / Quarterly I Composite l El
L------------ I u
Total Nitrogen
(NO2-N+NO3-N+TKN) Monthly Composite E
Total Phosphorus Monthly Composite El
Chronic Toxicity Quarterly Composite El
Cadmium Quarterly Composite El
Trichlorophenol 3.0 pg/L Quarterly Composite El
Pentachlorophenol 8.9 pg/L Quarterly Composite El
Selenium 10.6 µg/L Quarterly Composite Et
2,3,7,8 Tetrachloro-dibenzo- 0.014 pg/L, Quarterly Composite I,Et
p-dioxin10
Conductivity Daily Grab Pigeon River
Flow Daily Grab Pigeon River
Fecal Coliform Weekly Grab Pigeon River
Color Variable Grab Pigeon River
Temperature Variable Grab Pigeon River
Dissolved Oxygen Variable Grab Pigeon River
Footnotes:
1. Sample Location: I-Influent,El-Effluent,Pigeon River-Instream sampling as specified in A.(5.)Instream
Monitoring Special Condition.
2. AOX monitoring shall be in accordance Iitlty!I �It'e Sampling-PIAClustfr/ le Pazamefe�da ef-d arch 19,
2001)or subsequent modifications approved by the'Divi ion. data 2a�l�e su{miffed on a qu erly basis
along with other Effluent Guideline chem cal data; e er to Auedt Guutdeline Sam ling Plan pecial
Condition. /
3. See A. (8.) Color Analysis and Complian-e Special ,I dttion. \
4. The daily average effluent dissolved oxygen concentration shall not be ess than 6=0 mg/L. See A. (jl .)
Dissolved Oxygen Special Condition.
5. See A. (13.) Temperature Variance Review Special Condition.
6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0(on the standard units scale).
7. Chronic Toxicity(Ceriodaphnia)at 90%Effluent Concentration: March,June, September, December(see A.
(4.)Chronic Toxicity Permit Limit(Quarterly)).

Permit Number: NCOOOO272
8. Trichlorophenol and Pentachlorophenol limits and monitoring are provisionally waived since the facility has
certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include
chlorophenolic biocide,the Permittee shall notified the Division prior to use and the limits and monitoring
requirements shall become immediately effective.
9. If after 18 months selenium has not been detected,the facility may request that the Division review selenium
data for possible removal of the limitation.
10. See A. (9.) Dioxin Monitoring Special Condition.
11. See A. (5.) Instream Monitoring Special Condition.
See A. (6.) Best Management Practices(BMP) Special Condition.
See A. (11.) Town of Canton Inflow and Infiltration Special Condition.
Definitions:
MGD—Million gallons per day lb/day—Pounds per day
mlwlil t tti"1"er" OD—Bloch mica xygen a and
ggL;Miurwgramss er liter AAOX-Adsorbable-Organic1,161id
C D-Chemical�xyaen de �� g)L.-picograms]per liter
l .
/�__

Permit Number: NC0000272
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration, the
discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
outfall(s) 002 (E21),shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
Effluent Characteristics Limits Monitoring Requirements'-',
Monthly' Daily Measurement fSempleType3 Sample
Average Maximum Frequency Location,',-
Flow Weekly Calculated E2
Chloroform 5.15lb/day 8.60lb/day Weekly Grab E2
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E2
p-droxm DD)\
p-�7,8-Tetrachl ro dibenzol 31.9 pg/L/ 5 Monthly i Composime
tran(TCDF)� ( 1 J \
Trichlorosyringol , , 1 )< 2.5 µg%L5/ Nonthly I 1 Composite E}
3,1,5-�richlorocatecho� i /< 5.0 It Mpnthly I o—C mposlPe E}
3,1,6-Trichlorocateehof I < S.F dnthly I omposi a E}
3,j,5-Trichloroguaihc9l I \ < 2. `µg/I— Monthly I I Composite El
3,4,,6- richloroguaiaFol I l �< 2/`5 µg/L Monthly Composite E}
4,1,6-Trichloroguaiacol I \ �2.5µg/L5 Monthly I Composite E#
2,4,5-Trichlorophenol < 2.5 µg/LS Monthly Composite E2
2,4,6-Trichlorophenol < 2.5 µg/L5 Monthly Composite E2
Tetrachlorocatechol < 5.0 µg/LS Monthly Composite E,
Tetrachloroguaiacol < 5.0 µg/L Monthly Composite E2
2,3,4,6-Tetrachlorophenol < 2.5 µW Monthly Composite E2
Pentachlorophenol < 5.0 pg/L' Monthly Composite E2
Footnotes:
1. Sample Location: E2—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100 and from tap installed on filtrate pump from C102
bleaching stage D-2)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E.). See A. (7.)Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters (Internal Outfall 002 parameters+internal Outfall 003 parameters+AOX from Outfall
001)shall be reported on a quarterly basis or more frequently;refer to A. (7.)Effluent Guideline Sampling Plan
Special Condition.
3. Sample Type: Calculated- calculate separate flows for alkaline and acid sewers by water balance, and report
total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab samples every 4-
hours for 24-hour period from both the acjd-and-alkaline,streams which will-`then be-¢omposited-saparatel�ra
the lab,and analyzed as separate 24-hr corn osite-ad'd and�lkalin6samplest Composite=collecCseparategrab
samples every 4 hours for 24-hour period m botljme acid and alkaline/stye s,tliep pre and at{alyze a
single flow-proportioned composite ofth rid and�I a�riewastteestreattt./ \ l
4. For compliance purposes,the permittee m t report ithe tal chlo oform massloadir g based on addition of
separate acid and alkaline chloroform mass oadm s \
5. Limits are based on Minimum Levels (M)).speci ie�in I i CFR
Definitions:
lb/day—Pounds per day pg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NC0000272
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
outfall(s) 003 (E31), shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
Effluent,Characteristics Limits Monitorir g Require-mer ts'
Monthly Daily Average Measurement_ Sample Typ6l., Sample
Average Frequency _ Location'
Flow Weekly Calculated E3
Chloroform 7.141b/day 11.93lb/day Weekly Grab E3
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E3
p-cjtoxm CDI3)\ ....... F F1 —
2,3,7,8 T-etrachl ro-2libenzo= �\ 31.9 p r Monthly t
P-furan(TCDF) I 1 \ \ �omP�s�
I
Tr(chlbrosyringol , Ik 2.5 µg1L5� Monthly I Composite E#
3, ,5- richlorocateehol < 5.0µ-kfLjs Monthly I o`C-mposit'e Ei
3,4,6-xrichlorocatechol I —\ ` < 5.0 µgm d{thly Composite Ei
3,4,5-�richloroguaiac9l < 2. gµg/L--1 mithly I Composite Ei I
3,4,6-xrichloroguaiaeol I \< Ej I,jVLMonthly Composite
4,5,6-Trichloroguaiaco1 ( 1.5�g/LS Mohthly I Composite E
2,4,5-Trichlorophenol < 2.5 µg/L5 Monthly Composite E3
2,4,6-Trichlorophenol < 2.5 µg/LS Monthly Composite E3
Tetrachlorocatechol < 5.0 µis Monthly Composite E3
Tetrachloroguaiacol < 5.0 µg/L' Monthly Composite E3
2,3,4,6-Tetrachlorophenol < 2.5 µg/L' Monthly Composite E3
Pentachlorophenol < 5.0 µg/L' Monthly Composite E3
Footnotes:
1. Sample Location: E3-Effluent is composed of Bleach Plant Effluent-acid (acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100)and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage E.). See A. (7.)Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters(Internal Outfall 002 parameters+ internal Outfall 003 parameters+AOX from Outfall
001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)Effluent Guideline Sampling Plan
Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance,and report
total bleach plant flow (acid+alkaline wastestreams)in DMRs. Grab-collect separate grab samples every 4-
hours for 24-hour period from both the acid-andalkaline streams�which will then b -composited-separatel by
the lab,and analyzed as separate 24-hr com osite acd mil-alkaline�samples 1Composite=colle�ctse arate'grab
samples every 4 hours for 24-hour period P'om both the a d and Naline slte s,the p prepare and aat�alyze a
single flow-proportioned composite of the aLid and��ialine cvastes�a ./
4. For compliance purposes,the permittee must report't17�e tlotlal ch o ofo mass load' rsed on add DIn of
separate acid and alkaline chloroform mass �oadm S.
5. Limits are based on Minimum Levels(MI. s ec 5�d in I 0 CFROY
Definitions:
lb/day-Pounds per day µg/L-Micrograms per liter
pg/L-Picograms per liter

Permit Number: NCOOOO272
A. (4.) CHRONIC TOXICITY PERMIT LIMIT(QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubs at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarterl monitoring using test procedures outlined in the"North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised February 1998,or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent
versions. The tests will be performed during the months of March,June, September,December.Effluent sampling
for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit,then multiple-concentration testing shall be performed at a minimum, in each of the two following months as
described in"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or
subsequent versions. � � ��
The c' Ironic value Por multiple onc' enration tests will be d tf erm\n ned using a geometdc_meanlnfSh gh�st_J
co~lce{ttration ha ng�io detect ble impairment f reproduction or,survival ayd the lowest concentration that does
hate detectable impa rmerit o reproduction o�survivaIJ e deft ition offe't
etectable impairment,"cc leclion
methods,exposure�egzes,Ian further statistical methods re specnified in orth Carolina Phase II Chronic
Whol�I Effluent Toxtci . TestProcne ui�(Revised-February 199$)arr subsent versions.
Al�to�Cicity testing�jTF�es.tIts r Iqu ed as pa ofiithis perm,t condition ilk be entered on the Effluent Disch Lin
pM(,nitormg Form I+YLLr-1)for a months in this
tests pvere perforitedt using the parameter code TGP3�B or the
ass/f it re ,a d�'HP3B fo the Chroni Va ue. dditionally,D Q FormI &I -3 (original)is to be sent the
following addres . pL( LJ U
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center.
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data,and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,the
permittee will complete the information located at the top of the aquatic toxicity(AT)test form indicating the
facility name,permit number,pipe number,county,and the month/year of the report with the notation of"No Flow"
in the comment area of the form.The report shall be submitted to the Environmental Sciences Branch at the address
cited above.
Should the permittee fail to monitor during onth-in- hic toxicity onitoring s required xrtonitoring with e
required during the following month. 1
Should any test data from this monitoring requirnment�s [er�on)iied by' e prth C ro ma ivisio f Water
uali ind'c I J — � \ i
Quality indicate potential impacts to the recei�m stream, hisermit may be re-opened and modified to include
alternate monitoring requirements or limits. I ��� ` I ppA\ -
NOTE: Failure to achieve test conditions as specified in the cited document,such as minimum control organism
survival,minimum control organism reproduction,and appropriate environmental controls,shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Permit Number: NC0000272
A. (5.) INSTREAM MONITORING SPECIAL CONDITION
Stream Mile Location Description Parameter Frequency
Designation Marker
UP 63.8 Pigeon River upstream of the Temperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the Conductivity Daily
discharge) Color 2/Week
Flow' Daily
Fecal coliform Weekly
DNl 62.9 Pigeon River at Fiberville Bridge Temperature Daily
D.O. Daily
Conductivity Daily
Color ' 2/Week
DN2' 57.7 Pi eon River Above Cl de Tem ain D it
_r\ _g \ y`� D.Opl Daily
D143 I \55\5 1 1 Pigeon Rivets Below Clyde\ \ See Footnote 3 See Fo6tn to 3
D 4 13.1 I Pigeon River at NCS7175; \ See Fpoti ote 3 See Fogtn¢te 3
bridge 1
DN5 42.6 Pigeon Ri r at Hepdo / \ \11D.
Temperature WeeklO. !! Weekly
Color 21WCe
Daily
< � J Waterville Reservoir \ See Footnote 4 Annually
DN6 /26.0 U Pigeon Ri er promo mixing with�C or Variable)
Big Creek
BC —26.0 Mouth of Big Creek prior to Color Variable
mixing with the Pigeon River
DN7 24.7 Pigeon River at Browns Bridge Temperature Weekly
(—NC/TN State Line) D.O. Weekly
Color Variables
All instream samples shall be grab samples.
1. Color(See A. (8.) Color Analysis and Compliance Special Condition) All instream samples collected
shall be representative of the Pigeon River and Big Creek, respectively. Both true and apparent color
shall be monitored using the methods specified in A. (8.) Color Analysis and Compliance Special
Condition. Samples shall be collected at stations DN6, BC, and DN7 only when at least one generator
at CP&L is in operation and releasing water to the Pigeon River.
2. Flow monitoring is necessary, as specified above, for the True Color calculation stipulated in A. (8.)
Color Analysis and Compliance Special Condition.
3. Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9
(DNI), 57.7 (DN2), shall not be less than 5.0 mg/I and the instantaneous minimum dissolved oxygen
concentration shall not be less than 4.0 mg/I (See A. (10.) Dissolved Oxygen Special Condition). If
the dissolved oxygen drops below 5.0 g/L a tation�then monitoring halLbe_ equir d ae a tations
55.5 (DN3)and 53.5 (DN4). \1 ,
4. See A. (12.) Waterville Reservoir Sam ling S�ie�i I GondOn. //\\
5. Sampling is required 2/week during the summerlani ohn per week-during t e wt�r. Sum er is
defined as the period from April 1 th o gh Oc ob n 31, htle nter `11eu ed as Novent er 1
through March 31. u U Ll

Permit Number: NC0000272
A. (6.) BEST MANAGEMENT PRACTICES (BMP) SPECIAL CONDITION
The permittee must implement the BMPs specified in Section A below. The primary BMP objective is to
prevent leaks and spills of spent pulping liquors, soap, and turpentine. A secondary objective is to
contain, collect, and recover at the immediate process area, or otherwise control, those leaks, spills, and
intentional diversions of spent pulping liquor, soap, and turpentine that do occur. BMPs must be
developed according to best engineering practices and must be implemented in a manner that takes into
account the specific circumstances at the mill.
Section A. BMP Implementation Requirements
1. The permittee must return spilled or diverted spent pulping liquors, soap, and turpentine to the
process to the maximum extent practicable as determined by the mill, recover such materials outside
the process, or discharge spilled or diverted material at a rate that does not disrupt the receiving
was ewater treatments s em.
Y
2. The-permittee ust eetablish-a'pro am to identi n repair lea ing-equipmen items-T is�pmgram
it ust include: (i Reglil daily visIl inspection of rocess area with equipment items in spent
pulping liquo)r, soap, fan turpentine.,service; (ii?Iipm�ediate repairof leaking equipment it in ,when
possible. LeakinF egmpment-ite��at cann9 be repaired durin nornra}-operations mus be
identified,terr�poraryi mean s-f�r mitigating the leaks mSst be pro ided end-thelleaking egipment
items repairer(ddring the next maintenance outs e; ur Identific tion of conditions under lwliich
production ill be curtailed or ha)ted to repair//e- k�uipmen items or to prevent pulp ng�liquor,
soap,and-turpentine ntine leaks and spills;a d v) A means fbr�trackiAg�epairs over time to id�ntify those
equipmenti ems where pgrade or replacement maybe warrante based on frequency and,severity of
leaks, spills, or failures.
3. The permittee must operate continuous,automatic monitoring systems that the mill determines are
necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap,
and turpentine. These monitoring systems should be integrated with the mill process control system
and may include, e.g.,high level monitors and alarms on storage tanks; process area conductivity(or
pH) monitors and alarms; and process area sewer, process wastewater, and wastewater treatment plant
conductivity(or pH)monitors and alarms.
4. The permittee must establish a program of initial and refresher training of operators,maintenance
personnel, and other technical and supervisory personnel who have responsibility for operating,
maintaining, or supervising the operation and maintenance of equipment items in spent pulping
liquor, soap, and turpentine service.The refresher training must be conducted at least annually and
the training program must be documented.
5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor, soap, or
turpentine that is not contained at the immediate process area and any intentional diversion of spent
pulping liquor, soap, or turpentine that is not contained at the immediate process area. The report
must describe the equipment items involved,the circumstances leading to the incident,the
effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion,
and plans to develop changes to equipment and operating and maintenance practices as necessary to
prevent recurrence. Discussion of the�eports roust)e-included as paMof the annual Tefresher�ning.
6. The permittee must establish a program tore ie any planned mo ifications o the pulpm and
chemical recovery facilities and any c structio activities inithe p�hping a d chemical rec� very areas
before these activities commence. Th urpose f$uch-��(iew i�tQRrev�entjleaks-a d spil�s�of spent
pulping liquor, soap, and turpentine dui ng thelp anned ifications;-an to ensure that cpnstruction
and supervisory personnel are aware of iossib�e liqu r dive s'o�S and oft a requirement to revert
leaks ands ills of spent pulping li uois so�and t p entire du�in consttulction.
P� P P P g q A rP g
7. The permittee must install and maintain secondary containment (i.e., containment constructed of
materials impervious to pulping liquors) for spent pulping liquor bulk storage tanks equivalent to the
volume of the largest tank plus sufficient freeboard for precipitation.An annual tank integrity testing
program, if coupled with other containment or diversion structures, may be substituted for secondary
containment for spent pulping liquor bulk storage tanks.

Permit Number: NC0000272
8. The permittee must install and maintain secondary containment for turpentine bulk storage tanks.
9. The permittee must install and maintain curbing,diking or other means of isolating soap and
turpentine processing and loading areas from the wastewater treatment facilities.
10. The permittee must conduct wastewater monitoring to detect leaks and spills, to track the
effectiveness of the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must
be performed in accordance with Section E.
Section B. BMP Plan Requirements
1. The permittee must prepare and implement a BMP Plan. The BMP Plan must be based on a detailed
engineering review as described in this section. The BMP Plan must specify the procedures and the
practices required for the mill to meet the requirements of Section A,the construction the mill
determines is necessary to meet those requirements including a schedule for such construction, and
the monitoring program including the statistically derived action levels that will be used to meet the
xequuireemmen 'sof Section E. The BMA�lan also in st s ecify the eriod of time that the Ttthe
d tee rmine the\actionI lefels� e b s etl under Sect' n b may be mdeeded without trigresponses spccihed in Section E.2. Tre permitteemist conduct a detjCed�enginee re `i` of the�ullpingandchemical
operations--including but not limited�to process gwpment, storage tanks, pipelines and pumping
s stems, loading�and nloadm'g fa ities, and other-appurtcnant pulp'ing and chemical recove7
equipment itemin spent pulpinliquor, soap,pnd-turpentine service--for, the purpose of determining
the magnitude and routing of poteI tial�leaks, spills, and intentional diversions of spent pulping
ligtt6 p nd to eritine during�the'fo 64ing periods f d eration: (i) Process start-ups and shut
owns;(ii)'h�laintenance; (iii)Production-grade changes;�ivjPStorm or other weather events; (v)
Power failures; and (vi)Normal operations.
3. As part of the engineering review, the permittee must determine whether existing spent pulping liquor
containment facilities are of adequate capacity for collection and storage of anticipated intentional
liquor diversions with sufficient contingency for collection and containment of spills. The engineering
review must also consider: (i)The need for continuous, automatic monitoring systems to detect and
control leaks and spills of spent pulping liquor, soap,and turpentine; (ii)The need for process
wastewater diversion facilities to protect end-of-pipe wastewater treatment facilities from adverse
effects of spills and diversions of spent pulping liquors, soap, and turpentine; (iii)The potential for
contamination of storm water from the immediate process areas; and(iv) The extent to which
segregation and/or collection and treatment of contaminated storm water from the immediate process
areas is appropriate.
4. The permittee must amend its BMP Plan whenever there is a change in mill design, construction,
operation, or maintenance that materially affects the potential for leaks or spills of spent pulping
liquor,turpentine, or soap from the immediate process areas.
5. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP
Plan is prepared and, except as provided in Section BA., once every five years thereafter. As a result
of this review and evaluation, the permittee must amend the BMP Plan within three months of the
review if the mill determines that any new or modified management practices a�ineered controls
are necessary to reduce significantly t like`h od or'spent ulping iquor, soap,-and tucpe`— n�leaks,
spills, or intentional diversions from tTimmed at process a eas,h �yding a schedule for)
implementation of such practices and dntrols.� } J /Jl
6. The BMP Plan, and any amendments hereto mdst b�rev\��wed by the se�nio ec mcal manager at the
mill and approved and signed by the i mama a. r. ny persQn�ignmg then or its
amendments must certify to the Divi on_undec pe a ty of IatiJ,that the B11 P �1 Mn(or its amdndments)
has been prepared in accordance with good engineering practices and in accordance with this
regulation. The permittee is not required to obtain approval from the Division of the BMP Plan or any
amendments thereto.

Permit Number: NC0000272
Section C. BMP Recordkeeping Requirements
1. The permittee must maintain on its premises a complete copy of the current BMP Plan and the
records specified in Section C.2 and must make such BMP Plan and records available to the Division
for review upon request.
2. The permittee must maintain the following records for three years from the date they are created: (i)
Records tracking the repairs performed in accordance with the repair program described in Section A;
(ii)Records of initial and refresher training conducted-in accordance with Section A; (iii)Reports
prepared in accordance with Section A; and (iv) Records of monitoring required by Sections A and E.
Section D. Establishment of Wastewater Treatment System Influent Action Levels
1. The permittee must conduct a monitoring program per Section D.2,for the purpose of defining
wastewater treatment system influent characteristics (or action levels des, cribed i Section D•3. that
will trigger req�uirem nts to initiate investigation fon 13MP effect veness and to to a corrective actin .
2. Tie permittee must emp oyl the following procedure's in order to developon levels re uired by
S ction D: ) � � I /�/
Monitoring parameters.The perm/i/ttee must eolle\241-hour composite samples and analyze the
samples fora mews e-o orga`mc content/(e fig. -C—hemiSal Ox gen Demand(COD)or {ot I
Organic arbon Tqc)). Alternatively,7fie�ill-may�use a mead re related to spent pu�I ipg liquor
losses ensured continuously�anrf'�averaged over 24 ho4s (el., re
conductivity or dolor).
nttoring locations.The permittee,must conduct monitari4 ai the point influent enters the
astetvater treatment system. Forthe-purposes of this requirement, the permittee ma�select
alternate monitoring point(s) in order to isolate possible sources of spent pulping liquor, soap,or
turpentine from other possible sources of organic wastewaters that are tributary to the wastewater
treatment facilities (e.g., bleach plants, paper machines and secondary fiber operations).
3. By the permit effective date,the permittee must complete an initial six-month monitoring program
using the procedures specified in Section D and must establish initial action levels based on the
results of that program. A wastewater treatment influent action level is a statistically determined
pollutant loading determined by a statistical analysis of six months of daily measurements. The action
levels must consist of a lower action level,which if exceeded will trigger the investigation
requirements described in Section E, and an upper action level, which if exceeded will trigger the
corrective action requirements described in Section E.
4. By January 15,2002,the permittee must complete a second six-month monitoring program using the
procedures specified in Section D and must establish revised action levels based on the results of that
program. The initial action levels shall remain in effect until replaced by revised action levels.
5. Action levels developed under this Section must be revised using six months of monitoring data after
any change in mill design, construction, operation, or maintenance that materially affects the potential
for leaks or spills of spent pulping liquor,soap, or turpentine from the immediate process areas.
Section E. BMP Monitoring, Corrective gtion„aqd\\ RIe I ort 11e uireme\nts i� (
1. The permittee must conduct daily mo�qli oring 'f}h8 influeritho thl�\sfewa er�trea�ent system in
accordance with the procedures describ d in sec io far e pur o deY ctt' 'ng leaks and spills,
tracking the effectiveness of the BMP$, and deteeti treri to pent puling iquor losse[I
2. Whenever monitoring results exceed thelower acti n level\for,/the period_�f tmme specified ' the
BMP Plan, the permittee must conduct an investigation to determine the cause of such exceedance.
Whenever monitoring results exceed the upper action level for the period of time specified in the
BMP Plan, the permittee must complete corrective action to bring the wastewater treatment system
influent mass loading below the lower action level as soon as practicable.
3. Although exceedances of the action levels will not constitute violations of an NPDES permit, failure
to take the actions required by Section E.2 as soon as practicable will be a permit violation.

Permit Number: NC0000272
4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to
Section E.1. Such reports must include a summary of the monitoring results,the number and dates of
exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to
respond to such exceedances. Submission of such reports shall be annually, by March 31` of the
following year.
Section F. BMP Compliance Deadlines
1. The permittee is subject to the following BMP deadlines:
• Prepare BMP Plans and certify to the Division that the BMP Plan has been prepared in
accordance with this regulation not later than the permit effective date.
• Implement all BMPs specified in Section A that do not require the construction of containment or
diversion structures or the installation of monitoring and alarm systems not later than the permit
effective date.
Estali h initial action levels req 'red by Section D not later an the ermit a fective date.
• Commence operatio�i of any a or upgraded c�inuous, an orrtatic monitoring~s that the
mill dete�lril,es ti)b� necessary nder Section�A (other than those associated with con truction of
containment or dive s st`c ))not la cr than:tlie permit� mg e ective date.
Complete= stri ction and commence operation of any spen pulp liqu r, collectio ,
contaimn"Intlldiversion, ot-gt�r facilities; including anY associated continuous monitoring
systems,pecessa, t�fully impi n d MPS-specified\ 1p Sectio A not later than the permit
effective da4e.L-Es I ` Il
tab revisedTac ion levels regmre b/Section D as soon as)ossible after fully im lementing
the$ - s specified-in Section A�b4bof later than January 15;2002. u
Submit Annual Reports required by Section EA to the Division by March 31'of the following
year.
Section G. BMP Definitions
1. Action Level: A daily pollutant loading that when exceeded triggers investigative or corrective action.
Mills determine action levels by a statistical analysis of six months of daily measurements collected at
the mill. For example,the lower action level may be the 75th percentile of the running seven-day
averages (that value exceeded by 25 percent of the running seven-day averages)and the upper action
level may be the 90th percentile of the running seven-day averages(that value exceeded by 10
percent of the running seven-day averages).
2. Division: North Carolina DENR,Division of Water Quality, 1617 Mail Service Center, Raleigh,
North Carolina 27699-1617.
3. Equipment Items in Spent Pulping Liquor, Soap, and Turpentine Service: Any process vessel, storage
tank,pumping system, evaporator, heat exchanger,recovery furnace or boiler,pipeline, valve,fitting,
or other device that contains, processes, transports,or comes into contact with spent pulping liquor,
soap, or turpentine. Sometimes referred to as "equipment items."
4. Immediate Process Area: The location at the mill where pulping, screening,knotting, pulp washing,
pulping liquor concentration, pulping i uor_prgceslsin�gra�chemica recove , -faciliti'e—s a e�lo ted,
generally the battery limits of the afore entio�ed grQcess .�:Imm�dlate pro ess area" in ludes spent
pulping liquor storage and spill contrq�I anks locat Idttat-th mill,}v Seth or not are lgci ted in the
immediate process area. I-
5. Intentional Diversion: 'Inc planned rem valqf�pint pulpit liquor sod ,`o�i rpentine from
equipment items in spent pulping liqu r,_soap,, or rpentine�service by t e;mi I for any purpose
including, but not limited to, maintenance, grade changes, or process shutdowns.
6. Mill: The owner or operator of a direct or indirect discharging pulp, paper, or paperboard
manufacturing facility subject to this section.
7. Senior Technical Manager: The person designated by the mill manager to review the BMP Plan. The
senior technical manager shall be the chief engineer at the mill, the manager of pulping and chemical

Permit Number: NC0000272
recovery operations, or other such responsible person designated by the mill manager who has
knowledge of and responsibility for pulping and chemical recovery operations.
S. Soap: The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the
wood, which precipitate out when water is evaporated from the spent pulping liquor.
9. Spent Pulping Liquor: For kraft and soda mills "spent pulping liquor" means black liquor that is used,
generated, stored, or processed at any point in the pulping and chemical recovery processes.
10. Turpentine: A mixture of terpenes, principally pinene, obtained by the steam distillation of pine gum
recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft
pulping process. Sometimes referred to as sulfate turpentine.
D -RA

Permit Number: NC0000272
A. (7.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION
The bleach plant effluent samples (Outfalls 002 and 003) shall be analyzed for 2,3,7,8-TCDD in
accordance with EPA Method 1613. A single sample, from each of the bleach plant effluents, may be
analyzed to determine compliance with the daily maximum effluent limitation.
The bleach plant effluent samples (Outfall 002 and 003) shall be analyzed for the 12 chlorinated phenolic
compounds in accordance with EPA Method 1653. A single sample, from each of the bleach plant
effluents,may be analyzed to determine compliance with the daily maximum effluent limitation. The
Minimum Levels for each of the 12 chlorinated compounds are the same as the Daily Maximum
concentrations listed on the effluent pages for the respective outfall(s).
The final wastewater treatment plant effluent sample(Outfall 001)shall be analyzed for AOX in
accordance with EPA Method 1�650, or subsequenttest methods approved by the Division.
Tl�e plermittee,�a request future e'nronitor�g modificat� ions to the E uent-Guideline requirement ,
including 1) usebf ECF certification in)ieu ofmoniioring kr chloroform in the bleach plant effluents
g coin g
I
(Outfall(s) 002 and 003)when this rule is promulgated b}�EPA; )2 demonstratin liance sin
i I I p I l
samples collectedhess frequently-than every four}}ours;3)`us'mg automated-composite volatile samplers
foi chloroform sampling; an(14)-u m utomated/co posit samplers for-ehlorophenolic, 2,38 TCDD
and 2�3,7,8 TCDh safnpling. Suchfutur@@ requests will be evaluated i accordance with 15A C C
2i.0 14. � I \\ / /�\ \ I
The flow calcula ions for internal Outfall s 002 a/nd 003 shall noYbe subject to accuracy requilS ents
specified under Part II, Section D.3. This exclusion is similar to that provided for pump log flow
calculations.
Chemical data for Effluent Guideline parameters (Outfall(s) 002 and 003 parameters+AOX from Outfall
001) shall be submitted to the Division on a quarterly basis or more frequently(January-March,April-
June, July- September, October-December). Quarterly submissions shall be due 60 days following the
last day of each quarter(Due dates=May 31, August 31,November 30, and February 28). Chemical data
shall be submitted on Division-approved DMR forms,with a separate form provided for each month.

Permit Number: NC0000272
A. (8.) REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE SPECIAL CONDITION
1. The average daily discharge of true color for each calendar month shall not exceed 55,000 pounds per
day. The annual average effluent true color loading shall not exceed 48,000 pounds per day. For the
purpose of this permit/variance only, "pounds of true color" is calculated by the following equation:
Effluent Flow(mgd)x Effluent True Color Level
(Platinum Cobalt Units)x 8.34.
2. All samples collected for color analysis and for use in the above calculation shall be measured and
reported as true color and apparent color using the procedure referenced in FR 39 430.11 (b) (May 29,
1974)- true and apparent color or as amended by the EPA.
3. ul e RTdge-Paper has a re—I ady begutnthe process o t ratifying an8 tmpI6inking possii a process
o tittrizatioqn measures, —fit`ch can be taken to fu he\reduce colordiscliarges'from the ra!,1. Ise
p rmittee is directed to ontinue evaluating mil operations with he goal of fully identifying
o portunities, orlpreven ing and contrghing measnra'le lack liqo;leaks and spills (Bes
anagement�ractices=BMPsr'�uch BMPs�incf ude'bu kare no limited�b:
Continuous ifnprpvement• fop_eating practices so mo{e leak ai dspills are recovere ra her than
discharged t sewer' \\
> Improvement in pre aration or planne�o tages tom\imiz i capture of tank clean-out waste and
outing to lecover 6 ( \ I(
ucti6n of clea ater that coat' sly runs into suers to-prevent dilution of smallet spills
and facilitate recovery of highly colored wastewaters; and
> Improvement in the equipment used for handling of knot rejects to prevent black liquor leaks into
the recovery sumps.
4. By October 1, 2003,Blue Ridge Paper shall submit to the North Carolina Division of Water Quality a
report including a statistical analysis of the Blue Ridge Paper's monthly average color discharge,mill
performance as related to color, all available data necessary to derive the lowest achievable monthly
average color loading limits. By November 1,2003, the Division of Water Quality(in consultation
with the Technology Review Workgroup)shall recommend, considering the statistical analysis report
submitted by the permittee and the demonstrated performance of the mill, the lowest achievable
monthly average color loading effluent limitations. The monthly average effluent limit and the flow
criteria used for instream color determined to be achievable shall become effective on December 1,
2003, by written notification from the Director.
5. Beginning December 1, 2003,the annual average discharge of true color shall not exceed 42,000
pounds per day and the monthly average color shall not exceed the limit established according to
Special Condition A.(8.) Paragraph 4.
However, if by October 1, 2003,the Div sign Qf Water Qa1'ty(DWR`, in consulta_tto�i with-th
Technology Review Committee[, and tl�e NPb$S I mmittee agree/.that the 5eff are overwhelming
technical, economic, or operational barrprs to�hle �ittge'I abi�ity�o\attainithea ove-sila�ed color
loading limits, DWQ shall recommen$ o the i F TE C�tit\mittee,,alternate interim--limits td become
effective December 1, 2003. At that time,DW�shal recom et id�trew�ffective date for aLhieving
an annual average color loading limit�Yt42;000 pounds per\ga�jrhese IrAO mmendations all be
based on what DWQ concludes Blue Ridge Paper can reasonably achieve, consideration to the
actual demonstrated color levels discharged and process optimizations implemented pursuant to
The Technology Review Workgroup shall act in an advisory role to the Norq?Carolina Division of Water Quality,
and NC DWQ shall consult with Technology Review Workgroup prior to makfng any decisions regarding color
reduction activities at the Canton Mill.

Permit Number: NC0000272
Special Condition A. (8.) Paragraph 3. Based on DWQ's recommendations, the NPDES Committee
will determine the alternate interim limits to become effective on December 1, 2003, and the new
effective date for achieving an annual average color loading limit of 42,000 pounds per day. After the
NPDES Committee's final decision,the NPDES Permit will be modified in accordance with North
Carolina's permitting process.
6. The permittee shall submit to the Division of Water Quality,the Technology Review Workgroup and
the NPDES Committee by December 1,2003,a report on the feasibility of achieving a target annual
average color loading within the range of 34,000 pounds per day and 39,000 pounds per day. This
report shall include identified process improvements and any other actions that would result in
additional color reductions, actions taken by the permittee to reduce color loading(since permit
issuance), and the technical, economic, and operational feasibility of implementing the identified
process improvements on a continuous or intermittent basis, in order to achieve a target annual
avera a within the range of 34 000 pounds per day and 39,000 pounds perp dav_The report shall
identi specific economic and implementation issues associated with the im rovements. The re ort
s all also prpjezt expected additional al color reducti�r�fqr each technolog}yeva ua, ted and maximum
c for reduction possiblelusing the identified technologies.The rePort shall also include a pro�osed
sihedule for implementation of prouessl improvements re uired to a&eve an effluent color leading
within the targeted range. The permittee shall provide his,evaluaiion/report ogether with ar�updated
relport on the results of o�igomg�anr,,additional planned-col r reduction activities, to the ME ion of
water Quality the Technpology Review Wor1kgroup-and-the DES Committee. By Februa 1 2004
I7WQ (in consultation�Jith the Te�hn\gReview Worgr up) hall approve or modify It a Ridge
P reco en an for achicving�34,000—39,60, 0, ound per day target am a lerage.
If the limits determined to be achievable, pursuant to Special Condition A.(8.)Paragraph 7,by the
Division of Water Quality(in consultation with the Technology Review Workgroup) are not within
the target range,the Permit shall be modified in accordance with North Carolina's permitting process
to reflect those limits. .
7. By December 1, 2005, Blue Ridge Paper shall submit as related to the implementation of the process
improvements evaluated according to Special Condition A. (8.)Paragraph 6, a statistical analysis of
Blue Ridge Paper's effluent and a feasibility report on color reduction technologies associated with
the Chloride Removal Process. This report shall include a statistical analysis of the Blue Ridge
Paper's monthly average and annual average color discharge,mill performance as related to color, all
available data necessary to derive the lowest achievable annual average and monthly average color
loading limits. By January 1,2006, the Division of Water Quality(in consultation with the
Technology Review Workgroup)shall recommend, considering the statistical analysis report
submitted by the permittee and the demonstrated performance of the mill, the lowest achievable
annual average and monthly average color loading effluent limitations. If the limits determined to be
achievable are within the target range established pursuant to Special Condition A.(8.) Paragraph 6,
the limits shall become effective on March 1, 2006, by written notification from the Director. If the
limits determined to be achievable by the Division of Water Quality-in consultation with the
Technology Review Workgroup)are not withii the target la ge,the�Permit hall-be-modi�e n
accordance with North Carolina's permitting pr cc i s tact thgse`ii\its. d
This report also shall evaluate and rep Di on co r reduc�io techn to es�as ociate with the Chloride
Removal Process(CRP)wastestream.� e C analysis�� 11 colice Yrate on the technical,
economic, and operational feasibility ofimplemeni ng the idenYi is tecjinola ies. The report shall
identify specific economic and implementation issues associated with the improvements. The report
shall also project expected additional color reduction for each technology evaluated and maximum
color reduction possible using the identified technologies. The Division of Water Quality (in
consultation with the Technology Review Workgroup) shall evaluate the feasibility of implementing
identified technologies for further color reduction and shall submit to the NPDES Committee by

Permit Number: NC0000272
December 1, 2005, DWQ's recommendations regarding color reductions associated with the
treatment of the CRP wastestream.
8. By March 1, 2006, the permittee shall submit a report to Division of Water Quality,the Technology
Review Workgroup and the NPDES Committee on the comparative evaluation of the color reduction
efforts as part of the Variance review process(Triennial Review of North Carolina's Water Quality
Standards). This report shall also include an evaluation of color in the Pigeon River at the Fiberville
Bridge, and an evaluation on the feasibility of complying with North Carolina's Color Standard.
9. The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco
USGS gauge station. The new effluent limits in this permit are more stringent than the provisions in
the 1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is
possible to calculate the monthly flow at the Canton gage station above which instream color at the
Fiberville Bridge will not exceed 50 true color units. Using the 555 000 pounds per day monthly
average true olor loadin limit im la�mented on/thpffective date of the permit)th`e�at the
Canton Gage s ation,lwl}ich will prgvic7e for color less than 50 true color units at the Fibervil a Bridge
is� 171.8 MGD. herefo�e, the monlhlyjaverag%olor in he Pigeon River at the Fiberville Br�dge will
be less than 54 true colo units whenev r the month�verage fic w :at the Canton gage station) is
greater than 171.h MGDff.
10 The governing f7�w ciriterion f�Erue color a�Canton-is SS.1tMGD (30Q2 stream flow). Iihe flow
esltablished �u. uant to �pecial Cb dition�. (8.) Paragraph 9, is greater than this 30Q2 stream flow,
thurefofe f r flows less than the 177T8�dl)zt the Cantoi\Gnge istation but greater than 119313 MGD
0Q3-flo�t the Hepco gage station,-the-monthly average-colonri the Pigeon River at Hepco will
be less than 50 true color units.
11. Beginning December 1,2003,the monthly average color in the Pigeon River at the Fiberville Bridge
will be less than 50 true color units whenever the flow at Canton is greater than the flow established
using the following equation and based on the monthly average effluent limit established per Special
Condition A.(8.)Paragraph 4:
_A�
(Monthlyerage_EffLent_Color Limitjb/day-12468.3)
Flow_at_Ca�ton_USGSQvIGD)= - +31.6+2.4
308.58
For flows at the Canton Gage station less than the flow established here but greater than 193.3 MGD
at the Hepco gage station,the monthly average color in the Pigeon River at Hepco will be less than 50
true color units.
12. The potential exist that there could still be periods of time corresponding to periods of lower flow in
the river, when color at Fiberville might exceed 50 true color units. Therefore,the permittee shall
continue to implement the approved Low Flow Contingency Plan for mitigating the occurrence and
degree of these potential exceedences.
�� �� . .
13. The permittee shall not increase the mil 's pulp roduction capaci u mg the term of thi permit,
unless the permittee can demonstrate t� the i�c eas roductio ca e aehievedivhile educing
color loading. In addition, increasing iit��}}e mill" u�p p c(u\io� apaG t ma require per �t revision
in accordance with North Carolina's I I�DU rmltvng
14. The NPDES Permit shall be subject to reopening in order to modify the color requirements based
upon the following and in association with the required triennial reviews:
r Any breakthrough in color removal technologies. Such breakthroughs shall be brought to the
NPDES Committee for consideration,by Blue Ridge Paper and the Division of Water Quality, as
soon as they are discovered.

Permit Number: NC0000272
An acceptable statistical analysis of effluent color discharge data demonstrating significantly
better color removal performance than that currently prescribed in the variance and permit.
Successful application of end-of-pipe color reduction technology or in-mill color minimization
effort that results in significant and measurable reduced mass color discharge.
15. The transfer of this NPDES permit will not proceed until any successor—in—interest to the current
owner has agreed to accept the provisions of this permit and request and received from the NPDES
Committee a transfer of 2001 Revised Color Variance.
- Rx. /�

• Permit Number: NC0000272
A. (9.) DIOXIN MONITORING SPECIAL CONDITION
The permittee shall perform the analyses for 2,3,7,8 TCDD and 2,3,7,8 TCDF as outlined below:
Sampling Point VonitOring
Re uirements
Measurement Sample Type
Frequent
Influent to Wastewater Quarterly Composite
Treatment Plant
Effluent Quarterly Composite
Sludge Annual Composite
Landfill Leachate Annual Composite r
The sam h t�e anal �for3,7.%- CDD and 2 3 7,8 TCDF Lcordance with EPA Met od
16 3.1 A single sample may be analyzedl. �ltemativelZ tha sample volumes may be collected to enable
th simple to be split(duolieate_analy�s)me Mit(imurn 6vel in th effluent-for-2,3,7,8-TCDD and
2,�,78 TCDF by�PA Mi thI.d161Zxe
pg/l. / \
If 21),,7,8 TCDD orI/2,37,8 TCDFeteced m the effluent above the quantitation level the
PC-mtteeshaf i Jtiate more frequen moni oring of sludge and liandfill Leachate. I i
Additional Requirements
Fish tissue analysis shall be performed in accordance with the Division of Water Quality approved
monitoring plan,which will be reviewed as necessary. The monitoring plan is an enforceable part of this
permit. All dioxin data collected as part of this monitoring requirement will be reported as required in the
plan, no later than 180 days after sampling.
D
DDj %A

Permit Number: NC0000272
A. (10.) DISSOLVED OXYGEN SPECIAL CONDITION
The permittee shall maintain an average daily dissolved oxygen concentration of not less than 5.0 mg/1
with a minimum instantaneous value of not less than 4.0 mg/1 at River Miles 62.9 (DNI) and 57.7 (DN2).
The permittee shall 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,as necessary,to comply with this
requirement. 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. Blue Ridge Paper shall report the
date and duration of oxygen injection use as a supplement to the monthly Discharge Monitoring Report
(DMR) forms.If the dissolved oxygen drops below 5.0 mg/L at station DN2 then monitoring shall be
required at stations DN3 and DN4.
A. (11.) TOWN OF CANTON INFLOW AND INFILTRATION SPECIAL CONDITION
Tl�e-perm,ittce shall make.continued_ef or
to promote-re uction of inflowlinfiltration to_the-T n_o
Canton's wastew er collect'onsystem.
I
A. (12 ) A ERVIULE RESERVO R SAM LING S ECIAL CONDITION
1
Sa piling for Waterville Re ervoirsli b�conducte�onc annually Ju Iing2002-and 2004. Sam ling
shill be performed during a ow-flow-periods to correspon twi h the fish-tissue-study(see A. ( .) ioxin
Monitoring Special Condit'
I i
Sampling shall performe� at Waterville Reservoir prior to' a rel)ranch, Waterville Reservoir near
Wtlkms ree a d Watecvil a Reservoir:near the dam. Each loca ion shall be sampled for thelfollowing
para mters� U
PARAMETERS %
Temperature
Dissolved Oxygen
Conductivity
pH
Total Nitrogen
Nitrite+Nitrate
Ammonia
TKN
PO4
Total Phosphorus
Chlorophyll-a
Secchi Depth
All samples shall be collected at 0.1 meters beneath the surface of the water in the lake.
A. (13.) TEMPERATURE VARIA i -EE VTA PECI) CO) \ON
During the next permit renewal,Blue Rid Paper gal complete an �rialyps ofte' `n�ure att shall
submit a balanced and indigenous species dy, n� at rf than\May 11200-6. � s arrt of thus anal§sts,Blue
Ridge Paper shall submit a complete tempt ia�t Je repoIlldocu n i g th i need for a cu tinued
temperature variance. L1(� n
The study shall be performed in accordance with the Division of Water Quality approved plan. Request
for revisions to this plan shall be submitted for approval no later than March 1, 2005. The temperature
analysis and the balanced and indigenous study plan shall conform to the specifications outlined in 40
CFR 125 Subpart H and the EPA's Draft 316a Guidance Manual, dated 1977.

APPENDIX A
Announcement of Public Hearings

1 4'
nd lrilQWs�,�ua hQ ePreus NORTH CAROLINA
HAYWOOD COUNTY
'r tc
�� •,S�150 tten o s;
r 4 JwZ Rar�r W v`vny.
ez'�rte3los� AFFIDAVIT OF PUBLICATION
•OitedhrJ 4
""its seek � Before the undersigned,a Not Public of said Court and
,9 ) 800- 9 3S,@>Tt 32� g azl' ry
T Chnitit T 1lQ In 7�teI6iPg tgm State,duly commissioned, qualified,and authorized bylaw to
0 uf.1 ry S e tt c P, administer oaths,personally appeared '
penga 3M— le 1WW1 '99e t.
q matl4e tlr care l
eem110 a �L (e seek' �J ( ,,p who being first
elnfee pe((� °' g
duly swum,depose an says.that he(she)is
►LiHir�^ "ll� . oW ,Yr,#GIs
o Ro F f€`s : se� on nd `Q�, �Qm I
cenl���Sga�l 6 +��° � e og�yu�tr,•1
Bnro23t � bU9 n u 191m 2542�Q fi 0 h ems m +o. =.paum�v,punrh>,o,od=,fi=°rmpi
e av, ,riud m make hu 6davir) '
of THE ENTERPRISE MOUNTAINEER
K�G+ �g• -s , ; f ;) z� y�,r {try, 4f engaged in the publication of a newspaper known as
THE ENTERPRISE MOUNTAINEER
�" �t0 8 ,,,41�� f- published,issued;and entered as second class mail in the City of
Gdlt_�}0 epplil �HAn°p �! 3�s }lj$ P ry
C leSlelllA(n4�v! Q.is�t 'L�l+;uY in said County and Surf that he(she)is authorized o ized to make this affidavit and
ry ( )
kh 6 i(e)ltx 'FC S � [f !�Q.+.�y swum statement,Char the notice or other legal advertisement,a we copy of
� -.p 5 +sj Qr' which is attached hereto,was published in THE ENTERPRISE MOUN-
PO�i X� qd ' ibu2 ryd q a ryj�`j�. 1 TAI7N on the following dates:
Anne NE26.146 SYO( , ,Y:IY! #U711'Itl i,''s
and that theWd newspaper in which such notice,paper,document,or legal
� advertisement was published was,at the time of each and every such publica-
i,. i1 t lion, a newspaper meeting al1 of the requirements acid qualifications of
L a_A `
Section 1-597 of the General Statutes of North Carolina and was a qualified
newspaper within the meaning of Section 1-597 of rho General Statutes of
North Carolina.
O f
201QZ
y, ;—W,- „+ -° Vr ° .;4x-`'.goi~1
ri 3rai� `-}'4`v3rr, yt"d * Sworn to and s cribcd before me,this
rr11� A"-' vte
Fd
Yr`afct :* fl $t ft�..natv,?t C�,�� A',,' day of 20b
kink ayyk, 1'i4 'd'�Gbis3'.1�
My Commission spires:
ON
altt111[tIlll/I
1 ' �" n �'ti4 9%F• 's�'4'3t ��n7x: 101 MO <le"B c
td y -,;,na 4 + A•Ca is j EER
5 i `. '�z P C��?Ap e.
Ii4J 'vrA' tr ., t'#F�-.dam
A rca' q"414�4jf°s°'l�ls �UI BL�G G1
i l r��litis<�'i-.:Psi�tu" t}$• ;^xis h 4, - :�9j.,, ��
` Lr rg3 �t �{ cat °'•��U CoUN �''•
�n'� ��r#o1�4C�`��..�t"'��fi9��14trh WS!`ei, eea+luuuanfc�
�irv''F DI o _IuliS'rt 'tI
afters° s > } " r � uu
bp.2,9
for" ILoT�tF PSI die , Ylt ille ,
fl�e;�2'�N,� �(►�.St, n8§Mlle;N�
4 L;n:iNt y r.._ uFef"{+rt1i ACr1, t
,Y vi\KYf.r, 4F1 JS,."afl N E erN,f.
CiIASIF�IEDsSsr MB E�i1LES

f1QTIG O)r`PIIB�IC d•s � i n xlg ay rb 1'
r R � calorlaat�iag to Jha PigeD ft j the Dtvo taf. ater'
> HF RING � River,Jh`ei@jjq,ehu►are,4dGaVfj€will presell pn'
is 'iQ ttEIA 1(� upD},�! 1�¢ ) d jI_ •g'zp an I bf the_North.
t TF(E NQRT �AROLINA I`"re udia�is ms,2Q¢ tat rja� 'E{tvlronigenlol,`ION
rF ENVIR0NMEN1A"M.,3t nd061hswaa(dr$sulN�Minage nt (a mi tapsk
NAGS ENT. t t , r'edl,tharr ahtbd3 tot { � hsaid County and
tt6P�1"trhag ro ar and.
�i}RA115S ON:. vk °2 55 ilgf rvltf( ef" 'th$N�DES'�um�Ut{d,��j y Whorized by law to
teURJI:l1�A flbbr hearts
r (niNe •fofor fdadigg oGe D$t@Plate
mg has been 3[ doled con l e fkrm of ifie rmN The "tp pn @ '' '
XPlana�grtpn 1he,T cefpigThe foll$ mg itdmsmll �vo�(d tan uR(I;sdesregpe;t
" hr K�°dDP'a sa n1eparPnQ qtfNfC
n Cu"dBuIdraeE ' i
�rc,tl er e'auiAlde ' o, M)d1 e xPn.f
.ee
i.rh ahY o being first
, fiaf `in tm ve nf ' erfo
in�mggfme, fi�t {e SON , 3 e aNarA ,' nfor th P9
M'� Plug oi9b, et eoYox
'
r@quoson ¢ ewDl and 6osedDnthefin i • Tf Petml �o a .ea„a
¢ n (tt sre Irgd �Sti ,a t
�4 ssuan{e of�>iQpE;fYgrrt�if,t ESA ,thm�daTk�kT@r aID"»tf��
NCODDQb27 y� � s ' a ublw8him ►
F s & e ,Raviewr Wot gfDap ifrt� aknown as
` r >fo lh `31alelnRp[;
u¢R f a ar?h&§rb dfi4ge h@ d WOu d nt + �e
— a m! I td p ndi + farmla
D� Pp(fi�l ejDBafefi@}t{y'('bI� "URN
in[he Ciry of
+ '�sSRVafa lrD �thrWtlfef' pli 11l��°�Dr UCA a� f 1DI, ,
p �. ir�b ^-- t "'ttt,..} P Aala � Ut€ifiCl'
yt�1> gaa�l kp.+.;jar' fl`OfMJ�n}y11�I1JA,}P��jCeS� �I,�fQ� �t(�a �" ein t t �" +5� t]t Hake[his affidavit and
T�• ihhQ f eiRaw.a�-<''�+7afaef'r�01ya[Oje� �{prt�f�ar0 f i Y. bX+t�'�a5��ement�a vue ropy of
uegittlrf t d at77e = ' h@P_Y erTararsE MOvra-dg # ¢as ,rotor r dufjloy ro s @tong f¢ ep
it£>A a ,rtrthe D�aFih `lf �� )"
o c ; f oI nm i r
r• ; apah�e4 fr Blues 1 IP albs iIle
.f at ha af€rr ! Id9� I °)egsfr Ian-'a
t �taifd ark oti9Td �3�i ddpiti- G>fidt cr� document,of legal
5 �tojo dN?m§°Td1¢ea Ju r
Pf� rir�tt �Q:a t r "£o',.rr ftY Uf'E Ideverysudtpublia-
Az�'6 •"3 ' .`t� 7 and qualifications of
IIm11g,d ]I�PF_d15 '.aa and was a qualified
r faooppPlf P f1pi.A �njQ i rfy- ,�m i s '�',Z ' �rthaG �J affF'tF General Stanton of
NRgrxipa} iforPH�ear�s, I�� 7 t 5 ` tesenl taps 1(
a' fr1 tl s 4�. lay t�gr axt �h�g�, dil}mme�3
rhDlg T°, tp'` m e rtT C j�u kmQaal X
Wateg}aaterstdeslgnoted�r f 2' �( zoo
@ en{apieS, iCnl•
ts)]i Pjgeon River id 1(le pdt eldrf$ �ItQq�� ,� ¢e> led 3t�h DiVistan
fre�i�,Rrhad RrvEr blrsin f of To^e tg�T�7 C'btioy� ta( �I g Time )rw-
Dn a hosts $f tCjrrehrni natural ¢htkgmhnd't@n t ban
nor off review and ap n 1,po {use fa Cross ejCommghan of
{atrp of 7lrttcle Tf, faoxteed2yPgJu tf �r ' `
(hapfer `'14$ °Ggneral Pa�er; ,hu"s )eyaeFJed nyw4l�lo�eollgwedshow Zoa�
5lufufes of.North Caraligo, renewa�ofih3311i(a)Yem evke, }he heonng officer
and oIhgr'lawful slundards peratuie variance¢used an moy ask guesfmns for tlori `
andfregulehons, I¢g Mirth unafysiS`lho) ,pdjfaf jhot, fifalion •- v + :I, anry a e
Caraltna +Environmenial at thrs)imeda mare slnn� 6 Aftheheanngofhters
Map9tritent Commission YQent effluen► hmtltlian drscrehoo the record cots
ptap es fo ssUe a NPQ6 ,would Sausg"D fmanrial perd+ for]he fallaulhatnyf shomh"j'+uhn0dM5hiP ha o6 deed rrag
Autlfo5PedcpD hnzd us!io n
{auld hose the IniIL WHEN {5epthm r b, C�`'�,
iilahpip, acid spenul imndr LTbe %QtNorthfarolin6 20g1 m700 M <G,P
tr halo Irr orrgd,r%t t D�r r�4�l hl P l ti I, 4 WNERE aTusc Ip H gk'' c^
14
4 tQ dYG. t) ,$x� l _� onager n ,C-rtimis3iaa Schbol duddaqum,I t RY
Blue Rie Pa er P p T. a Isf 564 Tus'rola Sthbal Rain''
9 P bias ;Pro uses o r new lh art ?
f tequg;fgd giVtlnan{@ ftor� ipp[e )66dh(urag urs }� Y at @ North
•ih0 lifer quality hosed ,t@mperp ale t-rt and (o}ohna, : r ', _\G e;,
, , e(Nif t hmitohoh'Taf talpr ,ufider, pravtsiaa of H ood C`yy� "
}fari�tlihnian,NCrfanittyf�$etitup3ld�(va�Iro�ihk(�ean ,IN�RMi1TI0NfuPYaf' �����
„a qb entaJy�Prated,a>t ifo to dt}rBalnnted agd,bdnanfd rdgi>ej'(biT'6e`
Naverdher0, ll,l�i d D Ste f
h 9 q @s}S(fj e� tpsJfacled dtid tepi�d,6Y
1�871dfNPpf3,p.,�„)'� T(jSSDga�k� � Irh,��h)s�'canth m �` � �; ..
e;�ar=tmrtvc�ipblishoaw. Ingq,>lsDlY;sra t 4 'USavlrgnrflgtdal �ei� Aitoliscre )i� Y �rTsiarS>qf a(et:
PrdtUo w R ell vnl5at�it" u;c d @ e` of / Ifnrt a
bDse c� � f�
We enter
rd'for ol ,
' }allallf Df rya D Q tta S i t J' fN n i+�
a ra h
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44dd p
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•tiPo f tld$f9$ SQq��gkbtd4 ed�g�;itldr�e gfjf�€}ihe:rapphcMton '',"aiid
r fedu 9(IF` �IfEFn Yµ�h[`��tiQpup)Ipp14€'a }TdQR� `o}hkr$Ifgrindlioh`8re on'.
suedl•t ttfik;mlll yore I e rvtsien =s off ,ramown ri__..c. o: i ., .

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:� �.� '1

11
10
Legal Notices 10 Legal=tic� Public Notices Publl— o N=
of
°®— a of record. 20
City of Newport, American FIPDES permit, color Ads moonset
21 - CLASSMEp,. ,
I>nY Pri°ntY created
to any Being the same Canoe Associatbn and the v8rierice and temperature psrsorrsls `f2
fixture filing; PROCEDURE: The card Of Then u.�•': "Jy _
matter that an aavmla Promises conveyed to Vidd Tennessee Environmental vadence. DEADLINES .-'
survey of the Premises Hall, by dead from Alice Caper's• Blue Roue will be conducted N dF
dead dated Paper's requests continue hewing Loaf end Found 26 Tum ell of our urrwaMed •�
might disclose. In addition, MCCOY by s In the foflowing manner. Ghv Awaya 26 y -
to iMlowdns parties may February 16, 2001, and of to be based on a at this nalyse1.The 14 Auctions 27 merchandise in tfra B1tlb
sisho ao tterest in the .recce o} Cocks �oonry, time pa�morte eutstringent ,Qualiity will prresentVaenr Yard B Gorapa Sales 28 or garage into CASHII
above-referenced Property: a0uent limitation would explanation of the North F1as Markere 29 Call Brenda or
Tennessee,in Record Bock Sandy
ROBERT E. DALTON; cause a financial hardship Caroline Environmental and let us help you wth
UARIE DALTON; TOP 1056.at Page 53. 20 your Clessifietl Lln Ada
CONSUMER FINANCIAL The proceeds derived on the company end could MCom ns Pe the
and Display Ads. `I
SERVICES,INC. from this sale o1 said dose the mill. the procedures and ire Happy Ads
The sale held pursunt property wtl be applied to Since 1994, CLASSIFIED LINE IL
b this Notice may be the full amount due on the permitted color loading has NPDES Committee DEADLINES 4
rescinded at the debt and fife secured in been reduced by more that variance procedures. CLASSIFIED Tuesday_1pm MD^daY'
Successor•Trustee's option said deed of tout,together 81%. The North Carolina uesstt explanation
requirements LINE AD POLICY Wednesday-1pm Tina.. '1
at any time. The right is with all costs and expenses EnvManagement
anag men tAll ad copy subject
reserved to adjourn the day incident to the sale and proposes eto Commission e temperature variance. �tl approval i MOfb to �ThurW;Pfn��,
of the sale to another day, foreclosure, including any variance
to North 3. The applicant may publication. The Newport Sunday.loam FTWW
time, and place certain unpaid taxes.The balance, Camvariance thePlain Talk reserves the CALL 623-6177 .
upon anfurther nouncemenit at ins parties will bet paid to theentitled with ll conditions. tha��� action for make an ewhich the permit r(ght b add,refuse or reject
any etl at any me. The or come Into the office
time and place for the sale thereto.The address o1 N15 Va plan implementing uire the ill to continus measures to is required.4. Pblic Comment - Newport plain Talk 145 East Broadway _
set forth above. W8A No. above described Property reduce � color loading to Comments, statements, reserves the right to Newport,TN 37821 -
725-201067 . - 347 Old Knoxville Highway, n River. These data and other intormelin classty,index and position
Dated July 16,2001. Newport, Tormor see the Pigeo be submitted in writing ads eccoeNng to the
37821. include but are Trot limited may governing the
Wilson &Assooiates. Dated at Newport, to additional color prior to or during the be policies
betas d page
Wilson . Tennessee, this the 16th reductions in 2003 and in hearing or Met Nor ll ages. d 25
day of Ju •2001. 2006.This would result in a presen91e0 Dray ��� Oeps
Suxessor-Trustee It' reduction of 1643 b 2555 hearing. Persons desiringMTeM LOBt� 1
ear in the permitted to speak will indicate this .Gp;
By:Robes M.Wilson.Jr. BEN T TUTE TR III, tonsly .HAPPY AD IF YOU HAVE lost your
SUBSTITUTE TRUSTEE color loading over the term intent io the time °f POLICY dog or missing a dog-
Loan NO.30117248 01 the permit. The mill registration a the heating. Please can the Newport
qOY T.CAMPBELL,JR. would conduct sallies a°�spteak Pemayo dosinSO, Ali Happy Ads are payable Anima Shelter 623-1010.
FOR SALE WW.MY IR.00 N, ATTORNEY FOR
identified process _
vISR VN,"N.MYFlR.COM SUBSTITUTE TRUSTEE improvementsrrm eir feaasibil'ity lengthrder toy
at the discrets tion
b f in To aav� art' possible my d LOST: CH SN EEI PUG,1 .1.
July 20,27,Aug.3,2001 July 20.27,Aug.3,2001 for achieving color the hearing officer. Oral embarrassment, age�— reductions within a 'target' presentations Net exceed which includes an age must year omunitl in WARD
rson's full
NOTICE OF range based on the three mimes shout three nambe not e.You ma ude the Pula initials when found. Call R423-487--,
SUBSTITUTE OF 11 findings of the EPA - aanmpanied by Y
TRUSTEE'S SALE Public Notices chaired Technical Review written copies,which will be of first name. It no aagef is 5743 or 423-487-2662,
Workgroup. In addition,the filed with Division staff at mentioned,
Whereas, by Deed of mill would investigate the the time of registration. name may be used. 46
Trust dated February 16, NOTICE OF PUBLIC masibilfly of treating 5. Cross-examinationpresenting f aid hmustrsgive on bverifohle cing the Give-AWays
2001. of record in the HEARING TO Chloride Removal Process Persons Pre g address
and s,
Register of Dead's Office of BE HELD BY THE purge stream in order to testimony will not the Identification. This yy
Cake County,Tennessee, NORTH CAROLINA achieve further color allowed: however, FREE PUPPIES - mixed is not for
q
In Record Bak 1056, at ENVIRONMENTAL reductions. hearing officer rosy ask information with ph. Phone 423-487- 'S
page 55,VICKI HALL, did MANAGEMENT Temperature Vada^cn questions for clarification. publication in The Newport 4489• : !
convey in trust to JAMES COMMISSION Blue Ridge Paper has 6.At the hearing officer's Plain Talk, but will be —� .
C. MCSWEEN, JR•, requesed a variance from discretion the record may made available upon MIXED TERRIER,SMALL, It
Trustee, a certain tract of SUBJEfr�' A public the water quality based be closed at the conclusion request to inquiring Pn Talk black• white, and -Ten•
Ientl to secure payment of heating has been effluent limitation for of the hearing. Phone [phone]M .'
WHEN: September 6, reserves the right to evenings. £
the principal sum of Thirty- scheduled conceming the temperature for the Carrion, reject any Happy Ad '.f
Four Thousand Five following hems associated N.C. facility. The 2001 at 7:00 P.M. :E
Hundred Fifty Dollars with Blue Ridge Paper Inc. temperature limit was WHERE: Tuscola High " PALLETS
(S34,550.00).evidenced by located in Canton, North based on the North School Auditorium 564 ":e�.r «- A. TO GIVE AWAY .x
one promissory note Carolina in Haywood Carolina Standard for Tuscola School Road to- Come by The NewPM =J
Payable to ALICE MCCOY, County: temperature (15 NCAC 2B Waynesville. N° ,�. •"> �s. Plain Talk office at 145
said deed of trust being . Blue Ritl9e Paper has ,0211 l3) ll) antl set a Carolina,Haywood County MOP 3R t�, - East Broadway. NewPonC_et
Incorporated by reference; requested renewal end temperature requirement INFORMATION A copy °^ tl r. = TN. i
Arid issuance of NPOES rot fO exceed 2.8 degree of the draft NPDES permit
WHEREAS, by Permit NCOG000272 C above natural or 'vdomotion suplaorti^9 -y� �' PART AYERICAN TREE ,
Instrument dated Jury 13, Blue Ridge Paper has background conditions and the variance request can ?c.'�r,�`}Y• WALKER, red and.white,
2001, recorded July 16. requested renewal of the In no case to exceed 29 be inspected and copied by I,k�e atp famae ;
2001, in Record Book variance from the water uH WISH 4 ma tab, spayed
degree C. Blue Ridge contacting:
1069, Page 509. in the quality based effluent paper has requested Mr Michael Myers, NC At1APP 6 i0u46t61xe. Phone 423-
Ofice of the Register Of limitation for color. renewal of this 316(a) Division of Water Quality y ) rzyt —�_
Deeds of Cake County, . Blue Ridge Paper has temperature variance NPDES Unit, 1617 Mail .fir x-t7R S11Y t�.a� WARNING ADS -
Tennessee, Alice McCoy, requested renewal of the based On analyses that Service Center, Raleigh, 'j`{Ol'Wt FOR
exercising her authority as variance from the water indicate that at this time a North Carolina 27699-
owner and holder of sold quality based effluent more stringent effluent 1617. Telephone number, _. GIVE AWAY PETS
file, appointed, BEN W. limitation for temperature. limitation would cause a [phone], extension N Your beloved Pats
HOOPER Ill,as Substltule PURPOSE: NPDES finncial hadship on the 508. r' deserves a loving, cathlg
Trustee:and Permit Renewal company and could close The applications one N.yraxovA home.The ad for your free
WHEREAS,default has Blue Ridge Paper has the mill-The North Carolina Mitere Division are on file , pat may dray respomsO
been made In the payment applied for renewal Of its Environmental el the Division M Water trt, � �',�"L from Individuals whO ram`
of certain Installments of NPOES Pet for the Management Commission Quality, 512 North sell Your animal
said indebtedness, now discharge of treated proposes to renew this Salisbury Street.Room 925 wr•, research or fxeedt!g
d1�e, and the holder and wastewater to waters variance to North of the Archdale Guiding in . ,-- •KI, pulses. Please Berson
owner of said note has .designated.as_the.Pigoon Card s, temperatum Raleigh, NoM Carofiro flV respondents nsrefulyivfAm
ddclared the entire b§lance River in e Frerkfi Broad sfentland, , Yoder do•:and :st: rho•:' �°^'s p.,x:� ,prong an aMma e'4§y�
_-�,v du`
vayabla,and.,._ Rivgr,bgs�(r,p"fie basis p 16,,,�fr Seatign.Asheville ,Regieoel..,Otice Cf Yaurpdf,9hirmnikyDU ..
_hattss�'.. ; and palbf Itm',a.piafir imry•`slap rswew'• 316(a)M:tIW6C aP*aer .(59 '- "co
-iaidarsigned' Thirties to : andappliciRdw oY�r8d821 Acl,wkh tits 4xxidltion Itref,n Ashevill-NOrm Carolma). 28
. . foreclose.said deed'M trust.� of Chapter 143. Generaln l the mW -confine to
They may be Inspected _—
iNOW,THEREFORE,by Statutes of North Carolina, conducted Balanced and during normal office hours. 21 Yard/Garage Sales
vi&a of the authority id'Ne and other lawful standards Indigenous Species Copies M.t the information
vested, as Substitute and regulations, the North Studies. on file am available uponof the_ -Of Interest
228 Y _
TrZsiee Ostler said Carolina Emironmenol hssociMed with this request and paymentM AO Raturday.August 4th,Ba

W:m etas n,uye 1q-- :— temperature trot^ was wncn.: ,uaww , ,y:,
located in Canton: North based on the North School Auditorium, 564
ace Carolina In Haywood Carlin, Standard for Tuscola School Road, TO-GIVE AWAY 6 adua
x'AX County: ' temperature (is NCAC 2B Waynesville, North - Come by The Newport' SAY AND•SATUPAO
being Blue Ridge Paper has .0211 (3) bl and eel a Ca+Wrw.Haywood Count $ "' Plain T41k office at 145 -310
ttrhral requested renewal and temperature requirement IIFORMATION: A copy East Broadway, Newport, 6pfa :s
Issuance of NPDES net to exceed 2.6 degree ot the draft NPDES pennit TN. t13111. n's mid
by Permit NC00000272 C ' above natural or Information supporting
Y 13• • Blue Ridge Paper has background corKVbwa and the variance request can PART AMERICAN TREE FRIDAY AND. '
/ 16, requested renewal of the In no case to exceed 29 be inspected and copied by WALKER, red and.white, 7AM-12 nour6 842IEoUiLtuf'
Book variance from the water dogma C. Blue Ridge contacting: lc,:.. 1-yr old, spayed female, Drive. Man --wtlrtyN3
t quality based effluent Paper has requested Mr. Michael Myers, NC - medium size. Phone 423- clothing and 'plop
her of limitation for color.
ou^t• • Blue Ridge Paper has renewal re this 31 variants,
NPDES of Walar'17 M / ', 81348461. fats of
g temperature variance NPDES Unit 1817 Mail
by as requested renewal of the 'based-, t
on analyses that service center, Raleigh, WARNING ADS GIGANr1C YARD
rt variance from the water indhcate at at this rime a North Carolina 27699-
E saildd quality based effluent more stringent effluent ten, Telephone number. FOR �� 1
di W. limitation for temperature. fmilaton would cause a (919) 733-50e3, extension .. GIVE AWAY PETS from Pizza Hut
'
Wtute PURPOSE, NPDES "
Permit Rsnewaf financial hardship on the 506. mx,b, M Your beloved . .
n has Blue Ridge Paper has company emtl could close The applications end ,* deserves a loving, pmhg HUGE BAC�,
9 ape the mill.The North Carolina other.information are on file home.The ad for your free YARD SALE: FrL 1L.7 .
hmenotf applied for renewal of its Environmental at the Division of Water a ha ':,fir' =',"a pet may draw response (Aug 3 & 4) BuR- 1,
NPDES permit for the Management Commission Quality, 512 North T+�'"t t from Individuals who will 859 McGowan peekRd.rs,
r ^ discharge of treated proposes to renew this Salisbury Street.Room 925 sell your animal for
and wastewater to waters variance to North of the Archdale Building in € �„%, research or breeding Cos�TIpME
a has designated es.the.Pigeoo kAe
ne'a tperaure•_ Raleigh. North nZamlira purposes. Please screen ✓1d92River In the French Broad aid ,ary antler (h9'h end taw'.-'tlhe':.IIbroiorh's , respondents carefully when ' - t:.R^J@F. k!eP^ Pf boaa:,efl(x !^Ashvhdle i%gieedruOFFm -phring an animal away Ya prefmunery it naval of hClean Vyaler.-(59 , rWoodfin•--'Ptwe,'• .. YourpeTWrll thank you.I to and application of Article21 the,condNon tfw#,e AshevReWJorth Carolina). - tai° T �� �
I trust. of Chapter 143, General the .mill continue to They may be Inspected ��� '�`
iE,Wine
Statutes of North Carolina, conducted Balanced and during normal office hours.
28
hd me and other lawful standards
witute and regulations, the North Indigenous Species Copies of.the information 21 Yard/Garege Sales
said � Studies. _ on roe ere available upon '�Of Interest
the Carolina Environmental Associated with this request and payment of the-,— 22a LELTON RD.,
xh _ F
_ the Management Commission request, the Division of costs of reproduction. All
proposes to issue a Water Quality scientists such Comments and PLEASE CHECK Seta daY'August 4th Barn-
, _,y.,•a
ell, in NPDES permit for the evaluated 'Blue Ridge requests regarding this 7 Wallpaper, toys dolls, Let
odour tall subject to c YOUR AD ct iklren clothes,and much where you ..
lie.-et I specific Paper's Impact on the minter should make mom.Canceled t raining Advertlae with our -.
pollutant limitations and balanced and Indigenous reference to the Penh This newspaper makes
''moo^ special conditions. s has in tyre P' River numbers)Ilsted above. every effort to avoid errors eels apeeW. Yopr 1�
r'�T' Color Varianco species Moh>n in advertisements.Each ad 3 FAMILY behind Barter's (up to 14 wortle) rl4
id best and concluded tat Dove-In, C Cut-off. run for two
Blue Ridge Paper has temperature alone could AUGUST3,2001 Is carefully checked and Cosby dap
and in requested a variance tram not be idemitietl as proofread, but when you Thum., Fri. 6 Sat. 7am- You receive a yard ode
the water quality based prohibiting a balanced and handle hundreds of ads, 7pmIdt•••
1 ribed the effluent limitation for color Indigenous population. In FIT
mistakes do slip through. For ON �12.V V
I ict of for the Canton,N.C.facility. addition, Division staff HOUSING AUTHORITY We ask therefore, that you 3-FAMILY YARD SALE - Y
This effluent limitation was reviewed existing DEVELOPMENT check your ad and ff you 462 Smith St., 9em-3pm, Your yard sale kit asses, reviewed established by the U:S. temperature data end CORPORATION(NHADC) find an era,report it to the Friday and Saturday. No contains:
iculady Environmental Protection although some is accepting proposals for Cass'rfied Department Sales before Sam. •6 Fluorescent Signs
to-wit: Agency.Ina November 30, installed floor covering for immediate b coffin 623- Hundreds and hundreds of •60 Price Stickers
Four improvement of fits t y g name brand children's •6 Directions]Arrows
k(6)in The7,drat NPDES Permit. instream temperature has the Rhea-Mims Hotel TN. 6111 h t b regret tat we _
The color limit, established occurred Blue Ridge Paper E.Broadway,Newport,TN. g sot be responsible for clothing (boys and girls) •Marking Pen
iakland b the U.S. Environmental Drawings and more than ONE sizes newborn to 7, •Inventory a Tip Street
:o the Y still cannot meet tyre Norm
shown Protection Agency, was Carolina's temperature spedficatlons may be seen INCORRECT INSERTION pa teoN dress clothes. sae 2, PLUS your 14 weal ad
hddition based on the El requirement. - . at site. Submit, sealed, and only for tat portion of malerng winnew crib
imegretatron- of North The Director of the written bids orpmposals by to ad tat may-have been bedding set,twin sae bed, ALL YARD SALE -
9a C• Carolina's narative 10-00 a m August 20. rendered valueless by such strollers, name brand ADS ARE PAR IN
nber 3, Division of Water Quality teenage girls clothes,
in Map NCAC tl for color (nd pursuant to NCGS 143- New to 375 Alex 21. prof �f pub insertion fit g gr ' ADVANCE
NCAC 20.0211(b)(3)(f)and 15.1(c)(3), NCGS 143- Newport, TN 37621, proof of puWiration, end d meths and lemon's We accept Visa
t Page set color limit of 50 color 215.3(a),NCGS 143-214.3, Attention: Leon Bryant. is the responsibility o1 the clothes, car see6 toys, end Mastercard
r(Office units below the point of NCGS 214:1, Regulation This project is funded advertiser to check each glassware, flower
•,oumy, discharge. The color 15A NCAC 2H. Section under an agreement with insertion and call the error arrangements, ' books,
75 feet reductions currently TN Housing Development to our attention. many,marry other hems too The Newport PWn Tot
dud e• .0100, and Regulation 15A 145 East Broadway
g pursued at the mill are the NCAC 2B Section .0226,"kgency thru D HUD. The 'DEADLINE FOR numerous b mention. Newport,Tn
running result of a 1997 has determined taFit is in NHADC reserves the right CORRECTIONS:
udperty ,Pernc/Settlement the public Interest that n to reject say or all a--OOAMA2NOON 3-FAMILY YARD SALE - Ph.423-623-6171
parellel Agreement ' -' reached hearing fro held to receive a proposals. Davis-Bacon PHONE [phone] "August 4th, 139 Dell Way Y
r flrie of between fie State of North e minimum wage rotes ere off OId-Greeneville Hwy. Weekday Deadfim: •1
Bobbie all pertinent r public :CULSSIFlED HOURS:
Carolina, State .01 comment on whether to applicable. An -.Equal . Opal TOS P.M. -Dishes, curtains, home 1p.m.Prior to publkatiwL
a deed Tennessee.• EPA, Cadre Opportunity Employment interior, and lots more. date and on Sunday,
issue, muddy, or deny the MONDAY THRU FRIDAY 10 a.m.Friday 4:
s deed Courtly (Tennessee), The Agency. Sam-4pm.
♦ , 4 ♦ ♦ • , '®.:u. '"'" "`sue x: ..
40
0
#78206-Duplex apt.just min.from OTMIG-3>BRI1.5-BA home*With full #76181 -Wonderful subdiVlsleh.3- ..i77184-I"iATi�"
ROTTSVILLE,40.95 town on Hwy.411 this apartment basemeM.large fireplace,huge BR/2-BA,open jiving area, Joe Reed Road in Dewed
st property around, building features 2 bedrooms,I bath, '.rooms,covered porch,and creek. kitchen/dining combo.2-car garage, Tennessee.Improved volt
it,steep,hardwood, kitchen/dining room,and Irving room. Mobile home on property that rents huge storage building,level 1x acres. home w/CHA.Large femll
me sites with a great Each unit.Deck in back each unit.
for$300 monthly.Brand new on mar- 'Log exterior and natural woad finish. separate workshop,Dam.
Co. also both units share basement. ket,and only$124,9001 $127,900. mobile home,carport spl
Buyl 2 BR,1 BA,cen- Totally remodeled.$110.000. 85779.3-BR2-BA mobile home. 4t77985-A-frame home on wooded, pond and lots more.Deer
nice home with priva- #74750-REDUCED!$9,000 Will buy Immaculate.inside and out.Deck cov- fenced lot on Goff Course Rd.3-4 on the property.Absolutel
)0. this s/w on a rental lot In Point ered and nice fenced yard.Beautiful BRs2.5 BAs,fireplace.$134,900. appointment only,Cal Lo:
t located in Le High Pleasant.Nice,dean remodeled 2- landscaping and private.$69,900. .68014-Small cabin located on 6s i78475-DIN moh0eltt M
ich. BR/1-BA with all appliances.Lot rent ":#76847.3-BR/1.5-BA mobile home acres with 2 separate septic systems lot.Rent$1501110- 0!141
e•Excellent water Is$125 per month.Big yard,well located on lot in city limits.1310 sq. In Cosby.$45,000. . $53,500•
pprox.6 Miles from water. It.Great area.Only$24,900.Make an OM27-Nice home on 10 acres. i77077•Fixer upper•
derately railing to #74056•HARTFORD,12 acres,3 offer. Sun room,landscaping,file,private, jots in town.Could 11041¢
1perty Is getting BR2 BA brick,basement.Potential #77250-LAKE!!!!Off Hwy.411.2- close to town.$279,900. mercial property.$now
this one nut i Oniv RFD P. RRFAKFAST Next to Nat- BR/1-BA c0ga0e with vinyl Siding, (78M-1999 DIN.3-4 BRS2 BAS, #7112�;a-B•n-BA ti m

APPENDIX B
Presentation from Public Hearings

4-4
17�
Cd
a
a
Ct ❑ o
V1 J p w
p O O b
U ti p
ri [
(D p p O
�A, -1 ^ N."._," �� � llct+. .• •. i 4 4"., .Ia. ..i,rh ('. .1 I.

Facility Information
■ Blue Ridge Paper acquired ownership of
mill in May 1999, from Champion
International.:, _
r , ,e
■ Blue Ridge Paper is an employee-owned
company.
Facility Information — Continued
sIN Integrated pulp and paper mill
■ Operates two fiber lines - One hardwood
line and one pine (softwood) line
m Operates°four paper machines producing a° -
variety of products -
2

Major changes for 2001 permit
■ Federal Guidelines implemented
94
Wastewater,generated from the bleach.plant
will be limited/monitored. -
New Best Management_Practices for the
Industry
Major changes for 2001 permit
■ Dioxin'
— Federal guidelines designed to further address dioxin
Fish"tissue data indicates that dioxin levels continue to
decline,in the Pigeon River and Walters Lake
;. N,The fish consumption advisory exist for carp in Walters Lake.
3

Major changes for 2001 permit
■ Instream monitoring program
. Monitoring frequency at NC%TN monitoring station "r
modified to 2/week during the summer and once
per week during the winter.
. Modified instream monitoring at river mile 53.5
and river mile 57.7
Major changes for 2001 permit
■ Biochemical Oxygen Demand.(BOD)
Monthly average BOD5 limit reduced 71 tons
t per year.
Daily maximum BOD5 limit reduced 12.5%. '
N
4

2001 NPDES Permit and
Variance - Temperature
F '■ Continues the 316(a) temperature variance
- Temperature is not prohibiting a balanced and
indigenous"species below the_discharge.
Recommend continuation of temperature
variance and 0.4 mile mixing zone.
Finally
■ In the last decade, the efforts of all the
parties have resulted in remarkable progress
,for the Pigeon River.
;4
5

1997 NPDES Permit
■ 1997 - January 13th, the State of Tennessee _
filed a contested case petition challenging
the permit and color variance. '(Champion,
Locke County; City of Newport, Tennessee Environmental
,.Council, and American Canoe Association were allowed to
later intervene)'
■,1998 - Parties enter into a Settlement
Agreement,=resolving disputes surrounding
'the contested permit and color valiance and
described a process for permit renewal in
2001
Results
Comparison ofI994 Permit Pollutant LoaEing to 2001 Permit Pollutant Loadings for rho
Canton Mill
tm000
lfaam �„
y9u tmom
ti £ Ionian
y �''� _ •2Lrf1
£ r
y V @JOW
ADOX, '
EIAYM CdM1&tlay1199 Baby Meilmum 155-Mom�ly BOD-Daly''-. BOD-Mn11Ny
IaIW4. .t A�ea9e lm0'LI. Mmin,arlmYLl_ AvraTImNLI u
ri
pallwM
6

What these Efforts Have Accomplished
cemyasun ar Ermine Fmw rm...c.mnn Mill..d C.1.1h M.Pymn FW.,x Me
m finne:aetlNcmn
c. �m.shm Lm.
T
� mar
io
iYa
vymrNsmses u.RN�.1 'a+l.�l
2001 NPDES Permitting Strategy
o or
- Limits and conditioris'based on the EPA
chaired Technology Review Workgroup's
(TRW) recommendations.
■Members a
- Donald Anderson-Chair,EPA Headquarters -
- Karrie-Jo Shell' EPA Region IV
- Dan Bodien-EPA Contractor.
- Paul Davis-Tennessee Division of Water Pollution_.Control
-.
David McKinney-'.Tennessee Wildlife Resources `
- David Goodrich-North Carolina Division of Water Quality
- :Quality.Foxes[Westall,-North Carolina Division of Water
n�
7

2001 NPDES Permitting Strategy
oor -
TRW recommendations based on E.PA's Tech
Team Report and the Bleach Environmental,
Process Evaluation and Report (Conducted by:
Dr. Norman L-iebergott and Lewis Shackford)
■Tech Team
- Doh Anderson--EPAIEAb
-, Mark Perez-,EPA/EAD.
- - Karrie-]o Shell-'EPA Region IV - -
Y - Betsy Bicknell-ERG,Contractor to EPA, -
- Dr.Neil McCubbin,Ph.D.-Subcontractor to ERG • -
- Dan Bodien-Subcontractor to ERG•
2001 NPDES Permitting Strategy
Permit Limitations Verses
■ Draft'Color Reduction 2nd-stage Conditions
REQUIRE the mill to achieve additional
color reduction even if the TRW
-,technologies are not installed -
■ An additional Color Reduction of 30 % is a'
significant effort at the 'mill ,
■ The Liebergott'and Shackford report
indicates lower,expectations than those
8

2001 NPDES Permit and
Variance - Color
A ■ '2003 .
6,000'#/day initial color reduction
Blue Ridge Paper reports on studies of
identified and other technologies in order to
achieve an annual color loading between
34,000 #%day and 39 000 Wday:
- New monthly average color limit established
based on statistical evaluation of performance;
Instream flow criteria recalculated for
2001 NPDES Permit and
Variance - Color
: .`■ 2005
Blue Ridge Paper reports on the performance of
the technologies implemented as a result of the
2003 ;study. _
- Blue Ridge Paper report evaluating color
reduction technologies,associated with the
Chlorides Removal Process.
9

Conclusions
■ The second level of color reduction must be
achieved,-even if the technologies identified
by the TRW are not installed by Blue Ridge
.Paper.,...
■ 2001 Permit requires evaluation, for the first
time, of the feasibility of removing the color
variance.;
■ 2001 Permit provides a sound approach for
continued improvement, which will
r improve water quality in the Pigeon River.
Conclusions
■ The efforts of all the parties in the last
eca a as resulted in some reniffkable
progress on color-reductions in the Pigeon.
The focus of Tennessee, EPA,NC, Public
interest groups, and the company is to be
commended.
-■ The color_reduction job is not yet
completed, but by the end of this permit
T . cycle, DWQ has every expectation that Blue ,
,Ridge-Piper will be close to removing the

2001 NPDES Permit and
Variance - Color
02006
New annual average color limit'established'if between
34,000 - 3%000#/day. If outside of ihis'range NPDES
permit is reopened according to NPDES Procedures:
Monthly average color limit re-evaluated based on `
statistical analysis of performance data..'
"- Instream flow criteria recalculated for Fibe_iville°"
Bridge.
Blue Ridge Paper reports on color reduction efforts'and
feasibility of complying with North Carolina's color
standard.
Conclusions
■ By 2006, Color in the mill's effluent will be
reduced by an additional 19*to 29%-from
2001'permitted load (77.4% to 80%
reduction from 1994).
m Permit,Color removal requirements are tied
to the TRW recommendation, reflecting the
three levels of possible reduction (highest
certainty, reasonable certainty and low
certainty)
In-Stream Color compliance is now jusf-
10

APPENDIX C
Hearing Registration Sheets

\o��F W ATFRQG Michael F.Easley,Governor
William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
co r Gregory J.Thorpe,Ph.D.
={ Acting Director
p Division of Water Quality
Public Hearing Registration Record
Blue Ridge Paper Products, Inc.
NC0000272 ,
Name: Affiliatio : County of Residence: Public Official? trVes ❑No Written comments?
�-I If es,office held: ❑Yes o
a e of Residence: Do you wish to speak? ❑ Support permit
cS 0Z�S- I I-5- ❑Yes ❑No ❑ Onpose Dermit
Name: Affiliation: V County of Residence: Public Official? 0 Yes ❑No Written comments?
If yes,office held: ❑Yes ❑No
State of Residen : D ou wi .
❑ Oppose permit
Name: Affiliation: Public Official? [I Yes ONo Written comments?
_�o�\ f 4210 ounty of Residence: L' p If yes.office held: ❑Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
•psis []Yes ❑No ❑ Oppose permit
Nam
Affiliation: S',cunty ofgesidence: Public Official? ❑Yes 640 Written comments?
If yes,office held: ❑Yes ❑No
G State-oWesi ence: Do you wish to speak? ❑ Support permit
❑Yes D.Mb ❑ Oppose permit
Name: Affiliation: County of Resideqc�e: Public Official? OYes o Written comments?
�\ C GK'� If es,office held: ❑Yes ❑No
r ,_./' State of Resjdrn_cq: Do you wish to speak? ❑ Support permit
l�lfl�R. (� l /V ❑Yes OAor— ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes ul6 Written comments?
G C I� If yes,office held: ❑Yes ❑No
Iqq ) �,/ State of R n mit Do you wish to speak? ❑ Support per
Q •J Y� ��/ S fY/2Yy� A MV ❑Yes Ate ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes 041e Written comments?
/� '� If es,office held: ❑Yes O No
r I1 , { F 1 .e,n State of Residence: Do you wish 1papeak? ❑ Support pennil
pr 1 I a r'` ❑Yes ❑,Vo ❑ Oppose permit
Name: Affiliation: County of nce: Public Official? 0 Yes ❑No Written comments?
1AM-e— If yes,office held: ❑Yes ❑No
5� Ste l a idence: Do you wish eak? ❑ upport permit
\ 0 Yes U40 Oppose permit
Name: Affiliation: County of Residence: Public Official? D Yes Pflo Written comm ts?
oc r—- - It yes,office held: ❑Yes rr o
r L -/ State of Residence: Do you wish t�peak? ❑ Su oit permit
!! C fne / Ct de",L F/v ❑Yes p.NtS ose Permit
Name: Affiliation: CounMf,Resi �'cdenteI � Public Official? [I Yes ❑No Written comments?
Jn� If yes.office held: ❑Yes ❑No
Clp� State of Res id,€nce: Do you wish to speak? ❑ Support permit
J $� T (V es ❑No Onoose oermit
Name: Affiliation: County Residence: Public Official? D Yes No Wntten comments?
�l � ( {� I u'C,0 If es,office held: ❑Yes o
nj p'Cl�l aytG� State of ResidaT
Do you wish to speak? 0 Support permit
es ❑No A'Oppose Penit
Name: Affiliation: Co o(Residence: G� Public Official? 0Yes No Written com nts?
s� If es,office held: ❑Yes o
(H/J r'n �, State of Residenc ❑Do Yes OI h o speak? ❑ Support permit
❑ 0 ose permit
4;,f—
Illation: CouLof_Re�sidence: Public Official? ❑Yes c W' n comments?
u�Va r L L�r(/ If es,office held: es ❑No
(,,v /i f VC A State of Reside Do you wish to speak? ❑ Support permit
�(�(ftijLLNGt' ❑Yes ❑No ❑ Oppose ertnit
Nam Affiliation: County of Reside Public Official? ❑Yes No W'tten comments?
/'� /� V U% If es offce held: es ❑No
,1 Ike I (i —/� s State of Residence: ,/ Do you wish to speak? ❑ Support permit
AJ C. ❑Yes ❑No ❑ Opp oso permit
Name: Affi� tion: FF County of si :a: Public Official? ❑Yes 0 o Written comments?
f , ,�\,•� If es,office held: ❑Yes ❑No
W K1 State of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ Oppose ertnit
ArIM
NCDENTR
N.C. Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 [phone] Customer Service
1 800 623-7748
Page ) of 9

F \NATF Michael F.Easley,Governor
O R William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
UJ r Gregory J.Thorpe, Ph.D.
ctin Director
O Y Division of Water Quality
Public Hearing Registration Record
Blue Ridge Paper Products, Inc.
NC0000272
Name: Affiliation: Cou of R id ce: Public Official? 0 Yes []No Written comments?
1 If yes,office held: ❑Yes ❑No
�`•—�. , Slate of a 'dence: Do you wish to speak? ❑ Support permit
141,f'(1rhV Fel/� �ft��eF ❑Yes ONo D Oppose permit
Name: Affiliation: Cou of R itl ce: Public Official? ❑Yes ❑No Wntten comments?
tK C If yes,office held: 0 Yes ❑No
State of Residen e: Do you wish to speak? ❑ Support permit
1 ❑Yes ❑No ❑ Oppose permit
me: Affiliation: Public Official? DYes ONo Written comments?
County of Residence:ejcer� If yes.office held: ❑Yes ❑No
Slate of Residence: Do you wish to speak? ❑ Support permit
OI�C ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: 0 1 County of Re idenc Public Official? 0 Yes ❑No Written comments?
If yes.office held: ❑Yes ❑Nc
p State of Re ' Do you wish to speak? ❑ Support permit
W � (�.1 ❑Yes � �O ose ermit
Name: I County of Residence: Public Official? O Yes ❑No Written comments?
If yes,office held: ❑Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
OxG S ❑Yes ose ermit
Name: Affif tion: County of Residence: Public Official? ❑Yes ❑No Written comments?
` If yes,office held: ❑Yes ❑No
t n State of Residence: Do you wish to speak? ❑ upport permit
CW C9 S `1 I (A ❑Yes N Oppose permit
Name: Affiliation: CounJy�CResi ence: Public Official? D Yes ❑No Written comments?
ll CC If yes,office held: ❑Yes ❑No
Cy�� P�wNs �cnwAr�� �T� SlatWResidence: Do you wish to speak? ❑ Support permit
W N Yes ❑No 0,Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes W'No Written comments?
/lam /1 v.J GoMLS1= If es,office held: IkYes ❑No
State of Fesidence: Do you wish to speak? ❑ Support permit
V� /V ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: LL County of Reside Public Official? ❑Yes *No Written comments?
rIYJ�� G6 [G. f71G I c D yoes,u
office held: ❑Yes o
C n ✓ Stale of igqee��ce: Do you wish to speak? ❑ Support permit
95 5 L�) ) �V as ❑No O ose ermi1
Name: Affiliation: County f Residence: public Official? 0 Yes ❑No ntten comments?
y!/ If es,office held: O Yes ❑No
/�, (y�� Stateof ge�ftlenc ige a: Do youwishtospeak? ❑ Support permit
Ic•G��b6 .(l )L I / � t Do
❑No ❑ Oppose permit
Name: Affiliation: Countyy 0yde�: Public Official? 0 Yes ❑No Written comments?
M)4y,vy. (�P�S If es,office held: ❑Yes ❑No
tlP9 Tf ^�,TNy�y State of Residence: Do you wish to speak? ❑ Support permit
/(A�+ -+J��i ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: - - Public Official? 0 Yes ❑No Wntten comments?
If yes.
G office held: ❑Yes ❑, Stale of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ Oppose permit
Name: A is lon: Cou of Residence: Public Official? es ❑No Written comments?
If yes.office held: Imo. ❑No
�D .f ,tom Stateof Res' nce: 'Do'yoouu wish to speak? upport permit
/t -�,/ ry *tz Qpwea 0 No ❑ Oppose permit
Km e: Affilialon: County of esi ence: Public Official? DYes ❑No Written comments?
ps:t r� If es,office held: El Yes ❑No
I' r �//� ///(((����e State of Residence: Do you wish to speak? ❑ Support permit
/�
\e(J&4 r r K) ❑Yes iii.e ose permit
Name: Affiliation: County of esidence: Public Official? 0 Yes Pw Written comments?
If/-�r V"' _ l C t % D y office held: ❑Yes 0 No
(vF J Stateof Res en Do ya wish tospeak7 ❑ Su rt permit
t ❑No ose pqrmit
.�
NCDENR
N.C.Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748
Paget•of q

F WAT�r Michael F.Easley,Governor
\0�0 9pG William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
COr i Gregory J.Thorpe,Ph.D.
::4 Acting Director
O Y Division of Water Quality
Public Hearing Registration Record
Blue Ridge Paper Products, Inc.
NC0000272
Name: Affiliation: County of Residence: Public Official? D Yes ❑No Written comments?
yffn�, If es,office held: ❑Yes ❑No
Ke 1/ S 1� /1 I SCE Stale of Residence: Do you wish to speak? ❑ Support permit
t 1,' �lih c,i(: C,(�i4� ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? C Yes ❑No Written comments?
•.' C".. 3 If yes,office held: ❑Yes ❑No
} Slale of Re idence: Do you wish to speak? ❑ Support permit
C7-.j R. \ < C- ❑Yes ❑No ❑ Oppose permit
Name: I A Ration: LJ ' '~ Public Official? 0Yes ❑No Written comments?
County of Residence: It yes,office held: 0 Yes
❑N o
Stale of Residence: Do you wish to speak? ❑ Support per
mit
❑Yes ❑No ❑ Oppose permit
Na 1' Affiliation: %_ii ' County of Residence:. Public Official? D Yes ❑No Written comments?
It es,office held: ❑Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No L] Oppose permit
Name: Affiliation: v - Cbudty of Residence: Public Official? D Yes ❑No Written comments?
If yes.office held: ❑Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
�>rL� y fW `,rtr+ D �"�- C� .I• ❑Yes ❑No ❑ Oppose permit
Name: ll V Affiliation:J County of Residence: Public Official? 0 Yes ❑No Written comments?
If yes,office held: ❑Yes ❑No
S e of Residence: Do you wish to speak? ❑ Support permit
4K.V (JYd7lu 7.�'- ❑Yes ❑ Oppose permit
Namd/• 0 Affiliation:,--^• County of esidence: Public Official? 0 Yes ❑No Written comments?
f7 If es,office held: ❑Yes ❑No
i.,/' State of Residence: Do you wish to speak? ❑ Support permit
,%.,lf J, ✓"�'t �. l I•' !~ f ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: Cou of Residence: Public Official? ❑Yes ❑No Written comments?
}? If es,office held: ❑Yes ❑No
t,rt- hd State of Residence: Dg�you wish to speak? ❑ Support permit
-Qp Wb`A ��<<[tNCQ-' 7Yes ❑No VO ose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes ❑No written comments?
:
t If yes,office held: ❑Yes ❑No
� l
1 State of Residence: Do you wish to speak? ❑ Support permit
� 7 tJ ❑Yes ❑No ❑ 0 ose ermit
a e:` �Apffiliation: County of Residence: Public Official? ❑Yes-19,No Written comments?
r�� N O Q` `e'•�h env, �y„��,l If yes.office held: Yes ❑No
O Slate of Residence: Do you wish to speak? ❑ Support permit
.:Yes ❑No Oppose permit
Name: Affiliation: r9 County of Residence: Public Official? 0Yes ❑No Written comments?
I-, rc
A P� c i CK.< If es,office held: D Yes ❑No
p,N�(,Jp�i/ /`1ITcP•`f�t ! State of Re idence: Do you wish to speak? ❑ Support permit
�t" V pyds ❑No Q:'Zppose permit
Name: Affiliation: County of Residence: - Public Official? 0 Yes ❑No Written comments?
—T >_. If yes.office held: OYes ❑No
State of Residence:��I Do you wish to speak? ❑ Support permit
A U U 1-� i.-S' rJ` []Yes ❑No ❑ Oppose permit
Name: Affiliation: W C my of Rpsidence: Public Official? 0 Yes o Written comments?
L fl{Zo(_yr ¢^�� jL nIL rrJ Public
Id. ❑Yes o
rt/ rJ S 0 L'TD. ` " ' r/Nh State cf R�esldence: 0Do Yesu wish to speak? ❑ Support permit
31%4e- Y,.Oppose permit
Nam.1i Affiliation: Courty of Residenc : Puhlic Official? ❑Yes .FSNo Written comments?
00A I? If yes,office held: ❑Yes XNo
State of esidence: Do you wish to speak? KSupport permit
/c (-!7'21h ❑Yes XNo ❑ Oppose permit
Nam ' Affiliation: Coun 11 of Residence: Public Official? 0 Yes ❑No Written comments?
/� O.,.,Cc, office If es held: ❑Yes ❑No
MOM e 90 5 e N� C �e a,Cj�0 eY State of Residence: Do yo ish to speak? ❑ Sup pemlit
�/ C- s D/ No ose ermil
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 6233-7748
Page'l of 1

W ATFRo Michael F. Easley,Governor
William G.Ross Jr.,Secretary
`O G North Carolina Department of Environment and Natural Resources
rGregory J.Thorpe, Ph.D.
-{ Acting Director
D Y Division of Water Quality
Public Hearing Registration Record
Blue Ridge Paper Products, Inc.
NC0000272
Name: Affiliation: County of sltlence: Public Official? ❑Yes &4K Written comments?
i y� /a r( /1 ^ If es offish held: Dyes rt&Rr
per
1 1f , (CtA L`J i (31 State o(Residence: A ' Do you wish to speak? ❑ Support permit
1 JV qXtl ❑No ose permit
Name: Affiliation: County of Resid Public Official? 0 Yes ❑No Written comments?
e ce:
-rU If yes,office held: ❑Yes ❑No
br�/I \J • f 1 Z State of Residence: �N Do you wish to speak? ❑ Support permit
V �J 1,p �l 1 ❑Yes ose permit
Name: Affiliation: /'� y • Public Official? ❑Yes PWO Written comments?
1., {/�� County of Residence:l C� It es,office held: ❑Yes Q-KO
LA 6vtdV �1 F+ \ State of Residence: / Do you wish ty.speak? ❑ Support permit
-r/V ❑Yes CKo ose permit
Name: Affiliation: County of Residence* Public Official? ❑Yes I&W Written comments?
•� I ///•••��f Residence* Public
If yes,office held: ❑Yes ONO
State of Residence: —r t ! Do you wish to speak? ❑ Support permit
( �1/ ❑Yes o 34ppose permit
N me: Affiliation: County o Residenc • Public Official? 0 Yes o Written comments?
D you
office held: ❑Yes ❑No
Slate o s en Do you wish to speak? ❑ Support permit
Yes ❑No ose permit
Name: Affiliation: County of Residence: Mlle Official? ❑Yes El No ritten comments?
pJ c If es office held: [)Yes ❑No
�/�' i 1 jl°�� State of .den e: Do u wish to speak?
J� 1 �J�.� {r .G�" 5 V-1 esi es ❑No P ❑ Support permit
MC.
❑ Oppose emit
Name: � / Affiliation: Coun of Residence: Public Official? Dyes ❑No Written comments?
`�j,{h-1zz 0 , , l •,12 If es,office held: ❑Yes ❑No
C`hD-+t t �1 C�� C�• ;`� C� i State of R id ce: Do you wish to speak? ❑ Support permit
it C� Yes 0 No
ose permit
Na re: Affiliation: CouV of Residence: Public Official? 0 Yes ❑No Written comments?
Cot" If es,office held: []Yes ONO
C `f r5 LOW tiv-� � Z��� State of Residence: Do you wish to speak?
0
��, NL— ❑Yes t••No Oppose permit
Name: Affiliation: County of Residence; Public Official? 0 Yes J<NO Written comments?
s>�D"'h B`•ny'ILI Le If yes.office held: Dyes ANo
( State of Residence: Do you wish to speak? ❑ Sup permit
ermit
�90 FE P� aC��» B�b�',v Pro I(/ L es ❑No O se permit
Name: STD/N Affiliation: c , COU ty of idence Public Official? 0 Yes o W9'Ven comments?
CD 5j P-Wf ! &T �" 945- If yes,office held: arYes ❑No
State of R�epp))'d,ence: Do you wis to speak? ❑ Support permit
❑Yes o eO ose permit
Name: Affiliation: Cou of Re51idence: Public Official? 0 Yes DLNz— Written comments?
(L`(lyd•• 1-TYj (]G�G-� If yes,office held: [)Yes ❑No
Lc�c�re�� imme (J 5 K� Sate of Residence: Do you wish to speak? ❑ Support permit
[]Yes YA6-- se permit
Name: Affiliation: C my of Residence: Public Official? ❑Yes 0 - Written comments?
� � 1 If es,office held: ❑Yes Me
/ rill) l State Or�ce: Do you wish to speak? ❑ upport permit
O / ( ❑Yes o b<popose permit
Name: A li 1 County o esidepce: Public fficial? D Yes o Wri n comm nts7
r�CgC"I CSL- If es,office held: ❑Yes boo
Stale of Residence: Do you wish to speak? ❑ Sup rt permit
!! Fj ❑Yes 2Nd— Qppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes ❑No Written comments?
If yes,office held: ❑Yes ❑No
Gf4f State of Residence: Do you wish to speak? ❑ Support permit
S 4/72 ❑Yes ONO
❑ Oppose permit
Name: Affiliation: County of R idence: Public Official? O Yes ❑No Written comments?
�J f� If es,office held: ❑Yes ❑No
Na L1k�� p fV bCn l� l�/9/�� State of Reslden e: Do you wish speak? upport permit
L'J Dyes 1Ao ❑ 0 os//e�� emit
NCDENR
N.C. Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 [phone] Customer Service
1 800 623-7748
Page of-F

WA Michael F.Easley,Governor
William G. Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
UJ r Gregory J.Thorpe, Ph.D.
Acting Director
O Y Division of Water Quality
Public Hearing Registration Record
Blue Ridge Paper Products, Inc.
NC0000272
Name: Affiliation: Coun f Residence: Public Official? D Yes ❑No Written comments?
/may 14L,
` R �6 : P�T,� If you
office held: �s ❑Na
� r d � State of Rer�t ce: — Do you wish to speak? Support permit
r P s ❑No ❑ Oppose permit
Name: Affilia' rt: , County ofBeHd c P bill,Official? MY"
❑No Written comments?
, g. �n �/ ��(,J If es,office held: ❑Yes ❑No
�I��L-c-ril/IS s State of Resid�r�,�{ 6 D��'ou wish to speak? ❑ Support permit
�ixke—� / 1 / I'✓ X-S ❑No ❑ Oppose permit
Name: Affiliation: .,.J t Public Official? es ❑No , Written comments?
Avon County of Residence: / �jv� SSrO.VeP ❑Yes &W
t/G✓ �/ It es,office heltl: (,�
��,,�I/ /�j�1✓ ��D / State of Residence: Do you wish to speak? ❑ Support permit
/ '1 ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: n County of Residence Public Official? D Yes El No Written comments?
If yes,office held: ❑Yes ❑No
Slate of Residence: Do you wish to speak? O Support permit
3 stf ❑Yes ❑No ❑ Oppose permit
Name: Ill lion' County of Resi Public Official? D Yes Wo Written comments?
If yes,office held: ❑Yes No
AA I y� c T/V,� Slate of Re siden Do you wish to speak? q Sup ort permit
'V1) v�'✓lJ lA� C *KYes ❑No X oppose pemnit
Name: Affiliation: Coun (Residence: Public Official? 0Yes VK Written comments?
If es,office held: ❑Yes ON o
Slate of R ence: Do you wish to speak? ❑ Support pennit -
C/ Des ❑No ❑ Oppose pernnit
Name: Affiliation: C ttyy of Residence: Public Official? ❑Yes Written comments?
J,ULO � II yes,office held: VYes ❑No
Stale of R si eyce: Do you wish to speak? ❑ Support permit
es ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? O Yes ❑No Written comments?
If yes,office held: ❑Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
29 ❑Yes <f a ❑ Oppose permit
Na e: Affiliation: �j,r� ; } County t Residence: Public Official? D Yes n No Written comments?
, If yes,office held: ❑Yes ❑No
State of Reside .. Do you Wish to speak? ❑ Support permit
1• `�� I"' 1t.!trv� 'Y CU'T' CSri1.. :� ❑Yes o A Oppose permit
Name: AA f� (� Affiliation: Coun of R s' a Se: f� Public Official? D Yes o Written comments?
I1� IUr 8y., '11 t/� _ o ^ L3QOa� D you
office to
oyes ❑No
Pkej1lll I'htIOf(Y \1V-- �f ` p State of Reside Ice* Do you wishto speak? Support permit
C-- ❑Yes y^,46 ❑ Oppose permit
Namd. Affiliation, /1 �/ Cou fResidenb Public Official? 0Yes ❑No Written comments?
If yes,office held: ❑Yes Wd6
Sbfte of Re ' nce: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ Oppose Permit
ame: Affiliation: County of Residence: Public Official?�1 Yes ❑No Written comments?
If es,offce held Was ❑No
/ State sl nce: Do you wish to speak? ❑ Support permit
', lbt - ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: c e itlgncQ: Public Official? 0 Yes ❑No Written comments?
If yes.office held: ❑Yes ❑No
G(� f _ _ AArt State of Re i ence: Do you wish to speak? ❑ Support permit
Lab-, `p'IY�Y`^ /r'W. W �UN ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? es ❑No Written comments?
If es,office heltl: ❑Yes XNo
.I rr _ Stale of Residence: Do you wish to speak? III Support permit
at, r('(t !b ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: Cou of Res e: Public Official? 0 Yes o Written co ents?
R w Pulp
office held: ❑Yes o
State of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ O ose permit
XrA
1MENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748
Page of j

F W ATF Michael F.Easley,Governor
D \0�0 RpG William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
rGregory J.Thorpe, Ph.D.
>_ Acting Director
p Y Division of Water Quality
Public Hearing Registration Record
Blue Ridge Paper Products, Inc.
NC0000272
Name: Affiliati4D' C rlty of Residence: Public Official? ❑Yes ❑No WdttBfi comments?
�` /10 A G35—F If es,office held: �V(es ❑No
y)r1.11, Slala pf Residence: Do yQurWlsh to speak? ❑ Support permit
'7 g SS P es [I No ❑ Oppose permit
Name: Affiliation: County of Residenc : Public Official? OYes ❑No Written comments?
f p CDC If es,office held: ❑Yes ❑No
8/'112/I — �q5 r L/0147b 'rJxPe$5 State o esidence: Do you wish to speak? ❑ Support permit
❑Yes ❑ Oppose permit
Name: Affiliation: II II ^^ Public Official? ❑Yes No Wntten comments?
County of Residence:("T S 2 2.1c) If yes.office held: ❑Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
❑Yes o X Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes ❑No Written comments?
1 If es,office held: ❑Yes ❑No
v, , A /,a-r_ 7 State of Residence: Do you w' o speak? ❑ Support permit
�/� VVV" r'mil/ ❑Yes o ose permit
Name: Affiliation: County of Resl ence: Public Official? D Yes o Written corymants?
'o If es,office held: ❑Yes I�INo
f:J �95 State P Residence: Do you wish to speak? ❑ Support permit
N •(',. ❑Yes ❑DIf�' Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes t3'No Written comments?
305k FIN; 3U(IV50, If es,office held: Dyes DNo
tic>,a State of Residence: Do you wish to speak? ❑ Support permit
G V. C- ❑Yes No O ose permit
Name: Affiliation: Cou of Re idence: Public Official? D Yes IkNo Written comments?
C) 11 If yes,office held: ❑Yes D No
Ste ence: Do you wish to speak? ❑ Support permit
�22A ED! L t esi ❑Yes '000 —,�l<Oipipose permit
Name: Affiliation: L Cout of Resitl ce: Public Official? ❑Yes INo Wntten comments?
Senne�CFe C0� OC If es,office held: ❑Yes ❑No
�ec s { �� 1 S,lgol Residence: Do esu D No wish o speak? ❑ Support permit
/�/ C,10ppose permit
Name: Affiliation; II County of Residence: Public Official? 0 Yes ,^a Written comments?
S ch d/ C 0 C If yes,office held: ❑Yes ❑No
Stag si nce: Do you wish to speak? ❑ Support permit
��% I 1 -/ G7 es ❑No Oppose permit
Na Affiliation: U.J A k,( Ci Countya Residence�,y Public Official? 0Yes o Written camrpantS.
Go rN If es,office held: ❑Yes ❑
U ( ) State of Residence: Do you wi to speak? ❑ Support pe mit
O O ' r tj ❑Yes No ❑ O ose ermit �r
Na ye, 1 Iliation: Court esidence; ( Public Official? ❑Yes ❑No Wri�tCn comments?
1�)<�}�uA)'�12 t'S I tyU ID C If es,office held: RJFes D No
t'l �� �i t�r ZL State of Residence: Do you wish to speak? upport permit
—� •(?-- ❑Yes ❑No ❑ Oppose permit
N me: I Affiliation: ounty of Residence: Public Official? Dyes 54No Written comments?
�p L "!,ri'C 1V If es,office held: ❑Yes o
" •' -' Stat a Residence: Do you wish to speak? O Support permit
N GE (� KYes ❑No Oppose permit
Name: Affiliation: Co ty of Resid Public Official? 0 Yes ❑No Written comments?
�/q\/ I Uri (7/Vl If es,office held; ❑Yes D No
+' r/`Ijfe Q 1 State of,i2Qsidence: Do you wish to speak? upport permit
1 6 b JV L ❑Yes T-W ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes ❑No Written comments?
If yes.
you
El
held: ❑Yes p e 0 p
Slate of Residence: Do you wish to speak? Support rmit
❑Yes ❑No ❑ Oppose Permit
Nagle* Affiliation: Cou ty of Residence: Public Official? D Yes ❑No Written comments?
�S �� P �r Cow.b 0 you
office held: ❑Yes Imps
Statepf esidence: Do you wish speak? pport permit
`v G ❑Yes *0 O osh^e pemnit
NCDENR
N.C.Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 [phone] Customer Service
1 800 6233-7748
Page 6of

\Oa�F W A j'F9 pG� Michael F.Easley,Governor
William G.Ross Jr.,Secretary
DU
North Carolina Department of Environment and Natural Resources
co
r Gregory J.Thorpe, Ph.D.
Acting Director
p Y Division of Water Quality
Public Hearing Registration Record
Blue Ridge Paper Products, Inc.
NC0000272
Name: r,.,,y1 Affiliation: CA6nty of Residence: Public Official? Dyes ❑No Written comments?
Lzf If yes,office held: ❑Yes ❑No
State of Residence: Do you wish to speak? Support permit
C. D Yes Fero ❑ Oppose permit
Name: Affiliation: County of R l ence: Puhlic Official? D Yes UNo Written comments?
D you
office held: ! ❑Yes No
J/� State of Residence: � / Do you wish to speak? ❑ Support permit
C—r L r eY �l/C Yes ❑No XOppose permit
me: iliatlon: 1 Cor * . Public Official? D Yes ❑No Written comments?
♦' W✓zuk- If es,office held: D Yes ❑No
6ingStat of es' ce: Do you wish to c"eak? pport permit
( ❑Yes ❑ Oppose permit
Name: I Affiliation: Cour�yof Residence: Public Official? 0 Yes ❑No Written comments?
^ I q� ' f Re D you
office held: ❑Yes ❑No
17/J �jj( State of Residence: Do you wish to speak7 uppod permit
Gr r� /� t/C L /Y ❑Yes o ❑ Oppose permit
Name: Affiliation: unty of Rpsidence: Public fficial7 D Yes ❑No Written comments?
Uri(}ed J^ i'6V If es,office held: ❑Yes ❑No
b r�sd� GVxrt,Y( Sta(�oI Residen Do you wish to speak? ❑ Support permit
-�6ow Dec�cvre-6 ( lUo j� 1 nCti_. ;ZIes ❑No ose ermit
Affiliation: County of Residence* Public Official? ❑❑Yes No Written commenls7
llllll To'f"if O 'gY u'�C 0 If es,office held:
ld: D Yes ^ o
r State of Resiidence: Do you wish ak7 upport permit
N E ❑Yes c ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? D Yes ❑No Written_comments?
o If es,office held: ❑Yes ' No
Slate of esi ence: Do you wish to speak? f.8upport rmil
GA 7 ,1 ❑Yes 0�-Tto ❑ 0 ose er
Name: Affiliation: C ty of Residen : Public Official? es ❑No Written comments?
If yes,office het : C'Yes ❑No
t/ la a id e: Do you vi to speak? Support permit
❑Yes D O ose ermil
Na Affiliation: ty of ResideTT Public Official? D Yes C 07-— Written comments?
If es,office held: ❑Yes t o�
Sla a of esidence: Do you wish to speak? ❑ Support permit
Ic ❑Yes ❑No D Oppose permit
Name: I atl n: un f Residence: Public Official? 0 Yes.r'No Written comments?
If yes,office held: $Yes ❑No
esi ence: Do you wish to speak? ❑ Support permit
I -. i zIes ❑No I*Oppose pemilt
Narita: Affiliation: County of sitlQOD Public Official? El Yes ❑No Written comments?
K/� D you
office held: ❑Yes ❑No
V State of Residence: Do you wish to speak? D Support permit
❑Yes VNo ❑ Oppose permit
Name: Affiliation: Coupty ofResidence; Public Official? D Yes ❑No Written comments?
If yes,office held: Dyes ❑No
jilt Q n Sta e of Re idence: Do you wi h to speak? ❑ Support per
/� Li Nc ❑ Oppose permit
Name: Affiliation: Counw ofRe;idennce' \ Public Official? D Yes ❑No Written comments?
t
./ xC \ AJ If yes,office held: []Yes ❑No
D �C C�Y. State of Residence: Do you wish to speak? ❑ Support permit
1�1t67,W) )'IOW Y El Yes 121 ❑ Oppose permit
Name: Affiliation: County o Reside ce: Public Official? 0 Yes ❑No Written comments?
O o'0 If yes,office held: ❑Yes ❑No
State of silence: Do you wish to speak? ><Support permit
c ❑Yes VNo ❑10ppose permit
e: Affiliation: County of Residen Public Official? D Yes 0 No Written comments?
CUC If yes,office held: ❑Yes ❑No
yo
State of Residence: Do you wish to speak? ❑ Support permit
❑Yes 0401 1 ❑ Oppose permit
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748
Page of-7

F 1(�J/{TF Michael F.Easley,Governor
\oa0 RQG / William G.Ross Jr.,Secretary
(6/ North Carolina Department of Environment and Natural Resources
UJ r _ Gregory J.Thorpe,Ph.D.
Acting Director
O Y Division of Water Quality
Public Hearing Registration Record
Blue Ridge Paper Products, Inc.
NC0000272
Name: Affiiatio County of esidence: Public Official? ❑Yes No Written comments?
O. If es,office hee ld: ❑Yes o
Stater V idence: ❑Yesu wish to speak? ❑ Support p=tt
00 � 0 ose ertnit
Name: Affiliation: ' f Co tyof Residenyg: Public Official? DYes Oro Written comments?
/� ✓L(u , T 4T td : D yoes,u
office held: ❑Yes ❑No
�1�11xjtJ y F�� L l7IL� ^t State of Reside ce: Do you wish o speak? ❑ S pose permit
❑Yes ❑pf6 ose permit
ame: Affiliation: �, Public Official? D Yes ❑No dtten comments?
a M A'"Tl�Y
County of Residence:
C ' If yes,office held: ❑Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
II ��VV lllll....YYYYY ` ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? El Yes No Written comments?
If yes,office held: Xes ❑No
State of i ence: Do you wish to speak?a 2- Support permit
❑Yes o ❑ O ose ennit
Na e: Affiliation: Ccun lie n •®hp Pubrc0 is I? ❑Yes No Written ments?
7� V.CS If es,office held: ❑Yes -We
State f e ' ence: Do youwish ospeak? uppart permit
❑Yes o O ose Permit
Name: Affiliation: County of Residence: Publicce ❑Official? El Ye ❑No W en comments?
GIf es,offi held: ❑Yes No
f V,^ y / Stat of Re idence: Do you wisp to speak? ❑fupport permit
JK Qi�(at tJ �j - ❑Yes OtNo EOppose permit
IN Affiliation: (�IG,J Coun Resider) Public Official?.0 es ❑No Written comments?
If yes.office held: ❑Yes ❑No
State o,R,e;idence: Do you wish to speak? ❑ Support permit
/"e_ ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: CouriYof Residence: Public Official? ❑Yes 0 No Written comments?
dr) If yes,office held: ❑Yes ❑No
a fd J 9VJ4 2 State of e�sidence: Do you wish to speak? ❑ Support permit
of
❑Yes ❑No ❑ Oppose permit
Name: Affiliation: Cc ty of sidence• Public Official? ❑Yes ❑No Written comments?
M / 90 If yes.office held: ❑Yes ❑No
State of)R sid nce: Do you wish to speak? ❑ Support permit
Oafas D No F/Oppose permit
Na e: Affiliation: County of Residence: Public Official? D Yes ❑No Written comments?
If yes,office held: ❑Yes ❑No
�� aState of Residence: Do you wish to speak? ❑ Support permit
❑Yes ONo ❑ Oppose permit
me' Affiliation: Cou/� of Residence: / Public Official? ❑Yes D No Written comments?
7 CO d j g If yes,office held: ❑Yes ❑No
Spof sidence: Do you wish to speak? O-S"u-ppod permit
r ❑Yes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes ❑No Written comments?
(� ...b If yes,office held: ❑Yes ❑No
O�.(/ p State of Residence: Do you wish to speak? ❑ Support permit
�f-p C- lL ❑Yes XT40 ❑ Oppose permit
Name: A ion: County of Residence: Public Official? O Yes No Written comments?
d`7��f-+Q 5d/V If yes,office held: ❑Yes o
J State of Residence: Do you wish to speak? ❑ Support permit
L r Mom'GIN
N T6;J T Ne—� ❑Yes 290 ❑ Oppose permit
Name: Affiliation: County f Residencgg Public Official? 0 Yes o Written comments?
u.�c.L...{sei If yes,office held: ❑Yes ❑No
,9 �e 1^h State of Residence: Do you wish to speak? 0 Wort permit
/v ❑Yes ❑.1(0 Wuppose permit
Name: Affiliation: County)of Residence: Public Official? D Yes p7No Written comments?
C04/� Ali., 00 If es,office held: ❑Yes ❑No
I n n Aw. State of Residence: Do you wish to speak? ❑ Support pertnil
1�1 C. ❑Yes KNo P(Oppose permit
4�
NJCOEIdR
N.C. Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 [phone] Customer Service
1 80D 6233--7748Gy
Page'J_of-J

F WATF Michael F.Easley,Governor
�D�O qQG William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
CO r Gregory J.Thorpe, Ph.D.
>_ -q Acting Director
O Y Division of Water Quality
Public Hearing Registration Record
Blue Ridge Paper Products, Inc.
NC0000272
Name: Affiliation: County of Residence. Public Official? DYes 94fd' Written comments?
If yes.office held: ❑Yes ❑No
Stale.9t Residence: Do you wish to speak? ❑ Support permit
C • ❑Yes S4#6' EL-Oppose permit
Name: Affiliation: County of Residence: Public Official? D Yes ❑No Written comments?
WeNN Tl If yes,office held: ❑Yes ❑No
J6Jja fJ�UL r C.ETT'�+t� State of Residence: Do you wish to speak? /Support permit
7J es ❑No ❑ Oppose permit
Name: Affiliation: /i_ _ 1 Public Official? 0 Yes o Written comments?
County of Residence: (A
If office held: Dyes ❑No
D yo
State of Residence: Do you wish to speak? Cl Support permit
—�-C I El Yes D,DIo ose permit
Name: Affiliation: County of Resid nce: Public Official? ❑Yes piao Written comments?
Ca COCA If yes,office held: ❑Yes ffillo
C State of Residence: I Do you wish to speak? ❑ Support permit
0 ❑Yes ❑EIS 0—Oppose permit
Name: Affiliation: County of Resitlence: Public Official? ❑Yes p.No Written comments?
CO If yes.office held: ❑Yes RYCC'
1`/ State of Residence: Do you wish to speak? ❑ Support permit
Pif V/ ✓V .I !mac T-L, 1-YtM- 0No ClS�ose Permit
Name: Affiliation: ' County of Residence: Public Official? 0 Yes ❑No Wntten comments?
J If yes.office held: ❑Yes 0 No
late of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ Oppose permit
County of Residence: Public Official? 0 Yes ❑No Wntten comments?
If yes,office held: ❑Yes ❑No
Stale of Residence: Do you wish to speak? El Support permit❑Yes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes ❑No Written comments?
If yes,office held: ❑Yes ❑No
Stale of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? O Yes ❑No Written comments?
If yes,office held: ❑Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes ❑No Written comments?
If yes,office held: 0 Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes ❑No Written comments?
If yes.office held: ❑Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ Oppose e"it
Name: Affiliation: County of Residence: Public Official? DYes ❑No Written comments?-
If yes.office held: ❑Yes 0 No
Stale of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ Oppose Permit
Name: Affiliation: County of Residence: Public Official? D Yes ❑No Written comments?
If yes,office held: ❑Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
DYes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? 0 Yes ❑No Written comments?
If yes,office held: O Yes ❑No
State of Residence: Do you wish to speak? ❑ Support permit
❑Yes ❑No ❑ Oppose permit
Name: Affiliation: County of Residence: Public Official? DYes ❑No Written comments?
If yes,office held: ❑Yes ❑No
Stale of Residence: Do you wish to speak? ❑ Support permit
0 Yes ❑No ❑ O ose permit
Aga
d�CDENR
N. C.Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 [phone] Customer Service
1 800 623-7748
Page of J

APPENDIX D
Summary of Comments,Findings and Recommendations

Introduction
On the evening of September 6,2001, a public hearing was held on the color and temperature variances,
and the renewal of the National Pollutant Discharge Elimination System(NPDES)permit for the Blue
Ridge Paper Product's(formerly Champion)Canton mill. The hearing was held at the Tuscola High
School Auditorium in Waynesville,North Carolina and was well attended by parties both supporting and
opposing the draft permit. Approximately 127 people attended the hearing representing the State of
Tennessee,Environmental Protection Agency,Blue Ridge Paper, City of Newport, Cocke County,
Haywood County,City of Canton, environmental groups and concerned citizens.
Approximately 50 people commented on the mill,the draft NPDES Permit,color variance and/or the
temperature variance. Generally, all the comments were in support of the efforts of Blue Ridge Paper.
However,ruffle,60%of the comments expressed disapproval of the conditions proposed in the draft
permit. Opposition to the draft permit was primarily focused on the color conditions. The main concern by
those opposed was that the color conditions were not aggressive and not consistent with the EPA Tech
Team Report,the Bleach Environmental Process Evaluation and Report(Liebergott Report), and the 1997
Settlement Agreement. In addition,to commenting on the provisions for color,the Division received
comments on the temperature variance,dioxin,biochemical oxygen demand,nutrients and instream
monitoring conditions. Below is a summary of my recommendations,the comments received,and my
findings regarding the comments.
Color Recommendations
1. The color special condition should be revised to explicitly stipulate the conditions and requirements, in
order to ensure that there is no misinterpretation. The following concerns identified during the hearing
should be addressed in the revised color condition:
➢ The color special condition should be revised to clearly define the role of the color range and the
methodology for determining the final effluent color limit.
➢ The color range should be modified to 32,000—39,000 pounds per day. This range better reflects
the range identified during the hearing. Since the color range is used only as a tool for reopening
the permit,the expansion of the range does not conflict with the recommendations of the
Technology Review Workgroup or Bleach Environmental Process Evaluation and Report.
➢ The color condition should account for the possibility that the mill will perform better than
expected. Therefore,the condition should be structured so that a limit less than the target range
may be set without reopening the permit.
➢ The color condition should explicitly require the permittee to implement all the"Highest
Certainty"items,identified in the EPA Tech Team Report.
➢ In order to address concerns over consistency with the EPA Tech Team Report,the first color
reduction should reflect a range of 6,000—8,000 lbs/day. After implementation of the"Highest
Certainty" items,the new color limit effective December 1,2003,should be based on an
evaluation of mill performance.
➢ The color condition should explicitly define that the 3,000—8,000 lbs/day reduction is in addition
to the 6,000—8,000 lbs/day reduction. Comments expressed concern that the color requirements
did not clearly state that the additional 3,000—8,000 Ibs/day color reduction was in addition to the
initial 6,000—8,000 lbs/day reduction. In order to avoid any misinterpretation the color condition
should clearly state that the 3,000—8,000 lbs/day reduction is in addition to the 6,000—8,000
lbs/day reduction.
2. The draft color condition proposes the continuation of the Technology Review Workgroup. In
accordance with the recommendations of the Technology Review Workgroup, the draft permit and the
State of Tennessee, it is recommended that the role of the Technology Review Workgroup continue as
long as a color variance is required.
3. It is recommended that the baseline annual average effluent color limit for the start of the permitting
cycle remain at 48,000 lbs/day,based on the recommendations of the Technology Review Workgroup.

4. After submittal of the March 1, 2006 report (evaluating compliance with North Carolina's color
standard)the Division of Water Quality should evaluate the report and other pertinent data and make a
determination regarding compliance with North Carolina's color standard.
Comment:
Color conditions not aggressive enough and not consistent with the EPA Tech Team Report,the Bleach
Environmental Process Evaluation and Report(Liebergott Report),and the 1997 Settlement Agreement.
Findings:
After analysis of the comments received(speakers and written),there are very few differences regarding
color. The actual color reductions required in the draft permit are consistent with the comments received,
the main differences result from different starting points, confusion regarding the draft permit requirements
and confusion regarding the permitting strategy.
The color condition is consistent with the 1997 Settlement Agreement,but the color condition does not
explicitly define the color requirements. Not explicitly defining the color conditions could lead to
misinterpretation and confusion when evaluating consistency with the 1997 Settlement Agreement. After
reviewing the 1997 Settlement Agreement and the color condition,Blue Ridge Paper's comments correctly
address this issue;therefore,Blue Ridge Paper's comments are included below:
11
1. The Draft Permit is in Accord with the Settlement Agreement and 1997
Permit
Pursuant to a Settlement Agreement entered into in 1997 between EPA,the States of
North Carolina and Tennessee,the City of Newport, Cocke County,the American Canoe
Association and the Tennessee Environmental Council,the state of North Carolina issued
an NPDES Permit to the Canton Mill in December, 1997(the"1997 Permit").The 1997
Permit required evaluation and implementation of a number of Best Management
Practices (`BMP's")and process improvements.
The 1997 Permit also required evaluation and possible implementation of additional
technologies to reduce color. Based on expected color reductions from BMP's,process
improvements and other technologies,the 1997 Permit called for color reductions from
98,000 pounds per day(annual average)on January 1, 1998,to a range of 48,000 to
52,000 pounds per day(annual average)by May 1,2001.Blue Ridge implemented or
evaluated all required BMP's and process improvements,evaluated additional
technologies, submitted reports on the evaluations and implementations and met all
targeted color reductions.The effluent limits in the proposed permit,48,000 pounds per
day(annual average)and 55,000 pounds per day (monthly average)are a direct result of
the process established in the 1997 Permit.
2. The Draft Permit Continues the Process Developed in the Settlement
Agreement and 1997 Permit
The Draft Permit calls for improved BMP's and process improvements in the first phase
of the Permit just as the 1997 Permit did. These improved BMP's and process
improvements are expected to reduce color to 42,000 pounds per day(annual average)by
December 1,2003. Blue Ridge is required to submit a report,also by December 1,2003,
as to the feasibility of achieving an annual color average between 34,000 and 39,000
pounds per day and a schedule for achieving that target.By December 1,2005,Blue
Ridge is to submit a report with,"... all data necessary to derive the lowest achievable
monthly average and annual average color discharge and color loading limits." The
TRW continues to have a role in the process.Blue Ridge must meet the color reduction
targets unless it can demonstrate,to the satisfaction of the TRW and DWQ,that there are
"overwhelming technical,economic,or operational barriers..."to attaining color
reductions within the targeted range.

The Draft Permit continues the process of technology identification,evaluation and
implementation leading to further color reduction established in the 1997 Permit. It also
continues the role of the TRW in support of the cooperative effort by North Carolina and
Tennessee to require further color improvements in the Canton Mill's discharge.The
parties to the 1997 Settlement Agreement recognized that implementation of BMP's
requires time and capital,as does the evaluation and implementation of process
improvements and new technologies.The Draft Permit continues that pattern by allowing
Blue Ridge two years to implement BMP's and process improvements and to study
additional technologies for color reduction."
Comment:
Many of the comments centered on the range set for the final effluent color limit. Most of the comments
suggest that the range is to high to drive progress and that it was a disincentive requiring reopening of the
permit if the mill did better than expected.
Findings:
The range in the permit is not a permit limit;rather it is a clause to reopen the permit. If the final effluent
color limit,which will be set only after implementation of the"Highest Certainty"items and the
"Reasonable Certainty"(or equivalent)items,is outside of the range the permit would be reopened for
public comment.
Note:The final effluent color limit is set only after all the"Highest Certainty"items and
"Reasonable Certainty"(or alternative technology that will achieve similar color
reductions)items have been implemented. After implementation of these items,the
Division(based on the recommendation of the Technology Review Workgroup)will set a
final effluent color limit based on analysis of the performance of the mill.
The actual numerical range for the reopener clause was established based upon the recommendations of the
Technology Review Workgroup,EPA Tech Team Report,the Bleach Environmental Process Evaluation
and Report(Liebergott Report)and set in order to encompass the concerns of different parties.
Based on the findings that the range is not a limit and is intended to include the recommendations of
different parties,the lower end of the range should be modified to 32,000 lb./day. Modifying the range to
32,000—39,000 lb./day would better represent the recommendations of the different parties.
Based on my review of the color condition,the comment regarding reopening of the permit if the mill
performs better than anticipated is correct. However,the concern is giving Blue Ridge Paper equal
opportunity to contest the limit if set outside of the final color range. Blue Ridge Paper has agreed to waive
this opportunity,therefore the color condition should account for the possibility that the mill will perform
better than expected without any disincentives. Specifically, it is recommended not to reopen the permit if
the Division of Water Quality(based on mill performance and the Technology Review Workgroup's
recommendation)sets a limit below 32,000 lb./day.
Comment:
Require Bleach Filtrate Recycle Reliability Improvements and all the"Highest Certainty"items.
Findings:
The color condition implicitly indicates that all"Highest Certainty"items are required. In order to avoid
misinterpretation and address the concerns expressed at the hearing,the color condition should explicitly
direct the permittee to implement all the"Highest Certainty"items.
Comment:
The first reduction in the annual average color limit should be revised to 6,000—8,000 lb/day.
Findings:
To properly address this comment a review of the draft and final EPA Tech Team report,comments
submitted to the draft EPA Tech Team Report,TRW recommendations, and the Bleach Environmental
Process Evaluation and Report was conducted. The EPA Tech Team report recommends a color reduction

of greater than 7,400 lb./day based on implementation of the"Highest Certainty" items. The draft color
condition recommended an initial reduction of 6,000 lb./day. DWQ based this value on Technology
Review Workgroup's recommendations for implementation of the EPA Tech Team's Report on the
potential color reductions possible. In the Technology Review Workgroup recommendations for the draft
permit it was noted...
"the difference between"technological likelihood"and"regulatory limit" is an
important distinction that must be considered in"enforcing"permit conditions"
further the Technology Review Workgroup noted...
"that the options identified in the Tech Team Memorandum as having the
"highest certainty" ... should be implemented first and the permit/variance
should reflect a very specific level of reduction".
Additionally, in the development of the 6,000 lb./day initial reduction,DWQ to into account Dr.
Liebergott's Report were it was noted...
"It is very difficult,if not impossible,to predict color reduction from process
optimization, as the individual bleach stage flow numbers are already very low
and the variability is difficult to correlate to process variables"
and Blue Ridge Papers comments to the draft EPA Tech Team Report were it was noted:
"the draft final EPA tech team effluent color reduction estimate is too high and
is not reasonably achievable. In 2000 there was approximately 12,000 pounds
per day of color from all black liquor sources(excluding CRP). Based on
previous studies conducted at the Canton Mill by Duke University graduate
students, an average of 64%of brown color was removed across the simulated
wastewater treatment plant. A 5,000 pound per day final effluent color
reduction as shown in the draft Tech Team Report would require 13,900 pounds
of influent color treated at the average level of 64%. There is not 13,900 pounds
of influent brown color available;therefore, it is unreasonable to achieve a
>5,000 pound per day effluent color reduction."
Though the value set by DWQ for the initial color reductions is appropriate based on the Technology
Review Workgroups recommendations and the available information, it does not provide an opportunity for
Blue Ridge Paper to meet the expectations of the Technology Review Workgroup. Therefore,it is
recommended that the initial reduction adapt the range established by the State of Tennessee and then set
the color limit based on performance after implementation of the"Highest Certainty" items.
Comment:
The condition should require that the second 3,000—8,0001b/day reduction is in addition to the first
reduction.
Findings:
Again the color special condition implicitly implies that the first and second reductions are additive. The
condition should explicitly define that the second 3,000—8,000 lb/day reductions are in addition to the first
6,000—8,000 lb/day reductions.
Comment:
The Technology Review workgroup should be maintained.
Findings:
The draft color special condition continues the role of the Technology Review Workgroup as recommended
by the Technology Review Workgroup.
Comment:
The permit limit effective at the start of the permit cycle should be based on actual performance,which
indicates that the mill is currently achieving an annual effluent color of less than 45,0001b./day.

Findings:
The current 48,000 lb./day effluent color limit is based on the actual performance after taking into account
that the mill is not at full production.Based on the Technology Review Workgroup's recommendation the
Division set the annual average permit limit at 48,000 lb./day. The difference between the Technology
Review Workgroup's recommendation and the comments indicating a level of less than 45,000 lb./day of
effluent color is because the TRW's analysis accounted for the fact that the mill was not at full production
for much of the period of analysis.Since April there have been no changes at the mill that would justify
reevaluating the performance at the mill. The baseline color level proposed in the draft permit is consistent
with the permitting strategy used in the 1997 Settlement Agreement and NPDES Permit,therefore it is
recommended that the annual average effluent color limit at the beginning of the permit cycle be set at
48,000 lb./day.
Comment:
The appropriate way to review the reports on Blue Ridge Paper's performance from a regulatory standpoint
is in terms of volume of receiving water.
Findings:
This comment is correct for a water quality limited parameter. However, it is important to realize that
though the color limit is water quality based,the limit is technology derived.From that standpoint the
appropriate way to evaluate the data is based on end-of-pipe performance. It is important to realize that the
goal for the Canton mill is to eliminate the need for a color variance thereby achieving a limit that is both
water quality based and water quality derived.
Comment:
There were numerous comments that the color variance should not be granted beyond 2006.
Findings:
The goal for discharger with a variance is to eliminate the need for the variance and if that is not possible to
minimize the area impacted. The only way to eliminate the color variance is for Blue Ridge Paper to
comply with North Carolina's water quality standard. The need for this variance will be dictated to a large
extent by the performance of the mill. The State of North Carolina has every expectation that by the end of
this permit cycle that Blue Ridge Paper will be in a position to remove the variance. However, it is difficult
if not impossible to state at this time that the color variance will not be needed in 2006.
Temperatare Variance Recommendation:
Re-issuance of the temperature variance is recommended.The mill continues to reduce pollutant loading,
therefore reevaluation of the aquatic community should be conducted after achieving additional pollutant
reductions.
Comment:
Based on the assumption that the temperature variance is illegal,Blue Ridge Paper should be required to
conduct a comprehensive and independent Balanced and Indigenous Species Study within one year and that
the entity conducting the study should be agreed upon by all parties to the 1997 Settlement Agreement.
Findings:
The Temperature Variance for the Canton Mill was initially issued in 1984. Since that time,the Variance
has been reviewed during each Triennial Review of Water Quality Standards in North Carolina.The
Triennial Reviews were submitted to and approved by EPA.The draft permit continues the requirement of
conducting a comprehensive and independent Balanced and Indigenous Species Study within the term of
the permit as part of the Triennial Review process. D WQ concurs with the reissuance of the temperature
variance since temperature is one of several factors affecting the aquatic community downstream of the
mill. At this time temperature impacts cannot be delineated from the impact of other pollutants. Therefore,
the appropriate course of action is to re-evaluate the aquatic community after additional pollutant
reductions. Since all the pollutant reductions required by the NPDES Permit will not be achieved until
towards the end of the permit cycle,the study be conducted towards the end of the permit term.
Instream Monitoring Recommendation:

The permit should dictate that samples collected at the Fiberville Bridge should be collected at the midpoint
of the Bridge in order to obtain a worst case sample.
Comment:
Elimination of all monitoring at River Mile Station 55.5 is not acceptable,as instream monitoring at
Fiberville and Hepco is inadequate to assure characterization of instream impact of color in mill effluent.
Findings:
The instream monitoring program proposed in the draft permit is based on changes within the basin since
the monitoring program was originally established. Over the term of the current permit cycle,the Town of
Clyde has removed its discharge. The only potential major source of color between Fiberville and Hepco is
Richland Creek. Monitoring at Fiberville and Hepco is appropriate for monitoring the impact of Richland
Creek.
Additionally,this comment was made assuming that there is incomplete mixing at the Fiberville Bridge.
However, complete mixing is achieved at Fiberville Bridge,except under extreme high flow conditions.
Confusion exists on this matter due to the influence of the relatively small Beaver Dam Creek, which enters
the Pigeon River just upstream of the Fiberville Bridge. At the Fiberville Bridge the flow from Beaver
Dam Creek has not achieved complete mixing and the near shore area of the Pigeon River is substantially
clearer than the rest of the Pigeon River transect.
Dioxin Recommendation:
Because of the high level of concern, the permittee should continue full range dioxin monitoring on the
effluent of the W WTP until such time that the fish consumption advisory for dioxin is lifted for Walters
Lake or the effectiveness of the effluent guidelines on elimination of dioxin and halogenated organic
compounds can be evaluated.
Comment:
Full range dioxin monitoring should be required.
Findings:
Full range dioxin monitoring was not proposed in the draft permit due to the long history of non-detectable
levels at the mill,the continued reduction of dioxin levels in fish tissue and the implementation of the
revised effluent guidelines for the pulp and paper industry.One of the primary goals for the effluent
guidelines developed by the EPA is the elimination of dioxin and halogenated compounds from the bleach
plants effluent.
Programmatic and Other Issues:
Balanced and Indigenous Species Studies
Comment:
A uniform requirement for Balanced and Indigenous Species Studies should be required for all permitted
dischargers with temperature variances in North Carolina with the next two years,followed by a statewide
evaluation of impacts,and action to modify or remove variances as indicated.
Findings:
Part of the requirement for the 316(a)variance is a Balance and Indigenous Species Study. The Balanced
and Indigenous study is addressed during every permit renewal. The actual sampling plan is an agreement
with the State and the permittee based on each individual site.
Phosphate Limits for All Dischargers in the Basin
Comment:
In order to fully protect the water resources in low flow conditions,the Division must consider
implementation of phosphate limits for all dischargers in the basin,including appropriate biological
treatment to remove more of this nutrient from the discharge stream.
Findings:

The Division is scheduled to conduct biological data for the French Broad River Basin(including the
Pigeon River) in 2002. After collection,DWQ will assess the data(including chlorophyll a data) in order
to obtain a use support rating. Thereafter,DWQ will conduct public workshops in 2004, in order to obtain
public input. These workshops are designed to identify areas of concern and/or public interest. It is
recommended that this issue be addressed during the basinwide planning process. Individuals are
encouraged to get involved in the basinwide planning process and provide these concerns and any
additional concerns to the Division at these workshops.
Study of All North Carolina Discharges with Substantial Conductivity
Comment:
The Division should undertake a study of all NC discharges with substantial conductivity and consider
implementation of limits if this is found to be adding to impacts due to color and temperature.
Findings:
Conductivity is a general measure of inorganic pollution and is used,by the Division,when assessing the
impacts from dischargers on the receiving stream.For industrial dischargers in North Carolina where
inorganic pollution is a concern,the Division requires conductivity monitoring upstream and downstream
of the discharge point. This data is evaluated and reviewed during permit renewal for potential impacts by
the discharge. This evaluation is used to ensure that the permit limits for individual pollutants and chronic
toxicity is protecting water quality in the receiving stream.

APPENDIX E
Draft Permit, Fact Sheet, TRW Recommendation, and EPA Tech Team Report

S
State of North Carolina AFTW!
Department of Environment
a Natural Resources
and N ,►
Division of Water Quality
Michael F. Easley, Governor NCDENR
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
May 2,2001
Mr. Robert Cicale
Mill Manager
Blue Ridge Paper Products
P.O.Box 4000
Canton,North Carolina 28716
Subject: NPDES Pre-Draft Permit
Permit No.NC0000272
Blue Ridge Paper Products Inc.
Haywood County
Dear Mr. Cicale:
Blue Ridge Paper Inc.applied for an NPDES permit renewal on February 26,2001. The Division of Water
Quality has prepared a"pre-draft'permit soliciting comments from the Environmental Protection Agency,the State
of Tennessee,the City of Newport, Cocke County,and other concerned stakeholders.This pre-draft permit
represents as an effort to foster communication among the different groups and to allow for input prior to the release
of the draft permit.
Unfortunately,the Division has not received all the pertinent information necessary to recommend specific
color or temperature provisions at this time. This information is forth coming and will be reflected in the final draft
permit that will be issued on or around June 20,2001.
Neither the draft permit nor this pre-draft permit should be interpreted as the Division's final decision.
After receiving comments on the pre-draft permit,the Division will review all pertinent comments and revise the
final draft permit taking into consideration the concerns of those who responded.
There are numerous changes set forth in this permit and each are discussed in the fact sheet. Please review
the pre-draft permit and fact sheet carefully and submit initial comments to DENR—D WQ NPDES Unit by May 31,
2001,if possible. After the release of the final draft permit,the Division will conduct a public hearing and solicit
additional comments.
The final decision regarding this NPDES permit will be made only after public comments are gathered
during the public hearing(tentatively scheduled for July 26,2001)and the hearing officer has issued his/her
recommendations.At that time,the Director of the Division of Water Quality will review all available information
prior to making a final decision.
If you have any questions concerning the draft permit for your facility,please call me at(919)733-5083,
extension 508.
Sincerely,
Michael J. Myer , EIT'
NPDES Unit
cc: Central Files
NPDES Files
Aquatic Toxicology Unit
Forrest Westall - Asheville Regional Office/Water Quality Section
1617 MAIL SERVICE CENTER,RALEIGH,NORTH CAROLINA 27699-1617-TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER-50%RECYCLED/ 10%POST-CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Permit Number: NCO00O272
Dan Oakley- North Carolina Attorney General, Environmental Division
Keith Haynes - Asheville Regional Office/Water Quality Section
Rob Lang - Compliance and Enforcement Unit
Diane Reid- Classification and Standards Unit
Roosevelt Childress Jr. - Environmental Protection Agency
Karrie-Jo Shell - Environmental Protection Agency
Don Anderson- Environmental Protection Agency
Mark Perez- Environmental Protection Agency
Paul Davis -Tennessee Division of Water Pollution Control
6th Floor, L&C Annex
401 Church Street
Nashville, TN 37243-1534
David Jenkins-American Canoe Association
Hope Taylor - Clean Water Fund of North Carolina
David-McKinney -Tennessee-Wildlife Resources
R ert Williams—Blue{�dge�aper
Derric Bra n BlueiRid-c Paper
DRA

Permit Number: NC0000272
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In :OmFhFplia�nceithe p ov�sio' o N r h Carolina Arlina
a�Statute 43�215.1, other lawful stan ards and
regulations promulg ted an adopted by die North Environmental Management ommission,
and the Federal Voter Po luhon-Control ct,as amended,
Blue 12idge aper Products Inca
is ereby authorize to dischar' ge was\ afer f bm a facility c\ed It
LI 77/ 7
Blue Ridge Paper Products Inc.
Canton Mill Wastewater Treatment Plant
Off Highway 215
Canton
Haywood County
to receiving waters designated as the Pigeon River in the French Broad River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, III and IV hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on November 30, 2006.
Signed this day D
DD
A -F
Kerr T. Stevens,Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Number: NC0000272
SUPPLEMENT TO PERMIT COVER SHEET
Blue Ridge Paper Products, Inc.
is hereby authorized to:
1. Continue operation of a 29.9 MGD wastewater treatment plant for the treatment of wastewater
associated with the Blue Paper Products Inc. pulp and paper mill, the Town of Canton's
chlorinated domestic wastewater and landfill leachate. The treatment system consists of the
following treatment units:
Grit Chamber
• Bare Green
t p
• PolyT r\add tioa ��
• pH contrpl ( Oz injection r 2504 back p)
• Threeipr aryclari 2ers
• Nutrient eed
• Aera u basins
Three s concur} clarifiers
—Reid al belt�presses \
ffluent flo basins
Ll
• Cascade post aeration with oxygen injection
• Instream oxygen injection facilities
The facility is located at the Blue Ridge Paper Products WWTP, off Highway 215, Canton,
Haywood County,and;
2. Discharge treated wastewater from said treatment works at the location specified on the attached
map through outfall 001 into the Pigeon River, which is classified C water, in the French Broad
River Basin.
O

Permit Number: NC0000272
A. (I.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,the Permittee
is-authorized to discharge treated industrial,municipal,stormwater and landfill wastewater through
outfall(s) 001. Such discharges shall be limited and monitored by the Permittee as specified below:
`'Effluent?Gharacterestics Limits MiMoriitoing.Requirements
Monthly Daily ." Measurement Sam)tleType Sample
* Avgrage aximum,,= Frequency Locsfiont
Flow 29.9 MGD Continuous Recording I or El
BOD,5-day,20°C 3205 lb/day 10897 lb/day Daily Composite I,E,
Total Suspended Residue 12549 lb/day 49560 lb/day Daily Composite I,E,
NH3-N Daily Composite E,
AOX , —1S56-9-Ib/day 2822.2lb/,day, Daily,—Composite.— Er--
Co�or \ e Daily psslte E
Dissolved Oxygdq \ I \ 1 J \ t Dailyl I Grab I El
Teinporature \ : ) / \ Daily .j I Grab I El
PTF7 \ Dailyi Grab I El
Cobductivity / / J \ Daily] Grab I E(
Fecal Coliform i 2007N00{nl 4007 I00Vj= Grab I El
CQD I Weekly I Composite I El
\Qdarter)y I Composite I Ei
Zigc / \ e / f Qu' er)y I Composite I El
L----------- kN u
Total Nitrogen Monthly Composite El
(NO2-N+NO3-N+TKN)
Total Phosphorus Monthly Composite El
Chronic Toxicity Quarterly Composite El
Cadmium Quarterly Composite El
Trichlorophenol 3.0 pg/L Quarterly Composite El
Pentachlorophenol 8.9 pg/L Quarterly Composite. E,
Selenium 10.6 µg/L Quarterly Composite El
2,3,7,8 Tetrachloro-dibenzo- 0.1 pg/L Quarterly Composite E,
p-dioxin9
Conductivity Daily Grab Pigeon River
Flow Daily Grab Pigeon River
Fecal Coliform Weekly Grab Pigeon River
Color Variable Grab Pigeon River
Temperature Variable Grab Pigeon River
Dissolved Oxygen Variable Grab Pigeon River
Footnotes:
1. Sample Location: I-Influent,El—Effluent,Pigeon River-Instream sampling as specified in A. (5.)Instream
Monitoring Special Condition.
2. AOX monitoring shall be in accordance it�J h the S�mpli g"Plan f Clustfrle Para�ne ers da ed arc 19,
2001)or subsequent modifications approveby the 'vi ton. AO data/s)ta 1¢e sub fitted on a qu erly basis
along with other Effluent Guideline them c I data; a er to ffl erft Gujdel'�e am g Pl pecial
Condition.
3. See A. (8.) Color Analysis and Compliance Specia o dition.
4. The daily average effluent dissolved oxyg,n con5,e trati_9 shall n t ess than\0 Mg/L. See A. 1 .)
Dissolved Oxygen Special Condition.
5. See A. (13.) Temperature Variance Review Special Condition and A.(14.) Balanced and Indigenous Species
Special Condition. ,
6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0(on the standard units scale).
7. Chronic Toxicity(Ceriodaphnia)at 90%Effluent Concentration:March,June,September,December(see A.
(4.)Chronic Toxicity Permit Limit(Quarterly)).

Permit Number: NC0000272
8. Trichlorophenol and Pentachlorophenol limits and monitoring are provisionally waived since the facility has
certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include
chlorophenolic biocide,the Permittee shall notified the Division prior to use and the limits and monitoring
requirements shall become immediately effective.
9. See A.(9.) Dioxin Monitoring Special Condition.
10. See A.(5.) Instream Monitoring Special Condition.
See A. (6.) Best Management Practices(BMP)Special Condition.
See A.(11.) Town of Canton Inflow and Infiltration Special Condition.
Defintions:
MGD—Million gallons per day lb/day—Pounds per day
ml—Milliliter BOD—Biochemical Oxygen Demand
µg/L-Micrograms per liter AOX-Adsorbable Organic Halides
C D-Chemica-o gen demand g/L-picog rams per liter
U _ A1
RED

Permit Number: NC0000272
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
outfall(s) 002,shall be limited and monitored by the Permittee as specified below and in A. (7.)Effluent
Guideline Sampling Plan Special Condition:
Effluent Cr Lhn i M m2tc o q s
Monthly Daily "Measurement Sample Type3 5aiople
cy'ue Location
F i M Average axmum reqn ation
- _ _. . _ _ - _ _ _ .. .... __.
Flow_ Weekly Calculated E2
Chloroform 5.15lb/day 8.60lb/day Weekly Grab Ez
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite Ez
p-4mzm(TCDD),
2,317,8 Tetrachl ro tiibenzo- 31.9 Monthl offs asite
� \ Fit
p-furan(TCDF)� \ p \ y F p J I
Trychlorosyringol 1 I ) k 2.5 µgV 14onthly I Composite E{
3,4,5-�F7ichlorocatechol < 5.0 µg/L/5 Monthly omposi a El'
3,4,6-Trichlorocatedhof I 5.0pg 5 h 6l thly ompostte E#
3,4,5-Trichloroguaiacyl < 2.fpg/ od�hly Composite E{
3,4,6- richloroguaiacol 1 \< 2t5 µ�L. Montl(ly I Composite E#
4,�,,6-Trichloroguaiacol �2.5 µg/L Mopth y Composite E#
2,4,5-Trichlorophenol < 2.5 µW Monthly Composite E2
2,4,6-Trichlorophenol < 2.5 µg/L5 Monthly Composite E2
Tetrachlorocatechol < 5.0 µg/LS Monthly Composite Ez
Tetrachloroguaiacol < 5.0 pg/L' Monthly Composite Ez
2,3,4,6-Tetrachlorophenol < 2.5 pg/L' Monthly Composite Ez
Pentachlorophenol < 5.0 µg/2 Monthly Composite Ez
Footnotes:
1. Sample Location:Ez—Effluent is composed of Bleach Plant Effluent-acid (acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100 and from tap installed on filtrate pump from C102
bleaching stage D-2)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E,p). See A.(7.)Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters(Internal Outfall 002 parameters+internal Outfall 003 parameters+AOX from Outfall
001)shall be reported on a quarterly basis or more frequently;refer to A. (7.)Effluent Guideline Sampling Plan
Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance,and report
total bleach plant flow(acid+alkaline wastestreams) in DMRs. Grab-collect separate grab samples every 4-
hours for 24-hour period from both the acjd-andakz lineistreams�which 11-tthen becomposited-separately by
the lab, and analyzed as separate 24-hr co asite ai�d aril alkal' e\samples; Composite=coliectsepporate grab
samples every 4 hours for 24-hour period�t m botijthe aclid andAlkalin�sfre; s,tliea prepare and Ualyze a
single flow-proportioned composite of the�alid and P+al ine-was esfream
4. For compliance purposes,thelomfo inee as t r; epoEd
a tlota]ch(orofo ass loading based on add ti n of
separate acid and alkaline chloroform masts oadin I_5. Limits are based on Minimum Levels(Ml�)s eectEin 0 CFR
Defintions:
lb/day—Pounds per day pg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NC0000272
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration, the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
outfall(s) 003, shall be limited and monitored by the Permittee as specified below and in A. (7.) Effluent
Guideline Sampling Plan Special Condition:
-Effluent Characteristics Limits. Monitoring Require_ments2
Monthly Daily Average Measurement Sample Type3 Sample"
Average .: Frequency _Location
Flow Weekly Calculated E3
Chloroform 7.14lb/day 11.931b/day Weekly Grab E3
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly - CompositePEJ
p-Qioxm TCDD)\ F_—'\ r— �
2,3,7,8 Tetrachl ro 2libenzo- 31.9 pa Monthly rcnmpmiteJ p-fu . (TCDF)7 \ ' \ ITrichlbrosyringol , � ; k 2.5 µg1L5� t4onthly Composite3,4,5- richlorocatedhol < 5.0 µ� Monthly I omposi a I
3,d,&Trichlorocatedhol� I —\ ` < 5.0A d` thly roc mposlite3,4,52Frichloroguajacgl I < I$µg/l. orithly I I Composite I
3,4,6-Trichloroguaiacbl \< 2'5 µo? Mont1(ly I I Composite j I
4,�,6-Trichlorogaaiscol �2.5�g/LS Mdpthly I I Composite Ej I
2,4,5-Trichlorophenol < 2.5 pg/L' Monthly Composite E3
2,4,6-Trichlorophenol < 2.5 pg/L' Monthly Composite E3
Tetrachlorocatechol < 5.0 pg/L' Monthly Composite E3
Tetrachloroguaiacol < 5.0 µg/0 Monthly Composite E3
2,3,4,6-Tetrachlorophenol < 2.5 pg/L' Monthly Composite E3
Pentachlorophenol < 5.0 pg/L' Monthly Composite E3
Footnotes:
I. Sample Location: E3—Effluent is composed of Bleach Plant Effluent-acid (acid sewer collected from tap
installed on filtrate pump from CI02 bleaching stage D-100) and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage E.). See A. (7.)Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters(Internal Outfall 002 parameters+internal Outfall 003 parameters+AOX from Outfall
001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)Effluent Guideline Sampling Plan
Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance,and report
total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab samples every 4-
hours for 24-hour period from both the acid-and-al�calinel streams�which will the be composited-separately by
the lab, and analyzed as separate 24-hr com?osite it and alkaline samples`:`Composite=collect seporate grab
samples eve 4 hours for 24-hour period rom bot the uc3d and alkaline slrea s,then are re and aly ze a
singe flow-proportioned composite of th acid and I atirie-wasees6ea // \ P P I
4. For compliance purposes,the permittee mu�t reportt a total cl3 oroforetassloading based on add tion of
separate acid and alkaline chloroform mass oadin s.,
5. Limits are based on Minimum Levels(MII s�fied in (�CFR 0 ,
Defintions:
lb/day—Pounds per day pg/L—Micrograms per liter -
pg/L—Picograms per liter

Permit Number: NC0000272
A. (4.) CHRONIC TOXICITY PERMIT LIMIT(QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodophnia dubio at an effluent concentration of 90%.
The permit holder shall perform at a minimum,quarterl monitoring using test procedures outlined in the"North
Carolina Ceriodophnio Chronic Effluent Bioassay Procedure,"Revised February 1998,or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent
versions.The tests will be performed during the months of March,June, September,December.Effluent sampling
for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit,then multiple-concentration testing shall be performed at a minimum, in each of the two following months as
described in"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or
subsequent versions. /��
The chro' nic_value f r multiple�on' centrat on Petits will be jeter if ed using [ e geoth metric-mean glues
co centration ha-Vin"ho detectable impairment of reproduction or�survival and the lowest concentration that does
hae a detectable lin a}}�erit o re roduction ot�survival e definition of`d�detectable impa rment,"co legion
methods, exposure regr5rtes,lal further statistical methobs�re s�ceified in the" orth Carolina Phase II Ch onic
Wl le Effluent Tox+ici Test Proce�c ureRevised-February/ 199\)ar subsequent versions.
Alto l toxicity testing es Its r Iqu�red as pa t oI\this pe�t condition wil be a ter d on the Effluent Discharge
MQQnttoring Form( —I)for�}e months to which tuts were per orinf e us9�rtg t e parameter code TGPBor the
pass/fu" results-and 3B fot the Chronic VaSue.Qitionally,D Q om. Af I-3 (original)is to be sent to the
following address: �L j U u
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be-filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete,accurate,include all supporting chemical/physical measurements and all
concentration/response data,and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity(AT)test form indicating the
facility name,permit number,pipe number,county,and the month/year of the report with the notation of"No Flow"
in the comment area of the form.The report shall be submitted to the Environmental Sciences Branch at the address
cited above.
Should the permittee fail to monitor during a month-al- hid toxicity-monitori g s required,moait ring will be
required during the following month. �� [e�rorme
� �Should any test data from this monitoring requirement o t stsd by�tt e I Iorth Claro ma tvtsto f Water
Quality indicate potential impacts to the recei ng streak h� e�rntit ay be re-opt ed d om dtfied to clude
alternate monitoring requirements or limits. J� // � \\ /
NOTE: Failure to achieve test conditions as speci�fed,in the gifted document,such as minimum control organism
survival,minimum control organism reproduction,and appropriate environmental controls,shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Permit Number: NC0000272
A. (5.) INSTREAM MONITORING SPECIAL CONDITION
Stream Mile- Location Description Parameter Frequency
Designation Marker
UP 63.8 Pigeon River upstream of the Temperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the Conductivity Daily
discharge) Color' 2/Week
Flow' Daily
Fecal coliform Weekly
DN I 62.9 Pigeon River at Fiberville Bridge Temperature Daily
D.O. Daily
Conductivity Daily
Color ' 2/Week
DN 57.7 eon River Above Clyde Temperature Dail
��� --- �� D.O. I ' , Daily
DN3 \55\5 ( Pigeon Rivet'Below Clyde\ \ See Footnote 3 See Footnote 3
D i 4 I 3.$ ( I Pigeon Riverlat NCS7175\ \ See Tti ote 3 See Fo to to 3
bridge f /
DN5 4 .6 `Pigw-n er at Hep o� \Temperature Weekly
D.O. I Weekly
glowfF Color( Daily
1 —\ Colon Daily
Waterville Reser'oin \ See Footnote 4 Annually
DN� �6.0 U Pigeon Rive, r prior tb mixing with\-S-Oior Variable]
Big Creek
BC —26.0 Mouth of Big Creek prior to Color Variable
mixing with the Pigeon River
DN7 24.7 Pigeon River at Browns Bridge Temperature Weekly
( NC/TN State Line) D.O. Weekly
Color Variables
All instream samples shall be grab samples.
1. Color(See A. (8.) Color Analysis and Compliance Special Condition) All instream samples collected
shall be representative of the Pigeon River and Big Creek, respectively. Both true and apparent color
shall be monitored using the methods specified in A. (8.) Color Analysis and Compliance Special
Condition. Samples shall be collected at stations DN6, BC, and DN7 only when at least one generator
at CP&L is in operation and releasing water to the Pigeon River.
2. Flow monitoring is necessary, as specified above,for the True Color calculation stipulated in A. (8.)
Color Analysis and Compliance Special Condition.
3. Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9
(DNI), 57.7 (DN2), shall not be less than 5.0 mg/I and the instantaneous minimum dissolved oxygen
concentration shall not be less than 4.0 mg/l (See A. (10.) Dissolved Oxygen Special Condition). If
the dissolved oxygen drops below 5.0 211,a tati nn�- en mo ring hall_be_equire at lotions
55.5 (DN3)and 53.5 (DN4). �� I I ��
4. See A. (12.) Waterville Reservoir Sant ling S ectal Gondi ion. 7A
5. Sampling is required 2/week during thhe summYr an donee per week during tie wmTer. Si er is
defined as the period from April 1 thro gh cr�ob r 31, Nile w1ntr er `s��etj�ed as Novem er 1
through March 31. �/ �� ���J \� �I

Permit Number: NC0000272
A. (6.) BEST MANAGEMENT PRACTICES(BMP) SPECIAL CONDITION
The permittee must implement the BMPs specified in Section A below. The primary BMP objective is to
prevent leaks and spills of spent pulping liquors, soap, and turpentine. A secondary objective is to
contain, collect, and recover at the immediate process area, or otherwise control, those leaks, spills, and
intentional diversions of spent pulping liquor, soap, and turpentine that do occur. BMPs must be
developed according to best engineering practices and must be implemented in a manner that takes into
account the specific circumstances at the mill.
Section A. BMP Implementation Requirements
1. The permittee must return spilled or diverted spent pulping liquors, soap, and turpentine to the
process to the maximum extent practicable as determined by the mill, recover such materials outside _
the process, or discharge spilled or diverted material at a rate that does not disrupt the receiving
wastewater tFFeatmens em.
2. The-permittee ust establist�m to identify�n repair lea ing-equipment items.—Th� is�[program
must include;(i)`RegulaF daily visual inspection Opp
uess areawith equipment items inlspent
pulping liquor, sgap, and turpentinese�ice; (ii Immediate repaii o�leaking equipment items,when
possible. ea in equipment-ite s that cannot be repaired during normal operations muse be
identified,tecrjpo�rary meansfor mi igating the leaks must e pro3ided,and-thelleaking equipment
items repaired d�rin I the next maintenance 9uta e• m Identification of conditions underlw ich
pi oduction � ill be curtajled or ha&d to repaid eaking a uipment items or to prevent pulpin liquor,
snap and-tGrpj ntine leaks and spills a �v)�,means fbc tracking repairs over time to identify those
equip items where{upgrade or replacement may be warranted based on frequency and severity of
leaks, spills, or failures.
3. The permittee must operate continuous, automatic monitoring systems that the mill determines are
necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap,
and turpentine. These monitoring systems should be integrated with the mill process control system
and may include, e.g., high level monitors and alarms on storage tanks; process area conductivity(or
pH) monitors and alarms; and process area sewer, process wastewater,and wastewater treatment plant
conductivity(or pH)monitors and alarms.
4. The permittee must establish a program of initial and refresher training of operators, maintenance
personnel, and other technical and supervisory personnel who have responsibility for operating,
maintaining, or supervising the operation and maintenance of equipment items in spent pulping
liquor, soap, and turpentine service. The refresher training must be conducted at least annually and
the training program must be documented.
5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor, soap, or
turpentine that is not contained at the immediate process area and any intentional diversion of spent
pulping liquor, soap, or turpentine that is not contained at the immediate process area.The report
must describe the equipment items involved, the circumstances leading to the incident,the
effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion,
and plans to develop changes to equipment and operating and maintenance practices as necessary to
prevent recurrence. Discussion of the eports- ust)e-included as pa of therannual-refreshertr ning.
6. The ermittee must establish a ro a� to re ie n lanne�d mo t'ications�o t�hc pu n nndd
chemical recovery facilities and anyrc structioat vpie �i�lthe� �lptii�g a d chl emical a bery areas
before these activities commence. Th �urpose¢fuch-` tew��tQpLevent�leaks-a�C d spil�s of spent
pulping liquor, soap,and turpentine dur ng the/ anned m�'fications n to unsure that c� struction
and supervisory personnel are aware o �ossib�e liglr diveelss'ops�and oft�eLoquirement too revent
leaks and spills of spent pulping liquors,soap, and turpentine using construction.
7. The permittee must install and maintain secondary containment(i.e., containment constructed of
materials impervious to pulping liquors)for spent pulping liquor bulk storage tanks equivalent to the
volume of the largest tank plus sufficient freeboard for precipitation.An annual tank integrity testing
program, if coupled with other containment or diversion structures, may be substituted for secondary
containment for spent pulping liquor bulk storage tanks.

Permit Number: NC0000272
8. The permittee must install and maintain secondary containment for turpentine bulk storage tanks.
9. The permittee must install and maintain curbing, diking or other means of isolating soap and
. turpentine processing and loading areas from the wastewater treatment facilities.
10. The permittee must conduct wastewater monitoring to detect leaks and spills,to track the
effectiveness of the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must
be performed in accordance with Section E.
Section B. BMP Plan Requirements
1. The permittee must prepare and implement a BMP Plan. The BMP Plan must be based on a detailed
engineering review as described in this section. The BMP Plan must specify the procedures and the
practices required for the mill to meet the requirements of Section A,the construction the mill
determines is necessary to meet those requirements including a schedule for such construction, and
the monitoring program includin the statistically derived action levels that will be used to meet the
re uiq rreemeennts,9�f Section E. The BMP Ian also must specify the per dog of time ill a the mill
determines the action IeYelblish a under Sect' n may be exceeded wi outh t trigger ng the
responses sp�cified in Section E.
2. Tpe permitteelmi�st con a detailed ngineer�nre\i ie';of the?ull ing and chemical recovi ry
L
operations--including but not limittee o process equiprrlent, stora a tanks, pipelines and pum�mg
s y stems, loadingland�u l-oad'i f ilities, and`other appurtenant pulping and chemical recovery
e�juipment itemslin spent pulpin liquor, soap, and-turpentine ser ice--for the purpose of eetermining
the magnitude and routing of potegtia��eaksI spills, and intOer�tional biversions of spent puIpirI
li lus soap nd turpertine during�t\he olfowing periods f a�erati n: (i)Process start-u�s and shut
owns;(ii) aintenance; (iii)Production grade changes; 6v}stbrm or other weather events, (v)
Power failures; and(vi)Normal operations.
3. As part of the engineering review, the permittee must determine whether existing spent pulping liquor
containment facilities are of adequate capacity for collection and storage of anticipated intentional
liquor diversions with sufficient contingency for collection and containment of spills. The engineering
review must also consider: (i)The need for continuous, automatic monitoring systems to detect and
control leaks and spills of spent pulping liquor, soap, and turpentine; (ii)The need for process
wastewater diversion facilities to protect end-of-pipe wastewater treatment facilities from adverse
effects of spills and diversions of spent pulping liquors, soap, and turpentine; (iii)The potential for
contamination of storm water from the immediate process areas; and(iv) The extent to which
segregation and/or collection and treatment of contaminated.storm water from the immediate process
areas is appropriate.
4. The permittee must amend its BMP Plan whenever there is a change in mill design, construction,
operation, or maintenance that materially affects the potential for leaks or spills of spent pulping
liquor, turpentine, or soap from the immediate process areas.
5. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP
Plan is prepared and, except as provided in Section B.4., once every five years thereafter. As a result _
of this review and evaluation,the permittee must amend the BMP Plan within three months of the
review if the mill determines that any new or modified management ractices an d engineered controls
are necessary to reduce significantly t eti�k�ihood o�sp�ent�ulpinuor, soap,and turpe� ntin leaks,
spills, or intentional diversions from t e immedtat rC ocess alias mud din a schedule for
implementation of such practices and ontrols. I /
6. The BMP Plan, and any amendments hereto, I dst be evtiWed b/}rth � for ec mcal man ger at the
mill and approved and signed by the to ma)r/a�er. Any pQ n igning he IVIP Plan or its
amendments must certify to the Divisir on-under'penalty of la:YAfhat the B Plan (or its amendments)
has been prepared in accordance with good engineering practices and in accordance with this
regulation. The permittee is not required to obtain approval from the Division of the BMP Plan or any
amendments thereto.

Permit Number: NC0000272
Section C. BMP Recordkeeping Requirements
1.. The permittee must maintain on its premises a complete copy of the current BMP Plan and the
records specified in Section C.2 and must make such BMP Plan and records available to the Division
for review upon request.
2. The permittee must maintain the following records for three years from the date they are created: (i)
Records tracking the repairs performed in accordance with the repair program described in Section A;
(ii)Records of initial and refresher training conducted in accordance with Section A; (iii)Reports
prepared in accordance with Section A; and (iv)Records of monitoring required by Sections A and E.
Section D. Establishment of Wastewater Treatment System Influent Action Levels
1. The permittee must conduct a monitoring program per Section D.2, for the purpose of defining
wastewater treatment_system influent characteristics or action levels described in Section D.3.tha�
will trigger requirements to initiate investigations,on BMP effect veness and to take corrective action.
2. The permittee must emp old y the folloippppg proced s i order to e elopf the action levels re uired by
Section D: � � f
Monitoring para �Ieters.mhe�rm�ttee mu/tIC/10lle\24-hour composite sa ,ples and analyze the
samples f'r 'meas e-oorgan`c conten (e.g C-hemiSol Ox gen Demand(COD) or"otil
Organic lair T C)).Alternatively, e/mill-may use a m asure related to spent puhpi g liquor
losses ensured cogtinuously an&aveerraged over 24 hou� (e.�, specific conductivity r ylolor).
�nitoripg location. The permitte� u conduct mo�rtarin a the point influent en ersj the
wastewater treatificrit system. For-the-purposes of this requirement,the permittee ma)-select
alternate monitoring point(s) in order to isolate possible sources of spent pulping liquor, soap, or
turpentine from other possible sources of organic wastewaters that are tributary to the wastewater
treatment facilities (e.g.,bleach plants, paper machines and secondary fiber operations).
3. By April 15, 1999 or permit effective date, the permittee must complete an initial six-month
monitoring program using the procedures specified in Section D and must establish initial action
levels based on the results of that program. A wastewater treatment influent action level is a
statistically determined pollutant loading determined by a statistical analysis of six months of daily
measurements. The action levels must consist of a lower action level,which if exceeded will trigger
the investigation requirements described in Section E, and an upper action level, which if exceeded
will trigger the corrective action requirements described in Section E.
4. By January 15,2002, the permittee must complete a second six-month monitoring program using the
procedures specified in Section D and must establish revised action levels based on the results of that
program. The initial action levels shall remain in effect until replaced by revised action levels.
5. Action levels developed under this Section must be revised using six months of monitoring data after
any change in mill design, construction, operation, or maintenance that materially affects the potential
for leaks or spills of spent pulping liquor, soap, or turpentine from the immediate process areas.
Section E. BMP Monitoring, Corrective I ction and RIe J ortin Re uirements
1. The permittee must conduct daily modi oring f,he influen �o th /�`s ewa�Fei"-treatment s tem in
accordance with the procedures descrid in S�c io �D�oe purposelofdeieaks an spills,
tracking the effectiveness of the BMP$$, and det cti I tren�s in pen-Aping ignor lossesjjl
2. Whenever monitoring results exceed thelovverlaction level forlge period�fIt e specific the
BMP Plan, the permittee must conduct an investigation to determine the cause of such exceedance.
Whenever monitoring results exceed the upper action level for the period of time specified in the
BMP Plan, the permittee must complete corrective action to bring the wastewater treatment system
influent mass loading below the lower action level as soon as practicable.
3. Although exceedances of the action levels will not constitute violations of an NPDES permit, failure
to take the actions required by Section E.2 as soon as practicable will be a permit violation.

Permit Number: NC0000272
4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to
Section E.1. Such reports must include a summary of the monitoring results, the number and dates of
exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to
respond to such exceedances. Submission of such reports shall be annually,by March 31s`of the
following year.
Section F. BMP Compliance Deadlines
1. The permittee is subject to the following BMP deadlines:
• Prepare BMP Plans and certify to the Division that the BMP Plan has been prepared in
accordance with this regulation not later than April 15, 1999 or permit effective date.
• Implement all BMPs specified in Section A that do not require the construction of containment or
diversion structures or the installation of monitoring and alarm systems not later than April 15,
1999 or permit effective date.
• Establis initial action levels required by Section not later than A ril 15, 999, or pit
effective d te.
• Commence bper Itio of any new of upgraded 6ohti uous, au omatic' monitoring systems that the
mill deterfnii�es t�be necessary un�Aer Secsiorf A (�oth,r than those associated with conk tr ction of
containment�Or diversion stru`res)not later than�{1p\1 17, ?000, or permit effective iat�.
• Complete construction—an cc mence operation o any spent,pulping liquor, collection,
containmen��diversion, or other facilities, including�nj�ass associated continuous monitoring
systems�necessaiy t fully imple ent BMPs specified in Section A not later than April 16,2001
�Y�eenni ffectivle ate. \� i
—Establish revised;Crion levels required-by Section D as-soon as-possible after fully implementing
the BMPs specified in Section A, but not later than January 15, 2002.
Submit Annual Reports required by Section EA to the Division by March 31"of the following
year.
Section G. BMP Definitions
1. Action Level: A daily pollutant loading that when exceeded triggers investigative or corrective action.
Mills determine action levels by a statistical analysis of six months of daily measurements collected at
the mill. For example,the lower action level may be the 75th percentile of the running seven-day
averages (that value exceeded by 25 percent of the running seven-day averages)and the upper action
level may be the 90th percentile of the running seven-day averages(that value exceeded by 10
percent of the running seven-day averages).
2. Division: North Carolina DENR, Division of Water Quality, 1617 Mail Service Center, Raleigh,
North Carolina 27699-1617.
3. Equipment Items in Spent Pulping Liquor, Soap, and Turpentine Service: Any process vessel, storage
tank, pumping system, evaporator,heat exchanger,recovery furnace or boiler,pipeline,valve,fitting,
or other device that contains, processes, transports, or comes into contact with spent pulping liquor,
soap, or turpentine. Sometimes referred to as "equipment items."
4. Immediate Process Area: The locatio atat-the3hill 1 ere-p p'ng, sire Wing, offing bulp�v�rash�ng,
pulping liquor concentration,pulping i uor pro es ipg, ann coal ecove facilities ar located,
generally the battery limits of the afore entior�ed rbcesses :Immediate process area" in�ludes spent
pulping liquor storage and spill contrgl anks ]ddcat d at a mil��iv ttie�on t' they are lgci ted in the
immediate process area. I �J/� \
5. Intentional Diversion: The planned remosaLo spent.pulpingg iq or, soa ,bLturpentine from
equipment items in spent pulping liquor, soap, or turpentine service by the mill for any purpose
including, but not limited to, maintenance, grade changes,or process shutdowns.
6. Mill: The owner or operator of a direct or indirect discharging pulp, paper, or paperboard '
manufacturing facility subject to this section.
7. Senior Technical Manager: The person designated by the mill manager to review the BMP Plan.The
senior technical manager shall be the chief engineer at the mill,the manager of pulping and chemical

Permit Number: NC0000272
recovery operations, or other such responsible person designated by the mill manager who has
knowledge of and responsibility for pulping and chemical recovery operations.
8.. Soap: The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the
wood,which precipitate out when water is evaporated from the spent pulping liquor.
9. Spent Pulping Liquor: For kraft and soda mills "spent pulping liquor" means black liquor that is used,
generated, stored, or processed at any point in the pulping and chemical recovery processes.
10. Turpentine: A mixture of terpenes, principally pinene, obtained by the steam distillation of pine gum
recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft
pulping process. Sometimes referred to as sulfate turpentine.
5
D

Permit Number: NC0000272
A. (7.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION
The bleach plant effluent samples (Outfalls 002 and 003) shall be analyzed for 2,3,7,8-TCDD in
accordance with EPA Method 1613. A single sample, from each of the bleach plant effluents,may be
analyzed to determine compliance with the daily maximum effluent limitation. Alternatively,the sample
volumes may be collected to enable the sample to be split(duplicate analysis). If the analysis of either
split sample is below the Minimum Level (ML), the quantity is considered to be zero for compliance
evaluation. If both splits are positive,the results of two analyses shall be averaged to determine
compliance. The Minimum Level for 2,3,7,8-TCDD by EPA Method 1613 is 10 pg/L.
The bleach plant effluent samples (Outfall 002 and 003) shall be analyzed for the 12 chlorinated phenolic
compounds in accordance with EPA Method 1653. A single sample,from each of the bleach plant
effluents, may be analyzed to determine compliance with the daily maximum effluent limitation.
Alternatively,the sample volumes may be collected to enable the sample to be split(duplicate analysis).
If re analysis o either split sample is-below the Minimum Level (ML-)—the quantity is consideiedTo"e
ze o or-compliance evaluation-. 1ftroth s� its are osfti a the results of two-analyses shall-b av raged-to
�� � ,, J b
deer nine compliance. Tire mimuni evels for each of\e 12 chlorinated compounds are the se me as
the Daily Maximumlconcen rations listed on the effluent ages for the respective outfall(s).
I trIe fnal wastewlerltreal ment-plant f uent sa�ple�Out fall 01)shlall lbea�d for AOX in
accordance with PA Meth d 1650,o�\seq ent test method appr ved by the Division.
T le pemrittee-may request f�ture monitoring mo��]]tficati `ons to`h Effluent Guideline requirements,
ind1ludin 1 use of ECF certrfication in IieuWrn nitoring for iloro orm in the bleach plant effluents
(Outfall(s) 002 and 003) when this rule is promulgated by EPA; 2) demonstrating compliance using
samples collected less frequently than every four hours; 3)using automated composite volatile samplers
for chloroform sampling; and 4)using automated composite samplers for chlorophenolic,2,3,7,8 TCDD
and 2,3,7,8 TCDF sampling. Such future requests will be evaluated in accordance with 15A NCAC
2H.0114.
The flow calculations for internal Outfall(s) 002 and 003 shall not be subject to accuracy requirements
specified under Part II, Section D.3. This exclusion is similar to that provided for pump log flow
calculations.
Chemical data for Effluent Guideline parameters (Outfall(s) 002 and 003 parameters+AOX from Outfall
001) shall be submitted to the Division on a quarterly basis or more frequently(January-March,April-
June, July- September, October-December). Quarterly submissions shall be due 60 days following the
last day of each quarter(Due dates=May 31,August 31,November 30, February 28). Chemical data
shall be submitted on Division-approved DMR forms,with a separate form provided for each month.

Permit Number: NC0000272
A. (8.) REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE SPECIAL CONDITION
<RESERVED>
<<Reserved>>
Pending Technical Review Workgroups Recommendations.
The Technical Review Workgroup(TRW) is responsible for development of the limits,monitoring and conditions
regarding color. To date,the TRW has not released the recommendations regarding color. The Division fully
expects that the TRW will have the color recommendations prior to the release of the final draft permit on or around
June 20,2001.
I
RA -

Permit Number: NC0000272
A. (9.) DIOXIN MONITORING SPECIAL CONDITION
The permittee shall perform the analyses for 2,3,7,8 TCDD and 2,3,7,8 TCDF as outlined below:
SauiplingPoint`. . M&rflto ing
Requirements
Measurement Sample Type
Fre uenc"
Influent to Wastewater Quarterly Composite M
Treatment Plant
Effluent Quarterly Composite
Sludge Annual Composite
La
ndfill Leachate Annual Composite
I �� / "
The ana zeFd for 2,3,7,�-�CDD and 2I317,8 TCDF ilt accordance with EPA Met od
16 3.1 A single sample m�ayl e analyzed. ��Iternatively, t{�e\ample oh�mes may be collected!to�enable
the sample to be splitj(duplicate analysiUlf the analysis bf either split ample-is-below the Minimum
Level(ML), the q anti 's �.ousLdered to be zero I both spplits are psitive the reiults of tw I analyses
shall be averaged TL Min -be for 2,3,/7,8--�T"tTI�l�and\2,3,7,I
DF by EPA Method ldl3 is 10
pg,l. / 1� \
If 2,3 7 8 TCDD or 2,3,7 TCDF are de e�te" in the he effl�nt�ablo`e the quantitation level, the
permittee shall initiate more frequent monitoring of sludge and landfill Leachate.
Additional Requirements
Fish tissue analysis shall be performed in accordance with the Division of Water Quality approved
monitoring plan,which will be reviewed as necessary. The monitoring plan is an enforceable part of this
permit. All dioxin data collected as part of this monitoring requirement will be reported as required in the
plan, no later than 180 days after sampling.

Permit Number: NC0000272
A. (10.) DISSOLVED OXYGEN SPECIAL CONDITION
The permittee shall maintain an average daily dissolved oxygen concentration of not less than 5.0 mg/I
with a minimum instantaneous value of not less than 4.0 mg/1 at River Miles 62.9 (DNI), 57.7(DN2), and
55.5 (DN3). The permittee shall 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, as necessary, to comply with
this requirement. 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. Blue Ridge Paper shall
report the date and duration of oxygen injection use as a supplement to the monthly Discharge Monitoring
Report(DMR) forms. If the dissolved oxygen drops below 5.0 mg/L at station DN2 then monitoring shall
be required at stations DN3 and DN4.
A. (11.) TOWN OF CANTON INFLOW AND INFILTRATION SPECIAL CONDITION
T)c-permittee shall makerr continued-efforts to promote-reduction of inflawGnfiltration�0--fll wtLo
Cantons wast we titeerr col 1 IOctJonsyste \
A. (12.) A ERVI LE RESER�R SAMP 1N(j 6\PECIAL CO DITION
, I
SampIling for Wat rville Re ervoirsha I econducYed onc\annually during-2002 and 2004. Sam ling
shall be performed clLing a}owAl w periods to corr&espond wt h the is -tissue-study(see A. ( ) toxin
Monitoring Special ConditiolIn).
Sal phing shall b4 pe/rfor I ed at Watervill Res it prior to Laurel Branch, Waterville Reser oar near
W�lkm's Creek a d Wat tvil e Reservoirrte t�dam. Each loc�nllshall be sampled for the folllowing
parameters:—'
Temperature
Dissolved Oxygen
Conductivity
pH
Total Nitrogen
Nitrite+Nitrate
Ammonia
TKN
PO4
Total Phosphorus
Chlorophyll-a
Secchi Depth
All samples shall be collected at 0.1 meters beneath the surface of the water in the lake. _
A. (13.) TEMPERATURE VARIA�C�E RENEW i P�� C
During the next permit renewal, Blue Ridp Paper Ishal� compCetcan A aly t ofltem�erature. '�1 part of
-- <
this analysis,Blue Ridge Paper shall submi a comp4ete temperaturevartanc report documenting the
need for a continued temperature variance in accofdande Iwith�40�•C R 125, , ubpait H. The report shall
be submitted by May 1, 2006. -- VA L..I LJ

Permit Number: NCO0OO272
A. (14.) BALANCED AND INDIGENOUS SPECIES STUDY SPECIAL CONDITION
Blue Ridge Paper shall submit a balanced and indigenous species study, no later than May 1,2006. The
study shall be performed in accordance with the Division of Water Quality approved plan. Request for
revisions to this plan shall be submitted for approval no later than March 1, 2005. The balanced and
indigenous study plan shall conform to the specifications outlined in 40 CFR 125 Subpart H.
Lj
-DD R
AT

Department of Environment and Natural Resources o2oFY,�TE9o`
Division of Water Quality o �Fact Sheet For NPDES Permit NC0000272
Facility Information
Applicant/Facility Name': Blue Ridge Paper Products Inc.
Applicant Address': P.O. Box 4000
Facility Address': 175 Main Street
Permitted Flow2.4•7: 29.9 MGD
Type of Waste','.7: Industrial, domestic, stormwater, and landfill leachate
Facility/Permit Status°: Renewal
County-,4,7: Haywood
Miscellaneous
Receiving Stream2•4: Pigeon River
Stream Classification": C
303(d) Listed?': Yes -Fish Advisory, Dioxins
SubbasinI: 04-03-05
Drainage Area (mi2�. [calculated] 130 mil
Summer 7Q10 (cfs 52 cfs at Canton and 120 cfs at Hepco
Winter 7Q10 (cfs) . 63 cfs at Canton and 183 cfs at Hepco
Average Flow (cfs)6: 325 cfs at Canton and 677 cfs at Hepco
IWC (%): - 100% (See Text Below)
Primary SIC Code: 2621
Regional Office: Asheville
USGS Topo Quad: Canton (E 7 SE - State Grid)
Permit Writer: Michael Myers
Date: July 24, 2001
SuAuviARY
Blue Ridge Paper Products Inc. has requested renewal of their National Pollutant Discharge Elimination
System (NPDES) discharge permit NC0000272 allowing discharge of industrial, stormwater, municipal
and landfill leachate wastewaters to waters of the state. The NPDES permit will expire on November
30, 2001 and the application for renewal was received on February 23, 2001. This fact sheet
summarizes the rationale used to develop the North Carolina Division of Water Quality's
recommendations for the draft permit.
BACKGROUND
Blue Ridge Paper is an employee-owned and operated integrated, elemental chlorine free (ECF)
bleached kraft pulp with oxygen deligninifcation and bleach filtrate recycle, and paper mill in Canton,
North Carolina. Processes at the mill include a pine bleach line; hardwood bleach line, paperboard and
fine paper production lines. Pine and hardwood chips are transported to the site via rail or truck and
subsequently processed into pulp for paper or paperboard production.
In or around 1990, Champion International Corporation (Champion Paper - now Blue Ridge Paper)
initiated a $300 million dollar modernization project termed the Canton Modernization Project. This
project eliminated the use of elemental chlorine and implemented significant changes to both the pine
and hardwood bleaching lines.
The mill upgrade included two changes that dramatically improved the mill's environmental impact.
The first major change was the use of oxygen delignification. This process is used to separate the
lignin from the fiber. This resulted in significant improvement in the mills environmental performance.
The second major change was the implementation of full-scale bleach filtrate recycle (BFR) on the pine
bleach line and caustic extration stage (E.) filtrate recycle (-20%) on the hardwood bleach line. For a
Fact Sheet
NPDES Renewal

The Technology Review Workgroup report identifies process improvements that will result in permitted
color reductions of 6,000 pounds per day. In addition, the report identifies process improvements that
will require further study but are likely to result in total color reductions in the range of 9,000 — 14,000
pounds per day. The mill will also evaluate the feasibility of treating the highly colored low flow
wastestream from the chloride removal process (CRP). The feasibility of additional color reductions
associated with the treatment of the CRP wastestream is highly uncertain and no color reductions have
been established for this permit cycle. The result of a feasibility study on the Chloride Removal
Process wastestream will be evaluated for possible additional color reductions for the next permit cycle.
As shown in Table 1, the 6,000 pound per day annual average color reduction will become effective on
December 1, 2003. Additionally, the mill will evaluate additional process improvements in order to
achieve an annual average effluent color loading of 34,000 — 39,000 pounds per day. If the limits
determined to be achievable are within the target range,the limits shall become effective on December 1,
2005, by written notification from the Director. In the event that the achievable limits are outside of this
range then the NPDES will be reopened. At that time,public comments will be gathered and the permit
may be modified.
Table 1. Major Dates for Compliance/Reports.
SubmittaUCompliance Date Requirement
2002 is issue toy Report
October 1, 2003 Statisticalevaluation of performance for determination of the monthly
average effluent color limit
December 1, 2003 First reduction in effluent color limit
December 1, 2003 Feasibility report on additional process improvements for further color
reductions
2004 is issue toy Report
December 1, 200-') Statistical analysis and feasibility report on treatment of CRP
was testream
March econ reduction in effluent color limit
March omparative Invaluation Report
may 1, 2006 k5alanceaand indigenous Species Study Report
Temperature
The facility first requested and received a 316 (a) variance (approved by EPA) for temperature on
August 6, 1985. This determination demonstrated that the effluent limitations relating to the thermal
component of the Champion discharge were more stringent than necessary to assure protection and
propagation of a balanced indigenous population of shellfish, fish, and wildlife in the Pigeon River.
Therefore, the 316(a) determination was approved based on protection of the appropriate use
classification of the Pigeon River. The temperature variance was reviewed and renewed as part of the
Triennial Review in 1997.
Blue Ridge Paper submitted a Balance and Indigenous Species Study on the Pigeon River on June 1,
2001. DWQ scientist have reviewed the 'report and concluded that continuance of the temperature
variance is appropriate. Therefore, the Division of Water Quality is recommending continuation of the
temperature variance with reporting requirements consistent with the previous permits (see Table 1).
Oxygen Consuming Waste
An EPA approved model predicted that even with a BOD5' loading of 1209 lb/day (5.0 mg/L at 29
MGD) that the dissolved oxygen in the Pigeon River would not be protected. Since Blue Ridge Paper
cannot comply with such stringent limitations, an instream method was implemented to protect the
dissolved oxygen in the receiving stream. For further discussion on this subject refer to the
conventional pollutant section below.
Dioxins
Elevated levels of dioxins were found in fish tissue in the Pigeon River (around the late 1980s).
Subsequently, a fish consumption advisory was issued for sport fish, catfish and carp. The Canton Mill
has not discharged any detectable levels of 2,3,7,8 TCDD to the Pigeon River (since 1989) and dioxin
in fish tissue continue to decline. Currently, a fish consumption advisory continues for carp and
catfish. North Carolina has lifted the advisory on sport fish. However, the State of Tennessee
continues to post a precautionary fish consumption advisory for carp, catfish and red breasted sunfish.
' BODS is an analytical method used to estimate the biochemical oxygen demand.
Fact Sheet
NPDES Renewal

more detailed description of the mill improvements, refer to the Canton Modernization Project Section
below.
The Canton Modernization Project greatly reduced the wastewater generated and eventually discharged
to the Pigeon River. Even with these improvements, significant quantities of wastewater are generated
in the production of pulp and paper and proper treatment prior to discharge is required.
Wastewater generated by the Canton Mill, along with the Town of Canton's domestic wastewater, is
treated at Blue Ridge Paper's Wastewater Treatment Plant. The treatment plant is a 29.9 MGD
wastewater treatment system consisting of the following unit processes:
• Grit Chamber
• Bar screens
• Lift pumps
• Polymer addition
• pH control (CO2 injection or H2SO4 backup)
• Three primary clarifiers (one normally off-line)
• Nutrient feed
• Aeration basins
• Three secondary clarifiers
• Residual belt presses
• Effluent flow measurement
• Cascade aeration (with oxygen injection)
• Oxygen injection facilities
Solids at this facility are deposited into a dedicated landfill.
The history of this mill, under the ownership of Champion Paper and now Blue Ridge Paper, has been
controversial. Under Champion Paper, the environmental impacts of the Canton Mill were noted by
concerned citizens, environmental groups, the State of Tennessee, State of North Carolina, and the
United States Environmental Protection Agency (EPA). The issues raised by these individuals and
groups contributed to the Canton Mill's improved environmental performance and resulted in a
settlement agreement issued January 8, 1998. Today the relationship among the various stakeholders
has evolved to one of cooperation. The Division commends all the groups for their willingness to work
together to improve water quality. This permit has centered around four main issues emanating from
the mill's discharge: color, temperature, oxygen consuming waste and dioxin, and a brief synopsis
follows.
Color
On July 13, 1988, Champion Paper was granted a variance from North Carolina's narrative water
quality standard for color, which the EPA interpreted to be 50 color units. The EPA subsequently
issued a NPDES permit to Champion Paper facility in Canton, North Carolina.
In 1994, the EPA returned NPDES permitting authority for the Canton Mill back to North Carolina's
Division of Water Quality. During the permit renewal the original color variance was modified and
both were issued around December 11-12, 1996. As outlined above, over the course of this variance
the mill has initiated significant improvements, which have dramatically reduced the color loading and
other effluent characteristics.
Though the mill has made tremendous strides, color continues to be the focal point surrounding this
permit. The EPA chaired Technology Review Workgroup have recommended additional color
reduction for the up coming permit cycle. The recommendations issued by the Technology Review
Workgroup included the findings of a third party evaluation of Blue Ridge Paper's Canton mill and the
report issued by the EPA Tech Team9. The evaluation conducted by Dr. Norm Liebergott was co-
sponsored by Blue Ridge Paper and several environmental groups and provided valuable information
for the TRW'. In addition, to identifying areas for improvement and available technologies, Dr.
Liebergott compared the Canton mill to similar mills around the world. Dr. Liebergott concluded that
the Canton mill's environmental performance is among the best in the world.
Though incredible work has been done, there continues to be a need to reduce color further. Blue
Ridge Paper's openness and willingness to work towards continued improvements has resulted in an
atmosphere of trust and cooperation among all the interested parties. This cooperation has been
extremely valuable and will continue to be critical as the additional color reductions recommended by
the Technology Review Workgroup are implemented (see attached July 24, 2001, memo from the EPA
Tech Team to the Technology Review Workgroup).
Fact Sheet
NPDES Renewal

The fish consumption advisories in North Carolina and Tennessee are currently under review for
possible modification of the advisories. The North Carolina Division of Environmental Health (DEH)
has initiated a review of the fish consumption advisory on Pigeon River and Waterville Lake. DEH is
evaluating dropping the advisory on catfish in the North Carolina portion of the Pigeon River and
limiting the advisory on Carp to Waterville Lake. A final determination may not be finalized prior to
permit renewal, therefore, recommendations presented in this permit do not reflect this evaluation.
STREAM CONDITIONS
The facility discharges to the Pigeon River near Canton, North Carolina. The Pigeon River from
Canton to Hurricane Creek is listed as an impaired water, according to North Carolina's 2000 Draft
303(d) List, due to a fish consumption advisory for dioxins. Recent data indicate that the dioxin levels
in fish tissue continue to decline. There has been no detection of 2,3,7,8 TCDD in sport fish since
1995 and below North Carolina's fish consumption advisory level for 2,3,7,8 TCDD in catfish since
1997, based on Blue Ridge Paper's data. 2,3,7,8 TCDD continues to be detected in carp, though levels
continue to decline and are below North Carolina's advisory level.
The Pigeon River has been experiencing extremely low flows, due to extended drought conditions in
the western part of the state, with flows often less than the 7Q10 flows of 52 cfs (near Canton). Curtis
Weaver, with the USGS, provided the updated low flow statistics noted above using data from 1933
through 1999. The low flow statistics at Canton include the influence of Lake Logan, which was
constructed in 1932 and the influence of both Lake Logan and Lake Junaluska (constructed in 1913).
This reflects the current hydrography within the watershed and does not reflect conditions prior to
construction of the lakes.
The impact of this reevaluation of the low flow statistics is that the lowest seven day average flow
expected once in ten years (7Q10) has been reduced from 54 cfs to 52 cfs. This affects the instream
waste concentration which is used to determine the limits for the toxicity testing (discussed later).
INSTREAM MONITORING
The current permit requires Blue Ridge Paper to conduct an extensive instream monitoring program
consisting of 12 monitoring sites (1-upstream of mill in Pigeon River, 3-Waterville Reservoir, and 7-
downstream of mill in Pigeon River and 1-Big Creek; See Figure 1 and Table 2).
Instream Monitoring by Parameter
Blue Ridge Paper is required to monitor fecal coliform upstream (at station UP) and downstream of the
discharge (at station DNI). Analysis indicates no discernable difference between the upstream and
downstream fecal coliforin levels. Upstream fecal coliform is generally in the range of 100 to 200
/100m1. The same trend is evident at the downstream sampling point. These data suggest that Blue
Ridge Paper does not contribute significant levels of fecal coliform. Monitoring of the effluent is
sufficient to monitor the mill's impact on the river. Blue Ridge Paper has volunteered to conduct
upstream sampling and this requirement will remain as a condition in the permit. Thus, the Division's
recommendation is the elimination of the downstream fecal monitoring and once per week fecal
monitoring upstream.
Blue Ridge Paper is required to monitor conductivity upstream (at station UP) and downstream (at
station DN1). There is a significant increase in conductivity between the upstream and downstream
monitoring sites. Conductivity measurements are less than 50 umhos/cmZ at the upstream monitoring
station and generally greater than 250 umhos/cm2 at the Fiberville Bridge. This increase in
conductivity is expected since conductivity is a measure of inorganic material. Thus, the Division's
recommends that conductivity monitoring continue as required by 15A NCAC 2B .0508(d).
Fact Sheet

Figure 1. Instream Monitoring Stations for Blue Ridge Paper Products — Canton Mill.
/SYmn N]-XCRNSYY W
SYeon 35.a-Lea..ei3 C'•••
rr
•
SYJ•n•IA
-Wpca
l 5L3-Lean Cl/</
IO Ric Ind Ckvk ,
JI' S1s1bn 83.8•FYmiO•UtW3•
tYf.NlvfE.v
blin 545-Up•b••m 0 UW Rid,.F•p•r
USGS Sites
Primary Highways
Pigeon River Hydrography
NPDES Discharger
EM Municipal boundaries
The facility is required to monitor 5-day Biochemical Oxygen Demand (BODS) upstream at station UP
and downstream of the discharge at the station DN7. Levels of BOD5 have been less than 2.0 mg/L.
Based on this information and the Division's lack of need for the data, it is recommended that instream
BOD5 monitoring be eliminated from the permit.
Fact Sheet
NPDES Renewal
P•.n i

Table 2. Instream Monitoring Requirements According to the 1997 NPDES Permit and Color
Variance.
Stream Mile Location Description Parameter Frequency
Designation Marker
UP 3.8 Pigeon River upstream ot the emperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the BOD, I/Week
discharge) Conductivity Daily
Color 2/Week
Flow Daily
Fecal coliform I/Week
Pigeon River at Fiberville Bride I emperature at y
D.O. Daily
Conductivity Daily
Fecal Coliform I/Week
Color 2/Week
Pigeon River Above Clyde I emperature Daily
D.O. Daily
DNJ Pigeon River Below Clyde TemperatureI/Week
D.O. I/Week
Color 2/Week
DN4 Pigeon River at N CSR 1625 TemperatureI/Week
bridge D.O. ][Week
Color 2/Week
Pigeon River at Hepco emperatureI/Week
D.O. I/Week
Color 2/Week
Flow Daily
Waterville Reservoir Annually
DN6 26.0 Pigeon River prior to mixing Color ee
with Big Creek
out o ig ree poor to Color 2/Week
mixing with the Pigeon River
igeon River at Browns i3ridge I emperatureI/Week
(—NCITN State Line) D.O. ][Week
BODS ]/Week
Color 2/Week
Blue Ridge Paper monitors temperature upstream at station UP and downstream at all monitoring
stations except station DN6 and station BC. Comparing upstream to downstream, see Figure 2, the
temperature difference ranged from between 1.78 °C and 11.65 'C. At no time did the monthly
average temperature of the Pigeon River exceed the permitted limits of 32 °C (summer) or 29 °C
(winter).
Blue Ridge Paper monitors dissolved oxygen (DO) at all the instream stations except station DN6 and
station BC. Over the period of review (1998 — 2000), dissolved oxygen did not drop below the North
Carolina's standard of 5.0 mg/L for Class C streams at any of the instream monitoring locations.
Figure 3 summarizes the results of this analysis.
During the previous permit cycle, an EPA-approved computer model indicated that BOD5 limits were
required to protect North Carolina's instream dissolved oxygen standard of 5 mg/L for Class C waters.
An economically feasible end-of-pipe technology capable of consistently treating to levels necessary to
meet the limits specified by the model did not exist. North Carolina agreed with the continuation of the
requirement that Blue Ridge Paper meet the instream dissolved oxygen standard by use of sidestream
oxygen injection facilities. Blue Ridge Paper maintained these oxygen injection facilities at the effluent
and at approximately 0.9, 2.1, and 3.7 miles downstream of the discharge. The previous NPDES
permit required Blue Ridge Paper to maintain the oxygen injection facilities located 0.9 and 2.1 miles
downstream.
To ensure compliance with the above requirement, the average daily instream dissolved oxygen levels
at stations DNl, DN2 and DN3 were required to equal or exceed 5.0 mg/L and the minimum
instantaneous instream values were required to be greater than or equal to 4.0 mg/l. If dissolved
oxygen drops below the prescribed values Blue Ridge Paper shall utilize the instream dissolved.oxygen
injection stations to increase the dissolved oxygen in the river.
Fact Sheet
NPiIFS RPOPW�i

This method fulfilled the requirements of 40 CFR 125.3 (f).
Blue Ridge Paper has compiled an extensive database on instream dissolved oxygen concentrations and
stream flow. These data suggest that the dissolved oxygen sag occurs at station DN2.
Figure 2. Temperature in the Pigeon River Upstream and Downstream of Blue Ridge Paper's NPDES
Discharge.
35
Permitted Limits
���,y /+
NC 3faltdrd
30 Stmmlertumt-32T < '
Winti rUml=29T ar<2.9'c
25
0 20 �SlaGon UP
3 rt Slaficn DNI
e
a —i—Della T
E IS
PtrmhW D' =13.9°C
10
5
0
NOV-98 Feb-99 May-99 Aug-99 Deo-99 Mar-00 Jun-00 Oct-00 Jan-01 'Apr-01
Time
Figure 3. Average and Minimum Dissolved Oxygen in the Pigeon River from River Mile 63.5 to the
NC/TN State Line. (Average DO* = In (DO))
12.00
10.00
8.00
m
E
li Average DO
Minimum
6.000 —�Q®nOard
'e
>° —Average DO'
0
4.00 0
4P dischzge N&ON M Line
2.00
0.00
70.00 60.00 50.00 40.00 30.00 20.00 10.00 0.00
River Mlle
Fact Sheet
NPDES Renewal
D...e'1

Stations DN2 and DN3 were included because the dissolved oxygen model predicted that the DO sag
occurred in this area and because they represented monitoring locations upstream and downstream of
Clyde's discharge. The Town of Clyde has recently removed their discharge and the Division has
received a letter from the Town requesting rescission of the permit. Based on a review of the instream
data and the removal of Clyde's discharge, it is recommended that the dissolved oxygen compliance
point at station DN3 be eliminated.
The Division reviewed the 1998 through 2000 instream dissolved oxygen data. Over this time period,
Canton, North Carolina has experienced extreme drought conditions and flow in the Pigeon River has
often dropped below the updated 7Q10 stream flow. Under these conditions, the lowest dissolved
oxygen level observed in the North Carolina portion of the Pigeon River was 5.0 mg/L and occurred at
river mile 57.7. Additionally, a review of the average daily instream dissolved oxygen data and the
average over this time period indicates that the dissolved oxygen sag occurs at river mile 57.7. Based
on this analysis, the compliance point and monitoring requirement at river mile 55.5 have been
dropped. The oxygen injection facilities will continue to be maintained at the effluent, 0.9, and 2.1
miles downstream, and used as necessary to maintain an instream dissolved oxygen level of 5 mg/l.
The condition to maintain the instream dissolved oxygen stations shall remain a condition of the permit
until such time that the permitted loading of oxygen consuming waste to the Pigeon River is less than or
equal to that proposed by an appropriate water quality model.
If dissolved oxygen at station 57.7 drops below 5.0 mg/L, the facility is required to monitor dissolved
oxygen at river mile 55.5 and 53.5.
Instream monitoring continues to be required in order to assess Blue Ridge Paper 's impact on the
Pigeon River and to ensure that the dissolved oxygen standard is maintained within the river.
COLOR
The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco
USGS gauge station. The new effluent limits in this permit are more stringent than the provisions in the
1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is possible
to calculate the monthly flow at the Canton gage station above which instream color at the Fiberville
Bridge will not exceed 50 true color units. Using the 55,000 pounds per day monthly average true color
loading limit(implemented on the effective date of the permit) the flow at the Canton Gage station,which
will provide for color less than 50 true color units at the Fiberville Bridge is 171.8 MGD. Therefore,the
monthly average color in the Pigeon River at the Fiberville Bridge will be less than 50 true color units
whenever the monthly average flow(at the Canton gage station) is greater than 171.8 MGD. North
Carolina is recommending that the Fiberville bridge be the basis for the color variance.
The governing flow criterion for true color at Canton is 58.1 MGD (30Q2 stream flow). The flow
established is greater than this 30Q2 stream flow,therefore, for flows less than the 171.8 MGD at the
Canton Gage station but greater than 193.3 MGD at the Hepco gage station, the monthly average color in
the Pigeon River at Hepco will be less than 50 true color units.
Currently, the basis for the color variance is the Hepco station (DN5) within North Carolina, therefore
with the moving of the station from Hepco to Fiberville, DWQ recommends that the mill monitor the
Hepco station 2/week during the summer and once per week during the winter.
During the permit cycle, the effluent color limit will be reduced, therefore,the instream color criteria will
be adjusted accordingly. The monthly average color in the Pigeon River at the Fiberville Bridge will be
less than 50 true color units whenever the flow at Canton is greater than the flow established using the
following equation and based on the monthly average effluent limit established per Special Condition
A.(8.)Paragraph 4:
FlowatCanbnUSGS(MGD) _ (MonthlyAva-ageEfflumtColorLinit,lb/day—12468.3)+31.6+2.4
308.58
For flows at the Canton Gage station less than the flow established here but greater than 193.3 MGD at
the Hepco gage station, the monthly average color in the Pigeon River at Hepco will be less than 50 true
color units.
Compliance Summary
The facility has been in compliance with permit conditions during this cycle.
Fact Sheet

Toxicity Testing
Current Requirement: Chronic toxicity limit monitored quarterly @ 87%
In December 1999 the facility reported a chronic level of 81% (with a state split sample greater than
87%), with the following two months greater than 100. All other toxicity tests over the past four years
were greater than the stipulated 87%.
The toxicity testing requirement is placed on all major facilities and other facilities with complex
wastestreams. The toxicity limit is based on the instream waste concentration under 7Q10 conditions
(52 cfs updated April 2001). For Blue Ridge Paper, the instream waste concentration was determined
by also accounting for the out-take of surface water from the facility (31.6 MGD, as per application)
and water withdrawal by the Town of Canton (allocated 6.8 MGD). Therefore, the instream waste
concentration was determined to be 100% under 7Q10 conditions. The Division has set a ceiling on
the toxicity test of 90%. This was done because of difficulties associated with averaging toxicity test
with limits of 100%. The Division feels that 90% is sufficiently stringent to assess the chronic toxicity
of an effluent, while allowing for the averaging of multiple tests.
Recommended Requirement: Quarterly Chronic Toxicity @ 90% Mar, Jun, Sep, Dec
Blue Ridge Paper is required to perform the NC Whole Effluent Toxicity Test or an equivalent method
(as approved by the Division) on a quarterly basis at 90%. Any equivalent method shall also be
performed on a quarterly basis.
Toxicant Analysis
Using the self-monitoring data required per the NPDES permit, reasonable potential analyses were
conducted on the following toxicants: mercury, zinc, cadmium, selenium and silver. The standards
used for the analyses are consistent with North Carolina standards for a class C waterbody.
Cadmium — Based on the Division's analysis of self-monitoring data, this discharge does not pose a
reasonable potential to cause a violation of the North Carolina stream standard for cadmium. Effluent
monitoring of cadmium shall continue since cadmium continues to be detected in the effluent.
Mercury — Based on the Division's analysis of self-monitoring data, this discharge does not pose a
reasonable potential to cause a violation of the North Carolina stream standard for mercury.
Additionally, all mercury samples analyzed since January 1999 have been below North Carolina's
accepted detection level of 0.2 µg/L. Results from the Division's 1996 Fish Tissue Mercury
Assessment on the Pigeon River indicate, "total mercury results were comparable to 'background'
levels expected for fish across North Carolina." Based on the findings in this report and the
'Reasonable Potential' Analysis, it is recommended that mercury monitoring and limitation be removed
from the permit.
Silver- Based on the Division's analysis of self-monitoring data, this discharge does pose a reasonable
potential to cause an exceedence of the North Carolina's Action Level Standard for silver. Numerical
limits for silver are not being included since silver is an action level water quality standard and the
biomonitoring requirements are adequate to control toxicity due to the presence of silver. Though no
limit is proposed, if the facility experiences chronic toxicity violations, the discharge will be re-
evaluated and a silver limit may be implemented according to the Division's Action Level Policy.
Selenium — The Division's analysis indicates that the maximum predicted concentration for selenium is
greater than the allowable concentration. This analysis included only seven data points,.with six data
points below the quantitation level. One sample indicated the presence of selenium, however the
concentration reported was at the quantitation level for the method. Additionally, the QA/QC data
questions the validity of this data point. However, the Division has limited Blue Ridge Paper for
Selenium. After collecting for one and half years (six data points) of data, the facility can request that
the Division review the Selenium data for possible elimination of the limit.
Zinc - Based on the Division's analysis of self-monitoring data, this discharge does pose a reasonable
potential to cause an exceedence of the North Carolina's Action Level Standard for zinc. Numerical
limits for zinc are not being included since zinc is an action level water quality standard and the
biomonitoring requirements are adequate to control toxicity due to the presence of zinc in the facility
effluent. Though no limit is proposed, if the facility experiences chronic toxicity violations the
discharge will be re-evaluated and a zinc limit may be implemented according to the Division's Action
Level Policy. Monitoring requirements for zinc are consistent with 15A NCAC 2H .0508 (d).
Fact Sheet
NPDES Renewal
Page 9

OXYGEN CONSUMING WASTE POLLUTANTS
A site-specific Best Available Technology (BAT) based limit was calculated to determine the monthly
average 5 - day biochemical oxygen demand (BOD5) limit. A site-specific BAT approach was used
because North Carolina's Division of Water Quality continues to agree that an economically feasible
end-6f-pipe technology capable of reliably meeting the water quality limit specified by the existing
model does not exist at this time and no violations of the dissolved oxygen standard in the river have
been observed in recent years.
The North Carolina Division of Water Quality's recommendation for the draft permit BOD5 limit is
established based on the demonstrated level of performance for the existing treatment plant. Data on
treatment plant performance and influent loading from the Canton Mill (1998 through 2000) was
evaluated and examined for outliers. As indicated in the "Bleach Environmental Process Evaluation
and Report", the performance of this mill is among the best in the world. The maximum influent
loading and lowest treatment plant performance were used to develop the monthly average BODS limit.
The data set was sufficient to account for the day to day variability of the treatment system.
Over the time period evaluated, the treatment plant has performed extremely well. The lowest percent
removal was 96.9% and the highest influent loading was 414.9 mg/L. Based on this analysis, North
Carolina's Division of Water Quality recommends a monthly average BOD5 loading of 3205.0 lbs/day.
The limit presented in the draft permit represents and a 71-ton per year reduction in BOD5 loading to
the Pigeon River. Because Blue Ridge Paper has oxygen injection facilities in place to maintain the
instream dissolved oxygen standard should instream dissolved oxygen dictate a need, Blue Ridge Paper
complies with the conditions set forth by 40 CFR 125.3 (f).
The methodology used for the daily maximum 5 - day biochemical oxygen demand (BODS) limit was
recommended during the previous permit cycle. A site-specific daily maximum to monthly average
multiplier was used for determination of the recommended daily maximum limit. Using this
methodology and reviewing data since the Canton Modernization Project (1998 — 2/2001) the
recommended daily maximum limit based on a multiplier of 3.4 (daily maximum/monthly average) is
10897 lb/day. The limit proposed represents an achievable level and approximately a 12.5% reduction
in the daily maximum BOD5 limit.
Ammonia monitoring requirements are included in the permit to provide data concerning levels of
ammonia discharged to the Pigeon River (which may affect instream dissolved oxygen).
Effluent dissolved oxygen is limited at no less than 6 mg/l based on the above discussion. Daily
monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products, Class IV facility.
NUTRIENT POLLUTANT ANALYSIS
Total phosphorus and total nitrogen monitoring is required by 15A NCAC 2b .0508 (d) (2) (A).
Monthly monitoring is required to assess the contribution of nutrients from Blue Ridge Paper and the
potential impact to Waterville Reservoir. Waterville Reservoir is to be monitored once annually
(during opposite years of CP&L's montioring) to assist in the continued characterization of nutrient
impacts to the lake.
TOXICANTS
There is currently a fish consumption advisory due to dioxin for the Pigeon River downstream of the
discharge. Although the advisory was initially in effect for consumption of all fish species, this
advisory has been reduced to carp and catfish species only, reflecting continued improvements in the
river.
Currently, Blue Ridge Paper is required to monitor dioxin and dibenzofuran isomers quarterly from the
influent, sludge, landfill leachate, and effluent. Based on an evaluation of the data, the Division is
recommending a revision to the special condition requiring dioxin and dibenzofuran isomers
monitoring. An improved knowledge of the dioxin and dibenzofuran isomers indicates that only 2,3,7,8
TCDD and 2,3,7,8 TCDF are pollutants of concern. Therefore, it is recommended that the dioxin
isomer special condition be modified to require monitoring only for 2,3,7,8 TCDD and 2,3,7,8 TCDF.
Fact Sheet
NPDES Renewal

It is further recommended that the monitoring frequencies be modified based on the fact that
measurable quantities of dioxins and dioxin isomers have not been detected in the influent (since 1997),
the effluent (since 1996), sludge (since 1996) and the landfill leachate (since 1996).
The effluent limit for 2,3,7,8 TCDD has been reduced. During North Carolina's development of the
Total Maximum Daily Load for Dioxins on the Pigeon River, the EPA commented that the chronic
standard adopted by North Carolina should be applied as an effluent limit at the end of pipe. North
Carolina did not agree with this methodology, since it is inconsistent with the standard and North
Carolina rules. In addition, the management strategy implemented by North Carolina to address
dioxins in the Pigeon River for several years and the data show that this management strategy is
resulting in declining dioxin levels in the Pigeon River. The EPA, NC DWQ and Blue Ridge Paper
agreed that the TMDL requirement could be waived as long as Blue Ridge Paper's effluent was limited
at 0.014 pg/L. Therefore, the dioxin limit has been reduced to 0.014 pg/L and no TMDL will be
developed.
Annual fish tissue analysis shall continue to be performed by the facility in accordance with the
monitoring plan approved by the Division until such time that the fish advisory is lifted in both
Tennessee and North Carolina, according to North Carolina's deciiting procedures.
Trichlorophenoi/Pentachlorophenol limits and monitoring are not required. The permittee has
certified that chlorophenolic biocides are not used at the facility. This certification eliminates the
requirement to include effluent limits for these two parameters based on 40 CFR 430. However, if the
facility changes future operations to include chlorophenolic biocides, limits and monitoring will be
required.
OTHER POLLUTANTS OF CONCERN
The total suspended solids (TSS) limits were calculated using the EPA promulgated Effluent
Guidelines for the Pulp, Paper, and Paperboard Point Source Category and compared to existing limits.
The TSS limits contained in the current NPDES permit are more stringent than the calculated federal
effluent guidelines since the current limits are based on the 1993 proposed guidelines for the oxygen
delignification process. The Division recommends that the existing TSS limits remain unchanged for
this permit cycle.
North Carolina does not have a numeric standard for TSS. The rules specifically regulate floating
solids, settleable solids, and sludge deposits [ref. 15A NCAC 2B .0211(3)(c)]. The draft permit
restricts floating solids. Both benthic and IBI studies have indicated further improvement to the Pigeon
River. Therefore, a monthly average TSS limit of 12,549 lbs/day is recommended and a daily
maximum TSS limit of 49560 lbs/day is recommended.
Daily monitoring is required based on 15A NCAC 2B .0508 (d), Class IV facility.
The temperature requirement is based on a Section 316 (a) variance determination issued by the NC
Environmental Management Commission October 11, 1984 and approved by EPA August 6, 1985.
In making the recommendation to retain the current 316(a) variance, DWQ scientist evaluated Blue _
Ridge Paper's Balanced and Indigenous Species Report and concluded that temperature could not be
identified as prohibiting a Balanced and Indigenous population. In addition, DWQ staff reviewed
existing temperature data and although some improvement in the instream temperature has occurred
(most likely due to overall effluent flow decrease, associated with process improvements reducing
temperature impacts), Blue Ridge Paper still cannot meet the North Carolina temperature requirement
as indicated in Figure 2 above. Therefore, DWQ is recommending that the 316(a) variance continue,
with Blue Ridge Paper conducting a Balanced and Indigenous Species Study prior to the next permit
renewal.
The flow limit is based on Blue Ridge Paper's current flow values and post-CMP production plus 0.9
MGD for the Town of Canton's wastewater. Future plant improvements may reduce the contribution
of the mill's wastewater, however the Town of Canton is proposing to increase their contribution to the
treatment plant as they expand Canton's municipal boundary.
Since flows are currently approximately 80% of the permitted capacity, the Division recommends that
the flow limit remain unchanged. During the next permit cycle the flow limit should be re-evaluated
Fact Sheet
NPDES Renewal
V- 11

and if appropriate adjusted. Due to potential inflow/infiltration from the Town of Canton, the Division
continues the provision that requires Blue Ridge Paper to work with Canton to reduce I/I problems.
Chemical Oxygen Demand (COD) monitoring is required to assess the potential impact of chemical
oxygen demand from the Blue Ridge Paper wastewater effluent. Neither federal guidelines nor NC
water quality standards require a limit for COD. Though no limit is proposed, the EPA has reserved
COD for potential future limits. Therefore, COD monitoring will be continued.
Limitations for fecal coliform are based on the contribution of domestic wastewater from the Town of
Canton and the requirements of 15A NCAC 2B .0211 (b) (3) (E).
Metals toxicity is a function of water hardness, since Blue Ridge Paper has demonstrated reliable
compliance with toxicity, the Division recommends the elimination of hardness monitoring.
Conductivity monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products
(Water Quality Limited Facilities), for a Class IV facility.
Monitoring for total residue/total dissolved solids is required according to the existing NPDES
permit. The required conductivity monitoring is sufficient to assess Blue Ridge Paper's inorganic
loading to the Pigeon River. Therefore, the Division recommends removal of total residue and total
dissolved solids monitoring from the permit.
Limitations for pH 6.0 —9.0 are based on 15A NCAC 2B .0211 (b) (3) (G).
ISSUES ASSOCIATED wrTH EFFLUENT GUIDELINE IMPLEMENTATION
Relevant Background Information
Over the past five-year permitting cycle,the maximum 12-month production occurred from May 1999
through April 2000. Table 3 outlines the total production of various products generated at the Canton
Mill over this time period.
Pulp produced at the Canton Mill is supplemented with pine and hardwood pulp purchased from off-site
and pulp produced from trim or broke paper off the paper machines. The pulp is then used in
paperboard and fine paper production using one of the four paper machines on-site.
Table 3. Itemized Production Figures for the Maximum 12 Month Average Production Period.
Product Total for 12 Month Period Units
Pine Pulp 217,634.48 Air Dried Tons
Hardwood Pulp 298,833.91 Air Dried Tons
Purchased Pine Pulp 24,306.87 Air Dried Tons
Purchased Hardwood Pulp 22,252.21 Air Dried Tons
Broke Paper or Trim Pulp 46,559.08 Air Dried Tons
Paperboard Production 313,625.90 Off Machine Tons
Fine Paper Production 321,264.00 Off machine Tons
Blue Ridge Paper has not joined the Voluntary Advanced Technology Incentives Program (VATIP) for
existing direct or new direct dischargers as outlined in 40 CFR 430 Subpart B. The VATI Program
was set up for new or existing direct dischargers whereby mills agree to accept enforceable effluent
limitations and conditions in their NPDES permits that are more stringent than the BAT limitations, in
exchange for regulatory and enforcement related rewards and incentives.
Blue Ridge Paper will use steam stripping to treat process condensates, rather than hardpiping to the
WWTP; thus interface with the Division of Air Quality is not necessary.
Relevant Issues
Daily effluent monitoring for Adsorable Organic Halides (AOX) is required. AOX is an overall test
for adsorbable organic halides, which includes chlorinated organics. Trends in concentration changes
have been observed between AOX and specific pollutants (dioxins, chlorinated organics) at pulp and
Fact Sheet
NPDES Renewal

paper mills. Therefore, any decrease in AOX may also indicate a decrease in chlorinated organics.
Limits and daily monitoring for AOX are required in the EPA Cluster Rules. The cluster rules are the
combined air and water rules issued by the EPA for the pulp and paper industry. The
compliance/monitoring point for the AOX limits shall be as defined in the sampling plan.
During the next permit cycle, the Division will review the AOX data for possible reduction in
monitoring frequencies.
Chloroform monitoring/limits have been added to the permit. During the previous permitting cycle, it
was determined that the discharge from Blue Ridge Paper did not have a reasonable potential to exceed
the allowable level. Therefore, no effluent limit is proposed. Limits contained in the NPDES permit
on the bleach plant effluent are based on the EPA promulgated Effluent Guidelines for the Pulp, Paper,
and Paperboard Point Source Category. Since Blue Ridge Paper operates two separate fiber lines,
there shall be two compliance points for chloroform as stipulated in the sampling plan.
In addition to the dioxin limits and conditions stated, above dioxins shall be limited and monitored on
the effluent from the each bleach plant. 2,3,7,8 TCDD and 2,3,7,8 TCDF limits are based on the EPA
promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category. The
compliance/monitoring points for each bleach plant is required as stipulated'in the sampling plan.
Best Management Practices (BMPs) have been added for spent pulping liquors, turpentine, and soap.
At this time, Blue Ridge Paper is in compliance with the best management practices stipulated in the
EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category with
one remaining issue.
The remaining issue deals with the BMP Plan. As part of the EPA promulgated effluent guidelines,
facilities, which fall under subpart B, must develop a BMP Plan. This plan does not require the
approval of any regulatory authority, but must be certified by the mill manager. Currently, the BMP
Plan is in the development process and it is anticipated that this requirement will be completed prior to
issuance of this NPDES permit.
Per 40 CFR 430.24, the daily maximum limits for 12 chlorinated phenolics are "less than Minimum
Level" (<ML) as specified in 40 CFR 430.01. The compliance/monitoring point shall be set at the
effluent from the bleach plants as outlined in the sampling plan.
PROPOSED CHANGES FROM THE CURRENT NPDES PERMIT
• Monthly average BOD5 limit reduced 71 tons per year to 3205 lb/day.
• Daily maximum BODS limit reduced 12.5% to 10897 lb/day.
• Toxicity testing concentration increased to 90%.
• Removal of downstream fecal coliform monitoring with once per week upstream fecal monitoring.
• Removal of instream BOD5 monitoring.
• Removal of instream monitoring station 55.5.
• Removal of instream monitoring station 53.5.
• Reduce monitoring frequency at NC/TN monitoring station.
• Eliminate mercury monitoring and limitation.
• Add selenium limit.
• Trichlorophenol/pentachlorophenol monitoring has been removed.
• The upstream river mile marker now indicates that the upstream monitoring location is located at
river mile 63.8.
• The dioxin special condition has been modified to require 2,3,7,8 TCDD and 2,3,7,8 TCDF
individual isomer monitoring and to reduce the monitoring frequency of the sludge and landfill
leachate.
Fact Sheet
NPDES Renewal
Pane 13

• The 2,3,7,8 TCDD effluent limit has been modified to 0.014 pg/L.
• Two internal outfalls (002 and 003) have been added.
• .Removal of hardness monitoring.
• Removal of total dissolved solids monitoring.
• Removal of total residue monitoring.
• An AOX limit and daily monitoring has been added to the permit per EPA Cluster Rules.
• Dioxin, chlorophenolics and chloroform limits/monitoring have been added for the effluent from
the pine and hardwood line bleach plants per EPA cluster rule.
• The BMP special condition has been updated according to the requirements of the EPA Cluster
Rule.
• For color recommendations refer to the July 24, 2001, memo from the EPA Tech Team to the
Technology Review Workgroup.
This fact sheet represents North Carolina's recommendations. The Division will review all pertinent
comments received during the public comment period and the September 6, 2001 public hearing. After
reviewing all public comments, the Director of the Division of Water Quality and the NPDES
Committee of the Environmental Management Commission will make their recommendations.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Public Notice Draft Permit, temperature variance, color variance and Public August 3, 2001
Hearing
Public Hearing September 6, 2001
ADDITIONAL INFORMATION
CANTON MODERNIZATION PROJECT
Prior to 1993, knotting hardwood brownstock was washed through one of two brownstock washer
lines. After washing brownstock was screened using a two-stage fine screening process and bleached
in one of the two bleaching lines. The two bleaching lines were operated independently for 'low'
brightness and 'high' brightness.
Since 1993, the hardwood fiberline has incorporated numerous modifications designed to increase mill
performance from both an environmental and product quality standpoint. Currently, the hardwood
fiberline consist of two stage knotting followed by pre-oxygen delignification washers. After pulp is
processed through the oxygen delignification unit, it is washed again prior to the four stage pressurized
fine screening. After screening, the pulp is bleached through one medium consistency bleach line.
Prior to 1992, pine (softwood) pulp was processed through one brownstock washing line prior to the
two stage screening process. After screening, pulp was processed through one of the two bleaching
lines. Similar to the hardwood fiberline, the softwood fiberline bleaching was operated independently
for 'low' brightness and 'high' brightness.
Like the hardwood fiberline, the softwood fiberline has incorporated numerous modifications in order
to enhance product quality and environmental performance. Currently, the softwood fiberline process
consist of two stage knotting followed by a brownstock pre-oxygen delignification line. After the initial
washing the pulp is processed through the oxygen delignification unit followed by another washing.
After the second washing pulp is screened using four stage pressurized fine screen before entering a
medium consistency bleach line.
In addition to the improvements noted, the facility has implemented full scale bleach filtrate
recycle of the pine bleach line and caustic extraction stage (Eo) recycle on the hardwood bleach
line.
Fact Sheet
NPtIPC RMnrwol

References
1. Division of Water Quality's Basinwide Information Management System, April 20, 2001,
http:/lh2o.enr.state.nc.us/bims/reportstbasinsandwaterbodies/alpha/Neuse.pdf
2. 1995. NPDES Regional Staff Report for NPDES Permit NC0000272, January 18, 1995,
Asheville Regional Office.
3. 2000. French Broad River Basinwide Water Quality Plan. North Carolina Division of Water
Quality, Water Quality Section.
4. 2001. NPDES Permit Application EPA Forms 1 and 2C, Blue Ridge Paper Products Inc.
5. 2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of
Water Quality, Water Quality Section. Copies obtained through Planning Branch, Archdale
Building, 512 N. Salisbury St., Raleigh, North Carolina.
6. 1993. Low Flow Characteristics of Streams in North Carolina, United States Geological
Survey Water-Supply Paper 2403. Copies obtained at U.S. Geological Survey, Map
Distribution, Box 25286, MS306, Federal Center, Denver, CO 80225.
7. 1997. NCO000272 NPDES Permit. Issued to Champion Paper, expiration November 30,
2001. Copies obtained through The Division of Water Quality, Central Files, Archdale
Building, 512 N. Salisbury St., Raleigh, North Carolina.
8. 2001. Bleach Environmental Process Evaluation and Report. Dr. Norman Liebergott, PhD,
Liebergott and Associates Consulting, Inc. and Lew Shackford, June 8, 2001.
9. 2001. Additional Color Removal Technologies and Their Economic impacts on Blue Ridge
Paper Products, Canton, NC. July 25, 2001 Memorandum from EPA Tech Team to
Technology Review Workgroup.
State Contact
If you have any questions on any of the above information or on the attached permit, please contact
Michael) Myers at at [phone] ext. 508.
NAME: /// �/If�, DATE: ycy� Zyc�>
NPDES SUPERVISOR/
NAME: {/ /1^— DATE: /47 w 3 ZOo)
` Fact Sheet
NPDES Renewal
Page 15

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON,D.C.20460
J�ICtfiD SIAle ..
Q
'fit FROZE
MEMORANDUM
DATE: July 25, 2001
SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue
Ridge Paper Products, Canton,NC
FROM: EPA Tech Team`
TO: Technology Review Workgroup
Purpose of this Analysis
As required by the 1997 Settlement Agreement, this memorandum presents a summary of an
analysis of available technologies that may be employed to further reduce color discharges from
the Blue Ridge Paper Products, Inc. (Blue Ridge) mill in Canton,NC. The analysis also includes
•a summary of the economic impact ("gross margin test") of the cost of implementing identified
color reduction technologies.
Members of the Tech Team visited the Canton mill on March 14, 2001 to observe and gather
information and data on the status of technologies implemented and color discharges at the mill
since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered
from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical
and financial data. This final memorandum is based on the May 4, 2001 preliminary draft
memorandum, and revisions to the July 10, 2001 draft final memorandum, based on a review of
Blue Ridge's comments,the June 8,2001 Bleach Environmental Process Evaluation and Report
(BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group, Inc,
and additional comments from the Clean Water Fund of North Carolina, and the States of
Tennessee and North Carolina. This memorandum presents to the Technology Review
EPA Tech Team is comprised of--Mark Perez,EPAIEAD;Karrie-Jo Shell,EPA Region 4;Don Anderson,
EPA/EAD;Betsy Bicknell, ERG,contractor;Neil McCubbin,subcontractor to ERG; Dan Bodien, subcontractor to
ERG.

Workgroup (TRW)process improvements evaluated by the Tech Team and considered to be
available technologies and briefly addresses relevant technologies evaluated in the BEPER.
Background and History
Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton,NC, which it
purchased from Champion International Corporation in May 1999. Operations at the mill began
in 1908, but the mill has been extensively modernized, most recently in 1993. The mill currently
operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking,
pulp from each line is further delignified in single-stage oxygen delignification systems installed
in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence; pine pulp is bleached
with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery
(BFRTM) process, developed by Champion. A portion of the hardwood line bleach plant Eo-
stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated
paper including offset, tablet and envelope grades. The mill also produces 281,000 tons per year
of bleached paperboard used for liquid packaging and paper cups, including FDA approved
grades for milk and juice cartons. Since November 2000,pulp production has been reduced by
approximately 30 percent as the result of a major project to upgrade the No. 19 bleached
paperboard machine.
.Continued Color Reduction Opportunities Since the 1997 NPDES Permit
The Canton Mill's 1997 NPDES permit included a schedule requiring continued study,
evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge
submitted a series of reports to the NC Department of Environment and Natural Resources,
Division of Water Quality, evaluating the performance of the BFRTM process, end-of-pipe color
reduction technologies, and practices for minimizing color losses from manufacturing processes.
Since 1997 Blue Ridge has:
• continued full-scale operation of BFR for the pine line;
• concluded that full-scale BFR is not feasible for the hardwood line, but
implemented partial reuse of a portion of the Eo-stage filtrate as an effective
color-reduction approach;
• identified and implemented several practices for reducing losses of highly-colored
black liquor from manufacturing processes; and
• evaluated 16 end-of-pipe color removal technologies and determined that they
were presently economically and/or technically infeasible for the Canton mill.

Page 3
Process Improvements Analyzed by the Tech Team
The Tech Team identified five mill improvements capable of further reducing the discharge of
color in the mill effluent. For each of these improvements, technical feasibility, capital and
operating costs, and potential color reduction were reviewed. Each improvement can be
implemented independently of the others or in any combination. The costs incurred to
implement the improvements are additive,however separate evaluations are necessary to
accurately estimate the associated color reduction achieved by implementing any combination of
improvements. End-of-pipe color treatment technologies (e.g., chemically assisted clarification
with sludge dewatering and disposal) typically require initial capital investment and ongoing
operating expenses, not savings, and are likely to incur non-water quality environmental impacts.
For this reason, the Tech Team focused on pollution prevention approaches that offer the
potential to be more cost-effective: color reduction in low flow, highly color-concentrated
wastestreams, through manufacturing process changes or in-process treatment.
The first two process improvements, discussed below (improvements in BFR reliability and leak
and spill prevention and control -Best Management Practices (BMPs)), are improvements which
the Tech Team concludes offer the highest certainty for technical feasibility and color reduction.
Blue Ridge also identified these technologies as feasible color reduction opportunities that will
be implemented, but differed from the color reduction estimates included in this memorandum.
The next two process improvements (ozone addition to an existing chlorine dioxide bleaching
stage on the hardwood fiber line; adding a second stage to the current oxygen delignification
system on the softwood fiber line) also were evaluated by Liebergott, et. al., as feasible color
reduction opportunities. Additional technical evaluation and/or laboratory testing would be
appropriate to reliably determine the technical details of how to incorporate these processes into
the existing fiber lines and to more accurately predict their achievable color reduction, and the
relationship of these technologies to BFR. Additional analyses would be appropriate to
determine the most cost-effective design and the most economically feasible schedule for
implementing one or both of these improvements.
The fifth process improvement, color treatment for the chloride removal process (CRP)purge
stream (one of the two key components of the BFR process),has the potential for additional
color reduction. However, based upon initial bench-scale treatability studies by Blue Ridge,
further study of additional color treatment technologies is necessary. Process optimization on
both the hardwood and softwood fiber lines, as recommended in the BEPER, is anticipated to

Page 4
provide additional color reduction and is identified as the sixth process improvement. It was
concluded that the process optimization option was among those with the highest certainty for
technical feasibility and color reduction.
All color reductions resulting from the mill improvements are estimates based solely on available
data and information. While the Tech Team has concluded that these technologies would reduce
the color discharge from the Canton mill, there is a lack of directly comparable operating
experience with these technologies in other bleached papergrade kraft mills that can be used to
develop precise predictions of the extent of the color reduction benefits.
The BEPER evaluated additional in-process technology options for color discharge reduction
potential, including the implementation of a hot pressurized peroxide-enhanced extraction stage
in both fiber line bleach plants. At this time,the Tech Team does not have sufficient information
to confirm the applicability of this technology at the Canton mill nor relevant data to predict its
potential color discharge reduction capabilities. Therefore, while this memorandum does not
address this technology option, it may be feasible for implementation by Blue Ridge and
contribute to reducing color. In addition, the Tech Team did not analyze nor did the BEPER
recommend a Totally Chlorine-Free (TCF) bleaching option because of the high cost of this
technology and the lack of experience in producing and successfully marketing products made
by Blue Ridge at the Canton mill.
1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal
Process (MRP). Blue Ridge has found that this process element has been more challenging and
expensive to maintain than originally planned. The target BFR recycle rate (percent closure) for
the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and
metallurgy problems (e.g., erosion of multi-media filtration tank lining) in the MRP, however,
the pine line closure has averaged only 74 percent from October 1998 to the present. Blue Ridge
has undertaken improvements to the MRP system in order to maintain the process closure rate
and increase operating time. Improvements include rebuilding piping and valves, and changing
construction materials and metallurgy to better withstand the chemical and physical stress
experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80
percent, annual average final effluent color discharge will be reduced by 1,000 to 1,200 lbs/day.
At this time, the Tech Team has no means of making an alternative quantitative prediction of
final effluent color reduction to compare to the Blue Ridge estimate.

Page 5
2. Improved black liquor leak&spill collection and control (BMPs). The Canton mill has an
extensive spill recovery system. Sumps in this system, including one sump added in the court
yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped
with pumps that are activated automatically when sensors detect wastewaters with high
conductivity and color. High conductivity material is routed to the recovery system. Further
improvements to the black liquor collection system include:
• continuous improvement of operating practices so more leaks and spills are
recovered rather than discharged to sewer;
further improvement in preparation for planned outages to maximize capture of
tank clean-out waste and routing to recovery;
further reducing clean water that continuously runs into sewers to prevent dilution
of smaller spills and facilitate recovery of highly colored wastewaters; and
• further improvement in the equipment used for handling of knots rejects to
prevent black liquor leaks into the recovery sumps.
The plot below shows the color of wastewater treatment influent at the Canton mill. The
variability of influent color discharge to wastewater treatment is attributed to color discharge
peaks that represent, in part, unplanned spills or leaks discharged to sewers or intentional
diversions of highly-colored black liquor or other color sources routed to sewers during mill
equipment shutdowns.
100
kg/t
Figure 1 -
75 Daily color at influent to WWTP for Canton
50
25
0 30 60 90 120 150 180

Page 6
Due to the nature of the manufacturing processes and practical equipment operation and
reliability, all spills and color losses to sewers cannot be fully anticipated, predicted, and
completely contained. However, a comparison of the variability of the Canton mill influent color
data to available primary influent color data at another bleached papergrade kraft mill indicate
that a detailed review of the spill prevention and recovery system at the Canton mill (by mill
staff or external consultants), including involvement by the mill operators, can further uncover
the causes of and better quantify black liquor losses and other color sources that can be avoided
or recovered. This will result in an overall reduction in color discharge, both in long-term
average and variability. Through improved planning of mill equipment shutdowns, continuing
efforts to minimize process operation variability, and increased recovery of highly-colored leaks
and spills, discharges of highly colored material to the wastewater treatment system can be
reduced more consistently below existing levels.
Further reducing peaks in color discharges within the mill and preventing highly colored flows
from reaching the wastewater treatment system will further reduce the variability of color
discharges from the wastewater treatment system to the Pigeon River. For example, limiting the
color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to
improve the mill's BMP system and process operations would reduce the color loadings from
mill processes to the end-of-pipe wastewater treatment system by more than 8,000 lb/day. The
Canton mill operated under this primary clarifier influent color threshold approximately 74
percent of 2000, excluding November through December 2000. This time period was considered
not to be representative of steady-state operations because of the reduced pulp production
resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average
reduction of 45 percent across this wastewater treatment system for"brown" color derived from
black liquor, this would result in a minimum decrease of 4,400 lb/day in the average final .
effluent color load.
Clean water, such as packing gland water, presently flows in several sewers with recovery
sumps. These colorless streams dilute other colored wastestreams, such as small black liquor
leaks and spills, to the point where the in-stream conductivity is too low to trigger recovery. By
eliminating clean water streams or diverting them away from sewers that collect black liquor
leaks and spills, wastewater streams with elevated color can be recovered more readily, resulting
in a reduction in color discharge to the end-of-pipe wastewater treatment system. Also, the
unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can
be recovered.

Page 7
At this time, the Tech Team has no basis for determining an accurate correlation between
unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill
Environmental Performance Update presented by Blue Ridge during the March 14, 2001 Tech
Team Canton mill visit. During the March 14 visit,Blue Ridge staff indicated that results of
studies of sewer generated color showed a relationship between bleach plant filtrate pH and
temperature and unaccounted color generated in mill sewers. By operating within the range of
pH and temperatures identified during the studies the Canton mill has had some success in
controlling this source of unaccounted color. Based on this information, the Tech Team
concludes that by further reducing process operation variability, including operating within the
pH and temperature range identified during the studies, the mill can continue to also minimize
sewer generated color, thereby reducing one source of unaccounted color. Reducing overall
color discharges through BMPs and other management practices will likely farther reduce
remaining unaccounted color. However, additional studies are necessary to further develop any
relationship between accounted and unaccounted color sources.
As noted above, analysis of primary clarifier influent color loading data demonstrates that color
loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during
steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and
intentional discharges of colored streams and continuing efforts to minimize process operation
variability, the Canton mill can achieve further reduced primary clarifier influent color loads and
subsequent final effluent color discharge within this range on a more consistent basis than
demonstrated in 2000 (i.e., more than 74 percent of the time). On this basis, the Tech Team
concluded it is feasible to reduce final effluent color by more than 5,000 lbs/day through
improved black liquor leak and spill collection and control.
3. Ozone/Chlorine dioxide stage for hardwood bleach line. Ozone is used in more than ten kraft
mills around the world to bleach pulp, including two in the US and one in Canada. There are
several process configurations, but the most common is to operate an ozone (Z) mixer and
reactor immediately upstream of a chlorine dioxide reactor, without any washing between the
application of the two chemicals. This is known as a"ZD" stage. A system of this type was
retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999.2 Bleaching with ozone on
the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 27 percent reduction in
the discharge of color in the combined mill treated effluent' The conversion to a ZD stage
Y Munro,Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching Sequence,Tappi,2000.
3 Ibid.

Page 8
would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for
ozone. The energy requirements for ozone production would be offset by the energy savings
from less chlorine dioxide and caustic production, resulting in a net reduction in energy
consumption with the ZD stage.
As of September 2000, the long-term average color discharge from Canton's hardwood bleach
line was 12,800 pounds/day'. The Espanola experience suggests that implementation of a ZD
stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by
3,000 to 6,400 lbs/day. Based on comments received, the Tech Team acknowledges that
operating parameters, such as wood species processed and technology supplier performance
guarantees, may influence the practical color reduction achievable through implementation of a
ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are
based solely on the demonstrated performance and the Tech Team's assumption of color sources
at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada
(PAPTAC) meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible
communication between Blue Ridge and Domtar staff would be necessary to reliably predict the
achievable color reduction possible with this option for the Canton mill.
The technical evaluation of this process improvement included in the BEPER yielded a
hardwood filtrate color discharge reduction within the range of Tech Team estimates.
4 2ml stage OD for pine line. Oxygen delignification (OD) on the Canton Mill pine line is a
single stage system installed in 1993. It has been concluded that retrofitting a second OD stage
for the pine line could contribute to reduced color discharges in two ways. The first would be a
reduction in color for those filtrates presently not captured and reused in the BFR process. The
second would be a color reduction in the Chloride Removal Process (CRP) purge stream as a
result of less chloride from chlorine dioxide used for bleaching. -
Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed
upstream of the existing reactor. Previously, the Tech Team anticipated increasing the kappa
number (lignin content) of the cooked pulp from 24 to 32 and utilizing a two-stage OD system to
reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two-
stage system. Based upon comments from BRP and further technical analysis, and review of the
BEPER, it was concluded that it is technically feasible for a two-stage OD system at the Canton
4 Jacobs Engineering Group,2001 Color Removal Technology Assessment,February 2001.

Page 9
mill to achieve an overall reduction of 50 percent in kappa number, rather than 65 percent as
previously anticipated. Therefore, with the Canton mill continuing to pulp to a kappa number of
24,the new two-stage OD system would reduce pulp kappa number into the bleach plant from
the current output of 16 to about 12, corresponding to a 50 percent kappa number reduction from
the current digester output of 24. The quantity of color released from the bleach plant will be
reduced in proportion to the reduction of the input kappa number.
By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a
two-stage OD system, the quantity of chemicals required in the first two stages of the bleach
plant can be reduced, because there is less lignin present in the incoming pulp to remove by
bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional
reduction in chloride load to the CRP and reduce color discharged from the purge stream in
proportion to the reduction in chloride being treated.
In response to comments received, it has been concluded that implementing a two-stage OD
system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve
a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving
greater delignification with the proposed two-stage OD system. However, operating a two-stage
OD system with a higher than 50 percent delignification rate and a digester kappa number higher
than currently employed at the Canton mill is commonly seen at comparable bleached
papergrade kraft mills. Therefore, the Tech Team anticipates that additional process engineering
will maximize the benefits of a two-stage OD system at the Canton mill and enable the mill to
capture the increased delignifcation and yield gain potential of this technology and achieve
annual wood cost savings of up to approximate $950,000 from up to a 1.5 percent yield increase
across the proposed two-stage OD system.
Based on additional information supplied by Blue Ridge regarding operational limitations of the
BFR system, the Tech Team concludes that a two-stage OD system would not have a significant
impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on
a day-to-day basis.
For this analysis, it was estimated preliminarily that a second OD stage could reduce total
influent color discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from
reductions in pine line bleach plant filtrate color and CRP purge stream color.

Page 10
The technical evaluation of two-stage OD included in the BEPER yielded reduction in color
discharge influent to the wastewater treatment system within the range of the Tech Team
estimates.
5. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP) purge is a low
flow, highly concentrated waste stream. Color is typically 50,000 pcu, in a 10 gpm (0.01 MGD)
flow. The CRP purge contributes up to approximately 5,000 lbs/day (13 percent) to the total mill
loading to the wastewater treatment system influent, but only 0.06 percent of the discharge flow.
It was originally speculated that it may be feasible to reduce the color in this stream by
precipitating the colored organic material with lime at a dosage of 20 g/L3, and burning the
resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials
would be necessary to test the feasibility of color removal from the CRP purge stream by lime
treatment.
Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium
compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The
preliminary results of these trials show that at a dosage of 20 g/L, none of the compounds tested
reduced color in the CRP purge stream. Although color removal was demonstrated at higher
dosage rates, increased chemical usage would result in substantially higher operating costs,
require larger sized equipment at higher capital cost, and also result in a higher production rate of
sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not
burned must be landfilled at additional cost.
Based on preliminary laboratory trials, Blue Ridge concluded that lime treatment of the CRP
purge is not a feasible color reduction option for the Canton mill. However, the Tech Team
recommends additional review of other innovative technologies for treatment of color in the CRP
purge stream, such as the application of the X-Filter process recently implemented at a totally
chlorine free (TCF) mill6. By minimizing color contributions from this stream, the potential
exists to achieve a significant reduction in primary influent color discharge of up to 5,000
lbs/day.
5 NCASI Technical Bulleting No.239,The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching
Effluents with Lime.I. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970.
6 Comments on the Draft Report on Additional Color Removal Technologies and Economic Impacts for BRPP,Hope
Taylor,Clean Water Fund of North Carolina,July 18,2001

Page 11
6. Process Optimization, The BEPER identified sixteen recommendations for optimizing the
hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching
operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the
first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood
line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction
of up to 700 lbs/day from the hardwood line and up to 4001bs/day from the softwood line. The
Tech Team estimated an additional color reduction from the CRP purge stream of 600 lbs/day
resulting from the decreased chlorine dioxide usage. At this time, the Tech Team has no means
of making an alternative quantitative prediction of bleach filtrate color reduction to compare to
estimates presented in the BEPER. Therefore, it is estimated that through efforts by mill staff to
maximize the color reduction benefits from the process optimization opportunities identified by
Liebergott, et, al., the Canton mill would achieve a total color reduction of 1,700 lbs/day in
wastewater treatment system influent.
Color Reduction Summary
The Tech Team estimates that by improving BFR reliability and black liquor leak and spill
collection and control, the Canton mill final effluent will be reduced by more than 5,000 lbs/day.
Process optimization, as outlined in the BEPER, would result in a further final effluent color
reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45
percent across the existing wastewater treatment for the CRP purge stream and other"brown"
color sources derived from black liquor and no reduction in color from bleach plant filtrates.
Table 1 presents a summary of the estimated reductions in final effluent color attainable with the
highest certainty by implementing improved BFR reliability, improved BMPs, and process
optimization.

Page 12
Table 1: Summary of Process Improvements and Associated Color Reductions
(Highest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
1 BFR reliability improvement --- 1,000-1,200
2 Improved black liquor leak & spill collection and --- > 5,000
control
6 Process Optimization 1,700 1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION >7,400
Additional potential mill improvements to reduce color discharge at the Canton mill were also
identified. These process improvements require further study to more accurately determine
achievable color reduction and thus are not recommended at this time for immediate
implementation. These improvements include a ZD stage in the hardwood bleach plant, with a
preliminary estimate of a 3,000 to 6,4001bs/day color load reduction in influent to the
wastewater treatment system, and a second OD stage for the pine line, with a preliminary
estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment
system. Table 2 presents a summary of preliminary estimates of color reductions for these two
additional process improvements that need further study. Reductions presented in Table 2 are
preliminary estimates with reduced certainty compared to those presented in Table 1, but are
based upon identified technology options available for the Canton mill.

Page 13
Table 2: Summary of Process Improvements and Associated Additional Color Reductions
Needing Further Study (Reasonable Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400
line
4 2"d stage OD for pine line 1,500-2,000 1,100-1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 - 7,800
Table 3 presents a preliminary estimate of color reduction potential for the removal of color from
the CRP purge stream. The Tech Team recommends this stream for additional review of
potential color reduction technologies but cannot identify a particular technology option at this
time. Potential for additional color load reduction up to 2,750 lbs/day in final effluent to the
Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty.
Table 3: Summary of Additional Potential Color Reductions Needing Further Study
(Lowest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(Ibs/day) (Ibs/day)
5 1 Color Treatment of CRP Purge Stream #5,000 #2,750
TOTAL ADDITIONAL POTENTIAL FINAL EFFLUENT COLOR #2,750
REDUCTION

Page 14
Economic Analysis
The estimated capital and operating costs for the process improvements one through four were
estimated and are summarized below. Costs could not be developed at this time for process
optimization or CRP treatment and thus are not presented. However, costs for these
improvements should be modest.
Table 3: Estimated Costs
Process Improvement Capital Cost Annual O&M
($) ($/year)
1 BFR reliability improvement $1,300,000 $85,000'
2 Improved black liquor leak & spill collection and $100,000 $50,000
control
3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000)
line savings
4 2"d stage OD for pine line $2,000,000 ($2,100,000)
savings
Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven
plants (including the Canton Mill) from Champion International Corporation. Blue Ridge Paper
Products is owned 55 percent by KPS Special Situations Fund, L.P. and 45 percent by the
employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the
1997 report EPA documented substantial losses over five years for the Canton Mill and
Champion had just announced its intention to sell or close the mill. However, because of the sale
of the mill to the Blue Ridge, the previous data are not comparable to the more recent data.
Further, the data submitted by Blue Ridge is still confidential, so this report cannot present as
much detail as the 1997 report.
The current analysis is based on information submitted by Blue Ridge covering part of
1999 (May-December) and all of 2000 (all of the existing financial data for the company). The
results may be relatively uncertain because of the lack of data and the company may be too
young for the current data to reflect its ultimate financial health. EPA used three measures of
financial health (gross profit test, discounted cash flow, and Altman's Z)7 to assess the impact of
7 See Interim Economic Guidance for Water Quality Standards:Workbook,EPA 823-B-95-002,March 1995, and
Economic Analysis for the National Emission Standards for Hazardous Air Pollutants for Source Category: Pulp and
Paper Production;Effluent Limitations Guidelines,Pretreatment Standards,and New Source Performance
Standards: Pulp,Paper,and Paperboard Category—Phase 1,

Page 15
air emissions control technologies and devices (not addressed in this memorandum, such as
MACT II and regional NOX control) and wastewater compliance costs (separate and combined)
on the mill and company. The costs for the wastewater control options presented in Table 3 do
not change the financial status of the mill or company. However, the costs for some of the air
emissions control options do impact the health of one or both entities. When the wastewater
costs are added to costs for air emissions control, the impacts of the water costs do not change
the financial status of either the mill or company when compared to the impact of the air costs
alone.
References
Blue Ridge Paper Products, Inc. Canton Mill Canton Mill Environmental Performance Update,
Prepared for U.S. EPA Technology Review Workgroup. March 14, 2001.
Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic
Analysis of Blue Ridge Paper Products, from Bob Williams, May 18, 2001 (CBITS 00003911-
01)
Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown, Blue Ridge,
to Don Anderson, EPA, May 18, 2001
Comment Clarification of May 18, 2001 Blue Ridge Responses to EPA Questions, from Derric
Brown, Blue Ridge, June 4, 2001
Comments on Draft Final Tech Team Report, from Bob Williams, Blue Ridge, to Don Anderson,
EPA, July 13, 2001
Comments on Draft Final Tech Team Report, from Derric Brown, Blue Ridge,to Don Anderson,
EPA, July 17, 2001
Comments on Draft Final Report, email from Forrest Westall,North Carolina DENR, to Don
Anderson, EPA, July 17, 2001
Comments on Draft Final Report on Additional Color Removal Technologies and Economic
Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001

Comment on Draft Final Tech Team Report, email from Paul Davis, State of Tennessee, to Don
Anderson, Julyl8, 2001
Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott, to
Don Anderson, EPA, July 19, 2001
Jacobs Engineering Group, 2001 Color Removal Technology Assessment,Blue Ridge Paper
Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001.
Liebergott,Norm, and Lew Shackford, Bleach Environmental Process Evaluation and Report,
June 8, 2001
McCord, Aimee,A Laboratory Analysis of Color removal Across a Pulp and Paper Mill
Wastewater Treatment Facility, Canton, North Carolina, Duke University, School of the
Environment, 1995
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.
NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of
Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching
Effluent. July, 1970.
Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater
Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina, Duke University, School
of the Environment, 1996
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry. Page 182
Wiley Interscience, 1986.
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry, 3rd edition.
Page 286. TAPPI Press, 2000.

Appendix 1: Color Balance (9/1100 to 12/31/00)
Figure 2.6, Presented by Blue Ridge on March 14, 2001
Sewer Description Color Load
ID (Ibs/day)
2B Digester area sewer: Digesters, HW 4,323
line, knot rejects
3A Alkaline sewer: Pine and HW Eo, 12,954
Pine line BSW, 02 Delig
1 PMs11 & 12, HW weak liquor tank 1,991
5B Recovery, BLOx, CRP* 7,852
6A Acid sewer: Pine and HW D1 17,345
filtrate+Pine D2 filtrate
Contaminated Condensate 1,591
Combined Condensate 260
Total 46,316
Primary Influent(PI) 49,284**
Unaccounted Color Z968
(PI minus Total)
Secondary Effluent 37,696
Percent Removal in Treatment 23 %
* CRP contributes 5,000 to 6,000 lbs/day to 5B sewer
** Measured using test method in NCASI Tech. Bull. 803, An Update of Procedures for the
Measurement of Color in Pulp Mill Wastewaters, May 2000.

Appendix 2: Table of Effluent Color Limits, 1997 to Present
Color Limit Trite Color (lbs/day)
Monthly Average Annual (Long-term)
Average
1997 Permit 125,434 98,168
Settlement Agreement, February 1998 69,000 60,000
(starting December 1, 1998)
Settlement Agreement, February 1998 --- 48,000 to 52,000
(Ultimate Target)
Interim Limits, May 2001* 55,000 48,000**
* As recommended by Technology Review Workgroup (TRW) and incorporated by NC in
BRP's NPDES permit.
** Reduced end-of-pipe color discharges since November 2000 reflect, in part, reduced pulp
production (approximately 30 percent) during this period because of the ongoing project to
upgrade the No. 19 paper machine used to produce bleached paperboard.

Appendix 4: Two-Stage Oxygen Deligntfcation
Comparison of one- and two-stage oxygen delignification systems
Item Current Single-Stage System Proposed Two-Stage System
Oxygen Reactors One two
Input Kappa Number 24 24
Output Kappa Number 16 12
Total CIOZ Used 28 kg/ton* 22 kg/ton*
Oxygen Used 23.4 kg/ton* 28.3 kg/ton*
Total NaOH Used 45 kg/ton* :�737 kg/ton*
* air-dried metric ton of bleached pulp

Appendix 3: Ozone Bleaching
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based=Bleaching
Sequence,Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.

August 3, 2001
Memorandum
Subject: Additional Color Removal Opportunities, Blue Ridge Paper's (BRP) Canton,NC_
Bleached Kraft Paper Mill,2001 NPDES Permit Renewal
From: Technology Review Workgroup
Donald Anderson, Chair, EPA
Karrie-Jo Shell, EPA Region IV
Paul Davis, Tennessee
David McKinney, Tennessee
David Goodrich,North Carolina
Forrest Westall,North Carolina
To: North Carolina Division of Water Quality and the NC Environmental
Management Commission's NPDES Sub-Committee
In accordance with the 1997 NPDES Permit Agreement for the Canton Mill, the Technology
Review Workgroup (TRW) has examined the progress made at the facility in relation to reducing
the color content of the Mill's effluent and the potential for additional color reduction at the
plant. The focus of this examination includes a review of reports submitted by Blue Ridge Paper
(BRP), a visit to the Mill on March 14, 2001 by EPA's Tech Team, consultation among the EPA
Tech Team and the Workgroup's members, consideration of the separate Mill evaluation and
Liebergott report (Bleach Environmental Process Evaluation and Report) dated June 8, 2001, and
comments from environmental interest and other stakeholder groups (including Clean Water
Fund of North Carolina, American Canoe Association), and EPA's Tech Team Memorandum on
this subject dated July 25, 2001.
It is the finding of the TRW that the EPA Tech Team Memorandum represents an appropriate
evaluation of the potential for additional color reduction at the Mill over the next permit cycle
(December 1,2001 through November 2006). As a result of this finding,the TRW includes with
this memorandum a copy of the subject report for use by the Division of Water Quality and the
Environmental Management Commission's NPDES Sub-Committee as guidance for the
development of the effluent limitations for color and related special conditions of the draft
NPDES Permit renewal and North Carolina's Effluent Color Variance.
As the purpose of the TRW is to provide a review of the possible technology options available to
the Mill to further reduce the color discharge to the Pigeon River, the EPA Tech Team

Memorandum provides a solid foundation for developing specific conditions and limitations for
the Mill's next NPDES permit. In making this point, the TRW recognizes that not all of the
options outlined in the Tech Team Memorandum can be predicted to achieve specific color
reductions with complete accuracy. Consequently the Memorandum provides estimates of
possible reductions and in some cases a range of likely color reduction from the application of
specific technologies. The TRW also notes that several individuals and organizations provided
alternate estimates to the EPA Tech Team. Again, the difference between"technological
likelihood" and "regulatory limit" is an important distinction that must be considered in
"enforcing"permit conditions. When considering the potential color reduction options provided
in the Tech Team Memorandum in developing a draft NPDES Permit and Color Variance, the
TRW recommends that the following points be considered:
1. The highest priority for additional color reduction moving toward achieving the North
Carolina water quality standard for color rests with additional in-mill improvements,
particularly considering the success already achieved by continuing improvements in leak
and spill prevention and control (Best Management Practices—BMPs) and process
modifications. End-of-pipe technologies reflect significant economic,technical, and non-
water quality environmental impact problems at this mill.
2. The Tech Team Memorandum identifies by degree the "certainty" of three possible
categories of options that the Mill could undertake to further reduce color in the mill's
effluent. The "regulatory risk" of being able to achieve the reductions under these
categories increases as the certainty decreases. Any regulatory limitations/conditions
need to reflect this consideration.
3. The TRW recommends that the options identified in the Tech Team Memorandum as
having the "highest certainty" (i.e., improvements in reliability of the existing bleach
filtrate recycle system (BFR) and leak and spill prevention and control - BMPs, and
process optimization) should be implemented first and the permit/variance should reflect
a very specific level of reduction. The time necessary for the Mill to implement these
"primary" options should realistically reflect the ability of BRP to design, fund and install
the outlined options to achieve these color reductions. The TRW recommends up to two
years as a reasonable period of time for implementing these options. In determining the
actual color reduction"limit" to be placed in the permit the recommendations of the Tech
Team Memorandum should form the general basis of that decision. It may be appropriate
to consider the second tier of options identified in item 4 in setting the limitation
applicable to the implementation of the"highest certainty" options.
4. The process improvement options needing further study and identified as having
"reasonable certainty" of success (second stage oxygen delignifrcation on the softwood
fiber line; ozone addition to chlorine dioxide bleaching on the hardwood fiber line)
should be incorporated in the permit/variance as an additional increment of color
reduction to be demonstrated by the Mill. BRP should be required to evaluate the
technologies identified by the Tech Team and to develop an implementation plan that
would either utilize these technologies or identify other options that would result in
similar increments of color reduction. Because the Tech Team could not estimate at this
time with high certainty the color reduction achievable by these options,the _ - -

permit/variance needs to include a mechanism of application similar to that used in the
1997 Permit Agreement. That procedure involves review of a proposed plan from the
Mill, approval of the plan, a schedule for placing selected option(s) into service, a period
of demonstration of the effectiveness of the option(s), followed finally by setting
limitations considering the "target"reduction range but consistent with the actual effluent
color loadings achieved (see paragraph 6). The TRW recommends the option(s) selected
should be installed, operational, and appropriate limits developed within the next permit
term.
5. The potential additional color reduction in treatment of the Chloride Reduction Process
(CRP)purge stream was considered as an option with"lowest certainty" of success.
While this conclusion is supported by the preliminary treatability study already attempted
by BRP to remove color from this waste stream,the TRW recommends that the
permittvariance include requirements that the Mill continue to evaluate all technologies
that might result in significant reduction of this source of color in the Mill's sewers. The
approach here is directed at securing whatever additional reductions are possible based on
any demonstrated technology that works (one potential technology in the Liebergott
report was suggested) and can be economically applied to this color source. Full-scale
implementation of the results of this evaluation should logically follow those options
considered to have higher certainty of success.
6. It should remain the objective of the regulatory agency to monitor, evaluate and apply the
color reduction performance achieved at the Mill from application of pollution prevention
process technologies and BMPs. As the color reduction efforts outlined in the
permit/variance are put into operation at the Mill, the actual performance as measured by
daily effluent color loadings should be statistically evaluated to develop appropriate
limitations for the Mill including a long term average and a revised maximum monthly
average which captures actual variability.. The Division of Water Quality should apply
those limitations under the permit through formal notification.
7. The permit/variance should continue to require BRP to report on or identify any
"breakthrough" color reduction technologies developed at the Mill or that become
available within the industry or the research community.
8. To the extent possible,the TRW recommends to North Carolina that the in-stream
compliance point for color be moved as close to the point of discharge as possible (e.g.,
Fiberville Bridge). This compliance point must be related to the end-of-pipe color
loadings to be achieved by the technologies identified in this recommendation or
alternative technologies identified by the Mill as reflected in limitations included in the
permit/variance. The TRW further recommends that the compliance point ultimately be
moved to the Mill's end-of-pipe discharge point to the Pigeon River, and the format of
the limitations also be reviewed as it relates to capturing effluent variability.
9. The TRW believes it is important for the re-issued permit/variance to require a formal
evaluation by BRP of the Mill's efforts during this cycle (2001-2006) to comply with
North Carolina's water quality standard for color. This evaluation should be an important
part of the reporting requirements of the permit/variance.
10. The role of the TRW should continue through the next permit cycle, the re-issuance
process in 2006, and until the Mill has achieved compliance with North Carolina's in-

stream color standard (a variance is no longer needed). As a "clearinghouse"for the
reports and information submitted by BRP under the reissued permit, the TRW provides
an objective view that is useful to the two States, the parties to the 1997 Permit
Agreement, and other stakeholders. This advisory role is important to fostering the
cooperative completion of the color reduction process at the Mill.
In presenting these recommendations to the Division of Water Quality and the Environmental
Management Commission's NPDES Sub-Committee,the TRW wishes to acknowledge the
excellent success achieved since the 1997 Settlement Agreement and the continued effort of BRP
to improve on this excellent record. The substantial decrease in effluent color since the 1997
Settlement Agreement to the current levels of color observed day to day both at the Canton Mill
and downstream in Tennessee is a testament to the efforts of everyone involved in this process.
While the Canton Mill is among world leaders in the pulp and paper industry as measured by the
quality of its treated effluent,the commitment of the Company and the continued interest and
participation in this process by the regulatory agencies, stakeholder public and environmental
interest groups, and the general public makes additional improvement possible,ultimately
leading to elimination of the variance.
If there are questions concerning this recommendation,please feel free to contact the TRW.
Attachment: Memorandum from EPA Tech Team to the TRW, entitled,Additional Color
Removal Technologies and Their Economic Impacts on Blue Ridge Paper
Products, Canton,NC, dated July 25, 2001

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON,D.C.20460
J�aeo styrFs
t1
MEMORANDUM
DATE: July 25,2001
SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue
Ridge Paper Products, Canton,NC
FROM: EPA Tech Team'
TO: Technology Review Workgroup
Purpose of this Analysis
As required by the 1997 Settlement Agreement, this memorandum presents a summary of an
analysis of available technologies that may be employed to further reduce color discharges from
the Blue Ridge Paper Products, Inc. (Blue Ridge) mill in Canton,NC. The analysis also includes
a summary of the economic impact ("gross margin test") of the cost of implementing identified
color reduction technologies.
Members of the Tech Team visited the Canton mill on March 14, 2001 to observe and gather
information and data on the status of technologies implemented and color discharges at the mill
since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered
from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical
and financial data. This final memorandum is based on the May 4, 2001 preliminary draft
memorandum, and revisions to the July 10, 2001 draft final memorandum,based on a review of
Blue Ridge's comments, the June 8, 2001 Bleach Environmental Process Evaluation and Report
(BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group, Inc,
and additional comments from the Clean Water Fund of North Carolina, and the States of
Tennessee and North Carolina. This memorandum presents to the Technology Review
EPA Tech Team is comprised of--Mark Perez,EPA/EAD; Karrie-Jo Shell,EPA Region 4;Don Anderson,
EPA/EAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,subcontractor to
ERG.

Workgroup (TRW)process improvements evaluated by the Tech Team and considered to be
available technologies and briefly addresses relevant technologies evaluated in the BEPER.
Background and History
Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton,NC, which it
purchased from Champion International Corporation in May 1999. Operations at the mill began
in 1908, but the mill has been extensively modernized, most recently in 1993. The mill currently
operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking,
pulp from each line is further delignifred in single-stage oxygen delignification systems installed
in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence; pine pulp is bleached
with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery
(BFR ) process, developed by Champion. A portion of the hardwood line bleach plant Eo-
stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated
paper including offset, tablet and envelope grades. The mill also produces 281,000 tons per year
of bleached paperboard used for liquid packaging and paper cups, including FDA approved
grades for milk and juice cartons. Since November 2000,pulp production has been reduced by
approximately 30 percent as the result of a major project to upgrade the No. 19 bleached
paperboard machine.
Continued Color Reduction Opportunities Since the 1997 NPDES Permit
The Canton Mill's 1997 NPDES permit included a schedule requiring continued study,
evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge
submitted a series of reports to the NC Department of Environment and Natural Resources,
Division of Water Quality, evaluating the performance of the BFRTTm process, end-of-pipe color
reduction technologies, and practices for minimizing color losses from manufacturing processes.
Since 1997 Blue Ridge has:-
• continued full-scale operation of BFR for the pine line;
• concluded that full-scale BFR is not feasible for the hardwood line, but
implemented partial reuse of a portion of the Eo-stage filtrate as an effective
color-reduction approach;
• identified and implemented several practices for reducing losses of highly-colored
black liquor from manufacturing processes; and
• evaluated 16 end-of-pipe color removal technologies and determined that they
were presently economically and/or technically infeasible for the Canton mill.

Page 3
Process Improvements Analyzed by the Tech Team
The Tech Team identified five mill improvements capable of further reducing the discharge of
color in the mill effluent. For each of these improvements,technical feasibility, capital and
operating costs, and potential color reduction were reviewed. Each improvement can be
implemented independently of the others or in any combination. The costs incurred to
implement the improvements are additive,however separate evaluations are necessary to
accurately estimate the associated color reduction achieved by implementing any combination of -
improvements. End-of-pipe color treatment technologies (e.g., chemically assisted clarification
with sludge dewatering and disposal)typically require initial capital investment and ongoing
operating expenses, not savings, and are likely to incur non-water quality environmental impacts.
For this reason, the Tech Team focused on pollution prevention approaches that offer the
potential to be more cost-effective: color reduction in low flow, highly color-concentrated
wastestreams, through manufacturing process changes or in-process treatment.
The first two process improvements, discussed below(improvements in BFR reliability and leak
and spill prevention and control -Best Management Practices (BMPs)), are improvements which
the Tech Team concludes offer the highest certainty for technical feasibility and color reduction.
Blue Ridge also identified these technologies as feasible color reduction opportunities that will
be implemented, but differed from the color reduction estimates included in this memorandum.
The next two process improvements (ozone addition to an existing chlorine dioxide bleaching
stage on the hardwood fiber line; adding a second stage to the current oxygen delignification
system on the softwood fiber line) also were evaluated by Liebergott, et. al., as feasible color
reduction opportunities. Additional technical evaluation and/or laboratory testing would be
appropriate to reliably determine the technical details of how to incorporate these processes into
the existing fiber lines and to more accurately predict their achievable color reduction, and the
relationship of these technologies to BFR. Additional analyses would be appropriate to
determine the most cost-effective design and the most economically feasible schedule for
implementing one or both of these improvements.
The fifth process improvement, color treatment for the chloride removal process (CRP) purge
stream (one of the two key components of the BFR process), has the potential for additional
color reduction. However, based upon initial bench-scale treatability studies by Blue Ridge,
further study of additional color treatment technologies is necessary. Process optimization on
both the hardwood and softwood fiber lines, as recommended in the BEPER, is anticipated to

Page 4
provide additional color reduction and is identified as the sixth process improvement. It was
concluded that the process optimization option was among those with the highest certainty for
technical feasibility and color reduction.
All color reductions resulting from the mill improvements are estimates based solely on available
data and information. While the Tech Team has concluded that these technologies would reduce
the color discharge from the Canton mill, there is a lack of directly comparable operating
experience with these technologies in other bleached papergrade kraft mills that can be used to
develop precise predictions of the extent of the color reduction benefits.
The BEPER evaluated additional in-process technology options for color discharge reduction
potential, including the implementation of a hot pressurized peroxide-enhanced extraction stage
in both fiber line bleach plants. At this time, the Tech Team does not have sufficient information
to confirm the applicability of this technology at the Canton mill nor relevant data to predict its
potential color discharge reduction capabilities. Therefore,while this memorandum does not
address this technology option, it may be feasible for implementation by Blue Ridge and
contribute to reducing color. In addition, the Tech Team did not analyze nor did the BEPER
recommend a Totally Chlorine-Free (TCF)bleaching option because of the high cost of this
technology and the lack of experience in producing and successfully marketing products made
by Blue Ridge at the Canton mill.
1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal
Process (MRP). Blue Ridge has found that this process element has been more challenging and
expensive to maintain than originally planned. The target BFR recycle rate (percent closure) for
the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and
metallurgy problems (e.g., erosion of multi-media filtration tank lining) in the MRP,however,
the pine line closure has averaged only 74 percent from October 1998 to the present._Blue Ridge
has undertaken improvements to the MRP system in order to maintain the process closure rate
and increase operating time. Improvements include rebuilding piping and valves, and changing
construction materials and metallurgy to better withstand the chemical and physical stress
experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80
percent, annual average final effluent color discharge will be reduced by 1,000 to 1,200 lbs/day.
At this time, the Tech Team has no means of making an alternative quantitative prediction of
final effluent color reduction to compare to the Blue Ridge estimate.

Page 5
2. -Improved black liquor leak&spill collection and control (BMPs). The Canton mill has an
extensive spill recovery system. Sumps in this system, including one sump added in the court
yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped
with pumps that are activated automatically when sensors detect wastewaters with high
conductivity and color. High conductivity material is routed to the recovery system. Further
improvements to the black liquor collection system include:
• continuous improvement of operating practices so more leaks and spills are
recovered rather than discharged to sewer;
• further improvement in preparation for planned outages to maximize capture of
tank clean-out waste and routing to recovery;
• further reducing clean water that continuously runs into sewers to prevent dilution
of smaller spills and facilitate recovery of highly colored wastewaters; and
• further improvement in the equipment used for handling of knots rejects to
prevent black liquor leaks into the recovery sumps.
The plot below shows the color of wastewater treatment influent at the Canton mill. The
variability of influent color discharge to wastewater treatment is attributed to color discharge
peaks that represent, in part, unplanned spills or leaks discharged to sewers or intentional
diversions of highly-colored black liquor or other color sources routed to sewers during mill
equipment shutdowns.
100
kg1t
Figure 1 _
75 Daily color at influent to W WTP for Canton
50
25
0 30 60 90 120 150 180

Page 6
Due to the nature of the manufacturing processes and practical equipment operation and
reliability, all spills and color losses to sewers cannot be fully anticipated, predicted, and
completely contained. However, a comparison of the variability of the Canton mill influent color
data to available primary influent color data at another bleached papergrade kraft mill indicate
that a detailed review of the spill prevention and recovery system at the Canton mill (by mill
staff or external consultants), including involvement by the mill operators, can further uncover
the causes of and better quantify black liquor losses and other color sources that can be avoided
or recovered. This will result in an overall reduction in color discharge, both in long-term
average and variability. Through improved planning of mill equipment shutdowns, continuing
efforts to minimize process operation variability, and increased recovery of highly-colored leaks
and spills, discharges of highly colored material to the wastewater treatment system can be
reduced more consistently below existing levels.
Further reducing peaks in color discharges within the mill and preventing highly colored flows
from reaching the wastewater treatment system will further reduce the variability of color
discharges from the wastewater treatment system to the Pigeon River. For example, limiting the
color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to
improve the mill's BMP system and process operations would reduce the color loadings from
mill processes to the end-of-pipe wastewater treatment system by more than 8,000 lb/day. The
Canton mill operated under this primary clarifier influent color threshold approximately 74
percent of 2000, excluding November through December 2000. This time period was considered
not to be representative of steady-state operations because of the reduced pulp production
resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average
reduction of 45 percent across this wastewater treatment system for"brown" color derived from
black liquor, this would result in a minimum decrease of 4,400 lb/day in the average final
effluent color load.
Clean water, such as packing gland water,presently flows in several sewers with recovery
sumps. These colorless streams dilute other colored wastestreams, such as small black liquor
leaks and spills, to the point where the in-stream conductivity is too low to trigger recovery. By
eliminating clean water streams or diverting them away from sewers that collect black liquor
leaks and spills, wastewater streams with elevated color can be recovered more readily, resulting
in a reduction in color discharge to the end-of-pipe wastewater treatment system. Also,the
unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can
be recovered.

Page 7
At this time, the Tech Team has no basis for determining an accurate correlation between
unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill
Environmental Performance Update presented by Blue Ridge during the March 14, 2001 Tech
Team Canton mill visit. During the March 14 visit, Blue Ridge staff indicated that results of
studies of sewer generated color showed a relationship between bleach plant filtrate pH and
temperature and unaccounted color generated in mill sewers. By operating within the range of
pH and temperatures identified during the studies the Canton mill has had some success in
controlling this source of unaccounted color. Based on this information, the Tech Team
concludes that by further reducing process operation variability, including operating within the
pH and temperature range identified during the studies, the mill can continue to also minimize
sewer generated color, thereby reducing one source of unaccounted color. Reducing overall
color discharges through BMPs and other management practices will likely further reduce
remaining unaccounted color. However, additional studies are necessary to further develop any
relationship between accounted and unaccounted color sources.
As noted above, analysis of primary clarifier influent color loading data demonstrates that color
loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during
steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and
intentional discharges of colored streams and continuing efforts to minimize process operation
variability, the Canton mill can achieve further reduced primary clarifier influent color loads and
subsequent final effluent color discharge within this range on a more consistent basis than
demonstrated in 2000 (i.e., more than 74 percent of the time). On this basis, the Tech Team
concluded it is feasible to reduce final effluent color by more than 5,000 lbs/day through
improved black liquor leak and spill collection and control.
3. Ozone/Chlorine dioxide stage for hardwood bleach line. Ozone is used in more than ten kraft
mills around the world to bleach pulp, including two in the US and one in Canada. There are
several process configurations, but the most common is to operate an ozone (Z)mixer and
reactor immediately upstream of a chlorine dioxide reactor,without any washing between the
application of the two chemicals. This is known as a"ZD" stage. A system of this type was
retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999 2 Bleaching with ozone on
the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 27 percent reduction in
the discharge of color in the combined mill treated effluent 3 The conversion to a ZD stage
2 Munro,Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching Sequence,Tappi,2000.
3 Ibid.

Page 8
would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for
ozone. The energy requirements for ozone production would be offset by the energy savings
from less chlorine dioxide and caustic production, resulting in a net reduction in energy
consumption with the ZD stage.
As of September 2000, the long-term average color discharge from Canton's hardwood bleach
line was 12,800 pounds/day 4. The Espanola experience suggests that implementation of a ZD
stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by
3,000 to 6,400 lbs/day. Based on comments received,the Tech Team acknowledges that
operating parameters, such as wood species processed and technology supplier performance
guarantees, may influence the practical color reduction achievable through implementation of a
ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are
based solely on the demonstrated performance and the Tech Team's assumption of color sources
at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada
(PAPTAC) meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible
communication between Blue Ridge and Domtar staff would be necessary to reliably predict the
achievable color reduction possible with this option for the Canton mill.
The technical evaluation of this process improvement included in the BEPER yielded a
hardwood filtrate color discharge reduction within the range of Tech Team estimates.
4 2"d stage OD for pine line. Oxygen delignification(OD) on the Canton Mill pine line is a
single stage system installed in 1993. It has been concluded that retrofitting a second OD stage
for the pine line could contribute to reduced color discharges in two ways. The first would be a
reduction in color for those filtrates presently not captured and reused in the BFR process. The
second would be a color reduction in the Chloride Removal Process (CRP) purge stream as a
result of less chloride from chlorine dioxide used for bleaching. _
Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed
upstream of the existing reactor. Previously, the Tech Team anticipated increasing the kappa
number(lignin content) of the cooked pulp from 24 to 32 and utilizing a two-stage OD system to
reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two-
stage system. Based upon comments from BRP and further technical analysis, and review of the
BEPER, it was concluded that it is technically feasible for a two-stage OD system at the Canton
4 Jacobs Engineering Group,2001 Color Removal Technology Assessment,February 2001.

Page 9
mill to achieve an overall reduction of 50 percent in kappa number, rather than 65 percent as
previously anticipated. Therefore,with the Canton mill continuing to pulp to a kappa number of
24,the new two-stage OD system would reduce pulp kappa number into the bleach plant from
the current output of 16 to about 12, corresponding to a 50 percent kappa number reduction from
the current digester output of 24. The quantity of color released from the bleach plant will be
reduced in proportion to the reduction of the input kappa number.
By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a
two-stage OD system,the quantity of chemicals required in the first two stages of the bleach
plant can be reduced, because there is less lignin present in the incoming pulp to remove by
bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional
reduction in chloride load to the CRP and reduce color discharged from the purge stream in
proportion to the reduction in chloride being treated.
In response to comments received, it has been concluded that implementing a two-stage OD
system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve
a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving
greater delignification with the proposed two-stage OD system. However, operating a two-stage
OD system with a higher than 50 percent delignification rate and a digester kappa number higher
than currently employed at the Canton mill is commonly seen at comparable bleached
papergrade kraft mills. Therefore, the Tech Team anticipates that additional process engineering
will maximize the benefits of a two-stage OD system at the Canton mill and enable the mill to
capture the increased delignifcation and yield gain potential of this technology and achieve
annual wood cost savings of up to approximate $950,000 from up to a 1.5 percent yield increase
across the proposed two-stage OD system.
Based on additional information supplied by Blue Ridge regarding operational limitations of the _
BFR system, the Tech Team concludes that a two-stage OD system would not have a significant
impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on
a day-to-day basis.
For this analysis, it was estimated preliminarily that a second OD stage could reduce total
influent color discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from
reductions in pine line bleach plant filtrate color and CRP purge stream color.

Page 10
The technical evaluation of two-stage OD included in the BEPER yielded reduction in color
discharge influent to the wastewater treatment system within the range of the Tech Team
estimates.
5. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP)purge is a low
flow, highly concentrated waste stream. Color is typically 50,000 pcu, in a 10 gpm (0.01 MGD)
flow. The CRP purge contributes up to approximately 5,000 lbs/day (13 percent) to the total mill
loading to the wastewater treatment system influent, but only 0.06 percent of the discharge flow.
It was originally speculated that it may be feasible to reduce the color in this stream by
precipitating the colored organic material with lime at a dosage of 20 g/Ls, and burning the
resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials
would be necessary to test the feasibility of color removal from the CRP purge stream by lime
treatment.
Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium
compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The
preliminary results of these trials show that at a dosage of 20 g/L, none of the compounds tested
reduced color in the CRP purge stream. Although color removal was demonstrated at higher
dosage rates, increased chemical usage would result in substantially higher operating costs,
require larger sized equipment at higher capital cost, and also result in a higher production rate of
sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not
burned must be landfilled at additional cost.
Based on preliminary laboratory trials, Blue Ridge concluded that lime treatment of the CRP
purge is not a feasible color reduction option for the Canton mill. However, the Tech Team
recommends additional review of other innovative technologies for treatment of color in the CRP -
purge stream, such as the application of the X-Filter process recently implemented at a totally
chlorine free (TCF) mi116. By minimizing color contributions from this stream, the potential
exists to achieve a significant reduction in primary influent color discharge of up to 5,000
lbs/day.
s NCASI Technical Bulleting No.239,The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching
Effluents with Lime.I. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970.
6 Comments on the Draft Report on Additional Color Removal Technologies and Economic Impacts for BRPP,Hope
Taylor,Clean Water Fund of North Carolina,July 18,2001

Page 11
6. Process Optimization. The BEPER identified sixteen recommendations for optimizing the
hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching
operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the
first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood
line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction
of up to 700 lbs/day from the hardwood line and up to 400 lbs/day from the softwood line. The
Tech Team estimated an additional color reduction from the CRP purge stream of 600 lbs/day
resulting from the decreased chlorine dioxide usage. At this time,the Tech Team has no means
of making an alternative quantitative prediction of bleach filtrate color reduction to compare to
estimates presented in the BEPER. Therefore, it is estimated that through efforts by mill staff to
maximize the color reduction benefits from the process optimization opportunities identified by
Liebergott, et, al., the Canton mill would achieve a total color reduction of 1,700 lbs/day in
wastewater treatment system influent.
Color Reduction Summary
The Tech Team estimates that by improving BFR reliability and black liquor leak and spill
collection and control, the Canton mill final effluent will be reduced by more than 5,000 lbs/day.
Process optimization, as outlined in the BEPER, would result in a further final effluent color
reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45
percent across the existing wastewater treatment for the CRP purge stream and other "brown"
color sources derived from black liquor and no reduction in color from bleach plant filtrates.
Table 1 presents a summary of the estimated reductions in final effluent color attainable with the
highest certainty by implementing improved BFR reliability, improved BMPs, and process
optimization.

Page 12
Table 1: Summary of Process Improvements and Associated Color Reductions
(Highest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
1 BFR reliability improvement --- 1,000-1,200
2 Improved black liquor leak& spill collection and --- > 5,000
control
6 Process Optimization 1,700 1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION >7,400
Additional potential mill improvements to reduce color discharge at the Canton mill were also
identified. These process improvements require further study to more accurately determine
achievable color reduction and thus are not recommended at this time for immediate
implementation. These improvements include a ZD stage in the hardwood bleach plant, with a
preliminary estimate of a 3,000*to 6,400 lbs/day color load reduction in influent to the
wastewater treatment system, and a second OD stage for the pine line, with a preliminary
estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment
system. Table 2 presents a summary of preliminary estimates of color reductions for these two
additional process improvements that need further study. Reductions presented in Table 2 are
preliminary estimates with reduced certainty compared to those presented in Table 1, but are
based upon identified technology options available for the Canton mill.

Page 13
Table 2: Summary of Process Improvements and Associated Additional Color Reductions
Needing Further Study (Reasonable Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (Ibs/day)
3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400
line
4 2"d stage OD for pine line 1,500-2,000 1,100-1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 - 7,800
Table 3 presents a preliminary estimate of color reduction potential for the removal of color from
the CRP purge stream. The Tech Team recommends this stream for additional review of
potential color reduction technologies but cannot identify a particular technology option at this
time. Potential for additional color load reduction up to 2,750 lbs/day in final effluent to the
Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty.
Table 3: Summary of Additional Potential Color Reductions Needing Further Study
(Lowest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (Ibs/day)
5 1 Color Treatment of CRP Purge Stream #5,000 #2,750
TOTAL ADDITIONAL POTENTIAL FINAL EFFLUENT COLOR - #2,750
REDUCTION

Page 14
Economic Analysis
The estimated capital and operating costs for the process improvements one through four were
estimated and are summarized below. Costs could not be developed at this time for process
optimization or CRP treatment and thus are not presented. However, costs for these
improvements should be modest.
Table 3: Estimated Costs
Process Improvement Capital Cost Annual O&M
($) ($/year)
1 BFR reliability improvement $1,300,000 $85,000,
2 Improved black liquor leak& spill collection and $100,000 $50,000
control
3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000)
line savings
4 2"d stage OD for pine line $2,000,000 ($2,100,000)
savings
Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven
plants (including the Canton Mill) from Champion International Corporation. Blue Ridge Paper
Products is owned 55 percent by KPS Special Situations Fund, L.P. and 45 percent by the
employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the
1997 report EPA documented substantial losses over five years for the Canton Mill and
Champion had just announced its intention to sell or close the mill. However, because of the sale
of the mill to the Blue Ridge, the previous data are not comparable to the more recent data.
Further, the data submitted by Blue Ridge is still confidential, so this report cannot present as -
much detail as the 1997 report.
The current analysis is based on information submitted by Blue Ridge covering part of
1999 (May-December) and all of 2000 (all of the existing financial data for the company). The
results may be relatively uncertain because of the lack of data and the company may be too
young for the current data to reflect its ultimate financial health. EPA used three measures of
financial health (gross profit test, discounted cash flow, and Altman's Z)7 to assess the impact of
See Interim Economic Guidance for Water Quality Standards: Workbook, EPA 823-B-95-002,March 1995,and
Economic Analysis for the National Emission Standards for Hazardous Air Pollutants for Source Category:Pulp and
Paper Production;Effluent Limitations Guidelines,Pretreatment Standards, and New Source Performance
Standards:Pulp,Paper,and Paperboard Category—Phase 1.

Page 15
air emissions control technologies and devices (not addressed in this memorandum, such as
MACT II and regional NOX control) and wastewater compliance costs (separate and combined)
on the mill and company. The costs for the wastewater control options presented in Table 3 do
not change the financial status of the mill or company. However, the costs for some of the air
emissions control options do impact the health of one or both entities. When the wastewater
costs are added to costs for air emissions control, the impacts of the water costs do not change
the financial status of either the mill or company when compared to the impact of the air costs
alone.
References
Blue Ridge Paper Products, Inc. Canton Mill Canton Mill Environmental Performance Update,
Prepared for U.S. EPA Technology Review Workgroup. March 14, 2001.
Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic
Analysis of Blue Ridge Paper Products, from Bob Williams, May 18, 2001 (CBITS 00003911-
01)
Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown, Blue Ridge,
to Don Anderson, EPA, May 18, 2001
Comment Clarification of May 18, 2001 Blue Ridge Responses to EPA Questions, from Derric
Brown, Blue Ridge, June 4, 2001
Comments on Draft Final Tech Team Report, from Bob Williams, Blue Ridge, to Don Anderson,
EPA, July 13, 2001 _
Comments on Draft Final Tech Team Report, from Derric Brown, Blue Ridge, to Don Anderson,
EPA, July 17, 2001
Comments on Draft Final Report, email from Forrest Westall,North Carolina DENR, to Don
Anderson, EPA, July 17, 2001
Comments on Draft Final Report on Additional Color Removal Technologies and Economic
Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001

Comment on Draft Final Tech Team Report, email from Paul Davis, State of Tennessee, to Don
Anderson, July18, 2001
Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott, to
Don Anderson, EPA, July 19, 2001
Jacobs Engineering Group, 2001 Color Removal Technology Assessment,Blue Ridge Paper
Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001.
Liebergott,Norm, and Lew Shackford, Bleach Environmental Process Evaluation and Report,
June 8, 2001
McCord, Aimee,A Laboratory Analysis of Color removal Across a Pulp and Paper Mill
Wastewater Treatment Facility, Canton, North Carolina, Duke University, School of the
Environment, 1995
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.
NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of
Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching
Effluent. July, 1970.
Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater
Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina, Duke University, School
of the Environment, 1996
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry. Page 182
Wiley Interscience, 1986.
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry, 3'd edition.
Page 286. TAPPI Press, 2000.

Appendix 1: Color Balance (9/l/00 to 12/31/00)
Figure 2.6,Presented by Blue Ridge on March 14, 2001
Sewer Description Color Load
ID (!bs/day)
2B Digester area sewer: Digesters, HW 4,323
line, knot rejects
3A Alkaline sewer: Pine and HW Eo, 12,954
Pine line BSW, 02 Delig
1 PMs11 & 12,HW weak liquor tank 1,991
5B Recovery, BLOx, CRP* 7,852
6A Acid sewer: Pine and HW D1 17,345
filtrate +Pine D2 filtrate
Contaminated Condensate 1,591
Combined Condensate 260
Total 46,316
Primary Influent (PI) 49,284**
Unaccounted Color Z968
(PI minus Total)
Secondary Effluent 37,696
Percent Removal in Treatment 23 %
* CRP contributes 5,000 to 6,000 lbs/day to 5B sewer
** Measured using test method in NCASI Tech. Bull. 803, An Update of Procedures for the
Measurement of Color in Pulp Mill Wastewaters, May 2000.

Appendix 2: Table of Effluent Color Limits, 1997 to Present
Color Limit True Color (Ibs/day)
Monthly Average Annual (Long-term)
Average
1997 Permit 125,434 98,168
Settlement Agreement, February 1998 69,000 60,000
(starting December 1, 1998)
Settlement Agreement,February 1998 --- 48,000 to 52,000
(Ultimate Target)
Interim Limits, May 2001* 55,000 48,000**
* As recommended by Technology Review Workgroup (TRW) and incorporated by NC in
BRP's NPDES permit.
** Reduced end-of-pipe color discharges since November 2000 reflect, in part, reduced pulp
production (approximately 30 percent) during this period because of the ongoing project to
upgrade the No. 19 paper machine used to produce bleached paperboard.

Appendix 3: Ozone Bleaching
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.

Appendix 4: Two-Stage Oxygen Delignification
Comparison of one- and two-stage oxygen delignification systems
Item Current Single-Stage System Proposed Two-Stage System
Oxygen Reactors One two
Input Kappa Number 24 24
Output Kappa Number 16 12
Total C102 Used 28 kg/ton* 22 kg/ton*
Oxygen Used 23.4 kg/ton* 28.3 kg/ton*
Total NaOH Used 45 kg/ton* 37 kg/ton*
* air-dried metric ton of bleached pulp

sy C�`
PUBLIC NOTICE
` 9j ;j STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
.1617 Mail Service Center, Raleigh, NC 27699-1617
NOTIFICATION OF INTENT TO ISSUE A STATE NPDES PERMIT
On the basis of thorough staff review and application of Article 21 of Chapter 143,General Statutes of
North Carolina,Public Law 92-500 and other lawful standards and regulations,the North Carolina
Environmental Management Commission proposes to issue a permit to discharge to persons listed below on
January 7,2000,and subject to special conditions.
Persons wishing to comment upon or object to the proposed determinations are invited to submit same in
writing to the above address no later than January 17,2000. All comments received prior to that date will
be considered in the formulation of final determinations regarding the proposed permit. A public meeting
may be held where the Director of the Division of Water Quality finds a significant degree of public
interest in a proposed permit.
A copy of the draft permit is available by writing or calling the Division of Water Quality, 1617 Mail
Service Center,Raleigh,North Carolina 27699-1617,[phone].
The application and other information may be inspected at these locations during normal office hours.
Copies of the information on file are available upon request and payment of the costs of reproduction. All
such comments or requests regarding a proposed permit sho Id be make reference to the NPDES permit
number listed below. /
Date / 1 &%
r Kerr T. Stevens,Director
/V� I Division of Water Quality
NPDES No.NCS000105
Blue Ridge Paper Products,Inc.,P. O.Box 4000,Canton,NC 28716 has applied for a permit to discharge
stormwater associated with industrial activities at a facility located at Blue Ridge Paper Products,Inc.,
Canton Mill,Canton,Haywood County. The facility discharges to the waters of the French Broad River
Basin.

NCS000105
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE STORMWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELRYUNATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollutio ,Cpjftrol Act, as amended,
Blue Ridge Paper foduec
is herebyauthorized to discharge t
g s ormwater from a�tf' 1`i located at
Blue Ridge Paper Qede t rpy c. Canton Mill
toss'
d , unty
to receiving waters designated t9 n r,Bowen Branch, and Beaverdam Creek, class C
streams,in the French Broad ei as
in accordance with the disch rge imi ons, monitoring requirements, and other conditions set
forth in Parts I,11,III, IV, nd V, ereof.
This permit shall become effecMarch 1,2000.
This permit and the authorization to discharge shall expire at midnight on February 28, 2005.
Signed this day January 21, 2000.
for Kerr T. Stevens, Director
Division of Water Quality
By the Authority of the Environmental Management Commission

Permit No.NCS000105
TABLE OF CONTENTS
PART I INTRODUCTION
Section A: Individual Permit Coverage
Section B: Permitted Activities
Section C: Location Map
PART 11 MONITORING, CONTROLS,AND LIMITATIONS FOR PERMITTED
DISCHARGES
Section A: Stormwater Pollution Prevention Plan
Section B: Analytical Monitoring Requirements
Section C: Qualitative Monitoring Requirements
Section D: On-Site Vehicle Maintenance Monitoring Requirements
PART III STANDARD CONDITIONS
Section A: Compliance and Liability
1. Compliance Schedule
2. Duty to Comply
3. Duty to Mitigate
4. Civil and Criminal Liability
5. Oil and Hazardous Substance Liability
6. Property Rights
7. Severability
8. Duty to Provide Information
9. Penalties for Tampering
10. Penalties for Falsification of Reports
Section B: General Conditions
1. Individual Permit Expiration
2. Transfers
i

Pemvt No.NCS000105
3. Signatory Requirements
4. Individual Permit Modification, Revocation and Reissuance, or
Termination
5. Permit Actions
Section C: Operation and Maintenance of Pollution Controls
1. Proper Operation and Maintenance
2. Need to Halt or Reduce Not a Defense
3. Bypassing of Stormwater Control Facilities
Section D: Monitoring and Records
1. Representative Sampling
2. Recording Results
3. Flow Measurements
4. Test Procedures
5. Representative Outfall
6. Records Retention
7. Inspection and Entry
Section E: Reporting Requirements
1. Discharge Monitoring Reports
2. Submitting Reports
3. Availability of Reports
4. Non-Stormwater Discharges
5. Planned Changes
6. Anticipated Noncompliance
7. Bypass
8. Twenty-four Hour Reporting
9. Other Noncompliance
10. Other Information
PART IV LIMITATIONS REOPENER
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
PART VI DEFINITIONS
ii

Permit No.NCS000105
PART I INTRODUCTION
SECTION A: INDIVIDUAL PERMIT COVERAGE
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater associated with industrial activity. Such
discharges shall be controlled, limited and monitored as specified in this permit.
SECTION B: PERNIITTED ACTIVITIES
Until this permit expires or is modified or revoked, the permittee is authorized to discharge
stormwater to the surface waters of North Carolina or separate storm sewer system which has
been adequately treated and managed in accordance with the terms and conditions of this
individual permit. All discharges shall be in accordance with the conditions of this permit.
Any other point source discharge to surface waters of the state is prohibited unless it is an
allowable non-stonnwater discharge or is covered by another permit, authorization or approval.
This permit does not relieve the permittee from responsibility for compliance with any other
applicable federal, state, or local law,rule, standard, ordinance, order,judgment, or decree.
Part I Page 1 of 2

Permit No.NCS000105
SECT�IION C: LOCATION MAP
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tom:
Part I Page 2 of 2

Permit No.NCS000105
PART II MONITORING, CONTROLS, AND LIMITATIONS FOR
PERMITTED DISCHARGES
SECTION A: STORMWATER POLLUTION PREVENTION PLAN
The permittee shall develop a Stormwater Pollution Prevention Plan, herein after referred to as
the Plan. This Plan shall be considered public information in accordance with Part III, Standard
Conditions, Section E, Paragraph 3 of this individual permit. The Plan shall include, at a
minimum, the following items:
1. Site Plan. The site plan shall provide a description of the physical facility and the
potential pollutant sources which may be expected to contribute to contamination of
stormwater discharges. The site plan shall contain the following:
(a) A general location map (USGS quadrangle map or appropriately drafted
equivalent map), showing the facility's location in relation to transportation
routes and surface waters,the name of the receiving water(s)to which the
stormwater outfall(s) discharges, or if the discharge is to a municipal separate
storm sewer system,the name of the municipality and the ultimate receiving
waters; and accurate latitude and longitude of the point(s) of discharge.
(b) A narrative description of storage practices, loading and unloading activities,
outdoor process areas, dust or particulate generating or control processes, and
waste disposal practices.
(c) A site map drawn to scale with the distance legend indicating location of
industrial activities (including storage of materials,disposal areas, process areas
and loading and unloading areas), drainage structures, drainage areas for each
outfall and activities occurring in the drainage area, building locations, existing
BMPs and impervious surfaces, and the percentage of each drainage area that is
impervious.For each outfall, a narrative description of the potential pollutants
which could be expected to be present in the stormwater discharge.
(d) A list of significant spills or leaks of pollutants that have occurred at the facility
during the 3 previous years and any corrective actions taken to mitigate spill
impacts.
(e) Certification that the stormwater outfalls have been evaluated for the presence of
non-stormwater discharges. The certification statement will be signed in
accordance with the requirements found in Part III, Standard Conditions, Section
B, Paragraph 3.
2. Stormwater Management Plan. The stormwater management plan shall contain a
narrative description of the materials management practices employed which control or
minimize the exposure of significant materials to stormwater, including structural and
Part II Page 1 of 6

Permit No.NCS000105
nonstructural measures. The storrwater management plan, at a minimum, shall
incorporate the following:
(a) Feasibility Study. A review of the technical and economic feasibility of changing
the methods of operations and/or storage practices to eliminate or reduce exposure
of materials and processes to stormwater. Wherever practical, the permittee shall
prevent exposure of all storage areas,material handling operations, and
manufacturing or fueling operations. In areas where elimination of exposure is
not practical,the stormwater management plan shall document the feasibility of
diverting the stormwater runoff away from areas of potential contamination.
(b) Secondary Containment Schedule. A schedule to provide secondary containment
for bulk storage of liquid materials, storage of Section 313 of Title III of the
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals, or storage of hazardous substances to prevent leaks and spills from
contaminating stormwater runoff. If the secondary containment devices are
connected directly to stormwater conveyance systems,the connection shall be
controlled by manually activated valves or other similar devices [which shall be
secured with a locking mechanism] and any stormwater that accumulates in the
containment area shall be at a minimum visually observed for color, foam, outfall
staining, visible sheens and dry weather flow,prior to release of the accumulated
stormwater. Accumulated stormwater shall be released if found to be
uncontaminated by the material stored within the containment area. Records
documenting the individual making the observation, the description of the
accumulated stormwater and the date and time of the release shall be kept for a
period of five years.
(c) BMP Summary. A narrative description shall be provided of Best Management
Practices (BMPs)to be considered such as, but not limited to, oil and grease
separation, debris control,vegetative filter strips, infiltration and stormwater
detention or retention,where necessary. The need for structural BMPs shall be
based on the assessment of potential of sources to contribute significant quantities
of pollutants to stormwater discharges and data collected through monitoring of
stormwater discharges.
3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP)
shall incorporate an assessment of potential pollutant sources based on a materials
inventory of the facility. Facility personnel (or team) responsible for implementing the
SPRP shall be identified. A responsible person shall be on-site at all times during facility
operations that have the potential to contaminate stormwater runoff through spills or
exposure of materials associated with the facility operations. The SPRP must be site
stormwater specific. Therefore,a SPCC plan may be a component of the SPRP,but may
not be sufficient to completely address the stormwater aspects of the SPRP. The common
elements of the SPCC with the SPRP may be incorporated by reference into the SPRP.
4. Preventative Maintenance and Good Housekeeping Program. A preventative
maintenance program shall be developed. The program shall document schedules of
inspections and maintenance activities of stormwater control systems, plant equipment
Part 11 Page 2 of 6

Permit No.NCS000105
and systems. Inspection of material handling areas and regular cleaning schedules of
these areas shall be incorporated into the program.
5. Employee Training. Training schedules shall be developed and training provided at a
minimum on an annual basis on proper spill response and cleanup procedures and
preventative maintenance activities for all personnel involved in any of the facility's
operations that have the potential to contaminate stormwater runoff. Facility personnel
(or team) responsible for implementing the training shall be identified.
6. Responsible Party. The Stormwater Pollution Prevention Plan shall identify a specific
position(s)responsible for the overall coordination, development, implementation, and
revision to the Plan. Responsibilities for all components of the Plan shall be documented
and position assignments provided.
7. Plan Amendment. The permittee shall amend the Plan whenever there is a change in
design, construction,operation, or maintenance which has a significant effect on the
potential for the discharge of pollutants to surface waters. The Stormwater Pollution
Prevention Plan shall be reviewed and updated on an annual basis.
The Director may notify the permittee when the Plan does not meet one or more of the
minimum requirements of the permit. Within 30 days of such notice, the permittee shall
submit a time schedule to the Director for modifying the Plan to meet minimum
requirements. The permittee shall provide certification in writing (in accordance with
Part III, Standard Conditions, Section B, Paragraph 3) to the Director that the changes
have been made.
8. Facility Inspection Program. Facilities are required to inspect all stormwater systems on
at least a semiannual schedule, once in the fall (September-November) and once in the
spring (April -June). The inspection and any subsequent maintenance activities
performed shall be documented,recording date and time of inspection,individual(s)
making the inspection and a narrative description of the facility's stormwater control
systems, plant equipment and systems. Records of these inspections shall be
incorporated into the Stormwater Pollution Prevention Plan.
Stormwater discharge characteristic monitoring as required in Part II of this permit shall
be performed in addition to facility inspections.
9. Implementation. The permittee shall document all monitoring, measurements,
inspections and maintenance activities and training provided to employees, including the
log of the sampling data and of activities taken to implement BMPs associated with the
industrial activities,including vehicle maintenance activities. Such documentation shall
be kept on-site for a period of five years and made available to the Director or his
authorized representative immediately upon request.
Part II Page 3 of 6

Permit No.NCS000105
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
pemmittee is authorized to discharge stormwater subject to the provisions of this permit.
Analytical monitoring of stormwater discharges shall be performed as specified below in Table
1.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 4 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO). The permittee shall complete the
minimum 4 analytical samplings in accordance with the schedule specified below in Table 2.
Table 1. Analytical Monitoring Requirements
r�� 4 e 4 �'wY g} aNy, '¢ Y 4:kse wv+
SChai' e n t° t 4°' `� �f.`�' ti�"�ya$l�rbl;� � 11 �l' yi�XYdtr1
fW^ ,*yH 4}Y 1'•r' t¢ �`F v�" 3l' �31{'
e'1„��t �`�h��actertsftcs r •��,_;� 4 ,Untts<5� i��]�equehcy�� „� f .$'I;�pe2 ,1��, �s � catlon3�t
Total Suspended Solids mg/1 Quarterly-r year Grab SDO
Fecal Coliform4 mg/1 Quarterly-a year Grab SDO
BOD 5 mg/1 Quarterly-4i°year Grab SDO
Total Rainfa116 inches Quarterly-*'year
Event Duration6 minutes Quarterly-4i°year
Total Flow6 MG Quarterly-a year _ SDO
Footnotes:
I Measurement Frequency: Once per quarter during the a year of the permit term. A year is defined as the 12
month period beginning on the month and day of issuance of the Permit.See Table 2 for schedule of monitoring
periods.
2 If the stormwater runoff is controlled by a stormwater detention pond,a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm,then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Sampling is required only at Outfalls 1,2,3,4,5,6,7,8,9,6-4,and 6-10
4 Fecal Coliform sampling is only required for outfalls 1,2,and 3.
5 BOD,sampling is only required for outfall 3.
6 For each sampled representative storm event the total precipitation,storm duration,and total flow must be
monitored. Total flow shall be either;(a)measured continuously,(b)calculated based on the amount of area
draining to the outfall,the amount of built-upon(impervious)area,and the total amount of rainfall,or(c)
estimated by the measurement of flow at 20 minute intervals during the rainfall event.
Part II Page 4 of 6

Permit No.NCS000105
Table 2 Monitoring schedule
b4
Year 4- 1"quarter 1 March 1, 2003 May 31, 2003
Year 4 -2"quarter 2 June 1, 2003 August 31, 2003
Year 4 -3" quarter 3 September 1, 2003 November 30, 2003
Year 4 -4"quarter 4 December 1, 2003 February 29, 2004
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status and shall be performed as specified below in Table 3. Qualitative
monitoring is for the purpose of evaluating the effectiveness of the Storruwater Pollution
Prevention Plan (SPPP) and assessing new sources of stormwater pollution. No analytical tests
are required. Qualitative monitoring of stormwater outfalls does not need to be performed during
a representative storm event.
In the event an atypical condition is noted at a stormwater discharge outfall, the Permittee shall
document the suspected cause of the condition and any actions taken in response to the
discovery. This documentation will be maintained with the Stormwater Pollution Prevention
Plan.
All qualitative monitoring will be performed twice per year, once in the spring (April -June) and
once in the fall (September-November).
Table 3. Qualitative Monitoring Requirements
ffi�KV 6,C fi#k,;fejjstla5
'A
,le
Color Semi-Annual SDO
Odor Semi-Annual SDO
Clarity Semi-Annual SDO
Floating Solids Semi-Annual SDO
Suspended Solids Semi-Annual SDO
Foam Semi-Annual SDO
Oil Sheen Semi-Annual SDO
Other obvious indicators Semi-Annual SDO
of stormwater pollution
Footnotes:
Monitoring Location: Qualitative monitoring shall be performed at each stormwater discharge outfall(SDO)
regardless of representative outfall status.
Part Il Page 5 of 6

Permit No.NCS000105
SECTION D: ON-SITE VEHICLE MAINTENANCE MONITORING REQUIREMENTS
Facilities which have any vehicle maintenance activity occurring on-site which uses more than
55 gallons of new motor oil per month when averaged over the calendar year shall perform
analytical monitoring as specified below in Table 4. This monitoring shall be performed at all
outfalls which discharge stormwater runoff from vehicle maintenance areas.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 4 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO)which discharges stormwater runoff from
vehicle maintenance areas. The permittee shall complete the minimum 4analytical samplings in
accordance with the schedule specified in Table 2 (Part II, Section B).
Table 4. Analytical Monitoring Requirements for On-Site Vehicle Maintenance
aYkV .Sd@Yi+fir.M9^
lirseh iFttaracter�stres , Clint 'LIeasureme Sam le' t am �ri
�� "����r
rtS mr�--Ti� L" y v rz+z fE
H standard Quarterly-0 year Grab SDO
Oil and Grease m Quarterly-4m year Grab SDO
Total suspended Solids m Quarterly-4'year Grab SDO
New Motor Oil Usagegallons/month I Quarterly-0 year Estimate -
Total Flow4 MG Quarterly-4'year Grab SDO
Footnotes:
I Measurement Frequency: Once per quarter during the r year of the permit term. A year is defined as the 12
month period beginning on the month and day of issuance of the Permit. See Table 2 for schedule of monitoring
periods.
2 If the stormwater runoff is controlled by a stonnwater detention pond,a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm,then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) that discharges
stormwater runoff from area(s)where vehicle maintenance activities occur.
4 Total flow shall be;(a)measured continuously,(b)calculated based on the amount of area draining to the outfall,
the amount of built-upon(impervious)area,and the total amount of rainfall,or(c)estimated by the measurement
of flow at 20 minute intervals during the rainfall event. Total precipitation and duration of the rainfall event
measured shall result from the sampled representative storm event.
Part lI Page 6 of 6

Permit No.NCSOOO105
PART III STANDARD CONDITIONS FOR NPDES STORMWATER INDIVIDUAL
PERMITS
SECTION A: COMPLIANCE AND LIABILITY
1. Compliance Schedule
The permittee shall comply with Limitations and Controls specified for stormwater
discharges in accordance with the following schedule:
Existing Facilities: The Stormwater Pollution Prevention Plan shall be developed and
implemented within 12 months of the effective date of the initial permit and updated
thereafter on an annual basis. Secondary containment, as specified in Part 11, Section A,
Paragraph 2(b)of this permit, shall be accomplished within 12 months of the effective
date of the initial permit issuance.
Proposed Facilities: The Stormwater Pollution Prevention Plan shall be developed and
implemented prior to the beginning of discharges from the operation of the industrial
activity and be updated thereafter on an annual basis. Secondary containment, as
specified in Part 11, Section A,Paragraph 2(b) of this permit shall be accomplished prior
to the beginning of discharges from the operation of the industrial activity.
2. Duty to Comply
The permittee must comply with all conditions of this individual permit. Any permit
noncompliance constitutes a violation of the Clean Water Act and is grounds for
enforcement action; for permit termination, revocation and reissuance, or modification; or
denial of a permit upon renewal application.
a. The permittee shall comply with standards or prohibitions established under
section 307(a) of the Clean Water Act for toxic pollutants within the time
provided in the regulations that establish these standards or prohibitions, even if
the permit has not yet been modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates a permit condition is
subject to a civil penalty not to exceed$25,000 per day for each violation. Any
person who negligently violates any permit condition is subject to criminal
penalties of$2,500 to $25,000 per day of violation,or imprisonment for not more
than 1 year, or both. Any person who knowingly violates permit conditions is
subject to criminal penalties of$5,000 to $50,000 per day of violation, or
imprisonment for not more than 3 years, or both. Also, any person who violates a
permit condition may be assessed an administrative penalty not to exceed$10,000
per violation with the maximum amount not to exceed$125,000. [Ref: Section
309 of the Federal Act 33 USC 1319 and 40 CFR 122.41(a).]
Part III Page 1 of 10 Pages

Permit No.NCS000105
C. Under state law, a daily civil penalty of not more than ten thousand dollars
($10,000)per violation may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of a permit. [Ref:
North Carolina General Statutes 143-215.6A]
d. Any person may be assessed an administrative penalty by the Director for
violating section 301, 302,306, 307, 308, 318, or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act. Administrative penalties for Class I violations are not to
exceed$10,000 per violation, with the maximum amount of any Class I penalty
assessed not to exceed$25,000. Penalties for Class 11 violations are not to exceed
$10,000 per day for each day during which the violation continues, with the
maximum amount of any Class II penalty not to exceed$125,000.
3. Duty to NEtigate
The permittee shall take all reasonable steps to minimize or prevent any discharge in
violation of this individual permit which has a reasonable likelihood of adversely
affecting human health or the environment.
4. Civil and Criminal Liability
Except as provided in Part III,Section C of this permit regarding bypassing of stotmwater
control facilities,nothing in this individual permit shall be construed to relieve the
permittee from any responsibilities, liabilities, or penalties for noncompliance pursuant to
NCGS 143-215.3,143-215.6A, 143-215.613, 143-215.6C or Section 309 of the Federal Act,
33 USC 1319. Furthermore, the permittee is responsible for consequential damages, such
as fish kills, even though the responsibility for effective compliance may be temporarily
suspended.
5. Oil and Hazardous Substance Liability
Nothing in this individual permit shall be construed to preclude the institution of any
legal action or relieve the permittee from any responsibilities, liabilities, or penalties to
which the permittee is or may be subject to under NCGS 143-215.75 et seq. or Section 311
of the Federal Act, 33 USC 1321.
6. Property Rights
The issuance of this individual permit does not convey any property rights in either real or
personal property, or any exclusive privileges, nor does it authorize any injury to private
property or any invasion of personal rights, nor any infringement of Federal, State or local
laws or regulations.
Part III Page 2 of 10 Pages

Permit No.NCS000105
7. Severability
The provisions of this individual permit are severable, and if any provision of this
individual permit, or the application of any provision of this individual permit to any
circumstances, is held invalid, the application of such provision to other circumstances,
and the remainder of this individual permit, shall not be affected thereby.
8. Duty to Provide Information
The permittee shall furnish to the Director, within a reasonable time, any information
which the Director may request to determine whether cause exists for modifying,
revoking and reissuing,or terminating the permit issued pursuant to this individual permit
or to determine compliance with this individual permit. The permittee shall also furnish
to the Director upon request, copies of records required to be kept by this individual
permit.
9. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
individual permit shall;upon conviction, be punished by a fine of not more than $10,000
per violation, or by imprisonment for not more than two years per violation,or by both.
If a conviction of a person is for a violation committed after a first conviction of such
person under this paragraph,punishment is a fine of not more that$20,000 per day of
violation, or by imprisonment of not more than 4 years, or both.
10. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other document submitted or required to
be maintained under this individual permit, including monitoring reports or reports of
compliance or noncompliance shall, upon conviction, be punished by a fine of not more
than $10,000 per violation, or by imprisonment for not more than two years per violation,
or by both.
SECTION B: GENERAL CONDITIONS
1. Individual Permit Expiration
The permittee is not authorized to discharge after the expiration date. In order to receive
automatic authorization to discharge beyond the expiration date, the permittee shall
submit forms and fees as are required by the agency authorized to issue permits no later
than 180 days prior to the expiration date. Any permittee that has not requested renewal
at least 180 days prior to expiration, or any permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will be
Part III Page 3 of 10 Pages

Permit No.NCS000105
subjected to enforcement procedures as provided in NCGS §143-2153.6 and 33 USC
1251 et. seq.
2. Transfers
This permit is not transferable to any person except after notice to and approval by the
Director. The Director may require modification or revocation and reissuance of the
permit to change the name and incorporate such other requirements as may be necessary
under the Clean Water Act. Permittee is required to notify the Division in writing in the
event the permitted facility is sold or closed.
3. Signatory Requirements
All applications,reports, or information submitted to the Director shall be signed and
certified.
a. All applications to be covered under this individual permit shall be signed as
follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of
this Section, a responsible corporate officer means: (a) a president,
secretary,treasurer or vice president of the corporation in charge of a
principal business function, or any other person who performs similar
policy or decision making functions for the corporation, or(b) the manager
of one or more manufacturing production or operating facilities employing
more than 250 persons or having gross annual sales or expenditures
exceeding 25 million (in second quarter 1980 dollars), if authority to sign
documents has been assigned or delegated to the manager in accordance
with corporate procedures.
(2) For a partnership or sole proprietorship: by a general partner or the
proprietor,respectively; or
(3) For a municipality, State,Federal, or other public agency: by either a
principal executive officer or ranking elected official.
b. All reports required by the individual permit and other information requested by
the Director shall be signed by a person described above or by a duly authorized
representative of that person. A person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having
responsibility for the overall operation of the regulated facility or activity,
such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or
position having overall responsibility for environmental matters for the
Part III Page 4 of 10 Pages

Permit No.NCS000105
company. (A duly authorized representative may thus be either a named
individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Director.
C. Any person signing a document under paragraphs a. or b. of this section shall
make the following certification:
"I certify,under penalty of law, that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief,true, accurate,
and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing
violations."
4. Individual Permit Modification.Revocation and Reissuance, or Termination
The issuance of this individual permit does not prohibit the Director from reopening and
modifying the individual permit,revoking and reissuing the individual permit, or
terminating the individual permit as allowed by the laws,rules, and regulations contained
in Title 40, Code of Federal Regulations,Parts 122 and 123;Title 15A of the North
Carolina Administrative Code,Subchapter 211 .0100; and North Carolina General Statute
143-215.1 et. al.
After public notice and opportunity for a hearing,the individual permit may be terminated
for cause. The filing of a request for a individual permit modification,revocation and
reissuance, or termination does not stay any individual permit condition. The permit shall
expire when the individual permit is terminated.
5. Permit Actions
The permit may be modified,revoked and reissued, or terminated for cause. The
notification of planned changes or anticipated noncompliance does not stay any
individual permit condition.
SECTION C: OPERATION AND MAINTENANCE OF POLLUTION CONTROLS
1. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the
permittee to achieve compliance with the conditions of this individual permit. Proper
operation and maintenance also includes adequate laboratory controls and appropriate
Part III Page 5 of 10 Pages

Permit No.NCS000105
quality assurance procedures.This provision requires the operation of back-up or
auxiliary facilities or similar systems which are installed by a permittee only when the
operation is necessary to achieve compliance with the conditions of this individual
permit.
-2. Need to Halt or Reduce Not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with
the condition of this individual permit.
3. Bypassing of Stormwater Control Facilities
Bypass is prohibited and the Director may take enforcement action against a permittee
for bypass unless:
a. Bypass was unavoidable to prevent loss of life,personal injury or severe property
damage; and
b. There were no feasible alternatives to the bypass, such as the use of auxiliary
control facilities,retention of stormwater or maintenance during normal periods of
equipment downtime or dry weather. This condition is not satisfied if adequate
backup controls should have been installed in the exercise of reasonable
engineering judgment to prevent a.bypass which occurred during normal periods
of equipment downtime or preventive maintenance; and
C. The permittee submitted notices as required under,Part III, Section E of this
permit.
If the Director determines that it will meet the three conditions listed above, the Director
may approve an anticipated bypass after considering its adverse effects.
SECTION D: MONITORING AND RECORDS
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of
the volume and nature of the permitted discharge. Analytical sampling shall be
performed during a representative storm event. Samples shall be taken on a day and time
that is characteristic of the discharge. All samples shall be taken before the discharge
joins or is diluted by any other waste stream,body of water, or substance. Monitoring
points as specified in this permit shall not be changed without notification to and
approval of the Director.
PartlII Page 6 of 10 Pages
aqr.

Permit No.NCS000105
2. Recording Results
For each measurement, sample,inspection or maintenance activity performed or collected
pursuant to the requirements of this individual permit, the permittee shall record the
following information:
a. The date, exact place, and time of sampling, measurements, inspection or
maintenance activity;
b. The individual(s) who performed the sampling, measurements,inspection or
maintenance activity;
C. The date(s) analyses were performed;
d. The individual(s)who performed the analyses;
C. The analytical techniques or methods used; and
f. The results of such analyses.
3. Flow Measurements
Where required, appropriate flow measurement devices and methods consistent with
accepted scientific practices shall be selected and used to ensure the accuracy and
reliability of measurements of the volume of monitored discharges.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations
published pursuant to NCGS 143-215.63 et. seq, the Water and Air Quality Reporting
Acts, and to regulations published pursuant to Section 304(g), 33 USC 1314, of the
Federal Water Pollution Control Act, as Amended, and Regulation 40 CFR 136.
To meet the intent of the monitoring required by this individual permit, all test procedures
must produce minimum detection and reporting levels and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure.
5. Representative Outfall
If a facility has multiple discharge locations with substantially identical stormwater
discharges that are required to be sampled, the permittee may petition the Director for
representative outfall status. If it is established that the stormwater discharges are
substantially identical and the permittee is granted representative outfall status,then
sampling requirements may be performed at a reduced number of outfalls.
Part III Page 7 of 10 Pages

Permit No.NCS000105
6. Records Retention
Visual monitoring shall be documented and records maintained at the facility along with
the Stormwater Pollution Prevention Plan. 'Copies of analytical monitoring results shall
also be maintained on-site. The permittee shall retain records of all monitoring
information, including all calibration and maintenance records and all original strip chart
recordings for continuous monitoring instrumentation, and copies of all reports required
by this individual permit for a period of at least 5 years from the date of the sample,
measurement,report or application. This period may be extended by request of the
Director at any time.
7. Inspection and Entry
The permittee shall allow the Director, or an authorized representative (including an
authorized contractor acting as a representative of the Director), or in the case of a facility
which,discharges through amunicipal separate storm sewer system, an authorized
representative of a municipal operator or the separate storm sewer system receiving the
discharge, upon the presentation of credentials and other documents as may be required
by law, to;
a. Enter upon the permittee's premises where a regulated facility or activity is located
or conducted, or where records must be kept under the conditions of this
individual permit;
b. Have access to and copy,,at reasonable times, any records that must be kept under
the conditions of this individual permit;
C. Inspect at reasonable times any facilities, equipment(including monitoring and
control equipment),practices, or operations regulated or required under this
individual permit; and
d. Sample.or monitor at reasonable times, for the purposes of assuring individual
permit compliance or as otherwise authorized by the Clean Water Act, any
substances or parameters at any location.
SECTION E: REPORTING REQUIREMENTS
I. Discharge Monitoring Reports
Samples analyzed in accordance with the terms of this permit shall be submitted to the
Division on Discharge Monitoring Report forms provided by the Director. Submittals
shall be received by the Division no later than 30 days from the date the facility receives
the sampling results from the laboratory.
Part III Page 8 of 10 Pages

Permit No.NCS000105
2. Submitting Reports
Duplicate signed copies of all reports required herein, shall be submitted to the following
address:
Division of Water Quality
Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
3. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section
308 of the Federal Act, 33 USC 1318, all reports prepared in accordance with the terms
shall be available for public inspection at the offices of the Division of Water Quality. As
required by the Act, analytical data shall not be considered confidential. Knowingly
making any false statement on any such report may result in the imposition of criminal
penalties as provided for in NCGS 143-215.6B or in Section 309 of the Federal Act.
4. Non-Stormwater Discharges
If the storm event monitored in accordance with this individual permit coincides with a
non-stormwater discharge,the permittee shall separately monitor all parameters as
required under the non-stormwater discharge permit and provide this information with the
stormwater discharge monitoring report.
5. Planned Changes
The permittee shall give notice to the Director as soon as possible of any planned changes
at the permitted facility which could significantly alter the nature or quantity of pollutants
discharged. This notification requirement includes pollutants which are not specifically
listed in the individual permit or subject to notification requirements under 40 CFR Part
122.42 (a).
6. Anticipated Noncompliance
The permittee shall give notice to the Director as soon as possible of any planned changes
at the permitted facility which may result in noncompliance with the individual permit
requirements.
7. Bypass
a. Anticipated bypass. If the permittee knows in advance of the need for a bypass,it
shall submit prior notice, if possible at least ten days before the date of the bypass;
including an evaluation of the anticipated quality and affect of the bypass.
Part III Page 9 of 10 Pages

Permit No.NCS000105
b. Unanticipated bypass. The permittee shall submit notice within 24 hours of
becoming aware of an unanticipated bypass.
8. Twenty-four Hour Reportine
The permittee shall report to the central office or the appropriate regional office any
noncompliance which may endanger health or the environment. Any information shall be
provided orally within 24 hours from the time the permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
The written submission shall contain a description of the noncompliance, and its causes;
the period of noncompliance, including exact dates and times, and if the noncompliance
has not been corrected, the anticipated time compliance is expected to continue; and steps
taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance.
The Director may waive the written report on a case-by-case basis if the oral report has
been received within 24 hours.
9. Other Noncompliance
The permittee shall report all instances of noncompliance not reported under 24 hour
reporting at the time monitoring reports are submitted.
10. Other Information
Where the permittee becomes aware that it failed to submit any relevant facts in an
application for an individual permit or in any report to the Director,it shall promptly
submit such facts or information.
Part III Page 10 of 10 Pages

Permit No.NCS000105
PART IV LIMITATIONS REOPENER
This individual permit shall be modified or alternatively, revoked and reissued,to comply with
any applicable effluent guideline or water quality standard issued or approved under Sections
302(b) (2) (c), and (d), 304(b)(2)and 307(a)of the Clean Water Act,if the effluent guideline or
water quality standard so issued or approved:
a. Contains different conditions or is otherwise more stringent than any effluent limitation in
the individual permit; or
b. Controls any pollutant not limited in the individual permit.
The individual permit as modified or reissued under this paragraph shall also contain any other
requirements in the Act them applicable.
PART V ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
The permittee must pay the administering and compliance monitoring fee within 30 (thirty) days
after being billed by the Division. Failure to pay the fee in timely manner in accordance with
15A NCAC 2H.0105(b)(4)may cause this Division to initiate action to revoke the Individual
Permit.
PART VI DEFINITIONS
1. Act
See Clean Water Act.
2. Arithmetic Mean
The arithmetic mean of any set of values is the summation of the individual values
divided by the number of individual values.
3. Allowable Non-Stormwater Discharges
This permit regulates stormwater discharges. Non-stormwater discharges which shall be
allowed in the stormwater conveyance system are:
(a) All other discharges that are authorized by a non-stormwater NPDES permit.
Parts IV,V and VI Page 1 of 6

Permit No.NCS000105
(b) Uncontaminated groundwater, foundation drains, air-conditioner condensate
without added chemicals, springs, discharges of uncontaminated potable water,
waterline and fire hydrant flushings, water from footing drains, flows from
riparian habitats and wetlands.
(c) Discharges resulting from fire-fighting or fire-fighting training.
4. Best Management Practices (BMPs)
Measures or practices used to reduce the amount of pollution entering surface waters.
BMPs may take the form of a process, activity, or physical structure.
5. Bypass
A bypass is the known diversion of stormwater from any portion of a stormwater control
facility including the collection system, which is not a designed or established operating
mode for the facility.
6. Bulk Storage of Liquid Products
Liquid raw materials,manufactured products,waste materials or by-products with a
single above ground storage container having a capacity of greater than 660 gallons or
with multiple above ground storage containers located in close proximity to each other
having a total combined storage capacity of greater than 1,320 gallons.
7. Clean Water Act
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as
amended, 33 USC 1251,et. seq.
8. Division or DWO
The Division of Water Quality,Department of Environment and Natural Resources.
9. Director
The Director of the Division of Water Quality, the permit issuing authority.
10. EMC
The North Carolina Environmental Management Commission.
11. Grab Sample
An individual sample collected instantaneously. Grab samples that will be directly
analyzed or qualitatively monitored must be taken within the first 30 minutes of
discharge.
Part VI Page 2 of 6 Pages

Permit No.NCS000105
12. Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean
Water Act.
13. Landfill
A disposal facility or part of a disposal facility where waste is placed in or on land and
which is not a land treatment facility, a surface impoundment, an injection well, a
hazardous waste long-term storage facility or a surface storage facility.
14. Municipal Separate Storm Sewer System
A stormwater collection system within an incorporated area of local self-government such
as a city or town.
15. Overburden
Any material of any nature,consolidated or unconsolidated,that overlies a mineral
deposit,excluding topsoil or similar naturally-occurring surface materials that are not
disturbed by mining operations.
16. Permittee
The owner or operator issued a permit pursuant to this individual permit.
17. Point Source Discharge of Stormwater
Any discernible, confined and discrete conveyance including, but not specifically limited
to, any pipe, ditch, channel, tunnel, conduit, well, or discrete fissure from which
stormwater is or may be discharged to waters of the state.
18. Representative Storm Event
A storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72
hours in which no storm event measuring greater than 0.1 inches has occurred. A single storm
event may contain up to 10 consecutive hours of no precipitation. For example, if it rains for 2
hours without producing any collectable discharge, and then stops, a sample may be collected if a
rain producing a discharge begins again within the next 10 hours.
19. Representative Outfall Status
When it is established that the discharge of stormwater runoff from a single outfall is
representative of the discharges at multiple outfalls,the DWQ may grant representative
outfall status. Representative outfall status allows the permittee to perform analytical
monitoring at a reduced number of outfalls.
Part VI Page 3 of 6 Pages

Permit No.NCS000105
20. Rinse WaterDischaree
The discharge of rinse water from equipment cleaning areas associated with industrial
activity. Rinse waters from vehicle and equipment cleaning areas are process
wastewaters and do not include washwaters utilizing any type of detergent or cleaning
agent.
21. Secondary Containment
Spill containment for the contents of the single largest tank within the containment
structure plus sufficient freeboard to allow for the 25-year,24-hour storm event.
22. Section 313 Water Priority Chemical
A chemical or chemical category which:
a. Is listed in 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund
Amendments and Reauthorization Act (SARA)of 1986, also titled the Emergency
Planning and Community Right-to-Know Act of 1986;
b. Is present at or above threshold levels at a facility subject to SARA title III,
Section 313 reporting requirements; and
C. That meet at least one of the following criteria:
(1) Is listed in Appendix D of 40 CFR part 122 on either Table II(organic
priority pollutants),Table III(certain metals,cyanides, and phenols) or
Table IV (certain toxic pollutants and hazardous substances);
(2) Is listed as a hazardous substance pursuant to section 311(b)(2)(A) of the
CWA at 40 CFR 116.4; or
(3) Is a pollutant for which EPA has published acute or chronic water quality
criteria.
23. Severe Property Damage
Means substantial physical damage to property,damage to the control facilities which
causes them.to become inoperable, or substantial and permanent loss of natural resources
which can reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
24. Significant Materials
Includes,but is not limited to: raw materials; fuels; materials such as solvents, detergents,
and plastic pellets;finished materials such as metallic products; raw materials used in
food processing or production;hazardous substances designated under section 101(14)of
Part VI Page 4 of 6 Pages

Permit No.NCS000105
CERCLA; any chemical the facility is required to report pursuant to section 313 of Title
III of SARA; fertilizers; pesticides; and waste products such as ashes, slag and sludge that
have the potential to be released with stormwater discharges.
25. Significant Spills
Includes, but is not limited to: releases of oil or hazardous substances in excess of
reportable quantities under section 311 of the Clean Water Act (Ref: 40 CPR 110.10 and
CFR 117.21) or section 102 of CERCI A (Ref: 40 CFR 302.4).
26. Stormwater Runoff
The flow of water which results from precipitation and which occurs immediately
following rainfall or as a result of snowmelt.
27. Stormwater Associated with Industrial Activity
The discharge from any point source which is used for collecting and conveying
stormwater and which is directly related to manufacturing, processing or raw material
storage areas at an industrial site. Facilities considered to be engaged in "industrial
activities" include those activities defined in 40 CFR 122.26(b)(14). The term does not
include discharges from facilities or activities excluded from the NPDES program.
28. Stormwater Pollution Prevention Plan
A comprehensive site-specific plan which details measures and practices to reduce
stormwater pollution and is based on an evaluation of the pollution potential of the site.
29. Ten Year Design Storm
The maximum 24 hour precipitation event expected to be equaled or exceeded on the
average once in ten years. Design storm information can be found in the State of North
Carolina Erosion and Sediment Control Planning and Design Manual.
30. Total Flow
The flow corresponding to the time period over which the entire storm event occurs.
Total flow shall be either; (a) measured continuously, (b) calculated based on the amount
of area draining to the outfall, the amount of built-upon (impervious) area, and the total
amount of rainfall, or(c)estimated by the measurement of flow at 20 minute intervals
during the rainfall event.
31. Toxic Pollutant
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
Part VI Page 5 of 6 Pages

Permit No.NCS000105
32. Upset
Means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the permittee. An upset does not include
noncompliance to the extent caused by operational error, improperly designed treatment
or control facilities,inadequate treatment or control facilities,lack of preventive
maintenance, or careless or improper operation.
33. Vehicle Maintenance Activity
Vehicle rehabilitation, mechanical repairs, painting,fueling, lubrication, vehicle cleaning
operations, or airport deicing operations.
34. Visible Sedimentation
Solid particulate matter,both mineral and organic, that has been or is being transported
by water, air, gravity, or ice from its site of origin which can be seen with the unaided
eye.
35. 25-year. 24 hour storm event
The maximum 24-hour precipitation event expected to be equaled or exceeded, on the
average, once in 25 years.
Part VI Page 6 of 6 Pages

of ��tt9
(� Michael F.Easley
O G Governor
rWilliam G.Ross,Jr.,Secretary
>_ Department of Environment and Natural Resources
Kerr T.Stevens
Division of Water Quality
MEMORANDUM July 12, 2001
To: Jimmie Overton
Forrest Westall
Through: Trish MacPherson }+��
From: Bryn H.Tracy Q
Subject: Additional Comments on the NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc., Canton
Mill, Balanced and Indigenous Species Study for the Pigeon River
In an earlier memorandum to Mr.Jimmie Overton and Mr. Forrest Westall (undated, but written on June 12, 2001), 1
provided my comments on the report -- NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc., Canton Mill,
Balanced and Indigenous Species Study for the Pigeon River. I do not agree with the main conclusion of the report that
because a balanced and indigenous fish community exists in the Pigeon River below the mill, the thermal variance should
be continued.
However, I can not find fault in the NC DWQ's continuation of granting a thermal variance for the mill. Temperature is only
one of several factors affecting the current states of the communities in the river. Other factors may include, but not be
limited to, color, total and dissolved solids, biochemical oxygen demand, dissolved salts, and other constituents of the
mill's effluent. Temperature is not the sole factor for preventing balanced and indigenous fish communities from
establishing themselves in the river below the mill. After additional pollutant reductions are achieved, the issue of
temperature impacts will warrant a re-investigation.
It is my opinion, that Blue Ridge Paper Products Inc. should continue to make every effort to reduce more of the pollutants
discharging into the river. I also believe that recolonization sources are lacking downstream of the mill and that the darter
fauna and other fish species in the river have been severely impacted for many decades. Consequently, Blue Ridge
Paper Products Inc. (and other responsible entities, interested parties, and resource agencies) should fund efforts to
reintroduce species that were eradicated by the mill's effluent and now are prevented from recolonization by the Walters
Dam. Such efforts are currently under way in the Tennessee portion of the river by agencies in that state. Without
intervention, the recovery of a balanced and indigenous fish community below the mill in North Carolina will likely take a
long time, if ever.
BHT/bht
PC: Dave Goodrich
Keith Haynes
Michael Meyers
NCDENR
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh,NC 27699-1621 [phone]
1 1 800 623-7748

Kate Seader
P.O. Box 1194
� t _(pl! SEp ? 8 UUU hee, NC 28723
[e-mail]
September 27, 2001
North Carolina Department of the Environment and Natural Resources
Asheville Regional Office
59 Woodfin Place
Asheville, NC 28723
To Whom It May Concern:
I am a Natural Resources Management major at Western Carolina University. I am currently
conducting research for a report concerning the history of policy in the management of the Pigeon
River(vs. Champion/Blue Ridge)for an environmental policy class.
I would greatly appreciate any help you can provide concerning Champion/Blue Ridge's history of
pollution/color variances, policies enacted—Clean Water Act, NPDES, etc. I welcome any help
your organization can provide and I especially appreciate hard-copy information. Please reply to
addresses above.
Thank you very much and I look forward to hearing from you soon!
"6&,
Kate Seader
Western Carolina University
Department of Geosciences and Natural Resources Management
Senior, NRM—Water Resources

i
BLUE RIDGE
PAPER PRODUCTS INC.
b
September 12, 2001
Ms. Marion Deerhake �r A y "���f
Mr. Michael Myers d SEP
North Carolina Division of Water Quality ZJ 1UU/
yfNorth Carolina Department of Environment and Natural Resource s� j<<f Ul(�ry_ 4
1617 Mail Service Center GO CT10y
Raleigh,N.C. 27699-1617 Ffict
Re: Draft NPDES Permit for Blue Ridge Paper Products Inc. /Canton Mill
Dear Ms. Deerhake and Mr. Myers;
Blue Ridge Paper Products Inc. (`Blue Ridge") appreciates the efforts of the
Division of Water Quality ("DWQ") and the NPDES Committee of the Environmental
Management Commission in preparing and issuing the Draft NPDES Permit for the
Canton Mill (the"Draft Permit"). It is Blue Ridge's position that the color limits in the
Draft Permit and the reductions scheduled during the Permit term are in keeping with the
spirit of the 1997 Settlement Agreement, and are in accord with the recommendations of
the Technology Review Workgroup and the Bleach Environmental Process Evaluation
and Report prepared by Dr. Norm Liebergott and Mr. Lewis Shackford (the "Liebergott
Report"). Except as qualified by the comments in this letter, Blue Ridge believes the
Permit should be issued in its current form, and the Color Variance and Temperature
Variance should be continued in effect.
Blue Ridge submits the following comments in response to issues raised by a
number of speakers at the Public Hearing on September 7, 2001. This letter will also
address comments submitted by the State of Tennessee and discuss the Temperature
Variance.
1. The Draft Permit is in Accord with the Settlement Agreement and 1997
Permit
Pursuant to a Settlement Agreement entered into in 1997 between EPA, the States
of North Carolina and Tennessee, the City of Newport, Cocke County, the American
Canoe Association and the Tennessee Environmental Council, the state of North Carolina
issued an NPDES Permit to the Canton Mill in December, 1997 (the"1997 Permit"). The
1997 Permit required evaluation and implementation of a number of Best Management
Practices (`BMP's") and process improvements.
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone: [phone] • Fax: [phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
The 1997 Permit also required evaluation and possible implementation of
additional technologies to reduce color. Based on expected color reductions from
BMP's, process improvements and other technologies, the 1997 Permit called for color
reductions from 98,000 pounds per day (annual average) on January 1, 1998, to a range
of 48,000 to 52,000 pounds per day (annual average)by May 1, 2001. Blue Ridge
implemented or evaluated all required BMP's and process improvements, evaluated
additional technologies, submitted reports on the evaluations and implementations and
met all targeted color reductions. The effluent limits in the proposed permit, 48,000
pounds per day (annual average) and 55,000 pounds per day (monthly average) are a
direct result of the process established in the 1997 Permit.
2. The Draft Permit Continues the Process Developed in the Settlement
Agreement and 1997 Permit
The Draft Permit calls for improved BMP's and process improvements in the first
phase of the Permit just as the 1997 Permit did. These improved BMP's and process
improvements are expected to reduce color to 42,000 pounds per day (annual average)by
December 1, 2003. Blue Ridge is required to submit a report, also by December 1, 2003,
as to the feasibility of achieving an annual color average between 34,000 and 39,000
pounds per day and a schedule for achieving that target. By December 1, 2005,Blue
Ridge is to submit a report with, "... all data necessary to derive the lowest achievable
monthly average and annual average color discharge and color loading limits." The
TRW continues to have a role in the process. Blue Ridge must meet the color reduction
targets unless it can demonstrate, to the satisfaction of the TRW and DWQ, that there are
"overwhelming technical, economic, or operational barriers..."to attaining color
reductions within the targeted range.
The Draft Permit continues the process of technology identification, evaluation
and implementation leading to further color reduction established in the 1997 Permit. It
also continues the role of the TRW in support of the cooperative effort by North Carolina
and Tennessee to require further color improvements in the Canton Mill's discharge. The
parties to the 1997 Settlement Agreement recognized that implementation of BMP's
requires time and capital, as does the evaluation and implementation of process
improvements and new technologies. The Draft Permit continues that pattern by allowing
Blue Ridge two years to implement BMP's and process improvements and to study
additional technologies for color reduction.

BLUE RIDGE PAPER PRODUCTS INC.
3. The Color Numbers in the Draft Permit are Based on the Recommendations
of the TRW As Contemplated in the 1997 Permit.
The 1997 Permit also established a Technology Review Workgroup (the "TRW")
with representatives from EPA,Tennessee and North Carolina. The TRW was involved
in developing the 1997 Permit and, during the Permit term, in evaluating reports
submitted by Blue Ridge and providing recommendations to DWQ. Pursuant to the
provisions of Part III., E., Paragraph 14 of the 1997 Permit, Blue Ridge submitted to
DWQ and the TRW reports in March and June of 2001. In addition to these required
reports,Blue Ridge and a coalition of environmental groups led by the Clean Water Fund
of North Carolina, in an unprecedented display of cooperation, entered into an agreement
with Dr. Norm Liebergott and Lew Shackford to conduct a process audit of the bleaching
process at the Canton Mill. As a result of the audit, the Liebegott Report, referred to
previously herein,was prepared and submitted to DWQ and the TRW.
Based on the Liebergott Report, the TRW Recommendation and Tech Team
Report, DWQ has issued a Draft Permit with an initial color limit of 48,000 lbs per day
(annual average). Some concern was expressed at the public hearing that this number
does not reflect actual performance. The 48,000 pounds per day limit was recommended
by the TRW, based on a statistical analysis of Blue Ridge's performance submitted to
DWQ and the TRW on January 1, 2001 in accordance with Part III. E.,Paragraph 12 of
the 1997 Permit. A copy of the January 1, 2001 report is included with this letter.
4. Anticipated Color Reductions from Technologies Evaluated in the Liebergott
and TRW Reports Should Not Be Written into the Permit Until the
Technologies Have Been Thoroughly Evaluated on a Mill Specific Basis.
Both the Liebergott Report and the TRW Report (the"Reports") evaluated
methods for additional color reduction at the Canton Mill. The Reports concluded the
most cost effective ways to reduce color in the short term were: 1) improvements in BFR;
2) leak and spill prevention and control; and 3) process optimization. Blue Ridge is
committed to all of these BMP's. The Reports also evaluated additional technologies,
including the application of a second stage oxygen delignification system on the
softwood fiber line and ozone addition to the first chlorine dioxide bleaching stage on the
hardwood fiber line. It was the conclusion of the Reports that both of these technologies,
while promising, would require substantial further study, and that it would not be
possible to predict accurately the capital cost and possible cost savings or increases of
these technologies without such further study. Blue Ridge intends to study a second stage
oxygen delignification system on the softwood fiberline, ozone addition to the first
chlorine dioxide bleaching stage on the hardwood ftberline and other color reduction
technologies, and to report on those evaluations in accordance with the requirements of
the Draft Permit. To include a requirement that Blue Ridge implement these technologies
and a color reduction requirement based on anticipated color reductions without further

BLUE RIDGE PAPER PRODUCTS INC.
study is not recommended by the TRW or Liebergott reports and would be inconsistent
with the methodology of the Settlement Agreement and the 1997 Permit.
Likewise, estimated color reductions from the Chloride Removal Process should
not be considered in calculating color reductions for the Draft Permit. At this time there is
no identified technology, which is technically, economically and operationally feasible
for removal of color from this wastestream. Blue Ridge has already evaluated the use of
lime to remove color from this wastestream, and determined that it is not feasible.
5. Response to Comments from the State of Tennessee.
In comments submitted by Paul Davis, Tennessee Division of Water Pollution
Control, and David McKinney,Tennessee Wildlife Resources, the State of Tennessee
asked that: 1) the TRW continue its role; 2) all high certainty BMP's identified in the
TRW Report be implemented; 3) the initial reduction in the annual average for color,
42,000 pounds, be reduced to 40,000 to 42,000 pounds and that the second stage be
reduced accordingly, and 4)Blue Ridge continue monitoring for all dioxin isomers.
Blue Ridge will continue to submit copies of all required reports and evaluations
to the TRW and has no objection to a continued role for the TRW during the new permit
term. Blue Ridge is committed to implementation of the high certainty BMP's in the
TRW Report. Although 2,3,7,8—TCDD dioxin has not been detected in the Canton Mill
effluent since 1989, and the Draft Permit requires Blue Ridge to monitor the bleach plant
effluent prior to the outfall for all dioxin isomers, Blue Ridge has no objection to
continued monitoring for all dioxin isomers at the discharge. Finally,Blue Ridge does not
object to an annual average limit for color in the range of 40,000 to 42,000 pounds per
day, effective December 1, 2003,with second stage reductions to be in the range of
32,000 to 39,000 pounds per day.
6. The Temperature Variance for the Canton Mill Should be Continued in
Effect.
The Temperature Variance for the Canton Mill was initially issued in 1984. Since
that time, the Variance has been reviewed during each Triennial Review of Water Quality
Standards in North Carolina. The Triennial Reviews were submitted to and approved by
EPA.
Section 316(a) of the Clean Water Act allows for a variance from a state water
quality standard for temperature where the state standard is more stringent than necessary
to assure the protection and propagation of a balanced and indigenous population of
aquatic life. Blue Ridge submitted, in accordance with the requirements of the 1997

BLUE RIDGE PAPER PRODUCTS INC.
Permit, a comprehensive balanced and indigenous species study in May, 2001. The study
found significant improvement in the fish and benthic communities below the Mill.
DWQ, through its Biological Assessment Group, concurred in continuing the
Temperature Variance. In its concurrence,DWQ noted that temperature is only one of
several factors affecting the aquatic community downstream from the Canton Mill and
that the issue of temperature impacts would warrant re-investigation after additional
pollutant reductions. A copy of a letter from Bryn Tracy with the Biological Assessment
Unit is included with these comments. The Draft permit includes a requirement that Blue
Ridge complete an analysis of temperature and submit a balanced and indigenous species
study during the next permit renewal.
7. Based on the Foregoing Blue Ridge Requests that the Draft Permit be Issued
and the Variances for Color and Temperature be Continued in Effect.
Blue Ridge believes the Draft Permit, as issued, continues the cooperative Process
established in the Settlement Agreement and the 1997 Permit. Blue Ridge met all
milestones and targets in the 1997 Permit and worked cooperatively with DWQ, the
TRW and a coalition of environmental groups in the development of the Draft Permit.
Blue Ridge is committed to the continuation of the cooperative process and to continued
color reduction which is technically, economically and operationally feasible. Except as
qualified by these comments, Blue Ridge believes the Draft Permit should be issued and
the Color and Temperature Variances should remain in effect.
Blue Ridge appreciates the opportunity to submit these comments. Questions
should be directed to Bob Williams at the Canton Mill, 828-646-2033.
Blue Ridge Paper Products Inc.
P&60V'w�
By: Robert V. Williams
Director-Environmental, Health
and Safety Affairs

BLUER RIDGE
PAPER PODUCTS INC.
December 28,2000 /#6C
9?000
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products, Inc. Canton Mill
January 1, 2001 Color Limit Feasibility Report
Dear Mr. Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24,
and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving.a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 99's percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 Ibs/day and an average monthly color limit of 59,796 lbs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit),Blue Ridge Paper Products recommends using a 95°percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 950'percentile statistical review of the
limited data available from January 1998— October 31, 2000 the annual average color is 48,388 lbs/day
and the monthly average color is 55,556 Ibs/day. Blue Ridge Paper Products believes the 95's percentile
confidence interval will be appropriate with the additional color data that will be available for the June 1,
2001 analysis. The attached Table includes the summary of the 99th and 956'percentile statistical data.
Please call me at [phone] or Derric Brown at(828) 646-2318 if you have any questions regarding
this report.
Sincerely,
� 1 .
Bob Williams
Director- Environmental,Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations
f

RIDGE
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1,2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
1. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000—52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997
Permit provides in part, as follows:
'...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 Ibs/day
based on full implementation of the Near-Term Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits... "
This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000, Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000—52, 000 pounds per day is feasible.
1

Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
rn
400000
.a
v
0 300000
0
V
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
—•—SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
II. Color Performance
The Canton Mill has achieved a color reduction of over 85%o since 1988 in the annual
average amount of color discharged, as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project, full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRTm on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 Ibs/day and the 1999 average
annual color discharged was 41,048 Ibs/day. The 2000 average annual color(through
October) is 44,837 Ibs/day. All of these values are within or below the target annual
average color range of 48,000—52,000 lbs/day specified in Part III, Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion (30Q2),historical flow records, and the
January 1998 — October 2000 annual average color value of 45,458 lbs/day, it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
3

January 1, 2001— Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
III. Recommended Color Limits
The January 1998 —October 2000 actual average annual color of 45,458 lbs/day and the
January 2000— October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000— 52,000 lbs/day specified in Part
III, Paragraph I: 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated, that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 lbs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998 —October 2000 annual color average using a 991h percentile
distribution is 49,612 lbs/day. The January 2000— October 2000 annual color average
using a 990 percentile distribution is 48,911 lbs/day. These values are both within the
48,000—52,000 lb/day range. Based on a statistical review of the data and the limited
data set available, Blue Ridge Paper Products, Inc. recommends an annual average
effluent limit of 49,612 lbs/day.
The January 1998 —October 2000 monthly color average using a 99`"percentile
distribution is 59,796 lbs/day. The January 2000—October 2000 monthly color average
using a 990' percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available,Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,796 lbs/day.
4

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
I1I. Conclusion
Blue Ridge Paper Products, Inc. believes it is feasible to achieve a target annual average
color limit within the range of 48,000 — 52, 000 lbs/day. The Canton Mill recommends
an average annual color limit of 49,612 lbs/day and an average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria (30Q2),historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepco gage will be less than 50 true color units approximately 97%
of the applicable time.
5

TABLE
January 1, 2001 Color Limit Feasibility Report
Monthly Average Data - Max Month Cale
Data Set= 111198-10131/2000 11112000-10131/2000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. = 34 10
xbar 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 55556 54773
99th safe MONTH from normal dist 69796 68953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58542 58009

nEl P-LWO Fax:[phone] Jul 13 '01 10:45 P.02i02
�,� _•._- Governor
_r William G.Ross.Jr.,Secretary
c O I Department of Environment and Natural Resources
Kerr T.Stevens
Division of water Quality
MEMORANDUM July 12,2001
To: Jimmie Overton
Forrest Westall
Through: Trish MacPherson
From: Bryn H. Tracy Q
• i
Subject: Additional Comments on the NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc., Canton
Mill, Balanced and Indigenous Species Study for the Pigeon River
In an earlier memorandum to Mr.Jimmie Overton and Mr. Forrest Westalt(undated,but written on June 12,2001), I
provided my comments on the report --NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc.,Canton Mill,
Balanced and Indigenous Species Study for the PigeogRiver..I do not agree with the•main concluslorr of the report that
because a balanced and indigenous fish community exists in the Pigeon River below the mill, the thermal variance should
be continued.
However, I can not find fault in the NC DWO's continuation of grantingla thermal variance for the mill. Temperature is only
one of several factors affecting the current states of the communities 10 the river. Other factors may-include,but not be
limited to, color,total and dissolved solids,biochemical.oxygen demand, dissolved salts,and other constituents of the
mill's effluent. Temperature is not the sole factor for preventing balanced and indigenous fish communities from
establishing themselves in the river below the mill. After additional pollutant reductions are achieved,the issue of
temperature impacts will warrant a re-Investigation.
It is my opinion,.that Blue Ridge Paper Products Inc.should continue to make every effort to reduce more of the pollutants
discharging into the river. I also believe that recolonization sources are lacking downstream of the.mill and that the darter
fauna and other fish species in the river have been severely impacted for many decades. Consequently, Blue Ridge
Paper Products Inc. (and other responsible entities, interested.parties,land resource agencies)should fund efforts to
reintroduce species that were eradicated by the mills effluent and nowlare prevented from recolonfzation by the Walters
Dam. Such efforts are currently under way in the Tennessee portion of the river by agencies in that state. Without
intervention,the recovery of a balanced and Indigenous,fish community below the mill in North Carolina will likely take a
long lime, if ever.
BHTlbht
PC: Dave Goodrich
Keith Hayndii i
Michael Meyers
QW� l
MM '
Customer Service Environmental Scionoas Branch 1621 Mail Service Ctenter Raleigh;NC 27699.1621 [phone]
1 800 823.7748
• I
. ., ... . .. . �„ T..•a, rra nl nr_rr nenr.-❑ FRnnitr.TF. FROM:919 733 0719 Pet

BLUE RIDGE
PAPER PRODUCTS INC. r!)June 14, 2001
JUN 15 2001
Mr. Forrest Westall
Regional Water Quality Supervisor WATER ppUALITY SECTION
North Carolina Department of Environment ASHEVILLE REGIONAL OFFICE
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products Inc.
Request to Change Division of Water Quality Approved Study Plan for Dioxin
Monitoring in Fish Tissue,February 1990
Dear Mr.Westall:
Since 1990 the Canton Mill has been conducting annual fish tissue monitoring for dioxin in the
Pigeon River. This compliance monitoring requirement in Part Ill, Section H of the NPDES
Permit is performed in accordance with the DWQ approved Study Plan for Dioxin Monitoring in
Fish Tissue, February 1990. In 1994 North Carolina changed the"Do not consume"advisory for
all types of fish in the Pigeon River to a"Consumption advisory" for carp and catfish only.
During the term of the current NPDES Permit term, all sportfish(redbreast sunfish,black crappie,
smallmouth bass, largemouth bass and rock bass)have been below the level of detection for
2,3,7,8-TCDD (see attached table). Since 1996, the Toxicity Equivalent Concentrations(TEC's)
for all sportfish have been based on non-detect values for all isomers and all TEC values are well
below 3 ppt, the North Carolina level for fish consumption advisories.
Based on the fact that 2,3,7,8-TCDD has been non-detectable for the last six years and the non-
detect based TEC's are well below 3 ppt,Blue Ridge requests that the study plan be modified so
that it is no longer necessary to collect sportfish in these annual fish tissue surveys. It is also
requested that collection of bottom feeder whole bodies be removed from the study plan since the
consumption advisory covers filets,not whole bodies. Up to 90 fewer fish per year will be
collected from the Pigeon River as a result of this change to the annual study. If approved by the
DWQ,the 1990 Study Plan will be revised to reflect these changes.
Please contact me at(828) 646-2318 if you have any questions. The Canton Mill would
appreciate consideration of this matter so that, if approved,it will be applied to the August 2001
fish tissue collection.
Sincerely,
1111 s
Derric Brown
Manager,Environmental Affairs
Attachment
Xc: Mark Hale
Keith Haynes
Lou Ann Williams
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS, 1996-2000"d
I
1996 Resultsrol 1997 Resultsrol
Number of Length Number of Length
Station Species Fish Range(tom) 2,3,7,8-TCDDt't Station Species Fish Range(mm) 2,3,7,8-TCDDt'1
1 Redbreast sunfish 5 154-185 ND(0.13) 1 Redbreast sunfish 5 144-161 ND(0.11)
RM 64.5 Rock bass 5 160-208 ND(0.085) RM 64.5 Rock bass 5 162-194 ND(0.23)
Black redhorse 5 401-440 ND(0.089) Black redhorse 4 291-424 ND(0.22)
2 Redbreast sunfish 5 179-187 ND(0.10) 2 Redbreast sunfish 5 183-200 ND(0.26)
RM 59.0 Redbreast sunfish 5 183-191 ND(0.12) RM 59.0 Redbreast sunfish 5 160-181 ND(0.12)
Common carp 5 543-580 1.5 Common carp 5 506-615 1.4
3 Redbreast sunfish 5 184-190 ND(0.13) 3 Redbreast sunfish 5 187-202 ND(0.18)
RM 52.3 Redbreast sunfish 5 165-185 ND(0.13) RM 52.3 Redbreast sunfish 5 164-195 ND(0.18)
Common carp 5 516-630 0.87 Common carp 5 450-505 ND(0.33)
4A Black crappie 5 216-233 ND(0.15) 4A Black crapppie 5 215-231 ND(0.27)
RM 41.5 Black crappie 5 215-229 ND(0.18) RM 41.5 Black crappie 5 220-230 ND(0.10)
Common carp 5 562-632 4.2 Common carp 5 570-655 2.3
Channel catfish 5 418-482 2.0
4B Black crappie 5 223-258 ND(0.11) 4B Black crappie 5 226-241 ND(0.17)
RM 39.0 Largemouth bass 5 278-310 ND(0.13) RM 39.0 Largemouth bass 5 270-360 ND(0.21)
Common carp 5 470-623 4.0 Common carp 5 605-690 11.0
Flathead catfish 5 430-540 0.62
5 Rock bass 4 169-186 ND(0.077) 5 Rock bass 5 143-214 ND(0.15)
RM 19.0 Smallmouth bass 5 315454 ND(0.12) RM 19.0 Smallmouth bass 5 278-367 ND(0.27)
Smallmouth buffalo 5 451-555 ND(0.12) Smallmouth buffalo 5 406-525 ND(0.22)
Total Fish Filleted 89 Total Fish Filleted 99
I

BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS
1998 Resulls0) 1999 Results()
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDDt't Station Species Fish Range(mm) 2,3,7,8-TCDDO
1 Redbreast sunfish 5 145-176 ND(0.19) 1 Redbreast sunfish 5 141-177 ND(0.21)
RM 64.5 Rock bass 5 158-179 ND(0.29) RM 64.5 Rock bass 5 164-180 ND(0.37)
Black redhorse 5 340-396 ND(0.18) Black redhorse 5 352427 ND(0.33)
2 Redbreast sunfish 5 164-177 ND(0.20) 2 Redbreast sunfish 5 167-190 ND(0.37)
RM 59.0 Redbreast sunfish 5 166-193 ND(0.28) RM 59.0 Redbreast sunfish 5 158-178 ND(0.29)
Common carp 5 551-661 1.3 Common carp 5 544-615 ND(0.27)
I
3 Redbreast sunfish 5 168-193 ND(0.34) 3 Redbreast sunfish 5 169-189 ND(0.36)
RM 52.3 Redbreast sunfish 5 167-200 ND(0.22) RM 52.3 Redbreast sunfish 5 162-176 ND(0.37)
Common carp 5 449-550 ND(0.38) Common carp 5 500-591 0.57
4A Black crappie 5 220-240 ND(0.49) 4A Black crappie 5 220-268 ND(0.18)
RM 41.5 Largemouth bass 5 227-330 ND(0.15) RM 41.5 Black crappie 5 219-244 ND(0.08)
Common carp 5 585-621 1.6 Common carp 5 574-645 0.58
Channel catfish 5 416458 ND(0.28) Channel catfish 5 425482 0.83
4B Black crappie 5 233-252 ND(0.15) 4B Black crappie 5 233-244 ND(0.27)
RM 39.0 Largemouth bass 5 259-330 ND(0.17) RM 39.0 Largemouth bass 5 276-305 ND(0.32)
Common carp 5 563-686 9.1 Common carp 5 621-680 4.7
Flathead catfish 5 414-523 ND(0.20) Flathead catfish 5 372-513 ND(0.46)
5 Rock bass 4 155-190 ND(0.11) 5 Rock bass 5 170-203 ND(0.29)
RM 19.0 Smallmouth bass 5 295-365 ND(0.21) RM 19.0 Smallmouth bass 5 297430 ND(0.19)
Smallmouth buffalo 5 464-537 ND(0.31) Smallmcuth buffalo 5 476-565 ND(0.31)
Total Fish Filleted 99 Total Fish Filleted 100

BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS
2000 Resultsrol
Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDDO
1 Redbreast sunfish 5 137-148 ND(0.48)
RM 64.5 Rock bass 5 162-186 ND(0.45)
Black redhorse 5 357-396 ND(0.38)
2 Redbreast sunfish 5 169-176 ND(0.31)
RM 59.0 Redbreast sunfish 5 164-181 ND(0.43)
Common carp 5 505-582 ND(0.42)
3 Redbreast sunfish 5 169-181 ND(0.43)
RM 52.3 Redbreast sunfish 5 186-199 ND(0.32)
Common carp 5 514-569 ND(0.53)
4A Black crappie 5 212-241 ND(0.29)
RM 41.5 Black crappie 5 220-241 ND(0.24)
Common carp 4 559-604 1.1
Channel catfish 5 435487 ND(0.70)
4B Black crappie 5 213-231 ND(0.41)
RM 39.0 Black crappie 5 220-230 ND(0.37)
Common carp 4 593-712 4.4
j Flathead catfish 5 407-450 ND(0.42)
5 Rock bass 5 171-198 ND(0.45)
RM 19.0 Smallmouth has 5 209-238 ND(0.31)
Black redhorse 5 427-476 ND(0.35)
Total Fish Filleted 98
I
i

O�O� \N ATFROG r Michael Easley,Governor
William R G.Ross Jr.,Secretary
i North Carolina Department of Environment and Natural Resources
Gregory J.Thorpe,Ph.D.
> 1 Acting Director
p -r Division of Water Quality
August 22, 2001 ` 1
SEP 1 9 2001
Mr. Derric Brown
Manager, Environmental Affairs VVATERpuA,u)ySE--
Blue Ridge Paper Products ASHEVILL 6EGlOiVAL TION
P.O. Box 4000
Canton, North Carolina 28716
Subject: Dioxin Monitoring Plan
Blue Ridge Paper Products
NPDES No. NC0000272
Dear Mr. Brown:
The Water Quality Section has reviewed your request for modifications to the subject study plan
originally approved by the Division of Water Quality in February 1990. The 2001 dioxin fish tissue
monitoring plan is approved with the following changes:
• Sportfish may be removed from the study target list due to non detectable levels of CDD/F
isomers in these species since 1996.
• Collect a least one whole body bottom feeder sample from Walters Lake (stations 4A or 413)
to monitor ecological impacts of dioxin contamination in bottom species.
• Continue with the collection of bottom feeder fillet samples as approved in the 1990 study
plan.
If you have any further questions or comments please feel free to contact me at 919/733-5083.
Sincerely,
0 Co een Sulli
Chief, Water Quality Section
cc: Jimmie Overton
Dr. Luanne Williams
N�6EN
N.C.Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 (919)733-701.5 Customer Service
1 800 623-7748

APA
4h
NC®ENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor William G. Ross, Jr. , Secretary
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
WATER QUALITY SECTION
August 13 , 2001
Mr. R. T . Alexander, Sheriff
Haywood County Sheriff ' s Office
420 North Main Street
Waynesville, North Carolina 28786
Subject : Request for Assistance
Blue Ridge Paper
NPDES Public Hearing
Haywood County
Dear Sheriff Alexander:
On September 6, 2001, the Division of Water Quality will be holding a
public hearing for the renewal of the NPDES Permit, which allows Blue Ridge
Paper to continue discharge of treated wastewater into the Pigeon River.
The hearing will be held in the Tuscola High School Auditorium at 7 : 00
P.M. .
Based on interest for the past public hearings held for the renewals,
there is a possibility that a number of emotional people could be in
attendance . Some of those in attendance will be very adamant with their
objections to the reissuance of Blue Ridge' s Permit and the ensuing
discussions could get quite heated. Therefore, we think that it would be
in everyone ' s best interest that at least one of your deputies is on hand
for the hearing.
On August 9th, Mr. Keith Haynes of this Office spoke with Mr. Jimmy
Parton, your chief deputy. Deputy Parton indicated that having deputies at
the hearing should be no problem, but he thought that a letter requesting
such would be appropriate .
If you need additional information concerning this matter, please do
not hesitate to contact Mr. Haynes or me at 251-6208 . Thank you for your
consideration and support .
s r�� ?07re
sttaWaterQuaRegional Supervisor

r
r
BLUE RIDGE
PAPER PRODUCTS INC.
December 28, 2000
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin-Place — - -
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
January 1,2001 Color Limit Feasibility Report
Dear Mr. Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24,
and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 99°percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 lbs/day and an average monthly color limit of 59,796 lbs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit),Blue Ridge Paper Products recommends using a 95`h percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 95a'percentile statistical review of the
limited data available from January 1998—October 31, 2000 the annual average color is 48,388 Ibs/day
and the monthly average color is 55,556 lbs/day. Blue Ridge Paper Products believes the 95 s percentile
confidence interval will be appropriate with the additional color data that will be available for the June 1,
2001 analysis. The attached Table includes the summary of the 99 s and 95 h percentile statistical data.
Please call me at(828) 646-2033 or Derric Brown at(828) 646-2318 if you have any questions regarding
this report.
(2Sincerely,
l`��Oinrte�r�d_.
Bob Williams
Director- Environmental,Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE
PAYER PRODUCTS INC.
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000—52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997
Permit provides in part, as follows:
`...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 Ibs/day
based on full implementation of the Near-Teem Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits... "
This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000, Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000—52, 000 pounds per day is feasible.
1

January 1, 2001 - Color Limit Feasibility Report
Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
c>s
400000
N
.a
G
O 300000
6
V
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
--*—SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
H. Color Performance
The Canton Mill has achieved a color reduction of over 85%u since 1988 in the annual
average amount of color discharged, as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project, full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRTM on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average
annual color discharged was 41,048 lbs/day. The 2000 average annual color(through
October) is 44,837 lbs/day. All of these values are within or below the target annual
average color range of 48,000—52,000 lbs/day specified in Part III,Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion (30Q2), historical flow records, and the
January 1998—October 2000 annual average color value of 45,458 lbs/day, it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
3

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
III. Recommended Color Limits
The January 1998 —October 2000 actual average annual color of 45,458 Ibs/day and the
January 2000—October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000—52,000 Ibs/day specified in Part
III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated, that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 lbs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color,Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998—October 2000 annual color average using a 99`h percentile
distribution is 49,612 Ibs/day. The January 2000—October 2000 annual color average
using a 99`h percentile distribution is 48,911 Ibs/day. These values are both within the
48,000— 52,000 lb/day range. Based on a statistical review of the data and the limited
data set available, Blue Ridge Paper Products, Inc. recommends an annual average
effluent limit of 49,612 lbs/day.
The January 1998—October 2000 monthly color average using a 990,percentile
distribution is 59,7961bs/day. The January 2000—October 2000 monthly color average
using a 99`h percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available,Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,796 lbs/day.
4

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
III. Conclusion
Blue Ridge Paper Products, Inc. believes it is feasible to achieve a target annual average
color limit within the range of 48,000—52, 000 lbs/day. The Canton Mill recommends
_an average annual color limit of 49,612 lbs/day and an average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria(30Q2), historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepco gage will be less than 50 true color units approximately 97%
of the applicable time.
5

TABLE
January 1, 2001 Color Limit Feasibility Report
Monthly Average Data - Max Month Calc
Data Set= 1/1198-10/31/2000 1/112000-10/3112000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. = 34 10
xbar - 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 66556 54773
99th safe MONTH from normal dist 59796 58953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58542 58009

1
BLUE RIDGE
PAPER PRODUCTS INC. r �
June 14,2001 D f� 1uj n
Mr. Forrest Westall � 15 901
Regional Water Quality Supervisor
North Carolina Department of Environment WATER ppUALITY SECT ?!
and Natural Resources _ ASuEVILLE REGIO(lAi ,FICE
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products Inc.
Request to Change Division of Water Quality Approved Study Plan for Dioxin
Monitoring in Fish Tissue, February 1990
Dear Mr.Westall:
Since 1990 the Canton Mill has been conducting annual fish tissue monitoring for dioxin in the
Pigeon River. This compliance monitoring requirement in Part III, Section H of the NPDES
Permit is performed in accordance with the DWQ approved Study Plan for Dioxin Monitoring in
Fish Tissue, February 1990. In 1994 North Carolina changed the"Do not consume" advisory for
all types of fish in the Pigeon River to a"Consumption advisory"for carp and catfish only.
During the term of the current NPDES Permit term, all sportfish(redbreast sunfish,black crappie,
smallmouth bass, largemouth bass and rock bass)have been below the level of detection for
2,3,7,8-TCDD (see attached table). Since 1996,the Toxicity Equivalent Concentrations (TEC's)
for all sportfish have been based on non-detect values for all isomers and all TEC values are well
below 3 ppt, the North Carolina level for fish consumption advisories.
Based on the fact that 2,3,7,8-TCDD has been non-detectable for the last six years and the non-
detect based TEC's are well below 3 ppt,Blue Ridge requests that the study plan be modified so
that it is no longer necessary to collect sportfish in these annual fish tissue surveys. It is also
requested that collection of bottom feeder whole bodies be removed from the study plan since the
consumption advisory covers filets,not whole bodies. Up to 90 fewer fish per year will be
collected from the Pigeon River as a result of this change to the annual study. If approved by the
DWQ,the 1990 Study Plan will be revised to reflect these changes.
Please contact me at(828) 646-2318 if you have any questions. The Canton Mill would
appreciate consideration of this matter so that, if approved,it will be applied to the August 2001
fish tissue collection.
Sincerely,
Derric Brown
Manager, Environmental Affairs
Attachment
Xc: Mark Hale
Keith Haynes
Lou Ann Williams
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS, 1996-2000(a)
1996 Results(b) 1997 Results0)
Number of Length Number of Length
Station Species Fish Range(ram) 2,3,7,8-TCDDt Station Species Fish Range(mm) 2,3,7,8-TCDDt�
I Redbreast sunfish 5 154-185 ND(0.13) 1 Redbreast sunfish 5 144-161 ND(0.11)
RM 64.5 Rock bass 5 160-208 ND(0.085) RM 64.5 Rock bass 5 162-194 ND(0.23)
Black redhorse 5 401-440 ND(0.089) Black redhorse 4 291-424 ND(0.22)
2 Redbreast sunfish 5 179-187 ND(0.10) 2 Redbreast sunfish 5 183-200 ND(0.26)
RM 59.0 Redbreast sunfish 5 183-191 ND(0.12) RM 59.0 Redbreast sunfish 5 160-181 ND(0.12)
Common carp 5 543-580 1.5 Common carp 5 506-615 1.4
3 Redbreast sunfish 5 184-190 ND(0.13) 3 Redbreast sunfish 5 187-202 ND(0.18)
RM 52.3 Redbreast sunfish 5 165-185 ND(0.13) RM 52.3 Redbreast sunfish 5 164-195 ND(0.18)
Common carp 5 516-630 0.87 Common carp 5 450-505 ND(0.33)
4A Black crappie 5 216-233 ND(0.15) 4A Black crapppie 5 215-231 ND(0.27)
RM 41.5 Black crappie 5 215-229 ND(0.18) RM 41.5 Black crappie 5 220-230 ND(0.10)
Common carp 5 562-632 4.2 Common carp 5 570-655 2.3
Channel catfish 5 418482 2.0
4B Black crappie 5 223-258 ND(0.11) 4B Black crappie 5 226-241 ND(0.17)
RM 39.0 Largemouth bass 5 278-310 ND(0.13) RM 39.0 Largemouth bass 5 270-360 ND(0.21)
Common carp 5 470-623 4.0 Common carp 5 605-690 11.0
Flathead catfish 5 430-540 0.62
i
5 Rock bass 4 169-186 ND(0.077) 5 Rock bass 5 143-214 ND(0.15)
RM 19.0 Smallmouth bass 5 315454 ND(0.12) RM 19.0 Smallmouth bass 5 278-367 ND(0.27)
Smallmouth buffalo 5 451-555 ND(0.12) Smallmouth buffalo 5 406-525 ND(0.22)
Total Fish Filleted 89 Total Fish Filleted 99

BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS
1998 Resul&" 1999 ResultsOi
Number of Length Number of Length
Station Species Fish Range(mm) 2,3,7,8-TCDDot Station Species Fish Range(mm) 2,3,7,8-TCDD0)
1 Redbreast sunfish 5 145-176 ND(0.19) 1 Redbreast sunfish 5 141-177 ND(0.21)
RM 64.5 Rock bass 5 158-179 ND(0.29) RM 64.5 Rock bass 5 164-180 ND(0.37)
Black redhorse 5 340-396 ND(0.18) Black redhorse 5 352-427 ND(0.33)
2 Redbreast sunfish 5 164-177 ND(0.20) 2 Redbreast sunfish 5 167-190 ND(0.37)
RM 59.0 Redbreast sunfish 5 166-193 ND(0.28) RM 59.0 Redbreast sunfish 5 158-178 ND(0.29)
Common carp 5 551-661 1.3 Common carp 5 544-615 ND(0.27)
3 Redbreast sunfish 5 168-193 ND(0.34) 3 Redbreast sunfish 5 169-189 ND(0.36)
RM 52.3 Redbreast sunfish 5 167-200 ND(0.22) RM 52.3 Redbreast sunfish 5 162-176 ND(0.37)
Common carp 5 449-550 ND(0.38) Common carp 5 500-591 0.57
4A Black crappie 5 220-240 ND(0.49) 4A Black crappie 5 220.268 ND(0.18)
RM 41.5 Largemouth bass 5 227-330 ND(0.15) RM 41.5 Black crappie 5 219-244 ND(0.08)
Common carp 5 585-621 1.6 Common carp 5 574-645 0.58
Channel catfish 5 416458 ND(0.28) Channel catfish 5 425-482 0.83
4B Black crappie 5 233-252 ND(0.15) 4B Black crappie 5 233-244 ND(0.27)
RM 39.0 Largemouth bass 5 259-330 ND(0.17) RM 39.0 Largemouth bass 5 276-305 ND(0.32)
Common carp 5 563-686 9.1 Common carp 5 621-680 4.7
Flathead catfish 5 414-523 ND(0.20) Flathead catfish 5 372-513 ND(0.46)
5 Rock bass 4 155-190 ND(0.11) 5 Rock has 5 170-203 ND(0.29)
RM 19.0 Smallmouth bass 5 295-365 ND(0.21) RM 19.0 Smallmouth bass 5 297.430 ND(0.19)
Smallmouth buffalo 5 464-537 ND(0.31) Smallmouth buffalo 5 476-565 ND(0.31)
Total Fish Filleted 99 Total Fish Filleted 100

BLUE RIDGE PAPER CANTON MILL FISH FILLET TISSUE ANALYSIS RESULTS
2000 Results(b)
Number of Length
Station Species Fish Range(mn) 2,3,7,8-TCDDC'
1 Redbreast sunfish 5 137-148 ND(0.48)
RM 64.5 Rock bass 5 162-186 ND(0.45)
Black redhorse 5 357-396 ND(0.38)
2 Redbreast sunfish 5 169-176 ND(0.31)
RM 59.0 Redbreast sunfish 5 164-181 ND(0.43)
Common carp 5 505-582 ND(0.42)
3 Redbreast sunfish 5 169-181 ND(0.43)
RM 52.3 Redbreast sunfish 5 186-199 ND(0.32)
Common carp 5 514-569 ND(0.53)
4A Black crappie 5 212-241 ND(0.29)
RM 41.5 Black crappie 5 220-241 ND(0.24)
Common carp 4 559-604 1.1
Channel catfish 5 435487 ND(0.70)
4B Black crappie 5 213-231 ND(0.41)
RM 39.0 Black crappie 5 220-230 ND(0.37)
Common carp 4 593-712 4.4
Flathead catfish 5 407-450 ND(0.42)
5 Rock bass 5 171-198 ND(0.45)
RM 19.0 Smallmouth bass 5 209-238 ND(0.31)
Black redhorse 5 427-476 ND 0.35)
Total Fish Filleted 98
i

COMPARATIVE AND STATISTICAL
EVALUATION REPORTS
Prepared for:
North Carolina
Division Water Quality
4
Prepared by:
Blue Ridge Paper Products Inc.
Canton, North Carolina
May 31 , 2001

BLUE RIDGE
PAPER PRODUCTS INC.
May 29,2001
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No. NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
June 1,2001 Required Reports
Dear Mr.Westall:
Attached are the June 1, 2001 Comparative Evaluation Report and the June 1, 2001 Color
Performance Statistical Evaluation. These reports are submitted to fulfill part of the
requirements stated in Part III,Paragraph E 14 of the modified 1997 NPDES Permit.
Please call me at(828) 646-2033 or Derric Brown at(828) 646-2318 if you have any questions or
concerns regarding these reports.
Sincerel-\6k
Bob Williams
Director-Environmental,Health and Safety
Attachment
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

Xc: Keith Haynes
Dave Goodrich
Mikee Myeis

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
I. Introduction
The following report describes the important color reduction activities that have
been accomplished over the term of the modified 1997 NPDES Permit ("1997
Permit") and includes a discussion of technology assessments Blue Ridge has
undertaken to evaluate potential color reduction options. Part III, E. Paragraph
14 of the 1997 Permit provides, in part, that:
"...By June 1, 2001, the permittee will submit a report to the
NPDES Committee and N.C. DENR, Division of Water Quality,
on the comparative evaluation of the above collective efforts as
part of the Variance review process (Triennial Review of North
Carolina Water Quality Standards.)..."
This report is submitted to fulfill this requirement of Part III, E. Paragraph 14.
Permit No. NC0000272
Page 1

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
II. Summary of Color Reduction Activities
Since the issuance of the 1997 NPDES Permit, the Canton Mill has
accomplished the following color reduction activities:
1. Identified and implemented certain Best Management Practices
(BMP's) to reduce color. The following BMP's were implemented
before June 1, 1998, and a report on the implementation was
submitted to DWQ, the TRW and the NPDES Committee on that date.
a. Installation of replacement digester recirculation pumps.
b. Installation of a double-chambered pine courtyard spill collection
sump.
c. Installation of weak black liquor tank containment, and
d. Correction of evaporate set demister clogging, installation of
condensate instrumentation and sampling ports for the
evaporator set and assurance of continued dry conveying of
knot rejects.
2. Submitted Low Flow Contingency Plan to DWQ and TRW by
December 1, 1998 (approved by NPDES Committee in February
1999).
3. Prior to December 1, 1998, complied with a reduced color limit in the
Permit of 60,000 lbs. per day (annual average) and 69,000 lbs. per day
(monthly average).
4. Began implementation of partial Eo stage filtrate recycle on the
hardwood line before January 1, 1999 and submitted a report on the
color reduction benefit resulting from the partial implementation and a
projection of potential color reduction benefit to be gained from full
implementation of BFR on the hardwood line to DWQ, TRW and the
NPDES Committee by December 1, 1999.
5. Submitted a color limit feasibility report to DWQ, TRW and the NPDES
Committee before January 1, 2001, which concluded that the Canton
Mill could comply with a color limit within the range of 48,000-52,000
lbs. per day (annual average).
Permit No. NC0000272
Page 2

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
Implementation of these BMP's, together with improved mill operations and
continued commitment to further reduce color, has reduced color by 32% over
the term of the 1997 Permit. As described in the January 1st, 2001 Report, the
mill has achieved a target annual average color loading of 48,000 — 52,000
pounds per day. On May 1, 2001 the North Carolina Division of Water Quality
reduced the permit limit for annual average color from 60,000 Ibs/day to 48,000
Ibs/day and the monthly average color limitation was reduced from 69,000
Ibs/day to 55,000 Ibs/day. Based on data received from the National Council on
Air and Stream Improvement (NCASI), the Canton Mill has the lowest color of
any mill in its industry category.'
Based on a June 7,2000 Benchmarking Canton Wastewater Effluent Parameters letter from the National
Council for Air and Stream Improvement(NCASI).
Permit No. NC0000272
Page 3

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
III. Additional Color Reduction Studies
3.1 End-of-Pipe Treatment and In-Process Technologies
In an effort to identify either a breakthrough improvement in color removal
efficiency or reduction in cost, the mill has evaluated end-of-pipe color reduction
technologies three times in the past thirteen years, including a 2001 study by
Jacobs Engineering Group, Inc. (2001 Color Removal Technology Assessment,
the "Jacobs Report"). The Jacobs Report evaluated 16 end-of-pipe technologies.
It is clear that no breakthrough in economic or technical feasibility has or is likely
to occur in end-of-pipe color removal technologies. Such technologies have not
been commercially demonstrated and are generally not economically feasible
because they require a significant initial capital investment with continued
operating costs and no associated savings.
During this same thirteen-year period, however, the Canton Mill implemented
alternative in-process pollution prevention technologies including oxygen
delignification, Elemental Chlorine Free bleaching, Bleach Filtrate Recycle TM and
those technologies comprising the "Near-Term" package, resulting in a significant
reduction in the color discharged.
Therefore, based upon this record, it is Blue Ridge's intention in the future to
focus on in-process pollution prevention technologies and the potential treatment
of selected, colored wastewater streams before they enter the wastewater
treatment plant (WWTP) and, in particular, the Chloride Removal Process (CRP).
Blue Ridge believes in-process pollution prevention and treatment of selected
wastewater streams hold the greatest likelihood of success for further color
reduction. In the future, Blue Ridge believes its time and resources would be
Permit No. NC0000272
Page 4

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
better devoted to in-mill treatment of particular wastewater streams rather than
end-of-pipe, secondary effluent color removal approaches.
3.2 Polyamine Trials
Polyamine addition trials were conducted in January 2001 at the primary clarifier,
secondary clarifier, and colored in-mill wastewater streams, and were not
successful-.-The concept of polyamine addition is to reduce color through
precipitation of color bodies, which attach to the polyamine, coagulate, and settle
in primary clarification. Numerous trial approaches were conducted to study
comprehensively the effectiveness of polyamine for color removal. While
treatment of colored wastewater streams in the pulping and recovery areas
appeared to remove color, the color bodies re-solubilized in the wastewater
collection system and there was no significant net reduction in secondary effluent
color. Treating the primary clarifier resulted in color reductions, but wastewater
treatment plant sludge quality declined to an unmanageable condition and
recycled belt press filtrate solids increased significantly. Treating the secondary
effluent resulted in minimal color reductions; in addition, this type of treatment
would require the installation of equipment and increased operating costs as
described in the Jacobs Report , and might have adverse effects on the chronic
toxicity of the wastewater discharge.
3.3 CRP Treatment with Lime
Laboratory studies were recently performed on the Chloride Removal Process
(CRP) purge stream, a relatively high color, low flow stream,associated with the
BFRTM process. The purge stream was treated with various sources of calcium
in an effort to precipitate color bodies. Lime precipitation was concluded to be
Permit No. NC0000272
Page 5

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
infeasible due to the massive quantities necessary to partially reduce color and
the large quantities of solid waste generated.
3.4 Third Party Evaluation of Canton Mill
As part of Blue Ridge's commitment to continued color reduction, the Canton Mill,
in collaboration with a coalition of environmental groups, engaged Dr. Norm
-Liebergott,—President of--Liebergott—&Associates Consulting Inc., and Lewis
Shackford, Vice president of Technology for GL&V Pulp Group Inc., a major
supplier to the pulp and paper industry, to undertake a thorough evaluation of the
mill's pulping and bleaching operation. The evaluation is focusing on potential
process and equipment modifications targeted at environmental performance
improvements. Liebergott and Shackford will identify options for consideration
that may lead to decreased effluent load, in particular color, with technologies
that will not increase effluent toxicity. Blue Ridge plans to submit this information
to the Division of Water Quality for its consideration in conjunction with the
information from the Technology Review Workgroup (TRW) to evaluate options
for potential reductions in effluent color over the term of the next NPDES Permit.
Permit No. NC0000272
Page 6

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
IV. Commitments to Further Color Reduction
The Canton Mill is committed to further discharge color reduction. In conjunction
with the Technology Review Workgroup (TRW), the Canton Mill believes further
color improvements may be achieved utilizing the following options.
4.1 BFR Improvements
-Since October 1998, the average-BFR closure rate of the pine fiberline D1 and
Eo stages has averaged approximately 74%. This rate is lower than the targeted
BFR closure rate of 80%.
The obstacles to achieving a sustained pine fiberline closure of 80% are related
to the operational reliability of the BFR equipment, primarily the Metals Removal
Process (MRP). Blue Ridge is committed to undertake improvements to the
MRP in order to achieve an 80% pine fiberline closure rate. These
improvements include a new media filter and softener, rebuilding piping and
valves, and changing materials of construction to better withstand the harsh
environment (corrosivity, erosion and deposition). Blue Ridge estimates the cost
of these improvements to be up to $1,300,000 and the estimated discharge color
reduction from these upgrades to be 1,000 — 1,200 Ibs/day.
The other component of the BFR process is the Chloride Removal Process
(CRP). The CRP system purges chloride and potassium from the mill's chemical
recovery system. This purge is a low flow, relatively high color stream that
contributes an average of 6,000 Ibs of color per day to the wastewater treatment
plant primary influent (or less than 4,000 Ibs/day in the discharge). The Canton
Mill will investigate potential technologies that may reduce this source of color.
Permit No. NC0000272
Page 7

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
4.2 Additional Black Liquor Leak and Spill Control
The Canton Mill has extensive equipment to reduce black liquor leaks and spills.
Additional improvements to further manage black liquor losses to the wastewater
collection system are currently under evaluation. The first improvement involves
diversion of clean water from the digester area sump. This diversion of clean
water will prevent dilution of concentrated brown color, thereby allowing the sump
to capture a greater percentage of the -brown color from the digester area.
Another upgrade is to collect the filtrate from the knotter bins to reclaim color that
is leached from knots. An evaluation of alternatives to reduce screen room color
will also be conducted. Blue Ridge estimates the cost of these improvements to
be in excess of$100,000. The discharge color reduction could be in the range of
1,000 — 3,000 Ibs/day.
4.3 Evaluation of Potential In-Process Color Reduction Technologies
As described in Section 3.4, Liebergott and Shackford are evaluating
technologies that may result in reduced discharge color. While this report is not
yet complete, Blue Ridge can provide an overview of Liebergott's and
Shackford's scope of work.
The scope of the Liebergott and Shackford study involves evaluation of potential
process modifications to see if such modifications are technically, operationally
and economically feasible. The report will consider impacts on process control,
production capability and pulp production cost and quality. Liebergott and
Shackford will consider changes to each fiberline, 2-stage oxygen delignification,
strategic use of hydrogen peroxide and the alternative use of peracetic acid
Permit No. NC0000272
Page 8

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
and/or ozone in the bleaching stages.. An evaluation of whole mill effluent and
segregated higher color wastewater streams will also be conducted.
A final report will be issued summarizing the technical, economic and operational
feasibility of the technologies reviewed, including a discussion of commercially
demonstrated use. This report will be provided to the Division of Water Quality.
In addition to- this third -party assessment, the USEPA has a dedicated
Technology Review Workgroup that is studying additional color reduction
technologies. This report is also expected to be available to the Division of
Water Quality in the second quarter of 2001.
Permit No. NC0000272
Page 9

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
V. Conclusion
The Canton Mill has successfully reduced color from 83,000 Ibs/day to less than
48,000 Ibs/day over the term of the 1997 NPDES Permit. Blue Ridge is
committed to further improvements to the BFR process, the digester area spill
control systems and to the knotter and screen operations, which will further
reduce discharge color. Blue Ridge is also committed to evaluating other
process technologies, which may reduce color, over the term of the 2001 NPDES
Permit.
Permit No. NC0000272
Page 10

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
I. Introduction
The following report describes the statistical evaluation of the Canton Mill's color
discharge since completion of the color reduction activities required by the
modified 1997 NPDES Permit and Settlement Agreement. Part III, E. Paragraph
14 of the revised 1997 Permit provides, in part, the following:
"... Further, based on the continued development of color
discharge information from the reconfigured mill, the permittee
will statistically evaluate its monthly average color discharge, its
annual average color discharge, and the performance of the mill
in relation to color discharged..."
This report is submitted to fulfill this requirement of Part III, E. Paragraph 14.
Permit No. NC0000272
Page 1

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
II. Discussion
The Canton Mill has achieved a color reduction of over 88% since 1988 in the
annual average amount of color discharged, as illustrated in Figure 1. The
improved color performance is due to the Canton Modernization Project, full
implementation of the "Near-Term Package' and continuous color management
by the mill.
The Near-Term Package included the installation of BFWm on the mill's pine
fiberline, implementation of best management practices (BMPs) detailed in the
June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on
the hardwood fiberline. Partial hardwood Eo recycle was still being evaluated
and optimized through December 1999, and therefore, the January 2000 —
December 2000 time period was used as the basis for the statistical evaluation.
This period is representative of mill discharge color performance after
implementation of all activities (i.e. "the reconfigured mill") required in the 1997
NPDES Permit. However, it is important to note that November and December
2000 are not representative of typical mill pulp production. This is due to the No.
19 Paperboard Machine outage and start-up, when pulp production was very low
compared to normal operation.
Permit No. NC0000272
Page 2

Figure 1: Canton Mill Secondary Effluent Color Performance
Annual Averages: 1988 - 2000
400000 Including Permit Limitations
Permit Limitations:
350000 1-258,945#/d Monthly Ave.efi.4114/94
2-172,368#/d Annual Ave.eft.4/14/94
3-125,434#/d Monthly Ave.eH.12/12/96
4-98,168#/d Annual Ave e6.12/12/96
6-95,000 Old Monthly Ave eft.111198
300000 6-69,000 91d Monthly Ave.eR.1211198
T 7-60,000#/d Annual Ave.e8.1211/98
to 8-48,000#/d Annual Ave.eff.5/1/01
9
N
c 250000
ti
0 1
0
U
d 200000
LU
w
D150000
c 2
0
u
rn 100000 3
4
5
50000 6 7
8
0
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000
Blue Ridge Paper Products, Inc.
®Permit Limitaions i SE Color Annual Ave. Wd
Canton Mill 5/31/01

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
III. Statistical Evaluation of Color Performance Data
The attached Table summarizes the statistical evaluation. Based on January
2000 — December 2000 color data, the 95th percentile expected annual average
is 46,475 Ibs/day. This 95th percentile annual average is representative of the
reconfigured mill's performance.
The monthly average numbers were calculated, using the same data as above,
by two different statistical methods. The expected monthly color average based
on a 95th percentile distribution is 54,089 Ibs/day. Using a 95th percentile
distribution and interpolation from ranked observations, the expected monthly
color average is 55,003 Ibs/day. These two 951h percentile monthly average
numbers represent current mill performance. The maximum monthly average
observed during this time period was 58,009 Ibs/day.
1 Interpolated numbers come from the empirical (i.e. the actual ranked values) data
using the calculated percentile by assuming it lies linearly between the closest smaller
percentile and the closest larger percentile within the cumulative percentage distribution.
Due to the limited data set available, an interpolated statistical evaluation is only
possible for a monthly value, not for an annual value.
Permit No. NC0000272
Page 3

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
IV. Conclusion
Based upon color discharge data during the period after the Mill had
implemented all improvements required by the 1997 NPDES Permit, the
expected annual average is 46,475 Ibs/day. Expected monthly color averages
using the same data from two different statistical evaluations are 54,089 and
55,003 Ibs/day.
Using North Carolina's governing flow criteria (30Q2), historical flow records, and
the 2000 annual average color discharge of 43,386 Ibs/day, it is expected that
color in the Pigeon River at the Hepco gage will be less than 50 true color units
100% of the time at all flows above 30Q2.
Permit No. NC0000272
Page 4

Table 1: June 1, 2001 Statistical Evaluation
Monthly Average Data -Max Month/Annual Calculation
Data Set January 2000- December 2000
n = 12
X-bar 43,386
std dev 6527
95th percentile for Month 54,089
99th percentile for Month 58,593
Max month 58,009
95th percentile for Year from normal distribution 46,475
99th percentile for Year from normal distribution 47,775
Ranked observations-by interpolation
95th percentile for max month 55,003
99th percentile for max month 57,408
BRPP Inc.
Canton Mill
June 1,2001 Statistical Evaluation
Attachment

BLUE RIDGE _
PAPER PRODUCTS INC.
ECJ�71
SIN 1 5 2001 ,
_ I..
HEtl�QUALITY SECTION
REGIONAL OFFICE
June 14, 2001
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products Inc. Canton Mill
Addendum to June 1, 2001 Statistical Evaluation
Dear Mr. Westalh
As we discussed on May 31, 2001, a statistical evaluation was performed on the mill color data
from January 2000 through October 2000. The 95 s percentile expected monthly color from this
data was 54,773 Ibs/day and the 95°percentile expected annual color was 47,704 lbs/day.
In November of 2000, substantial process improvements were implemented on No. 19
Paperboard Machine to improve product quality and yield. No. 19 Paperboard Machine
manufactures over half of the total daily production of the Canton Mill. As of June 14, 2001,this
machine is still under-performing,which limits pulp mill production by as much as 100 to 150
tons per day. During November 2000,an equivalent of one fiberline was out of service.
Please call me at [phone] if you have any questions or concerns regarding these reports.
Sincerely,
Deric Brown
Manager—Environmental Affairs
Xc: Don Anderson
Keith Haynes
Mike Meyers
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

OF W ArFR Michael F. Easley
JF pG Governor
ij William G. Ross,Jr.,Secretary
> Department of Environment and Natural Resources
O Y Kerr T.Stevens
Division of Water Quality
MEMORANDUM
To: Jimmie Overton 5
Forrest Westall q 2001 I_,
Through: Trish MacPherson'"" — QQ
From: Bryn H. Tracy T ASHEVILLEURFG SIE otiCE
JALO
Subject: Comments on the NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc., Canton Mill,
Balanced and Indigenous Species Study for the Pigeon River
I have reviewed this study and my comments are provided herein:
1. This study was required by NPDES permit, but the work was not performed by a NCDWQ-certified laboratory.
2. in a letter from Ms. Coleen Sullins to Mr. Robert Williams (Blue Ridge Paper Products, Inc, (BRP)), it was specifically
stated: "Task 1 --It is important to select species for modeling, which are native to the Pigeon River basin." And in an
e-mail from me to Keith Haynes (dated March 17, 2000), 1 specifically requested: "Task 1 -- Species chosen for study
should be those native species currently inhabiting the Pigeon River or species that were known or suspected to have
occurred in the river prior to mill operation but no longer occur in the river due to mill operation. The importance of
modeling species native to the French Broad River and Pigeon River basins can not be over emphasized." Two of
the species (common carp and redbreast sunfish) which were modeled are not native to the basin and should not
have been modeled. Other species, such as the river chub, mottled sculpin, and banded sculpin should have been.
NC DWQ was not given the opportunity to comment on the species chosen for modeling.
3. In the same letter and e-mail, it was stated: "It is our findings that there are currently no nuisance species in the river.
And, . . ."to my knowledge, there are no commercially important or nuisance species in the river. Common carp
should not be modeled as a nuisance species. Consultant should define nuisance species". The consultant never
defined nuisance species prior to the study and common carp should not have been modeled as a representative
important species. My use of the word: "nuisance" was based upon their study plan, where they stated: ". . . and
one species that has the potential to become a nuisance species". My definition or understanding of "nuisance" was
different than BRP's definition.
4. In the same letter and (more emphatically) in the same e-mail it was stated: "The NCIBI should not be used as its
metrics were not calibrated nor was it correctly designed for streams the size of the Pigeon River". Despite this, the
1995/1997 version of the Index was used. Conclusions based upon the 1995/1997 Index and its metric criteria were
not and are not currently valid.
5. Page 1-2 -- "By the mid-80's the aquatic life in the river was consistent with the expectations for a Class C stream in
North Carolina (EA 1988)". This statement, which was repeated in 1990s reports, was pointed out in 1996 to BRP (at
that time Champion International Corp.) that their interpretation of the regulations was in error and this statement was .
not true.
'
t•NCDENIR
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621 [phone]
1 800 623-7748

OF W A rFR Michael F. Easley
PG Governor
William G.Ross,Jr.,Secretary
j Department of Environment and Natural Resources
O Y Kerr T. Stevens
Division of Water Quality
6. Page 3-1 -- If recolonization sources are lacking downstream of the mill and because the darter fauna in the Pigeon
River has been severely impacted for many decades, would BRP (and other responsible entities and interested
parties) fund efforts to reintroduce species that were eradicated by the mill's effluent and prevented from
recolonization by the Walters Dam?
7. Pages 3-2 and 3-3 -- "Species richness in the most thermally affected zone (Fiberville) is comparable to upstream of
the mill and better than the NC zones further downstream" --this maybe true, but the species (and their abundances)
above and below the mill are entirely different. Later(buried in the report), Table 4-7 shows that the fauna of the most
thermally affected site is only 16% similar to that of the reference site. Equating equal species richness at the two
sites with having no thermal impact and indicative of a balanced fish community below the mill is not valid.
8. Pages 3-2 and 3-3 --common carp and redbreast sunfish are not native to the Pigeon River basin and both species
are considered tolerant. Nuisance species, as requested in an earlier correspondence, was never defined.
9. Pages 3-2, 3-3, and 3-9-- redbreast sunfish is a thermally tolerant fish whose percent abundance progressively
declines the further removed from the mill (refer to Table 4-2). Above the mill, the species constitutes only 2.5% of
the fauna, at Fiberville 64%, and at River Mile 19.3, 0%. Contrary to the report, this species clearly indicates that
nuisance species are dominant and the community, at certain sites, is dominated by thermally tolerant species.
Likewise, biomass data (page 4-15) also show the dominance of these two species in the nearfield areas (53%-68%).
10. Page 3-3 -- YOY (young-of-year) should not be collected and-should not be considered when using the NC IBI (or any
other version).
11. Page 3-4-- as earlier stated, the NC IBI should not have been used as a measure of community health or as a tool to
assess thermal impacts.
12. Page 3-4 -- if the upstream site is used as the reference site (a thermally unimpacted site), then downstream sites
clearly show spatial faunal differences that can be attributed, at least in part, to temperature differences.
13. Page 3-5 -- what is BRP's evidence (basis) that the river below the mill should not be cool water system, like it is
above the mill? The elimination of darters and other species was most likely due to extremely poor water quality (in
the broadest sense including chemical and thermal pollutants). The recovery below the mill in North Carolina of the
greenside darter, greenfin darter, tangerine darter, and other species will likely take a long time, if ever.
14. Page 3-9 -- species richness conclusion -- this is clearly a misinterpretation of the data.
15. Page 3-10 -- Competitive Advantage to Certain Species -- Redbreast sunfish seemed to dominate the communities
below the mill. Would not this species decrease and rockbass increase if the temperature below the mill was cooler?
16. Page 3-11 -- Community Dominated by Thermally Tolerant Species -- "Furthermore, most citizens and anglers
probably consider the presence of large numbers of redbreast sunfish to be a positive attribute of the fish community
rather than a negative one." This clearly is an opinion and not supported by any published facts. The redbreast
sunfish is not native to the mountain streams and is a indicator of some past alteration to the stream and community.
In eastern Tennessee, this species is implicated in out-competing and displacing the native longear sunfish (Etnier
and Starnes 1993. This presence and abundance of the redbreast sunfish in mountain waters should not be viewed
as a positive attribute.
VA
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh,NC 27699-1621 [phone]
1 800 623-7748

F WArF
\Oct RQG Michael F.Easley
Governor
rWilliam G. Ross,Jr.,Secretary
,i Department of Environment and Natural Resources
O * Y Kerr T.Stevens
Division of Water Duality
17. Page 3-13 --Common Carp -- "The state has already stated that common carp is not a nuisance species in the Pigeon
River(memo from Bryn Tracy dated 17 March 2000)." The exact wording of my memorandum was: "To my
knowledge, there are no commercially important or nuisance species in the river. Common carp should not be
modeled as a nuisance species. Consultant should define nuisance species." I believe my words were taken out of
context and meaning.
18. Page 3-15 -- Redbreast sunfish -- "Since this is a popular species with anglers, it is expected that most people would
view its increased abundance downstream of the mill as a positive rather than an adverse impact." Clearly, this is an
opinion and not based upon published facts.
19. Pages 3-15 and 3-16-- Darters --The presence of one or two individuals of any species of darters (or any other
species) downstream of the mill does not equate with viable populations and with improving and tolerable conditions.
20. Appendix A, Page 1-1 -- "The North Carolina Division of Water Quality(NCDWQ) does not have an established
protocol for conducting 316(a) demonstrations(email from Mr. Bryn Tracy date 116100). Nonetheless, biological
sampling was conducted in accordance with standard NCDWQ field protocols." The precise wording of my e-mail
was: "The North Carolina Division of Water Quality does not have a formal protocol for conducting 316 (a)
demonstrations such as the one being proposed for the Pigeon River. Typically, the Division handles the study
design on an informal communicative basis. You would, however, be safe in using the federal protocol and having us
approve the study design before the actual sampling is to be conducted later this year. In terms of the benthic
invertebrate community, the thermal effluent is treated just like any other WWTP effluent and upstream-downstream
type studies are done." In a later email (dated 03/17/200) and in a letter from Ms. Sullins, BRP was instructed not use
the NCIBI in its 316 (a) demonstration.
21. Appendix A, Page 2-12 -- "For this report, the IBI is used only to compare the 1995 and 2000 results". This statement
is not valid. The inaccurately-derived Index is used to support BRP's position that a continuation of the variance is
warranted.
22. Appendix A, Page 4-8 -- "No single species dominate the mainstream catch." The redbreast sunfish's abundance,
below the mill in North Carolina, constituted 64% (near field) to 17% (far field) of all the fish collected. Approximately
25%of all the fish collected from the entire river were the tolerant redbreast sunfish.
23. Appendix A, Page 4-11 -- Percent Similarity-- as mentioned earlier, the thermally affected sites below the mill were
very dissimilar to the thermally unimpacted reference site.
24. Appendix A, Page 4-26 -- Life Stage and Spawning Activity--This assessment should have been made on a site-by-
site basis, not for the entire river from River Mile 64.5 to River Mile 19.3. Young-of-year should also not be included in
the analyses.
BHT/bht
PC: Dave Goodrich
&Keif.'Haynes; ,
Michael Meyers
AVIA
NCDM
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621 [phone]
1 800 623-7748

1
BLUE RIDGE PAPER PRODUCTS INC.
1
bxc: Mike Ferguson
Dave Goodrich
Melanie Hager
C:Ke`itFHaynes---)
Terry Huskey
Mike Meyers
Steve Single
Forrest Westall
Bob Williams
WAT�I�LF RE�0lA1C-O�yCE
ASHES

BLUE RIDGE
PAPER PRODUCTS INC.
July 17, 2001
Mr. Don Anderson
U.S. Environmental Protection Agency
Mail Code 4303
Room 195A, East Tower
401 M Street, SW
Washington, D.C. 20460
Re: Response to EPA Tech Team's July 10, 2001 Draft Final Report
Dear Mr. Anderson:
Attached are Blue Ridge Paper Products Inc. (Blue Ridge) comments on the July 10,
2001 EPA Tech Team Report. These comments are in addition to Bob William's July
13, 2001 email to you.
This information is consistent with Blue Ridge's May 18, 2001 and June 4, 2001
response to the EPA Tech Team and the Liebergott and Associates and GL&V Pulp
Group, Inc. Bleach Environmental Process Evaluation and Report. Incorporation of
these technical comments in the Final EPA Tech Team Report is important to Blue
Ridge Paper Products Inc.
Please call me at [phone] or Bob Williams at [phone] if you have any
questions or need additional information.
Sincerely,
Derric Brown
Manager— Environmental Affairs
Blue Ridge Paper's Response to Tech Team's 7/10/01 Draft Report
7/18/01
1
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
Table 1: Summary of Process Improvements and Associated Color Reductions
Process Improvement Influent Final
Color Effluent
Reduction Color
(lbs/day) Reduction
(lbs/day)
1 BFR reliability improvement Tech Team: --- 1,000-1,200
Blue Ridge: 1,000-1,200
23 Improved black liquor leak & spill collection and control
Tech Team: --- > 5,000
Blue Ridge: 2,800-8,300 1,000-3,000
6 Process Optimization
Tech Team: 1,700 1,400
Blue Ridge: 1,100 900
TOTAL FINAL EFFLUENT COLOR REDUCTION Tech Team: >7,400
Blue Ridge: 2,900-5,100
aBlue Ridge agrees there are additional opportunities to reduce color from black liquor leaks and
spills. However, the draft final EPA tech team effluent color reduction estimate is too high and
is not reasonably achievable. In 2000 there was approximately 12,000 pounds per day of color
from all black liquor sources (excluding CRP). Based on previous studies conducted at the
Canton Mill by Duke University graduate students, an average of 64% of brown color was
removed across the simulated wastewater treatment plant. A 5,000 pound per day final effluent
color reduction as shown in the draft Tech Team Report would require 13,900 pounds of influent
color treated at the average level of 64%. There is not 13,900 pounds of influent brown color
available; therefore, it is unreasonable to achieve a >5,000 pound per day effluent color
reduction. Blue Ridge estimates a 1,000 — 3,000 pound per day reduction in brown color is
achievable and would require a 2,800 —8,300 pound per day reduction in influent color based on
a 64%wastewater treatment efficiency.
bThe Bleach Environmental Process Evaluation and Report (BEPER) prepared by Liebergott and
Associates and GL&V Pulp Group, Inc. states the color reduction from process optimization may
potentially be up to 1,100 pound per day. The Tech Team estimated an additional color
reduction from the CRP purge stream of 600 pounds per day resulting from the decreased
chlorine dioxide usage. As Blue Ridge has stated previously, a reduction in chlorides does not
necessarily translate into a reduction in the amount purged from the CRP or to a reduction in
color in the CRP purge. While reduced liquor system chlorides may translate into a reduced
CRP purge rate, a reduced purge rate would not be expected to result in a reduction of the total
mass of color in the CRP purge. Chloride purging and CRP color are independent variables.
The amount of color in the precipitator-CRP loop is independent of chloride loading. Therefore,
any reduction in volumetric flow rate of the purge stream made possible by reduced chloride
loading will not reduce the amount of color "purged" from the CRP. Since the absolute mass of
color would not change, the concentration of color in the purge stream would be expected to
increase accordingly, resulting in no change in the total mass of color purged. Therefore, Blue
Blue Ridge Paper's Response to Tech Team's 7/10/01 Draft Report
7/18/01
2

BLUE RIDGE PAPER PRODUCTS INC.
Ridge supports an estimated influent color reduction of 1,100 pounds per day and a final effluent
color reduction of 900 pounds per day from process optimization.
Table 2: Summary of Process Improvements and Associated Additional Color Reductions
Needing Further Study
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
3` Ozone/Chlorine Dioxide stage for hardwood
bleach line Tech Team: 3,000-6,400 3,000-6,400
Blue Ridge: 3,550 3,550
4 2"dstage OD for pine line Tech Team: 1,500-2,000 1,100-1,400
Blue Ridge: 1,500-2,000 1,100-1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION
NEEDING FURTHER STUDY Tech Team: 4,100 - 7,800
Blue Ridge: 4,650—4,950
Table 2A: Continued Evaluation of CRP Purge Stream Color Treatment Opportunities
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
5 dColor Treatment of CRP Purge Stream
Tech Team: 6,000 3,300
Blue Ridge: 0-5,000 0-2,300
TOTAL POTENTIAL FINAL EFFLUENT COLOR REDUCTION
Tech Team: 3,300
Blue Ridge: 0-2,300
`Based on an extensive analysis of the operating conditions and equipment at the Canton Mill,
the BEPER estimated a color reduction of 3,550 pounds per day from the use of an
ozone/chlorine dioxide (ZD) stage for the hardwood bleach line. Therefore, the 3,000 — 6,400
pound per day range should be revised to 3,000—4,000 pounds per day.
dThe Tech Team assumes that color treatment of the purge stream will be feasible. Blue Ridge
conducted laboratory tests using polyamine and various sources of lime or calcium to remove
color from the CRP stream. While color was removed in the laboratory at very high dosages, the
cost for coagulants and/or precipitants would be very high. In addition, for this low flow stream,
Blue Ridge Paper's Response to Tech Team's 7/10/01 Draft Report
7/18/01
3

BLUE RIDGE PAPER PRODUCTS INC.
• large-scale equipment would be required to handle the solids and significant quantities of
additional solid waste would be generated. Blue Ridge recommends removing Item 5, Color
Treatment of the CRP Purge Stream, from Table 2. While Blue Ridge supports conducting a
study of potential CRP color removal options, there are no known feasible options available at
this time.
Based on actual test data the CRP purge averages approximately 4,500—5,000 pounds per day of
influent color. Assuming CRP color is treated similarly to brown color, a 64% reduction in CRP
color currently achieved across the WWTP would result in approximately 2,300 pounds per day
of final effluent color.
Table 3: Estimated Costs
Process Improvement Capital Annual O&M
Cost ($/year)
($)
1 BFR reliability improvement Tech Team: $1,300,000 $85,000
Blue Ridge: $1,300,000 $85,000
2 Improved black liquor leak &spill collection and
control Tech Team: $100,000 $50,000
Blue Ridge: $100,000 $50,000
3 Ozone/Chlorine Dioxide stage for hardwood bleach
line Tech Team: $1,500,000 ($350,000)
savings
Blue Ridge: $1,500,000- ($350,000)
2,000,000''r
4 2" stage OD for pine line
Tech Team: $2,000,000 ($3,100,000)
Blue Ridge: $2,500,000 ($800,000-
-3,000,000 r 1,200,000)'
'Installed costs for the Ozone generation and power supply systems are estimated to be in excess
of an additional $3,000,000.
rAdditional cost is required due to the constructability of this system in this area of the mill.
'Appendix 4 of the July 10, 2001 draft final Tech Team Report correctly adjusted the oxygen
delignification stage input kappa number to 24. However, the yield credit of 1.5% is still shown
for the proposed two-stage oxygen delignification system. The yield credit for a 2-stage oxygen
delignification system at Canton is zero (0). Therefore, the annual O&M cost should be adjusted
down from a $3,100,000 savings as shown in the draft final Tech Team Report to an $800,000 -
$1,200,000 annual savings.
Blue Ridge Paper's Response to Tech Team's 7/10/01 Draft Report
7/18/01
4

R
•I M k
M
STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
Division of Water Pollution Control
6°'FI. L & C Tower
401 Church Street
Nashville, Tennessee 37243 - 1534
PHONE: [phone]; FAX: [phone]
April 16, 2001
The Honorable Charles Lewis Moore
Cocke County Executive
Room 146, Court House Annex !Ll�,p��r_ ,_ �� I _�,�_
360 East Main Street tl� r!I ��
Newport, Tennessee 37821 I
Ji1 APR r 9 ��`
RE: Pigeon River
Joint Watershed Advisory ASHn,. f '_ %5
cc
Committee Meeting May 8, 2001
Dear Mr. Moore:
At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we
agreed that we would like to invite the EPA technical experts on pulp and paper to visit
with the committee and discuss about pollution control and wastewater treatment
technology. I am pleased to report that this meeting has been scheduled, and that EPA has
committed to have their national experts meet with both our committee and the
Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper
Products will contact the other committee.
The meeting will be from 9:00 am to noon at the Newport Community Center. That's
located on Highway 321, the Cosby Highway, about a mile or so north ofI-40 at exit 435.
The Community Center will be on the right as you go north. It has plenty of parking and
you will want to use the upper entrance. We have the upstairs meeting room reserved.
Please contact me at 615/531-0632 if you have.any questions.
Sincerely,
a.�
Paul E. Davis
Director
Division of Water Quality Control
PED/gss

STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
Division of Water Pollution Control
6`h Fl. L & C Tower
401 Church Street
Nashville, Tennessee 37243 - 1534
PHONE: [phone]; FAX: [phone]
April 16, 2001
Mr. David Dudek _"
Haywood Community College
185 Freedlander Drive ti APR 19 2001 ���
Clyde, North Carolina 28716 r
i�. AShCVI lEU.;i�r S`("TIO,p
RE: Pigeon River l pFRbS
Joint Watershed Advisory
Committee Meeting May 8, 2001
Dear Mr. Dudek:
At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we
agreed that we would like to invite the EPA technical experts on pulp and paper to visit
with the committee and discuss about pollution control and wastewater treatment
technology. I am pleased to report that this meeting has been scheduled, and that EPA has
committed to have their national experts meet with both our committee and the
Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper
Products will contact the other committee.
The meeting will be from 9:00 am to noon at the Newport Community Center. That's
located on Highway 321, the Cosby Highway, about a mile or so north of I-40 at exit 435.
The Community Center will be on the right as you go north. It has plenty of parking and
you will want to use the upper entrance. We have the upstairs meeting room reserved.
Please contact me at 615/531-0632 if you have any questions.
Sincerely,
Paul E. Davis
Director
Division of Water Quality Control
PED/gss

STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
Division of Water Pollution Control
6'h Fl. L & C Tower
401 Church Street
Nashville, Tennessee 37243 - 1534
PHONE: [phone]; FAX: [phone]
April 16, 2001 7ar ,
Mr. Tim Dockery 1
Newport Parks and Recreation
433 Prospect Avenue IONNewport, Tennessee 37821 L AFFICE
RE: Pigeon River
Joint Watershed Advisory
Committee Meeting May 8, 2001
Dear Mr. Dockery:
At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we
agreed that we would like to invite the EPA technical experts on pulp and paper to visit
with the committee and discuss about pollution control and wastewater treatment
technology. I am pleased to report that this meeting has been scheduled, and that EPA has
committed to have their national experts meet with both our committee and the
Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper
Products will contact the other committee.
The meeting will be from 9:00 am to noon at the Newport Community Center. That's
located on Highway 321, the Cosby Highway, about a mile or so north of I-40 at exit 435.
The Community Center will be on the right as you go north. It has plenty of parking and
you will want to use the upper entrance. We have the upstairs meeting room reserved.
Please contact me at 615/531-0632 if you have any questions.
Sincerely,
c� LL—o
Paul E. Davis
Director
Division of Water,Quality Controb- -
PED/gss -"

STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
Division of Water Pollution Control
6`h Fl. L & C Tower
401 Church Street
Nashville, Tennessee 37243 - 1534
PHONE: [phone]; FAX: [phone]
April 16, 2001
Mr. Kenny Sutton
Post Office box 1772
Canton, North Carolina 28716 //, ✓
19
RE: Pigeon River sy`t;F?91,
Joint Watershed Advisory
Committee Meeting May 8, 2001
y 4/�
Dear Mr. Sutton:
At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we
agreed that we would like to invite the EPA technical experts on pulp and paper to visit
with the committee and discuss about pollution control and wastewater treatment
technology. I am pleased to report that this meeting has been scheduled, and that EPA has
committed to have their national experts meet with both our committee and the
Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper
Products will contact the other committee.
The meeting will be from 9:00 am to noon at the Newport Community Center. That's
located on Highway 321, the Cosby Highway, about a mile or so north of I-40 at exit 435.
The Community Center will be on the right as you go north. It has plenty of parking and
you will want to use the upper entrance. We have the upstairs meeting room reserved.
Please contact me at 615/531-0632 if you have any questions.
Sincerely,
Paul E. Davis
Director
Division of Water Quality Control
PED/gss —

��ku
STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
Division of Water Pollution Control
61h Fl. L & C Tower
401 Church Street
Nashville, Tennessee 37243 - 1534
PHONE: [phone]; FAX: [phone]
April 16, 2001
Mr. Jerry Wilde
402 West Broadway 4P1 v y�
Newport, Tennessee 37821 R /9 f�
,,`ASIYq�F Z�Qw,d
RE: Pigeon River
Joint Watershed Advisory
Committee Meeting May 8, 2001
Dear Mr. Wilde:
At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we
agreed that we would like to invite the EPA technical experts on pulp and paper to visit
with the committee and discuss about pollution control and wastewater treatment
technology. I am pleased to report that this meeting has been scheduled, and that EPA has
committed to have their national experts meet with both our committee and the
Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper
Products will contact the other committee.
The meeting will be from 9:00 am to noon at the Newport Community Center. That's
located on Highway 321, the Cosby Highway, about a mile or so north of I-40 at exit 435.
The Community Center will be on the right as you go north. It has plenty of parking and
you will want to use the upper entrance. We have the upstairs meeting room reserved.
Please contact me at 615/531-0632 if you have any questions.
Sincerely,
Paul E. Davis
Director
Division of Water Quality Control
PED/gss

XR
n
STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
Division of Water Pollution Control
6`h Fl. L & C Tower
401 Church Street
Nashville, Tennessee 37243 - 1534
PHONE: [phone]; FAX: [phone]
April 16, 2001
Mr. Jack Horton, County Manager '^
Haywood County Manager's Office (/11� .il�7
215 North Main Street
Waynesville, North Carolina 28786
Newport, Tennessee 37821 9
RE: Pigeon River
cFc,J
Joint Watershed Advisory ICE
Committee Meeting May 8, 2001
Dear Mr. Horton:
At our March meeting of the Pigeon River Joint Watershed Advisory Committee, we
agreed that we would like to invite the EPA technical experts on pulp and paper to visit
with the committee and discuss about pollution control and wastewater treatment
technology. I am pleased to report that this meeting has been scheduled, and that EPA has
committed to have their national experts meet with both our committee and the
Community Advisory Committee in Newport. Bob Williams with Blue Ridge Paper
Products will contact the other committee.
The meeting will be from 9:00 am to noon at the Newport Community Center. That's
located on Highway 321, the Cosby Highway, about a mile or so north of I-40 at exit 435.
The Community Center will be on the right as you go north. It has plenty of parking and
you will want to use the upper entrance. We have the upstairs meeting room reserved.
Please contact me at 615/531-0632 if you have any questions.
Sincerely,
Paul E. Davis
Director
Division of Water Quality Control
PED/gss

s
1
BLUE RIDGE
PAPER PRODUCTS INC.
December 28,2000
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
January 1,2001 Color Limit Feasibility Report
Dear Mr. Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24,
and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 99 s percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 Ibs/day and an average monthly color limit of 59,796 lbs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit), Blue Ridge Paper Products recommends using a 95's percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 95 h percentile statistical review of the
limited data available from January 1998—October 31, 2000 the annual average color is 48,388 lbs/day
and the monthly average color is 55,556 lbs/day. Blue Ridge Paper Products believes the 95°percentile
confidence interval will be appropriate with the additional color data that will be available for the June I,
2001 analysis. The attached Table includes the summary of the 99° and 95°percentile statistical data.
Please call me at(828) 646-2033 or Derric Brown at(828) 646-2318 if you have any questions regarding
this report.
(Sincerely,
Bob Williams
Director-Environmental,Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

BLUE RIDGE
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000—52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997
Permit provides in part, as follows:
"...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 lbs/day
based on full implementation of the Near-Term Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits... "
This report is submitted to fulfill the requirements of Part III,Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000, Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000—52, 000 pounds per day is feasible.
I

January 1, 2001 - Color Limit Feasibility Report
Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
400000
N
.0
v
L
0 300000
0
U
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jui-96 Apr-99
-+--SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
II. Color Performance
The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual
average amount of color discharged, as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project, full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRm on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average
annual color discharged was 41,048 lbs/day. The 2000 average annual color(through
October) is 44,837 lbs/day. All of these values are within or below the target annual
average color range of 48,000— 52,000 lbs/day specified in Part III,Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion (30Q2),historical flow records, and the
January 1998—October 2000 annual average color value of 45,458 lbs/day, it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
3

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
III. Recommended Color Limits
The January 1998 —October 2000 actual average annual color of 45,458 lbs/day and the
January 2000—October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000—52,000 lbs/day specified in Part
III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated, that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 lbs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color,Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998 —October 2000 annual color average using a 99a'percentile
distribution is 49,612 lbs/day. The January 2000—October 2000 annual color average
using a 990'percentile distribution is 48,911 lbs/day. These values are both within the
48,000—52,000 lb/day range. Based on a statistical review of the data and the limited
data set available,Blue Ridge Paper Products,Inc. recommends an annual average
effluent limit of 49,612 lbs/day.
The January 1998— October 2000 monthly color average using a 99`s percentile
distribution is 59,796 lbs/day. The January 2000—October 2000 monthly color average
using a 99a'percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available, Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,796 lbs/day.
4

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
III. Conclusion
Blue Ridge Paper Products, Inc. believes it is feasible to achieve a target annual average
color limit within the range of 48,000— 52, 000 lbs/day. The Canton Mill recommends
an average annual colorlimitof49,612.1bs/day and_an average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria(30Q2),historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepco gage will be less than 50 true color units approximately 97%
of the applicable time.
5

TABLE
January 1, 2001 Color Limit Feasibility Report
Monthly Average Data -Max Month Calc
Data Set= 111/98-10/3112000 11112000-10131/2000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. = 34 10
xbar 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 55556 54773
99th safe MONTH from normal dist 59796 58953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58542 58009

BLUE RIDGE
PAPER PRODUCTS INC.
December 28,2000
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
January 1,2001 Color Limit Feasibility Report
Dear Mr.Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24,
and the Revised Color Variance, paragraph SH. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 99'h percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 Ibs/day and an average monthly color limit of 59,796 lbs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit),Blue Ridge Paper Products recommends using a 95'h percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 95'h percentile statistical review of the
limited data available from January 1998—October 31, 2000 the annual average color is 48,388 lbs/day
and the monthly average color is 55,556 lbs/day. Blue Ridge Paper Products believes the 95`h percentile
confidence interval will be appropriate with the additional color data that will be available for the June 1,
2001 analysis. The attached Table includes the summary of the 99'h and 95'h percentile statistical data.
Please call me at [phone] or Derric Brown at(828) 646-2318 if you have any questions regarding
this report.
Sincerely,
��a''rt�IfYOL,
Bob Williams
Director-Environmental, Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
1. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000—52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997
Permit provides in part, as follows:
"...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 Ibs/day
based on full implementation of the Near-Term Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits... "
This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000,Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000— 52, 000 pounds per day is feasible.
1

January 1, 2001 - Color Limit Feasibility Report
Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
400000
N
.0
O 300000 -- 47 1�
0
V
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
+SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
II. Color Performance
The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual
average amount of color discharged, as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project, full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRm on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 Ibs/day and the 1999 average
annual color discharged was 41,048 lbs/day. The 2000 average annual color(through
October) is 44,837 lbs/day. All of these values are within or below the target annual
average color range of 48,000—52,000 Ibs/day specified in Part III, Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion (30Q2),historical flow records, and the
January 1998 —October 2000 annual average color value of 45,458 lbs/day, it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
3

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
III. Recommended Color Limits
The January 1998 —October 2000 actual average annual color of 45,458 lbs/day and the
January 2000—October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000—52,000 lbs/day specified in Part
III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated, that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 lbs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998—October 2000 annual color average using a 990'percentile
distribution is 49,612 lbs/day. The January 2000—October 2000 annual color average
using a 99a percentile distribution is 48,911 lbs/day. These values are both within the
48,000—52,000 lb/day range. Based on a statistical review of the data and the limited
data set available, Blue Ridge Paper Products,Inc. recommends an annual average
effluent limit of 49,6121bs/day.
The January 1998—October 2000 monthly color average using a 991'percentile
distribution is 59,796 lbs/day. The January 2000—October 2000 monthly color average
using a 99`h percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available, Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,7961bs/day.
4

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
III. Conclusion
Blue Ridge Paper Products, Inc. believes it is feasible to achieve a target annual average
color limit within the range of 48,000— 52, 000 lbs/day. The Canton Mill recommends
an average-annual color limit of 49,612 lbs/day and-an-average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria (30Q2), historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepeo gage will be less than 50 true color units approximately 97%
of the applicable time.
5

TABLE
January 1, 2001 Color Limit Feasibility Report
Monthly Average Data -Max Month Calc
Data Set= 1/1198-10131/2000 1/112000-10131/2000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. = 34 10
xbar 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 55556 54773
99th safe MONTH from normal dist 59796 58953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58642 58009

t
BLUE RIDGE
PAPER PRODUCTS INC.
December 28,2000
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
January 1,2001 Color Limit Feasibility Report
Dear Mr.Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24,
and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 99 h percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 lbs/day and an average monthly color limit of 59,796 Ibs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit), Blue Ridge Paper Products recommends using a 95'h percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 95a'percentile statistical review of the
limited data available from January 1998— October 31, 2000 the annual average color is 48,388 lbs/day
and the monthly average color is 55,556 Ibs/day. Blue Ridge Paper Products believes the 95 h percentile
confidence interval will be appropriate with the additional color data that will be available for the June 1,
2001 analysis. The attached Table includes the summary of the 99a'and 95`h percentile statistical data.
Please call me at [phone] or Derric Brown at(828) 646-2318 if you have any questions regarding
this report.
(Sincerely,
C.1�►� eir`-°ItYOL
Bob Williams
Director- Environmental,Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000— 52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997
Permit provides in part, as follows:
`...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 Ibs/day
based on full implementation of the Near-Term Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits... "
This report is submitted to fulfill the requirements of Part III,Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000,Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000—52, 000 pounds per day is feasible.
1

January 1, 2001 -Color Limit Feasibility Report
Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
A
400000
rn
G
0 300000
0
V
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
—.—SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
II. Color Performance
The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual
average amount of color discharged, as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project, full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRTM on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average
annual color discharged was 41,048 lbs/day. The 2000 average annual color(through
October) is 44,837 lbs/day. All of these values are within or below the target annual
average color range of 48,000—52,000 lbs/day specified in Part III, Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion (30Q2),historical flow records, and the
January 1998 —October 2000 annual average color value of 45,458 lbs/day, it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
3

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
III. Recommended Color Limits
The January 1998—October 2000 actual average annual color of 45,458 lbs/day and the
January 2000— October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000—52,000 lbs/day specified in Part
III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated, that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 Ibs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998 —October 2000 annual color average using a 99a'percentile
distribution is 49,612 lbs/day. The January 2000—October 2000 annual color average
using a 99a'percentile distribution is 48,911 lbs/day. These values are both within the
48,000—52,000 lb/day range. Based on a statistical review of the data and the limited
data set available,Blue Ridge Paper Products,Inc. recommends an annual average
effluent limit of 49,612 lbs/day.
The January 1998—October 2000 monthly color average using a 99"'percentile
distribution is 59,796 lbs/day. The January 2000—October 2000 monthly color average
using a 99a' percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available, Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,796 lbs/day.
4

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
• Canton,North Carolina
III. Conclusion
Blue Ridge Paper Products, Inc. believes it is feasible to achieve a target annual average
color limit within the range of 48,000— 52, 000 lbs/day. The Canton Mill recommends
an average annual color limit of 49,612 lbs/day and an average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria (30Q2), historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepco gage will be less than 50 true color units approximately 97%
of the applicable time.
5

1,
TABLE
January 1, 2001 Color Limit Feasibility Report
Monthly Average Data - Max Month Calc
Data Set= 1/1198-10/3112000 1/112000-10/3112000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. = 34 10
xbar • 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 55556 54773
99th safe MONTH from normal dist 59796 58953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58542 58009

BLUE RIDGE
PAPER PRODUCTS INC.
December 28,2000
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272, Blue Ridge Paper Products,Inc. Canton Mill
January 1,2001 Color Limit Feasibility Report
Dear Mr. Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24,
and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 99u'percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 Ibs/day and an average monthly color limit of 59,796 lbs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit), Blue Ridge Paper Products recommends using a 95a' percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 95`s percentile statistical review of the
limited data available from January 1998— October 31, 2000 the annual average color is 48,388 lbs/day
and the monthly average color is 55,556 Ibs/day. Blue Ridge Paper Products believes the 95's percentile
confidence interval will be appropriate with the additional color data that will be available for the June 1,
2001 analysis. The attached Table includes the summary of the 99"'and 95i'percentile statistical data.
Please call me at(828) 646-2033 or Derric Brown at(828) 646-2318 if you have any questions regarding
this report.
(Sincerely,
Bob Williams
Director-Environmental, Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE
.AMEX PEGDUCTf INC
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000—52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III,Paragraph E 12 of the 1997
Permit provides in part, as follows:
"...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 Ibs/day
based on full implementation of the Near-Term Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits..."
This report is submitted to fulfill the requirements of Part III,Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000, Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000— 52, 000 pounds per day is feasible.
1

January 1, 2001 - Color Limit Feasibility Report
Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
400000
rn
.O
0 300000
O
V
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
Il. Color Performance
The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual
average amount of color discharged, as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project, full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRTM on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average
annual color discharged was 41,048 Ibs/day. The 2000 average annual color (through
October) is 44,837 lbs/day. All of these values are within or below the target annual
average color range of 48,000—52,000 lbs/day specified in Part III, Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion (30Q2),historical flow records, and the
January 1998 —October 2000 annual average color value of 45,458 Ibs/day, it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
3

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
III. Recommended Color Limits
The January 1998 —October 2000 actual average annual color of 45,458 lbs/day and the
January 2000—October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000—52,000 lbs/day specified in Part
III,Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated, that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 lbs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998— October 2000 annual color average using a 99u'percentile
distribution is 49,6121bs/day. The January 2000—October 2000 annual color average
using a 99u'percentile distribution is 48,911 lbs/day. These values are both within the
48,000— 52,000 lb/day range. Based on a statistical review of the data and the limited
data set available, Blue Ridge Paper Products,Inc. recommends an annual average
effluent limit of 49,612 lbs/day.
The January 1998—October 2000 monthly color average using a 991'percentile
distribution is 59,796 lbs/day. The January 2000—October 2000 monthly color average
using a 99u'percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available, Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,796 lbs/day.
4

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
III. Conclusion
Blue Ridge Paper Products, Inc. believes it is feasible to achieve a target annual average
color limit within the range of 48,000— 52, 000 lbs/day. The Canton Mill recommends
an average annual color limit of49,612_lbs/day and an average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria(30Q2),historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepco gage will be less than 50 true color units approximately 97%
of the applicable time.
5

,
. TABLE
January 1, 2001 Color Limit Feasibility Report
Monthly Average Data -Max Month Calc
Data Set= 1/1/98-10/31/2000 1/1/2000-10/31/2000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. = 34 10
xbar • 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 55556 54773
99th safe MONTH from normal dist 59796 58953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58542 58009
I

r, BLUE RIDGE
1 PAPER PRODUCTS INC.
Ap
December 28,2000
0
�r /��� �/
Mr.Forrest Westall Sy��Cq0, Q
Regional Water Quality Supervisor i llF��l/jj,
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272, Blue Ridge Paper Products,Inc. Canton Mill
January 1,2001 Color Limit Feasibility Report
Dear Mr. Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24,
and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 99`'percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 lbs/day and an average monthly color limit of 59,796 lbs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit), Blue Ridge Paper Products recommends using a 95`h percentile,confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 95`h percentile statistical review of the
limited data available from 4anuary 1998—October 31, 2000 the annual average color is 48,388 lbs/day
and the monthly average color is 55,556 Ibs/day. Blue Ridge Paper Products believes the 95'h percentile
confidence interval will be appropriate with the additional color data that will be available for the June 1,
2001 analysis. The attached Table includes the summary of the 99 h and 95°1 percentile statistical data.
Please call me at(828) 646-2033 or Derric Brown at(828) 646-2318 if you have any questions regarding
this report.
Sincerely,
E& a,rL61rio-
Bob Williams
Director-Environmental,Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000—52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997
Permit provides in part, as follows:
"...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 Ibs/day
based on full implementation of the Near-Term Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits... "
This report is submitted to fulfill the requirements of Part III,Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000, Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000—52, 000 pounds per day is feasible.
1

January 1, 2001 - Color Limit Feasibility Report
Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
A
t�
$ 400000
N
J?
C
0 300000
O
U
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
--*—SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
II. Color Performance
The Canton Mill has achieved a color reduction of over 85% since 1988 in the annual
average amount of color discharged,as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project, full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRM on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average
annual color discharged was 41,048 lbs/day. The 2000 average annual color(through
October) is 44,837 lbs/day. All of these values are within or below the target annual
average color range of 48,000—52,000 lbs/day specified in Part III, Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion (30Q2),historical flow records, and the
January 1998—October 2000 annual average color value of 45,458 lbs/day, it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
3

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
M. Recommended Color Limits
The January 1998—October 2000 actual average annual color of 45,458 Ibs/day and the
January 2000—October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000—52,000 lbs/day specified in Part
III, Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated, that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 lbs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color,Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998 —October 2000 annual color average using a 99`h percentile
distribution is 49,612 lbs/day. The January 2000—October 2000 annual color average
using a 991h percentile distribution is 48,911 lbs/day. These values are both within the
48,000— 52,000 lb/day range. Based on a statistical review of the data and the limited
data set available,Blue Ridge Paper Products, Inc. recommends an annual average
effluent limit of 49,6121bs/day.
The January 1998—October 2000 monthly color average using a 99`h percentile
distribution is 59,796 lbs/day. The January 2000—October 2000 monthly color average
using a 99`h percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available, Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,7961bs/day.
4

January 1,2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
III. Conclusion
Blue Ridge Paper Products, Inc. believes it is feasible to achieve a target annual average
color limit within the range of 48,000—52, 000 lbs/day. The Canton Mill recommends
an average annual color limit of 49,612 lbs/day and an average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria(30Q2), historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepco gage will be less than 50 true color units approximately 97%
of the applicable time.
5

TABLE
January 1,2001 Color Limit Feasibility Report
Monthly Average Data-Max Month Calc
Data Set= 1/1/98-10/31/2000 111/2000-10/3112000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. = 34 10
xbar • 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 55556 54773
99th safe MONTH from normal dist 59796 58953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58542 58009

r
�t
9
2000B Applications
Project ID 2000E-402
Applicant Name Haywood Waterways Asso. & Haywood SWCD
Applicant Type Non-profit
Purpose Restoration
Request S $677,555
Total$ $1,077,810
Duration (months) 24
Watershed French Broad `l
Region Western
County Haywood
Contact Mr. Gordon Small
Title
Organization Name Haywood Waterways Asso. & Haywood SWCD
Address 1496 Fern Trail
City Waynesville
state NC
Postal Code 28786-
Work Phone [phone]
Mobile Phone
Fax Number [phone]
E-Mail [e-mail]
4.4r
� V�v�•.
y v
Tuesday,January 01,1001
• now

HAYWOOD WATERWAYS ASSOCIATION , INC .
4�'
�
b
NARRATIVE PROPOSAL O Project Description:
This project is focused on restoring degraded waters by sediment reduction and storm water management in two sub-
watersheds of the Pigeon River Watershed The water quality improvement goals are: (1) reducing sediment deposition in
Richland Creek and Lake Junaluska,(2)reducing erosion and sedimentation from eroding river banks in the Canton
Recreation Park at Canton,NC,and(3)improving sediment monitoring in the Richland Creek watershed There are 5
parts to this application—(a)restoring eroding creek banks and pastures,and reducing animal access points in the Richland
Creek watershed; (b)a demonstration project to control storm water runoff and erosion from a small subdivision at the
headwaters of Richland Creek(c)improved monitoring in the Richland Creek watershed; (d)restoring eroding river banks
and managing storm water runoff at the Canton Recreation Park, (e)public information and awareness. The application is
requesting$677,555.
A campaign is underway to find the money to remove sediment from Lake Junaluska. However,the long-term
answer is to reduce the rate of sedimentation. In order to effectively address this issue,the primary sources of the
sedimentation had to be identified
HWA had previously entered into a cooperative agreement with the Tennessee Valley Authority(TVA)for an Integrated
Pollutant Source Identification(IPSI)project in 1999.The project was funded with a Pigeon River Fund grant. This
$140,000 color infrared aerial survey and non-point source inventory generated a digital geographic database with
information on landscape features that are sources of non-point pollution. Computer models provided estimates of soil loss
and pollutant loading by sub-watershed
Using the IPSI data, it was learned that eroding stream banks contribute 47%of the sediment to streams in the Richland
Creek Watershed. Eroding roads,ditches,and road banks contribute 32%. Pastures contribute 9%,other uses 6%.animal
PO BOX 389 • WAYNESVILLE, NC • 28786
PHONE: [phone] OR 828-456-5195 • FAX: [phone]

access 5%,and cropland 1%.
Based on the IPSI data,and other water quality information,the TAC is developing a Watershed Action Plan to reduce non-
point source pollution in the Pigeon River Watershed. The Richland Creek sub-watershed has been identified as a priority
sub-watershed because of the impacts of sediment on Lake Junaluska and the rapidly changing land uses in this sub-
watershed The draft plan incorporates a schedule to reducing the current sources of sediment by 37%in 5 years,based on
available resources and anticipated landowner response. This application in the first of several to request funds to
accomplish this 5-year sediment reduction goal. Subsequent applications will be submitted as landowners are contacted and
specific projects developed
Integrating Haywood County's Land Records GIS information with the TVA data identified parcels of land with eroding
stream banks. Limiting the potential contact list to larger parcels with significant percentages of eroding stream banks
refined the list to 35 landowners.The GIS information also identified which of the 35 landowners had eroding pasture lands
and animal access issues.The Haywood Soil and Water Conservation District contacted several landowners identified in
this database.The District personnel discussed opportunities to improve pasture conditions when talking to landowners
about their eroding stream banks. All work was proposed on the basis of a 20%match from the landowners.
Eleven landowners agreed to participate.These 11 properties include 11,500 feet of eroding stream banks,or about 20%of
the eroding stream banks in the Lake Junaluska watershed The work to be done to stabilize these banks include whole-tree
revetments, rock veins,some bank hardening and shaping,installation of root wads,and establishing riparian buffers. An
additional 12 acres of pasture will be restored on one property,and 5 animal access points will be eliminated
The GIS data was also used to identify roads with erosion problems—the second major cause of sedimentation in Richland
Creek streams. A field review was conducted to identify opportunities to demonstrate practices that effectively manage
storm water and reduce erosion from roads in mountainside subdivisions. Many eroding road banks were located within
current developments and industrial projects where the developer is still responsible for limiting erosion. In some cases,the
scope and scale of the needs were too large to serve as an initial demonstration project. However,the Balsam Meadows
subdivision is a small,private development on the headwaters of Richland Creek. It is well suited for demonstrating
erosion control practices along unpaved roads. The original developer did a poor job of locating roads and installing

appropriate drainage and storm water controls. The development went bankrupt,and was subsequently purchased by a local
Realtor who has been selling the unsold lots. The homeowners are completing the formation of a non-profit property
owners association.The landowners are willing to participate in this demonstration. The road conditions represent
common issues for mountainside development in the Pigeon River Watershed There are 2400 feet of gravel road in this
small development.The work includes installing 10 culverts and energy dissipating structures,reshaping and revegetating
eroding cut banks,hardening about 1,000 feet of ditch lines,installing water dispersion structures,and otherwise directing
concentrated storm water flows out of problem areas.
The application includes funds for sediment monitoring stations above and below Lake Junaluska as well as 10 WIN sites
in the Richland Creek Watershed Sediment monitoring is a new effort to track changes over time in sediment loads in the
most impacted Pigeon River sub-watersheds. It will include bed load and proportional sampling. Staff from the Coweeta
Hydrologic Laboratory will install the proportional samplers.This enhanced monitoring will provide needed information
about the nature of the sediment;how much is being trapped by the lake;help develop sediment models;track trends;and
assess the effectiveness of BMPs over time.
Part of this application provides funding to reduce sedimentation and erosion from stream banks in the Canton Recreation
Park. This popular site has about 1,000 feet of eroding stream banks adjacent to the Pigeon River. The proposed practices
include stabilizing the eroding banks with appropriate structures,managing storm water, and revegetating eroding banks by
planting trees and shrubs. The cooperation by the town of Canton at this popular site will greatly increase awareness of
non-point pollution issues within the Pigeon River Watershed
The public information component of this application includes printing and distribution of the Haywood County Watershed
Action Plan,currently being completed. It will also provide funding for development and publication of a"user-friendly"
introduction to BMPs in Haywood County,reprinting of a HWA publication entitled"It's Not Just Dirt", and several public
forums focused on the results of the watershed action plan planning process. This component is an on-going effort to
increase public awareness and support,encourage landowner participation,and action by local units of government to
develop practices and procedures that will reduce future non-point pollution problems.

Water quality objectives and how they will be achieved
The primary objective of all the proposed practices and actions will be to reduce sedimentation in the Pigeon River
Watershed,with a focus on Richland Creek and Lake Junaluska as well as the Upper Pigeon sub-watershed. This will be
done by applying BMPs to eroding stream banks,pastures,animal access points,and eroding roads where landowners have
agreed to participate. The staff of the HS&WCD and NRCS will manage the design and application of practices.
The draft of the watershed action plan proposes to reduce the sediment load from current sources in the Richland Creek sub-
watershed by 37%over the next 5 years. This application will address about a third of this sedimentation reduction goal
(10%). In addition,these practices will serve as demonstration projects for other landowners with similar erosion problems.
The above work addresses current problems. However, it is also necessary that future sediment sources are prevented if this
work is to have lasting value.
Carrying out these projects on the Lake Junaluska watershed and the Canton Recreation Park will serve as visible reminders
of the care we need to take of our watershed. Local newspapers have demonstrated an eagerness to highlight any
conservation efforts in this area. These projects over the next two years will provide numerous opportunities for newspaper
articles,tours,conservation columns,and other media to focus on the situation in the Pigeon River Watershed
Lake Junaluska is a high profile issue focused squarely on the consequences of accelerated erosion and sedimentation.
Following through with prompt action from the conservation community demonstrates a level of commitment that can help
lead the way for the more difficult changes by local governments and others.
The monitoring stations will provide information as to the nature,source,and rate of change of sedimentation over time in
the Richland Creek Watershed. This information is needed to not only assess the effects of practices,but to effectively
characterize the problem with the public as well as various levels of government.

Total funds required for the project:
The total funds required for this project are$1,077.810,with$677,555 of that total being requested by this application.
Other possible funding sources for the project
We anticipate receiving funds from an EPA Section 319 Grant in April of 2001. These funds are earmarked for Fines
Creek and Hyatt Creek. The work in Hyatt Creek will help accomplish the proposed 37%sediment reduction goal over the
next 5 years.
The North Carolina Agriculture Cost Share Program can provide funds for BMPs. Since only about a maximum of$80,000
has been available in any given year from this source,it has limited capability to make substantive impacts. It is not
earmarked for the Richland Creek Watershed The work is normally distributed throughout Haywood County.
The North Carolina Wetland Restoration Fund is another source of funding,particularly for stream bank stabilization.
There is one Wetland Restoration project currently under consideration at this time—the 303(d)listed Hurricane Creek
watershed in the Lower Pigeon sub-watershed Depending on the outcome of that project,additional funds may be
requested for other needs.
Need for the project:
Lake Junalnska is an important water resource for western North Carolina. Completed in 1914,this 200-acre lake hosts
thousands of visitors to the area each year. The annual economic contribution to Haywood County from payroll,general
expenditures,and tourist monies exceeds$30 million.The lake is a place of beauty that is a major recreation center for
visitors and residents alike. It is a part of the"sense of place"for this part of North Carolina.
All this is at risk. As with any reservoir,sedimentation is a fad of life. In the case of Lake Junaluska,all sediment arriving
in the lake is generated by activities within the Richland Creek Watershed However,the sediment loads being delivered to
Lake Junaluska far exceed naturally occurring levels. Over the years,the Assembly has spent hundreds of thousands of
dollars removing sediment from the Lake. However,sediment is arriving at such a rate that this work does not keep up with

deposition. This grant application is the first in a series to focus specifically on this problem.
Richland Creek is a State designated trout stream. It is also the most heavily impacted and changing sub-watershed in
the Pigeon River Watershed Current V WIN data is indicating declining water quality in some segments of the stream.
This trend needs to be reversed.
The Richland Creek Watershed and the Lake Junaluska problems provide an outstanding opening for exploring the best
ways to maintain economic development without destroying our natural resources. However,in order to participate in that
debate,the conservation community needs to demonstrate that these problems can be addressed in a positive way. This
application is a commitment to work with the community in cleaning up the waterways.
Sincere
Ronald J.Moser
Director,Haywood Waterways Association,Inc.
November 30,2000

CLEAN WATER MANAGEMENT TRUST FUND
2313-B Executive Park Circle st�q
Greenville,North Carolina 27834 [phone] APPLICATION FORM Application Closing: December 1, 2000
Proposals postmarked on or before December 1,2000 will be considered during this funding cycle. (A postage meter tape from an
agency or business is not adequate to verify mailing by the due date).Proposals postmarked after December 1,2000 will be considered
during the subsequent cycle scheduled to close on June 1,2001. CWMTF is not able to accept applications by facsimile. Aomlication
materials should not be bound in any way,and all materials should be suitable for photocopy in black and white.
FOR OFFICE USE:APPLICANT NUMBER: (Detailed instructions on page 2)
Project:
Objective: Restoration of degraded water
Primary use: Restore degraded lands for their ability to protect water quality
Secondary use:_Improve stormwater controls and management
Funding sought from CWMTF: $677,555
Total Cost of Project:__� 1,077,810
Duration: 2 years
Location:
Region of NC: (circle one) estern Central Eastern
County: Haywood
River Basin: French Broad
Stream Segment: Pigeon River (Richland Creek&Upper Pigeon River)
Latitude/Longitude: 35029'/82059'
Project Street Address(if applicable):
Applicant:
Organization Name: Haywood Waterways Association. Inc.and Haywood Soil&Water Conservation District
Eligible Applicant Type: Non-profit (HWA) Fed Tax ID#: 56-2108874 (HWA)
Contact:
Name: Gordon Small
Mailing Address: 1496 Fern Trail
City: Waynesville Zip code: 28786
Phone: [phone] Fax: [phone]
E-mail: gordons891aaol.com

"Most of this application will be evaluated according to CWMTF quantitative criteria,and will yield a"score"from 0-165
points;however,Trustees will also consider non-quantitative criteria that are identified in CWMTF published guidelines.
Answers should he direct,thorough and concise.Please limit responses to space available an the form.
Project: (Up to 135 points*")
045 points: (1)To what extent will the proposed project either(a)restore degraded waters,or(b)protect relatively unpolluted
waters.
This application is the first step in a 5-year program to reduce sedimentation in the Lake Junaluska watershed from existing
sources by 37%. The practices included in this 2-year project will reduce pollution from existing sources by 10%. This
demonstrated commitment by conservation agencies and organizations will focus attention on the need to prevent future
problems,provide landowner information and incentives,and provide improved sediment monitoring information.The work at
the Canton Recreation Park will restore 1000 feet of eroding river bank and provide a daily demonstration to hundreds of
residents as to the source of much of the sediment in area streams.
0-25 points: Describe any special significance of waters(in terms of NC-DWQ water quality classification,a g.High Quality or
Impaired)to be enhanced,restored or protected by the project.Note also any special recreational,educational or
economic values of specific waters.
Lake Junaluska is a 200-acre body of water drawing thousands of visitors to the area each year. The annual economic contribution to
Haywood County from payroll,general expenditures,and tourist monies exceeds$30 million. There are 750 privately owned residences
around the lake that contribute$74,000,000 to the tax base of Haywood County,and about$370,000 in tax revenue each year.It
provides summer employment for over 400 people,and has about 190 on staff during the winter months. The lake is a place of beauty
that is a major recreation center for visitors and residents alike. It is a clean industry,depending on the continued presence of the water
resource that is Lake Junaluska.
0-20 points: What does the NC-Division of Water Quality Basinwide Management Plan say about the specific waters,which will be
restored or protected by your project?(Make page specific references to the plan and explain how your project will
solve documented problems and ensure protection or restoration).
Page 98 of the French Broad River Basinwide Water Quality Plan describes Lake Junaluska as having problems with sedimentation and
eutrophication. The report states that sedimentation has increased primarily because of residential and commercial growth in the
watershed.
This application directly addresses the concern in the Basinwide Plan by reducing sedimentation. The primary sources of sedimentation
have been identified and landowners contacted The project addresses eroding stream banks and the roads associated with development
—the two most significant sources of sedimentation in this watershed.
0-20 points: What will be the measurable and enduring outcomes of the project?
An immediate reduction of 10%in sedimentation from existing sources in the Lake Junaluska(LJ)watershed
Increased public and landowner support for achieving the 5-year goal of a 37o/u reduction in sedimentation in the LJ watershed
Over 12,000 feet of eroding stream banks,2,400 feet of eroding road banks will be stabilized
Sediment monitoring will provide conservation agencies and local governments with a needed assessment and planning tool.
Public awareness of and participation in water quality issues will be increased
BMP examples will provide effective technology transfer to residents of western North Carolina.
The completed watershed action plan will provide focus to efforts to reduce non-point pollution in the Pigeon River Watershed
0-5 points:Does the project employ innovative procedures or technology?If so,what are the implications for water quality?
There are three significant new technologies being introduced in the Pigeon River Watershed. The IPSI GIS model contains an
unprecedented level of specificity about known or suspected sources of non-point pollution as well as a data analysis identifying
the condition of the riparian zone,potential sources of sediment and pollutant loads to streams. This innovative tool
substantially enhances planning and project implementation provides an assessment and monitoring tool,and is an
outstanding means of communicating information about watershed conditions to the public,elected officials,and others.

The second innovation is addressing the issue of sediment from private roads in mountain subdivisions.It is one of the most
significant sources of sediment in many watersheds in western North Carolina. Initiating the Balsam Meadows demonstration
project will help refine practices,draw attention to the issue,and encourage private landowners and developers to apply
improved practices during development.
Installing proportional monitoring and bed load samplers will provide needed information about the nature, quantity,and
timing of sediment movement in this watershed In addition,this data will assess the effects of changing land uses and the
effectiveness of BMPs,while improving sediment delivery modeling.
0-20 points:Does the project establish functional riparian buffers or greenways?If so,provide details of buffer design and estimates of
pollution reduction.
The project establishes functional riparian buffers in 2 sub-watersheds. The total length of these riparian buffers is over 12,000
feet. These buffers are generally 35'wide. Trees will be planted in these buffers to stabilize stream banks and reduce water
temperatures. There will be no intensive agricultural uses or development within these buffers. Longterm maintenance
agreements with incentive rentals or easements will be used to assure protection of these riparian buffers.
Applicant: (Up to 30 points")
0-20 points:Describe other resources committed towards this project:
There are over 25 volunteers gathering water quality data in support of this effort.The Pigeon River Fund has provided
$73,300 in funding to initiate the IPSI effort. Tens of thousands of dollars worth of time from professionals from TVA.NRCS,
HS&WCD, SWNC RC&D Council,DENR,HWA and Haywood Community College are contributed to the HWA Technical
Advisory Committee each year. Private landowners will contribute thousands of dollars of cost share money and in-kind
services as the BMPs are put on the ground
0-10 points:Briefly describe organization's qualifications to accomplish the proposed project:
HWA is a 50l(c)3 non-profit corporation under North Carolina law. The Board includes decades of experience in
administering a wide variety of grants. The President is also the Director of Environmental Programs for the Land of Sky
Regional Council. The two staff administering these projects are both professionals with over 50 years cumulative experience.
One was a former District Director for Farmer's Home Administration—the other a forester who had previously served as the
Watershed Director for the Eastern Region of the USDA-Forest Service. The Technical Advisory Committee is composed of
over a dozen professional staff from federal,state and local agencies. The HS&WCD,NRCS,and the NC Extension Service
have trained and experienced engineers and conservationists committed to insuring the BMPs are properly placed on the
ground
Is there a long-term management plan to which this proposed project is strategically related?(Explain)
A Watershed Action Plan has been drafted by the HWA Technical Advisory Committee to guide watershed improvement work
in the Pigeon River Watershed for years to come. The proposed work is among the highest priority projects identified in this
draft plan.
Is there a local land use plan for the county or municipality in which the project will occur?What assurance can you provide regarding
long term management of the project?
There is no local land use plan affecting the project area. The riparian zones will be made subject to conservation easements or
15-year maintenance agreements.Easements will be transferred to a qualified land trust,such as the Southern Appalachian
Highlands Conservancy, for administration. The 15-year agreements will allow the trees in the riparian corridors to become
large enough that it would generally be impractical to remove them at that point. The watershed improvements made to
homeowner association roads will reduce maintenance costs for the association,thus insuring their longevity.
Is this project eligible for funding under other state or federal grant programs?If so,elaborate.
The project is eligible for Section 319 Grants from EPA. Such a grant was approved by the State,and money is anticipated in
April of 2001. However,those funds are committed to the Fines Creek and Hyatt Creek areas, and do not address some of the

highest priority sources in the Lake Junaluska watershed and do nothing for correcting problems at the Canton Recreation
Park The North Carolina Agriculture Cost Share Program funds BIv1Ps. However,only about$80,000 are available in any
give year,thus limiting the effectiveness of that source. In addition,those resources are generally not targeted to the Lake
Junaluska watershed The North Carolina Wetland Restoration Fund also provides funds for such practices as stream bank
stabilization. These monies,whether from the Fund or the DOT,may be a beneficial supplement to this project.
Is the property wherein the project will be located subject to any environmental laws,Hiles or regulations(existing or pending)which
impose obligations or restrict the use or marketability of the property?(If yes,please explain) [Please do not exceed 4 pages!]
No.

Budget Summary Ck
Applicant:Haywood Waterways Association&Haywood Soil 8 Water Conservation District 0
Date:November 29,ZOOD m� ??QOO
Two Year Proiect Budget Summary <E, N0
Local CWMTF Total
Staff $ 174,600.00 $ 89,960.00 $ 264,560.00
Travel $ 19,800.00 $ 3,900.00 $ 23,700.00
Monitoring& Evaluation $ 10,924.00 $ 17,650.00 $ 28,574.00
Public Education $ 10,400.00 $ 2,180.00 $ 12,580.00
Equipment $ 22,214.00 $ 2,267.00 $ 24,481.00
Supplies $ 2,500.00 $ - $ 2,500.00
Easements& Management Agreements $ - $ 25,000.00 $ 25,000.00
Best Management Practices $ 134,608.00 $ 403,827.00 $ 538,435.00
BMPs&Storm Water Management $ 22,000.00 $ 88,000.00 $ 110,000.00
Storm Water Management $ 3,209.00 $ 12,836.00 $ 16,045.00
Construction Contingency $ - $ 19,935.00 $ 19,935.00
Contract&Project Management $ - $ 12,000.00 $ 12,000.00
Total Project Cost: $ 400,255.00 $ 677,555.00 $ 1,077,810.00
CWMTF Grant Request=$677,555
Note: Pursuant to the instructions, a one page summary is provided.To adequately itemize Costs
a threepage budget was necessary. Please see attached two year budget and notes.
Page 1

Lake Junaluska Watershed
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05/6`3%2691 11:30 G475770489 IES PAGE 02
y
Su
as
Serving the Legal and Insurance communitias • Investigating I Auditing y Consulting ~
V.
May 3, 2001 '
Attn:Keith Haynes
NC Dept of Environment&Natural Resources
Asheville Itegioaal Office
Divisioq of Water Quality
59 Woodfim Place =z
Asheville,NC 28801 FAX [phone] -
:y
RE: Champion Paper Min, Canton,NC - FUe Review jaw
Dear Mr. Haynes,
I wanted to thank you again for your time the other day in discussing.the information that I am
Iooldng for regarding the above-mentioned site. As I mentioned during our phone conversation, r
I will be in Asheville from May 14-17,2001, and I am sending this letter to confirm my —_
appointment for a file review for Wednesday,May 16t5 at 9;00am. _
S1S..
Please do not hesitate to contact me at 847/577-0022 with any questions,or if you need to
change our appointment time. -`
Thank you again, and I look forward to meeting you in May. ` }
Very Truly Yours,
jT-
Nadine L. Burg,
i vL�
Executive Consultant = _
IES—Claims Services —_
1
Ei"YI•
3315 Algonquin Road, Suite 105 • Rolling Meadows, IL 60008 .Voice 847.577.0022 fax 84+7577.0489 _=

05/03/2001 11:30 8475770499 IES PAGE 01
IES' Claims Services
3315 West Algonquin Road
Suite 105
Rolling Meadows,IL 60008
Phone: [phone]
84 5 7.0489
tl=sial,�=�19�cs.�FqlAr'�--'�.�;rur��._'S'.�ircaw'�19k6t��!RSG�uil , _Ws� � a.,:11n��`�.mu>c..-��Fm��i '�,vY"r �'�.4h11�'�175F i`�tl�Imr��r-i•�a>e"��('px e:r!��,�r ��� �.�'i.l_��.tli 1.
faes• • e tmmmitrai
Keith Haynes
To: Division of Water Quality Fax: [phone]
NCpBNR
From: Nadine L.Burg N Data: 513/01
Re: File Review—Champion Paper Mill Pages: Two,including cover sheet
nry �I° �i m. arm�l;�ir� •,�,n9 x ixrl Y,�6n K� mx1aJY ''f�nt'�!':F4

STATE OF NORTH CAROLINA
Department of Environment and Natural Resources
59 Woodfin Place, Asheville, NC 28801
828/251-6208
FILE ACCESS RECORD
Guidelines For Access: The staff of the Asheville Regional Office are
dedicated to making public records in our custody readily available to
the public for review and copying. We also have the responsibility to
the public to safeguard these records and to carry out our day-to-day
program obligations . Please read carefully the following guidelines
before signing this form:
1. We prefer that you call at least a day in advance to schedule an
appointment to ,review the files. Appointments will be schedule between
9:00 am and 3 .00 pm. Viewing time ends at 5 :00 pm Anyone arriving
without an appointment may view the files to the extent that time and
staff supervision is available.
2 . You must specify files you want to review by facility name. The number
of files that you may review at one time will be limited to five.
3 . You may make copies of a file when the copier is not in use -by the staff
and if time permits. The cost per copy is 15 cents: payment may be make
by check, money order, or cash to the Water Ouality Secretary. Please
make checks payable to DENR.
4 . FILES MUST BE KEPT IN THE ORDER YOU FOUND THEM. Files may hot be taken
from the office. To remove, alter, deface, mutilate or destroy material
is one of these files is a misdemeanor for which you can be fined up to
$500 . 00 .
5 . In accordance with General statute 25-3-512 a $20 . 00 processing fee will
be charged and collected for checks on which payment has been refused.
FACILITY NAME COUNTY
1.
2 .
3 .
4 .
5 . ,, // 2
NAME of reviewer: rint Neli?z L� SV?2(r /ES G/liI`nS Sep-y��
Signature:
NAME of reviewer: prin
Signature: /
REPRESENTING: I ES _ �/!a s '5 /r inGPrt
Please Attach a Business Card to This Form
Date: S / S D ( Time In: Time Out:

^L _
i
STATE OF NORTH CAROLINA
Department of Environmental and Natural Resources
Water Quality Section
59 W`oodfin Place, Asheville, NC 28801
828/251-6208
File Access Record
FACILITY NAME COUNTY
I/WE, PU0 have been provided
(print n e/s)
(print name/s)
access to the above-named file by personnel of the Water Quality
Section. I understand that this statement shall be made a permanent
part of any file which is viewed under the Freedom of Information
provision of the North Carolina General Statutes .
Li-gi ture) (date)
11 (signature) (date)
name/initials of WQ staff member
permit number

r
r �
COMPARATIVE AND STATISTICAL
EVALUATION REPORTS
Prepared for:
North Carolina
Division Water Quality
Prepared by:
Blue Ridge Paper Products Inc.
Canton, North Carolina
May 31 , 2001
t

BLUE RIDGE.
PAPER PRODUCTS INC.
May 29,2001
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
June 1,2001 Required Reports
Dear Mr.Westall:
Attached are the June 1, 2001 Comparative Evaluation Report and the June 1, 2001 Color
Performance Statistical Evaluation. These reports are submitted to fulfill part of the
requirements stated in Part III,Paragraph E 14 of the modified 1997 NPDES Permit.
Please call me at(828) 64&2033 or Derric Brown at(828) 646-2318 if you have any questions or
concerns regarding these reports.
Sincerel
Bob Williams
Director-Environmental,Health and Safety
Attachment
175 Main Street o P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

Xc: I th Haynes9
Dave Goodrich
Mike Myers

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
I. Introduction
The following report describes the important color reduction activities that have
been accomplished over the term of the modified 1997 NPDES Permit ("1997
Permit") and includes a discussion of technology assessments Blue Ridge has
undertaken to evaluate potential color reduction options. Part III, E. Paragraph
14 of the 1997 Permit provides, in part, that:
"...By June 1, 2001, the permittee will submit a report to the
NPDES Committee and N.C. DENR, Division of Water Quality,
on the comparative evaluation of the above collective efforts as
part of the Variance review process (Triennial Review of North
Carolina Water Quality Standards.)..."
This report is submitted to fulfill this requirement of Part III, E. Paragraph 14.
Permit No. NC0000272
Page 1

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
li. Summary of Color Reduction Activities
Since the issuance of the 1997 NPDES Permit, the Canton Mill has
accomplished the following color reduction activities:
1. Identified and implemented certain Best Management Practices
(BMP's) to reduce color. The following BMP's were implemented
before June 1, 1998, and a report on the implementation was
submitted to DWQ, the TRW and the NPDES Committee on that date.
a. Installation of replacement digester recirculation pumps.
b. Installation of a double-chambered pine courtyard spill collection
sump.
c. Installation of weak black liquor tank containment, and
d. Correction of evaporate set demister clogging, installation of
condensate instrumentation and sampling ports for the
evaporator set and assurance of continued dry conveying of
knot rejects.
2. Submitted Low Flow Contingency Plan to DWQ and TRW by
December 1, 1998 (approved by NPDES Committee in February
1999).
3. Prior to December 1, 1998, complied with a reduced color limit in the
Permit of 60,000 lbs. per day (annual average) and 69,000 lbs. per day
(monthly average).
4. Began implementation of partial Eo stage filtrate recycle on the
hardwood line before January 1, 1999 and submitted a report on the
color reduction benefit resulting from the partial implementation and a
projection of potential color reduction benefit to be gained from full
implementation of BFR on the hardwood line to DWQ, TRW and the
NPDES Committee by December 1, 1999.
5. Submitted a color limit feasibility report to DWQ, TRW and the NPDES
Committee before January 1, 2001, which concluded that the Canton
Mill could comply with a color limit within the range of 48,000-52,000
lbs. per day (annual average).
Permit No. NC0000272
Page 2

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
Implementation of these BMP's, together with improved mill operations and
continued commitment to further reduce color, has reduced color by 32% over
the term of the 1997 Permit. As described in the January 1st, 2001 Report, the
mill has achieved a target annual average color loading of 48,000 — 52,000
pounds per day. On May 1, 2001 the North Carolina Division of Water Quality
reduced the permit limit for annual average color from 60,000 Ibs/day to 48,000
Ibs/day and the monthly average color limitation was reduced from 69,000
Ibs/day to 55,000 Ibs/day. Based on data received from the National Council on
Air and Stream Improvement (NCASI), the Canton Mill has the lowest color of
any mill in its industry category.'
Based on a June 7,2000 Benchmarking Canton Wastewater Effluent Parameters letter from the National
Council for Air and Stream Improvement(NCASI).
Permit No. NC0000272
Page 3

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
III. Additional Color Reduction Studies
3.1 End-of-Pipe Treatment and In-Process Technologies
In an effort to identify either a breakthrough improvement in color removal
efficiency or reduction in cost, the mill has evaluated end-of-pipe color reduction
technologies three times in the past thirteen years, including a 2001 study by
Jacobs Engineering Group, Inc. (2001 Color Removal Technology Assessment,
the "Jacobs Report"). The Jacobs Report evaluated 16 end-of-pipe technologies.
It is clear that no breakthrough in economic or technical feasibility has or is likely
to occur in end-of-pipe color removal.technologies. Such technologies have not
been commercially demonstrated and are generally not economically feasible
because they require a significant initial capital investment with continued
operating costs and no associated savings.
During this same thirteen-year period, however, the Canton Mill implemented
alternative in-process pollution prevention technologies including oxygen
delignification, Elemental Chlorine Free bleaching, Bleach Filtrate Recycle-rm and
those technologies comprising the "Near-Term" package, resulting in a significant
reduction in the color discharged.
Therefore, based upon this record, it is Blue Ridge's intention in the future to
focus on in-process pollution prevention technologies and the potential treatment
of selected, colored wastewater streams before they enter the wastewater
treatment plant (WWTP) and, in particular, the Chloride Removal Process (CRP).
Blue Ridge believes in-process pollution prevention and treatment of selected
wastewater streams hold the greatest likelihood of success for further color
reduction. In the future, Blue Ridge believes its time and resources would be
Permit No. NC0000272
Page 4

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
better devoted to in-mill treatment of particular wastewater streams rather than
end-of-pipe, secondary effluent color removal approaches.
3.2 Polyamine Trials
Polyamine addition trials were conducted in January 2001 at the primary clarifier,
secondary clarifier, and colored in-mill wastewater streams, and were not
eopmine aon isCo reduce color throughsuccessful�heconcpt d
precipitation of color bodies, which attach to the polyamine, coagulate, and settle
in primary clarification. Numerous trial approaches were conducted to study
comprehensively the effectiveness of polyamine for color removal. While
treatment of colored wastewater streams in the pulping and recovery areas
appeared to remove color, the color bodies re-solubilized in the wastewater
collection system and there was no significant net reduction in secondary effluent
color. Treating the primary clarifier resulted in color reductions, but wastewater
treatment plant sludge quality declined to an unmanageable condition and
recycled belt press filtrate solids increased significantly. Treating the secondary
effluent resulted in minimal color reductions; in addition, this type of treatment
would require the installation of equipment and increased operating costs as
described in the Jacobs Report , and might have adverse effects on the chronic
toxicity of the wastewater discharge.
3.3 CRP Treatment with Lime
Laboratory studies were recently performed on the Chloride Removal Process
(CRP) purge stream, a relatively high color, low flow stream associated with the
BFRTrm process. The purge stream was treated with various sources of calcium
in an effort to precipitate color bodies. Lime precipitation was concluded to be
Permit No. NC0000272
Page 5

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
infeasible due to the massive quantities necessary to partially reduce color and
the large quantities of solid waste generated.
3.4 Third Party Evaluation of Canton Mill
As part of Blue Ridge's commitment to continued color reduction, the Canton Mill,
in collaboration with a coalition of environmental groups, engaged Dr. Norm
-Lieberrgott,- President -of-Liebergott-&Associates-Consulting- Inc.,- and Lewis
Shackford, Vice President of Technology for GL&V Pulp Group Inc., a major
supplier to the pulp and paper industry, to undertake a thorough evaluation of the
mill's pulping and bleaching operation. The evaluation is focusing on potential
process and equipment modifications targeted at environmental performance
improvements. Liebergott and Shackford will identify options for consideration
that may lead to decreased effluent load, in particular color, with technologies
that will not increase effluent toxicity. Blue Ridge plans to submit this information
to the Division of Water Quality for its consideration in conjunction with the
information from the Technology Review Workgroup (TRW) to evaluate options
for potential reductions in effluent color over the term of the next NPDES Permit.
Permit No. NC0000272
Page 6

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
IV. Commitments to Further Color Reduction
The Canton Mill is committed to further discharge color reduction. In conjunction
with the Technology Review Workgroup (TRW), the Canton Mill believes further
color improvements may be achieved utilizing the following options.
4.1 BFR Improvements
— mce October 1998,-the average BFR closure rateof-the pine fiberline D1 and
Eo stages has averaged approximately 74%. This rate is lower than the targeted
BFR closure rate of 80%.
The obstacles to achieving a sustained pine fiberline closure of 80% are related
to the operational reliability of the BFR equipment, primarily the Metals Removal
Process (MRP). Blue Ridge is committed to undertake improvements to the
MRP in order to achieve an 80% pine fiberline closure rate. These
improvements include a new media filter and softener, rebuilding piping and
valves, and changing materials of construction to better withstand the harsh
environment (corrosivity, erosion and deposition). Blue Ridge estimates the cost
of these improvements to be up to $1,300,000 and the estimated discharge color
reduction from these upgrades to be 1,000 — 1,200 Ibs/day.
The other component of the BFR process is the Chloride Removal Process
(CRP). The CRP system purges chloride and potassium from the mill's chemical
recovery system. This purge is a low flow, relatively high color stream that
contributes an average of 6,000 Ibs of color per day to the wastewater treatment
plant primary influent (or less than 4,000 Ibs/day in the discharge). The Canton
Mill will investigate potential technologies that may reduce this source of color.
Permit No. NC0000272
Page 7

June 1, 2001 Comparative Evaluation Report .
Blue Ridge Paper Products Inc.
Canton, North Carolina
4.2 Additional Black Liquor Leak and Spill Control
The Canton Mill has extensive equipment to reduce black liquor leaks and spills.
Additional improvements to further manage black liquor losses to the wastewater
collection system are currently under evaluation. The first improvement involves
diversion of clean water from the digester area sump. This diversion of clean
water will prevent dilution of concentrated brown color, thereby allowing the sump
to capture a greater percentage of the brown color from the digester area.
Another upgrade is to collect the filtrate from the knotter bins to reclaim color that
is leached from knots. An evaluation of alternatives to reduce screen room color
will also be conducted. Blue Ridge estimates the cost of these improvements to
be in excess of$100,000. The discharge color reduction could be in the range of
1,000 — 3,000 Ibs/day.
4.3 Evaluation of Potential In-Process Color Reduction Technologies
As described in Section 3.4, Liebergott and Shackford are evaluating
technologies that may result in reduced discharge color. While this report is not
yet complete, Blue Ridge can provide an overview of Liebergott's and
Shackford's scope of work.
The scope of the Liebergott and Shackford study involves evaluation of potential
process modifications to see if such modifications are technically, operationally
and economically feasible. The report will consider impacts on process control,
production capability and pulp production cost and quality. Liebergott and
Shackford will consider changes to each fiberline, 2-stage oxygen delignification,
strategic use of hydrogen peroxide and the alternative use of peracetic acid
Permit No. NC0000272
Page 8

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
and/or ozone in the bleaching stages.. An evaluation of whole mill effluent and
segregated higher color wastewater streams will also be conducted.
A final report Will be issued summarizing the technical, economic and operational
feasibility of the technologies reviewed, including a discussion of commercially
demonstrated use. This report will be provided to the Division of Water Quality.
--In addition-to this third party assessment,—the USEPA Was-a dedicated
Technology Review Workgroup that is studying additional color reduction
technologies. This report is also expected to be available to the Division of
Water Quality in the second quarter of 2001.
Permit No. NC0000272
Page 9

June 1, 2001 Comparative Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
V. Conclusion
The Canton Mill has successfully reduced color from 83,000 lbs/day to less than
48,000 Ibs/day over the term of the 1997 NPDES Permit. Blue Ridge is
committed to further improvements to the BFR process, the digester area spill
control systems and to the knotter and screen operations, which will further
reduce discharge color. Blue Ridge is also committed to evaluating other
process technologies, which may reduce color, over the term of the-2001 NPDES
Permit.
Permit No. NC0000272
Page 10

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
I. Introduction
The following report describes the statistical evaluation of the Canton Mill's color
discharge since completion of the color reduction activities required by the
modified 1997 NPDES Permit and Settlement Agreement. Part III, E. Paragraph
14 of the revised 1997 Permit provides, in part, the following:
Further, based on the continued development of color
discharge information from the reconfigured mill, the permittee
will statistically evaluate its monthly average color discharge, its
annual average color discharge, and the performance of the mill
in relation to color discharged..."
This report is submitted to fulfill this requirement of Part III, E. Paragraph 14.
Permit No. NC0000272
Page 1

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
II. Discussion
The Canton Mill has achieved a color reduction of over 88% since 1988 in the
annual average amount of color discharged, as illustrated in Figure 1. The
improved color performance is due to the Canton Modernization Project, full
implementation of the "Near-Term Package" and continuous color management
by the mill.
The Near-Term Package included the installation of BFRTm on the mill's pine
fiberline, implementation of best management practices (BMPs) detailed in the
June 1, 1998 Color Technology Report, and partial BFR (Eo filtrate recycle) on
the hardwood fiberline. Partial hardwood Eo recycle was still being evaluated
and optimized through December 1999, and therefore, the January 2000 —
December 2000 time period was used as the basis for the statistical evaluation.
This period is representative of mill discharge color performance after
implementation of all activities (i.e. "the reconfigured mill") required in the 1997
NPDES Permit. However, it is important to note that November and December
2000 are not representative of typical mill pulp production. This is due to the No.
19 Paperboard Machine outage and start-up, when pulp production was very low
compared to normal operation.
Permit No. NC0000272
Page 2

Figure 1: Canton Mill Secondary Effluent Color Performance
Annual Averages: 1988 - 2000
400000 Including Permit Limitations
Permit Limitations:
350000 1-258,945#/d Monthly Ave,off.4114/94
2-172,368 Wd Annual Ave.off.4/14194
3-125,434#/d Monthly Ave.eff.12112/96
4-98.168#/d Annual Ave eff.12/12/96
6-95,000 Wd Monthly Ave eff.111198
300000 6-69,000#/d Monthly Ave.eff.1211198
T 7-60,000#/d Annual Ave.eff.U/1/98
t0 8-48,000#/d Annual Ave.eff.5/1/01
9
N
a 250000
0
0
U
v 200000
E
W
9 150000
0 2
0
u
fu
N
100000 3
4
5
50000 6 7
8
0 1
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000
Blue Ridge Paper Products, Inc. Permit Urnitaions t SE Color Annual Ave.#/d
Canton Mill 5/31/01

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
III. Statistical Evaluation of Color Performance Data
The attached Table summarizes the statistical evaluation. Based on January
2000 — December 2000 color data, the 95th percentile expected annual average
is 46,475 Ibs/day. This 95th percentile annual average is representative of the
reconfigured mill's performance.
The monthly average numbers were calculated, using the same data as above,
by two different statistical methods. The expected monthly color average based
on a 95th percentile distribution is 54,089 Ibs/day. Using a 95th percentile
distribution and interpolation from ranked observations, the expected monthly
color average is 55,003 Ibs/day. These two 95th percentile monthly average
numbers represent current mill performance. The maximum monthly average
observed during this time period was 58,009 Ibs/day.
1 Interpolated numbers come from the empirical (i.e. the actual ranked values) data
using the calculated percentile by assuming it lies linearly between the closest smaller
percentile and the closest larger percentile within the cumulative percentage distribution.
Due to the limited data set available, an interpolated statistical evaluation is only
possible for a monthly value, not for an annual value.
Permit No. NC0000272
Page 3

June 1, 2001 Statistical Evaluation Report
Blue Ridge Paper Products Inc.
Canton, North Carolina
IV. Conclusion
Based upon color discharge data during the period after the Mill had
implemented all improvements required by the 1997 NPDES Permit, the
expected annual average is 46,475 Ibs/day. Expected monthly color averages
using the same data from two different statistical evaluations are 54,089 and
55,003 Ibs/day.
Using North Carolina's governing flow criteria (30Q2), historical flow records, and
the 2000 annual average color discharge of 43,386 Ibs/day, it is expected that
color in the Pigeon River at the Hepco gage will be less than 50 true color units
100% of the time at all flows above 30Q2.
Permit No. NC0000272
Page 4

Table 1: June 1, 2001 Statistical Evaluation
Monthly Average Data - Max Month/Annual Calculation
Data Set January 2000 -December 2000
n = 12
X-bar 43,386
std dev 6527
95th percentile for Month 54,089
99th percentile for Month 58,593
Max month 58,009
95th percentile for Year from normal distribution 46,475
99th percentile for Year from normal distribution 47,775
Ranked observations-by interpolation
95th percentile for max month 55,003
99th percentile for max month 57,408
BRPP Inc.
Canton Mill
June 1, 2001 Statistical Evaluation
Attachment

BLUE RIDGE
�IPAPER PRODUCTS INC. N=-.1 ry
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July 1, 2004 °o 9V
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ATT: Central File
Mr. Bradley Bennett ;1
Supervisor, Stormwater and General Permits
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh,NC 2.7699-1617
Subject: Request for Designation of Representative Outfall Status.
Blue Ridge Paper Products Inc., Canton Mill, Haywood County
Stormwater Permit NCS000105
Dear Mr. Bennett:
The purpose of this letter is to request representative status for stormwater outfall 6-18
with 6-4 and 6-10 being considered typical for our landfill, as granted in our permit for
analytical sampling. Also to give notice that 6-5 Outfall located at the No. 6 Landfill no
longer exists as the drainage from this area was inside the now active 6A-West cell and
has been tied-in to the leachate collection system. Outfall 6-5 has been removed from our
Stormwater Program.
Outfall 6-18 is a new outfall. This outfall collects stormwater from the gravel road at the
North West comer of the 6A-West Cell in accordance with the Division of Solid Waste
approved plans at the No. 6 Landfill. Our"Stormwater Pollution Plan"has been revised
(see attachments)to reflect the addition of the new outfall and to include the outfall in our
qualitative and facility inspections.
If you have any questions or need additional information, please contact Louie Justus at
828-646-2372.
Sincer
Loouie\Justus / Paul Dickens
Senior Environmental Engineer Manager, Environmental Affairs
175 Main Street • P.O.Box 4000 • Canton,North Carolina 28716
Phone:[phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
July 1, 2004
Certification for Permit No NCS000105
I certify, under penalty of law, that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate and complete. I am aware that there are significant
penalties or submitting false information, including the possibility of fines and
imprisomnent for knowing violations.
Respectfully,
Mr. Robert M. Shanahan
Vice President—Operations Manager

BLUE RIDGE PAPER PRODUCTS INC.
Xc: t M Forest_Westall
NCDENR Division of Water Quality
2090 US 70 Hwy.
Swannanoa,NC 28778
Canton Mill:
Bob Williams—Director, Regulatory Affairs
D\:New 6-18.doe Outfall

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EXISTING
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Drawing Legend: Outfall # 18 (Landfill # 6 )
Total Drainage Area: 6,000 Square Feet (See Note, Below)
Drainage Area Outline:
Drainage and Discharge Structures: Drop Basins
Culvert Pipes
Impervious Surfaces: Roads
Buildings
Stormwater Structural Control Measures: Rip-Rap
Springs
Hazardous Waste Storeage Area HW
Satellite Hazardous Waste Storage Area
Materials Loading and Access Areas LOAD
Note: New Outfall established 5/20/04.

r
WC®ENR AUG - 6 bond
North Carolina Department of Environment and Natural eso rces
Division of Water Quality LARORATORY SECTION
Michael F. Easley, Governor AI AssRJr, Secret&y- -
Alan W. Klimek, P.E., Director.
August 5, 2004
198
Mr. John J. Pryately
Blue Ridge Paper Products Inc. WTP
P.O. Box 4000
Canton, NC 28716
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Mr. Pryately:
Enclosed is a report for the inspection performed on July 21, 2004 by Mr. Gary
Francies. No deficiencies or lettered comments and/or recommendations are cited in
this report, a response is not required. We appreciate the fine job you and your staff are
doing. As a certification requirement, your laboratory must continue to carry out the
requirements set forth in 15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from
this office. Thank you for your cooperation during the inspection. If you wish to obtain an
electronic copy of this report by email, or if you have questions or need additional
information please contact us at 919-733-3908.
Sincerely,c,
James W. Meyer
Laboratory Section
Enclosure
cc: Gary Francies
Laboratory Section 1623 Mail Service Center,Raleigh,North Carolina 27699-1623 One
4405 Reddy Creek Road,Raleigh,North Carolina 27609 NorthCaTolina
Phone: [phone]/FAX:[phone]/Internet:www.dwglab.org
An Equal Opportunity/Affirmative Action Employer—50%Recycledl10%Post Consumer Paper Naturally

On-Site Inspection Report
LABORATORY NAME: Blue Ridge Paper Products WWTP Lab
ADDRESS: P.O. Box 4000
Canton, NC 28716
CERTIFICATE NO: 198
DATE OF INSPECTION: 7/21/04
TYPE OF INSPECTION: Maintenance
EVALUATOR: Gary Francies
LOCAL PERSON(S) CONTACTED: Mr. Paul Dickens, Mr. John Pryately, Ms. Lori Cooper
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
II. GENERAL COMMENTS:
The staff is congratulated for doing a good job of maintaining the laboratory program. The laboratory is
spacious and well equipped. Since the last inspection a new laboratory dishwasher has been obtained.
All equipment is well maintained. Records are well kept and most data appeared accurate.
III. DEFICIENCIES, REQUIREMENTS, COMMENTS, AND RECOMMENDATIONS:
No deficiencies or comments were noted.
IV. PAPER TRAIL INVESTIGATION:
No paper trail was performed because the facility had performed its own internal audit of Discharge Monitoring
Reports (DMR) from April 2003 through April 2004. Amended DMRs were submitted for all errors noted.
V. CONCLUSIONS:
No deficiencies were found during the inspection. No response is required.
Report prepared by: Gary Francies Date: 7/29/04

BLUE RIDGE
PAPER PRODUCTS INC
12 July 2004 CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5184
Mr. D. Keith Haynes
Environmental Specialist
North Carolina Department of Environment
and Natural Resources D C �/ 2
Asheville Regional Office L� D
Division of Water Quality
2090 US Highway 70 AUG 14 2004
Swannanoa,North Carolina 28778
DIVISION OF AIR OUALITV
ASHEVILLE REGIONAL OFFICE
Subject: NPDES NCS000105
Non-Stormwater Discharge to Storm Drain
Blue Ridge Paper Products,Inc.
Canton Mill
This follows our telephone call to you today at 1315. At 1045 today, we confirmed a non-stormwater
discharge to our stormdrain system. The discharge occurred between 1500 and 1700 on 6 July 2004 and
involved less than 1000 gallons of washwater associated with coal handling equipment maintenance.
The water contained turbidity and coal fines.
At the time of discovery on 6 July, we checked the Camp Branch discharge to the Pigeon River
(stormwater outfall#7) .This discharge and was clear. We concluded that the washwater was routed to
and contained in our coal pile stormwater pond. Water in the coal pile stormwater pond is pumped to the
Canton Mill sewer system for treatment. After discussion with knowledgeable persons and tracing
stormdrains this morning, we discovered that washwater observed on 6 July entered the stormdrain
system below the coal pile stormwater pond. There was a release to the river through stormwater outfall
#8. The outlet of stormwater outfall#8 is not readily accessible and is hidden by weeds along the river
bank. The stormdrain routing is not obvious from the ground, which is the reason we were mislead on 6
July when we investigated the washwater discharge.
As corrective action,the Canton Mill will use portable hoses, a vacuum truck and other means in the
future to collect all washwater associated with coal handling equipment maintenance. This water will be
diverted to the mill sewer system.
Paul S. Dickens F. Louie Justus
Environmental Manager Senior Environmental Engineer
828-646-6413 828-646-2372
[e-mail] iustul@bluerid eoaper.com
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5313
22 September 2004
Mr. Forrest Westall
Water Quality Supervisor S� 2r ���q
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office A 110glk4
Division of Water Quality `
2090 US Hwy 70
Swannanoa, North Carolina 28778
Subject: NPDES NC0000272
Ivan - Flood Event of 17 September 2004
Unanticipated Bypass of Treatment
Sanitary Sewer Overflow
Blue Ridge Paper Products, Inc.
Town of Canton, North Carolina
Dear Forrest—
This is the written report required under the subject permit documenting flood damage
and loss of wastewater treatment associated with Hurricane Ivan on the morning of 17
September 2004. The wastewater treatment plant operated by Blue Ridge Paper Products
also treats sewage from the Town of Canton. This report is submitted for both Blue
Ridge Paper Products and the Town of Canton.
The Ivan flood came 9 days after flooding and damage from Hurricane Frances. These
back-to-back floods are unprecedented. Both floods set records for river stage in Canton,
NC at 21 feet and 23 feet respectively. The dike system protecting our wastewater
treatment plant was designed to withstand floods of-- 20 feet river stage, which is above
the historic flood level for Canton. Both floods overtopped our dike. Floodwaters from
Ivan were deeper and more violent than Frances.
We notified DENR by telephone at 0650 on the morning of 17 September 2004 that our
wastewater plant was flooded and shut down. Mill operations were still curtailed as a
result of Frances. We subsequently provided'daily updates on progress towards restoring
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
22 Sep 2004, Page 2
wastewater treatment for the town's wastewater. Wastewater treatment was restored on
the afternoon of 21 September 2004. During the period that wastewater treatment was
down, untreated sewage from the town entered the Pigeon River, both from the mill's
influent lift station and from the town's sewage pump stations that were submerged and
damaged by floodwater. Since mill operations were already down before Ivan and
remained down, there was no release of untreated industrial wastewater. Chemicals and
oil storage on the Blue Ridge site remained secure.
Flood Event
The remnants of Hurricane Ivan passed through Western North Carolina on 16 and 17
September 2004. The mill revised its flood protection plan based on experience with the
Frances flood and began aggressive preparations for Ivan on 11 September 2004. These
advance preparations included installation of large diesel pumps to keep the wastewater
plant and mill dry during a storm event similar in magnitude to Frances.
Blue Ridge Paper began a formal flood watch on the morning of 16 September and
completed installation of floodgates and dike reinforcements protecting the mill and
wastewater treatment plant. The plan for Ivan was to run power boilers and generate mill
power to keep wastewater influent pumps running and the wastewater plant dry. If the
river stage rose to the point of flooding our secondary clarifiers, we would cut off the
effluent discharge and bypass pump over the dike into the river using the diesel pumps.
Between midnight and 0400 on the morning of 17 September, floodwaters backed up into
the wastewater treatment area and overtopped the secondary clarifiers. During this
period, the diesel bypass pumps were able to keep up with both influent and floodwater
flow. The river stage stabilized at— 19 feet from 0330 until 0400, and we felt that we
might succeed in surviving Ivan. In hindsight, the pause in river stage rise was the result
of flooding into the Town of Canton upstream of the mill. When the town filled with
floodwaters, the river stage quickly jumped to 21 feet, then peaked at 23 feet- a new
record for Canton.
At 0408, the mill lost CP&L power. We were generating mill power at that time and
keeping pace with floodwater infiltration, but the surge from loss of external power
tripped out the mill's internal power distribution system. Our influent wastewater pumps
stopped, and the wastewater plant began flooding at the influent lift station. At about
0440, the river overtopped the dike protecting the wastewater plant. Floodwaters rushed
in. By 0500, there was 7 to 8 feet of water in the wastewater treatment area, 3 to 4 feet
higher than the Frances flood. This water flooded the influent lift station, sludge pump
room, secondary clarifiers and switchgear rooms as well as the wastewater control room,
lab and offices. The lower aeration basins also flooded. Only the primary clarifiers and
upper aeration basins remained above flood level. Floodwaters running through the
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 a 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
22 Sep 2004, Page 3
wastewater plant cut a temporary channel along the river side of the aeration basins and
washed out a section of dike between the aeration basins and river.
Downtown Canton was severely flooded, and the town's sewage pump stations along the
Pigeon River were submerged. The town's disinfection pretreatment system located at
the headworks of the Blue Ridge wastewater plant was also submerged.
Recovery
Flood waters started to recede on the afternoon of 17 September 2004. By the morning
of 18 September, Blue Ridge was able to drain and pump remaining floodwater from the
wastewater area and start work to restore wastewater treatment. The Town of Canton
also began work to repair and restore sewage pump stations damaged by the flood.
To drain remaining floodwaters from the wastewater treatment plant and from the mill,
diesel pumps were installed at the influent low lift pumps to the mill's wastewater
treatment system. These pumps discharged to the river.
On the evening of 18 September 2004, the Town of Canton began pumping sewage back
to the mill's wastewater headworks. These waters were then bypass pumped into the
river. On the afternoon of 19 September, the Town of Canton was able to restore the
disinfection pretreatment system. The disinfected wastewater was then pumped into the
river. These interim sewage handling and treatment arrangements had been discussed
with DENR staff and were agreed to be the best measures for public health protection
until full wastewater treatment could be restored.
Work by Blue Ridge personnel to restore wastewater treatment continued non-stop after
floodwaters were drained from the wastewater area. This was truly a heroic effort by our
electricians, mechanics, wastewater operators and contractors. Blue Ridge was able to
restart wastewater treatment operations on the afternoon of 21 September 2004.
Discharge of untreated and partially treated sewage from the Town of Canton through
diesel pumps at the mill's wastewater headworks stopped at 1145 on 21 September 2004.
Blue Ridge resumed compliance monitoring of the wastewater plant effluent that night.
Sanitary Sewer Overflows
The Blue Ridge wastewater treatment facilities were down from 0408 on 17 September
2004 until the afternoon of 21 September 2004. During this period, untreated sewage
from the Town of Canton was discharged to the Pigeon River, both from overflows at
damaged pump stations owned by the town and from the influent of the mill's wastewater
treatment system. Floodwaters and cleaning water from the mill and town were also
discharged to the river.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
22 Sep 2004, Page 4
The quantity of sewer system overflow is difficult to estimate,but is greater than 15,000
gallons. The majority of the overflow was floodwater and cleaning water necessary to
restore sewage pump stations and wastewater treatment. The mill locked restrooms and
installed portable toilets during the wastewater treatment outage to avoid discharge of
domestic sewage to the river from the mill.
A SSO reporting form is enclosed for the period of wastewater treatment outage.
Summary
The Ivan flood was worse than Frances, which was the worst flood event in Canton, NC
for at least 60 years. These back-to-back floods were truly severe acts of nature and
overwhelmed the flood protection structures at the Blue Ridge Paper Products mill. Mill
operations prior to Ivan were still curtailed from Frances. We took aggressive additional
flood protection measures to prepare for Ivan, but the Pigeon River ultimately rose higher
than these extra measures could protect. The Ivan flood and second loss of wastewater
treatment resulted in overflow of untreated sewage from the Town of Canton into the
Pigeon River. We will learn from both floods and prepare a strategy to strengthen flood
protection at the mill.
Blue Ridge Paper Products and the Town of Canton worked diligently and non-stop to
restore treatment of the town's wastewater following the Ivan flood. We were able to
restore essential wastewater services within 4.25 days of the flood event. The Town
restored wastewater disinfection within 2.5 days of the flood event. We greatly
appreciate DENR's assistance and understanding with the emergency recovery efforts. In
particular, we appreciate the multiple site visits by Keith Haynes of your staff to assess
flood damage and recovery efforts for wastewater treatment.
Sincerely—
Paul S. Dickens
Manager, Environmental Affairs
828-646-6141
[e-mail]
Enclosure: SSO Form for Ivan flood event
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

OF VJATF9
Form CS-SSO
Collection System Sanitary Sewer Overflow Reporting Form
P ^C
PART I
This form shall be submitted to the appropriate DWQ Regional Office within five days of the first knowledge of
the sanitary sewer overflow (SSO).
Permit Number: NC 0000272
(WQCS#if active, otherwise use treatment plant NC/WQ#)
Facility: Blue Ridge Paper Products,Inc.-Wastewater Treatment Plant Incident#
Owner: Blue Ridge Paper Products,Inc. Region: Asheville
City: Mill also treats wastewater for Town of Canton,NC County: Haywood Co.
Source of SSO(check applicable): 0 Sanitary Sewer 0 Pump Station
SPECIFIC location of the SSO(be consistent in description from past reports or documentation-i.e. Pump Station 6,
Manhole at Westall& Bragg Street, etc,): Multplewertlowsto Pigeon Riverin Canton,NCdudngandalterlvanPooduntilFlooddamagecauldberepaired.
Latitude(degrees/minute/second): 35/32/06 Longitude(degrees/minute/second) 82/50/34
Incident Started Dt: 09-17-2004 Time, 4:08 am Incident End DT09-21-2004 Time, 11:45 am
(mm-dd-yyyy) hh:mm AM/PM (mm-dd-yyyy) hh:mm AM/PM
Estimated volume of the SSO: unknown> 15,000 102
gallons Estimated Duration(Round to nearest hour):
Describe how the volume was determined: Flood conditions, overflows mixed with flood waters, total volume unknown
Weather conditions during SSO event:Hurricane Ivan, record flood on Pigeon River in Canton, NC, 2nd flood in 9 days
Did SSO reach surface waters? El Yes❑No❑ Unknown Volume reaching surface waters(gallons): unknown
Surface water name: Pigeon River
Did the SSO result in a fish kill? ❑Yes ❑✓ No ❑Unknown If Yes,what is the estimated number of fish killed?
SPECIFIC cause(s)of the SSO:
❑✓ Severe Natural Condition ❑ Grease ❑ Roots
❑ Inflow and Infiltration ❑ Pump Station Equipment Failure ❑ Power outage
❑ Vandalism ❑ Debris in line ❑ Other(Please explain in Part II)
Immediate 24-hour verbal notification reported to: DENR 1-800 number at 06:50 on 9/17, follow-up with Keith Haynes ARO
0 DWQ El Emergency Mgmt. Date(mm-dd-yyyy):09-17-2004 Time(hh:mm AM/PM): 6:50 am
If an SSO is ongoing, please notify Regional Office on a daily basis until SSO can be stopped.
Per G.S. 143-215.1 C(b),the responsible party of a discharge of 1,000 gallons or more of untreated wastewater to surface
waters shall issue a press release within 48-hours of first knowledge to all print and electronic news media providing general
coverage in the county where the discharge occurred.When 15,000 gallons or more of untreated wastewater enters surface
waters, a public notice shall be published within 10 days and proof of publication shall be provided to the Division within 30 days.
Refer to the referenced statute for further detail.
The Director, Division of Water Quality, may take enforcement action for SSOs that are required to be reported to Division unless it
is demonstrated that:
1)the discharge was caused by severe natural conditions and there were no feasible alternatives to the discharge;or
2)the discharge was exceptional, unintentional,temporary and caused by factors beyond the reasonable control of the Permittee
and/or owner, and the discharge could not have been prevented by the exercise of reasonable control.
Part II must be completed to provide a justification claim for either of the above situations.This information will be the basis
for the determination of any enforcement action.Therefore, it is important to be as complete as possible.
WHETHER OR NOT PART II IS COMPLETED,A SIGNATURE IS REQUIRED AT THE END OF THIS FORM.
CS-SSO Form October 9,2003 Page 1

�o�wnr�y G
4 Form CS-SSO
Collection System Sanitary Sewer Overflow Reporting Form
PART I I
ANSWER THE FOLLOWING QUESTIONS FOR EACH RELATED CAUSE CHECKED IN PART I OF THIS FORM
AND INCLUDE THE APPROPRIATE DOCUMENTATION AS REQUIRED OR DESIRED
COMPLETE ONLY THOSE SECTIONS PERTAINING TO THE CAUSE OF THE SSO AS CHECKED IN PART I
In the check boxes below, NA=Not Applicable and NE = Not Evaluated
A HARDCOPY OF THIS FORM SHOULD BE SUBMITTED TO THE APPROPRIATE DWQ REGIONAL OFFICE
UNLESS IT HAS BEEN SUBMITTED ELECTRONICALLY THROUGH THE ONLINE REPORTING SYSTEM
Severe Natural Condition (hurricane, tornado, etc.)
Describe the"severe natural condition" in detail.
Passage of Hurricane Ivan resulted in record flood, overtopped flood dikes and flooded WTP.
How much advance warning did you have and what actions were taken in preparation for the event?
Activated revised flood plan on 9/16 and took all reasonable precautions to prevent flood of WTP
Comments:
Blue Ridge Paper WTP also treats sewage from Town of Canton. Mill shutdown, sewage from town overflowed.
Grease (Documentation such as cleaning, inspections, enforcement
actions, past overflow reports, educational material and distribution date,
etc. should be available upon request.)
When was the last time this specific line(or wet well)was cleaned? Not applicable
Do you have an enforceable grease ordinance that requires new or retrofit of grease traps/interceptors? []Yes[] No dA❑NE
Have there been recent inspections and/or enforcement actions taken on nearby restaurants or other []Yes[]No ONA❑NE
nonresidential grease contributors?
Explain.
Have there been other SSOs or blockages in this area that were also caused by grease? ❑Yes❑ No UNADNE
When?
If yes,describe them:
Have cleaning and inspections ever been increased at this location? []Yes[:] No MLNA FINE
Explain.
CS-SSO.Form October 9,2003 Page 2

Have educational materials about grease been distributed in the past? ❑Yes❑ No WNA❑NE
When?
and to whom?
Explain?
If the SSO occurred at a pump station,when was the wet well and pumps last checked for grease
accumulation?
Were the floats clean? []Yes[] No NA❑NE
Comments:
Roots
Do you have an active root control program? []Yes[-] No NA❑NE
Describe /
1
Have cleaning and inspections ever been increased at this location because of roots? ❑Yes❑No UNA❑NE
Explain:
What corrective actions have been accomplished at the SSO location(and surrounding system if
associated with the SSO)?
What corrective actions are planned at the SSO location to reduce root intrusion?
Has the line been smoke tested or videoed within the past year? ❑Yes❑ No NA❑NE
If Yes,when?
Comments:
Inflow and Infiltration
Are you under an SOC(Special Order by Consent)or do you have a schedule in any permit that ❑Yes❑No NA❑NE
addresses I/I?
CS-SSO Form October 9,2003 Page 3

Explain if Yes:
What corrective actions have been taken to reduce or eliminate I&I related overflows at this spill location
within the last year?Has there been any flow studies to determine 1/1 problems in the collection system at the SSO location? ❑Yes1--I[]No NA❑NE
If Yes,when was the study completed and what actions did it recommend?
Has the line been smoke tested or videoed within the past year? ❑Yes❑No LZINA❑NE
If Yes,when and indicate what actions are necessary and the status of such actions:
Are there 1/1 related projects in your Capital Improvement Plan? LJYeL1 No L&NA NE
If Yes,explain:
Have there been any grant or loan applications for 1/1 reduction projects? ❑Yes❑No BNA❑NE
If Yes, explain:
Do you suspect any major sources of inflow or cross connections with storm sewers? ❑Yes[]No UNA❑NE
If Yes,explain:
Have all lines contacting surface waters in the SSO location and upstream been inspected recently? ❑Yes❑No NA❑NE
If Yes, explain:
What other corrective actions are planned to prevent future 1/1 related SSOs at this location?
Comments:
Pump Station Equipment Failure (Documentation of testing records etc.,
shoul be provided upon request.)
What kind of notification/alarm systems are present?
Auto-dialer/telemetry(one-way communication) ❑✓Yes
CS-SSO Form October 9, 2003 Page 4

Audible aes
Visual ❑Yes
SCADA(two-way communication) ❑Yes
Emergency Contact Signage ❑Yes
Other ❑Yes
Describe the equipment that failed?
Flood waters submerged WTP and sewage pump stations, power was lost as result of flooding
What kind of situations trigger an alarm condition at this station(i.e. pump failure, power failure, high
water,etc.)?
high level ,
Were notification/alarm systems operable? Yes❑NoHNAEINE
If no, explain:
If a pump failed,when was the last maintenance and/or inspection performed?
What specifically was checked/maintained?
If a valve failed,when was it last exercised?
Were all pumps set to alternate? []Yes[]No MINNA❑NE
Did any pump show above normal run times prior to and during the SSO event? ❑Yes❑NoU(A❑NE
Were adequate spare parts on hand to fix the equipment(switch,fuse,valve,seal, etc.)? ❑Yes❑ No NA❑NE
Was a spare or portable pump immediately available? DYes11 No NA❑NE
If a float problem,when were the floats last tested? How?
If an auto-dialer or SCADA,when was the system last tested? How?
Comments:
CS-SSO Form October 9,2003 Page 5

Power outage (Documentation of testing, records, etc., should be
provided of alternative power source upon request.)
What is your alternate power or pumping source?
• Generator
Did it function properly? ❑Yes❑No BNAFINE
Describe?
When was the alternate power or pumping source last tested under load?
If caused by a weather event, how much advance warning did you have and what actions were taken to
prepare for the event? Activated revised flood plan on 9/16 and took all reasonable precautions to prevent flood of WTP
Comments:
Vandalism
Provide police report number: �-ry
Was the site secured? DYes❑ No NA❑NE
If V.. hn,.)
Padlocked Control Panel /
Have there been previous problems with vandalism at the SSO location? Yes❑No EINA UNE
If Yes,explain:
What security measures have been put in place to prevent similar occurrences in the future? []Yes[-] No NA❑NE
Comments:
Debris in line (Rocks, sticks, rags and other items not allowed in the
collection system, etc.)
What type of debris has been found in the line?
How could it have gotten there?
Are manholes in the area secure and intact? U YesU No UNA NE
CS-SSO Form October 9,2003 Page 6

When was the area last checked/cleaned? r{/
Have cleaning and inspections ever been increased at this location due to previous problems with debris? ❑Yes❑No MINA❑NE
Explain:
Are appropriate educational materials being developed and distributed to prevent future similar ❑YesEI No UNADNE
occurrences?
Comments:
Other(Pictures and a police report should be available upon request.)
Describe:
Were adequate equipment and resources available to fix the problem? ❑Yes❑ No LANA❑NE
If Yes,explain:
If the problem could not be immediately repaired,what actions were taken to lessen the impact of the
SSO?
Comments:
For DWQ Use Only: /NA
IDWQ Requested an Additional Written Report: ❑Ye 1^No ONE
If Yes,What Additional Information is Needed:
Comments:
SSOs were result of 2nd major flood event in 9 days that damaged wastewater treatment plant
owned by Blue Ridge Paper Products and also damaged sewage pump stations owned by Town
of Canton. See letter from Blue Ridge Paper Products dated 22 Sep 2004.
CS-SSO Form October 9,2003 Page 7

As a representative for the responsible party, I certify that the information contained in this report is true and accurate
to the best of my knowledge.
Person submitting claim: Bob Shanahan Date: 22 Sep 2004
Signature: ") Title: VP and Mill Manager
Telephone Number. 828-646-2840
Any additional information desired to be submitted should be sent to the appropriate Division Regional Office within rive days of first
knowledge of the SSO with reference to the incident number(the incident number is only generated when electronic entry of this form
is completed, if used).
Reference letter from Blue Ridge Paper Products dated 22
September 2004.
CS-SSO Form October 9, 2003 Page 8

contact:Robert Williams,Director-Regulatory Affairs BLUE RIDGE
Blue Ridge Paper Products Inc.
Phone:(828)646—2033 PAPER PRODUCTS INC.
Email:,[e-mail]
For Immediate Release
City of Canton's Municipal Waste Returned to Full Treatment
Canton, NC -- September 22, 2004 -- On September 16, 2004 Haywood County and Western North
Carolina again received floodwaters. Hurricane Ivan caused the shutdown of Blue Ridge Paper
Products' wastewater treatment plant. Manufacturing operations at the Canton Mill were still in
curtailment from the floods associated with Hurricane Frances that occurred on September 8`s' The
Blue Ridge wastewater treatment plant also receives municipal waste from the Town of Canton. As a
result of this shut down untreated waste from the Town of Canton was released to the Pigeon River.
On September 21, 2004 Blue Ridge Paper Products was able to fully restore wastewater
treatment operations. Town of Canton and Blue Ridge Paper personnel worked diligently and
non-stop to restore wastewater services following the flood.
Representatives of the Haywood County Health Department, the North Carolina Department of
Environment and Natural Resources, and Haywood County Emergency Services were notified of
flood damage to Canton and Blue Ridge wastewater treatment systems. These agencies closely
monitored actions to restore essential wastewater services and provided valuable assistance with the
flood response effort.

Sep-14-2004 07:50pm Ffwr6LLE RIDGE PAPER 8286466892 T-068 P.001 F-384
c BLUE RIDGE
PARR PRODUCTS IMc '
175 MAIN STREET
CANTON, NC 28716
FACSIMILE TEANSIAITTAL SHEET
`ro: FROM:
COMPANY: DATE:
ILA SAP zo0LI
FAX NUMBER:<92j:? 24q -�o43 -TOTAL NO.OP PAdamGES iNC =NG COVER:
- _
PHONE NUMBER SENOFR'S REFERENCE NUMBER:
yzs - 291'-- L["so0
ItE_ YO[E'REFERENCE NUMBER:
.17 P -�-
I7 URGENT Al FOR REVIEW ❑PLEASE COMMENT [I PLEASE REPLY ❑PLEASE RECYCLE
(VOTES/COMMENTS,`:
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return,by mail,the original message to us. Thank you.'
SEP 1 4 2004 D
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE

Serr14-2004 07:50pm FrurBLUE RIDGE PAPER 8286466892 T-068 P.002 F-384
Paul To [e-mail]
DickenslCerdon/BlueRidge [e-mail]
09/14/2004 0722 PM Pryately/Canton/BlueRtdge@BlueRidgePaper,Bob
William K-antonlBlueRidge@BlueRidgePaper,Daryl
4YhitUCantonlBImRidge@BlueRidgePaper,Michael
KoerscbnerlCantonA31ueRidge@BlueRidgePaper,Steve
hcc Si ngl e/Canto n/BlueRidge@BlueRidg ePaper
Subject Blue Ridge Flood Outage Letter and Status Update
14 Sep 2004
Keith Haynes, NC DENR ARO DWO-
An electronic copy of our flood outage letter is attached. I will also fax a copy with the enclosure tonight.
We serit this out by certIfled mail this rooming,and tonight I found one typo on the last page. We were
able to restore full treatment of the town of Canton wastewater within 3.5 days or 82 hours of the time that
we lost wastewater treatment to floodwaters. This is corrected on the electronic copy and fax.
Blue Ridge Paper Products greatly appreciates your help and assistance with restoring wastewater
treatmcmt after the flood.Your visits an 8 September and today were great. Thanks also for your guidance
on replacing our flood damaged strip chart recorders with more modem data trend loggers. I think this is
the coat,we will go.
As you are aware,Blue Ridge contracted with PACE Labs to inn our dally process and compliance
wastewater samples. This will continue until we are able to restore our former wastewater lab capability.
We have restored on-site capability for pH, DO,conductivity,temperature and color monitoring.
Compliance sampling and the dally river inn resumed on 12 September,or within 4 days of the flood.
Yesterday,we restored our wastewater flow totalizer. We continue to take 4-hr manual flow readings as
well as pH and DOs to check that our instrumentation is reading correctly. We do not yet have continuous
flow or pH recording although the instruments are working and providing readouts IocaRy or In our control
room. ,NubDmaUc data recording capability will take a while to restore.
We will have a gap In our wastewater compliance monitoring from 7 September thru 11 September 2004
due to the flood. I previously sent you an e-mail documenting the samples in our refrigerator that were
lost to the flood. I also sent you information on our flood protection plan for Ivan expected this Friday.
Keith,cote again,thank you so much for DENR's help and assistance with the flood.
Paul Dickens
Manager, Environmental Affairs
Blue Ridge Paper Products,Inc.
dickepdpblueridgepaper.com
828-64141i-6141 FAX [phone]
l FITI
fI=dfvN,U994.doc

Sep-14-2004 07:51pm From-BLUE RIDGE PAPER 8286466892 T-068 P.003 F-384
BLUE RIDGE
BLUE
E
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
14 September 2004 7099 3220 0007 0371 5306
Mr.Forrest Westal
Water Quality Supervisor
North Carolina Department of Environment
:md Natural Resources
Asheville Regional Office
Division of Water Quality
2090 US Hwy 70
Swannanoa,North Carolina 28778
SuiDject: NPDES NC0000272
Flood Event of 8 September 2004
Unanticipated Bypass of Treatment
Sanitary Sewer Overflow
Blue Ridge Paper Products,Inc.
Town of Canton,North Carolina
Dear Forrest—
Th is is the written report required under the subject permit documenting flood damage
and loss of wastewater treatment associated with hurricane Frances on the morning of 8
September 2004. The wastewater treatment plant operated by Blue Ridge Paper Products
also treats sewage from the Town of Canton. This report is submitted for both Blue
Ridge Paper Products and the Town of Canton.
Wt:notified DENR by telephone at 0745 on the morning of 8 September that the mill was
shut down and that our wastewater plant was flooded. We subsequently provided daily
updates on progress towards restoring wastewater treatment for the town's wastewater.
Wastewater treatment was restored on the afternoon of 11 September 2004. During the
period that wastewater treatment was down, untreated sewage from the town entered the
Pigeon River,both from the mill's influent lift station and from the town's sewage pump
stations that were submerged and damaged by floodwater. Since mill operations were
curtailed in advance of the flood and remained down,there was no release of untreated
industrial wastewater. Chemicals and oil storage on the Blue Ridge site remained secure.
Environmental Group
175 Maio Street . PO Box 4000
Canton,North CarolIna 28716• 828-646-2000
Raising Your Expectations

Sep-14-2004 07:51 pm Frmn-BLUE RIDGE PAPER 8236466892 T-068 P.004/015 F-384
Forrest Westall, NC DENR ARODWQ
14 Sep 2004, Page 2
Flood Event
The remnants of hurricane Frances passed through Western North Carolina on 7 and 8
September 2004. The mill began a flood watch early on the morning of 7 September.
Based on water levels in Pigeon River,the mill activated its flood protection plan at 1600
on 7 September and installed floodgates in the dikes protecting the mill and wastewater
treatment plant. At- 1900 the mill began a controlled shutdown of the backend of the
mi'11-recovery and pulp production-as a precaution against flooding. At.-2200 based
on rapid river rise, we began a controlled shutdown of paper production as a precaution
agadnst flooding. We also started a controlled shutdown of power boilers.
At 0253 on the morning of 8 September,floodwaters backed up into the wastewater
treatment area and overtopped the secondary clarifiers. At that time,the low lift pumps
to wastewater treatment were stopped. This started an unanticipated bypass of treatment
necessary to prevent severe property damage. At this time all mill operations were down,
and chemical and oil tanks were secure. Aerators in the aeration basins were turned off
to !tebde and store activated sludge.
At 0330 on 8 September,power to the mill site including wastewater treatment was
turned off to prevent damage to electrical substations and switch gear from flood water.
The mill went cold at that time,and all industrial wastewater generation stopped.
At-0600 on 8 September,the Pigeon River crested at 21 feet, a record for Canton. The
mi I1's protective dike system was overtopped. There was 4 to 5 feet of water in the
wastewater area.This water flooded the influent lift station,secondary clarifiers and
svr.tch gear rooms as well as the wastewater control room,lab and offices. The aeration
basins and primary clarifiers remained above flood level.
Downtown Canton was severely flooded, and the town's sewage pump stations along the
Pigeon River were submerged. The towns disinfection pretreatment system located at
the head-works of the Blue Ridge wastewater plant was also submerged.
Recanvery
Flood waters started to recede on the afternoon of 8 September. By the morning of 9
September,Blue Ridge was able to drain and pump remaining floodwater from the
wastewater area and start work to restore wastewater treatment. The Town of Canton
also began work to repair and restore sewage pump stations damaged by the flood.
To drain remaining floodwaters from the wastewater treatment plant and from the mill,
portable diesel pumps were installed at the influent low lift pumps to the mill's
wastewater treatment system. These pumps discharged to the river.
Environmental Group
175 Main Street . PO Box 4000
Canton,North Carolina 28716• M-646-2000
Raising Your Expectations

Sep-1 4-2004 07:52pm From-BLUE RIDGE PAPER 8286466992 T-068 P.005/015 F-384
Forrest Westall, NC DENR ARO DWQ
14 Sep 2004, Page 3
Ont the morning of 10 September 2004,the Town of Canton was able to restore the
disinfection pretreatment system. At that time,the town began pumping sewage back to
the:trill's wastewater headworks. The disinfected wastewater was then pumped into the
river. This interim treatment had been discussed with DENR staff and was agreed as the
best measure for public health protection until full treatment could be restored.
Work by Blue Ridge personnel to restore wastewater treatment continued non-stop after
floodwaters were drained from rite wastewater area. Blue Ridge was able restart
wastewater treatment operations on the afternoon of I September 2004. Discharge of
untreated and partially treated sewage from the Town of Canton through diesel pumps at
the mill's wastewater headworks stopped at— 1250 on I 1 September. Blue Ridge
resumed compliance monitoring of the wastewater plant effluent that night.
Sanitary Sewer Overflows
The Blue Ridge wastewater treatment facilities were down from 0300 on 8 September
2004 until the afternoon on 11 September 2004. During this period,untreated sewage
from the Town of Canton was discharged to the Pigeon River,both from overflows at
damaged pump stations owned by the town and from the influent of the mill's wastewater
treatment system. Floodwaters and cleaning water from the mill and town were also
discharged to the river.
The quantity of sewer system overflow is difficult to estimate,but is greater than 15,000
gallons. The majority of the overflow was floodwater and cleaning water necessary to
restore sewage pump stations and wastewater treatment The mill locked restrooms and
installed portable toilets during the wastewater treatment outage to avoid discharge of
domestic sewage to the river from the mill.
An SSO reporting form is enclosed for the period of wastewater treatment outage.
Summary
Th'..s event was truly a severe act of nature and overwhelmed the flood protection
structures at the Blue Ridge Paper Products mill in Canton,North Carolina. We executed
a controlled shutdown of the mill in advance of the flood and prevented release of
untreated industrial wastewater,chemicals or oil. The flood and loss of wastewater
treatment did result in overflow of untreated sewage from the Town of Canton into the
Pigeon River. We will leam from this event and make revisions to the mill's flood
protection plan.
Environmental Group
175 Main Street • PO Box 4000
Canton,North Carolina 28716• 1328-646-2000
Raising Your Expectations

Sep-14-2004 07:52pm Frmn-BLUE RIDGE PAPER 8286466892 T-068 P.006/015 F-384
Forrest Westall, NC DENR ARO DWQ
14 Sep 2004, Page 4
President Bush declared Western North Carolina as a Federal disaster area as a result of
the hurricane Frances flood. Blue Ridge Paper Products and the Town of Canton.worked
diligently and non-stop to restore treatment of the town's wastewater following the flood.
We:were able to restore essential wastewater services within 3.5 days of the flood event.
We greatly appreciate DENR's assistance and understanding with the emergency
recovery efforts. In.particular,we appreciate the site visit by Keith Haynes and Roy
Davis of your staff on 8 September to assess flood damage to our wastewater plain.
Sincerely—
Paul S. Dickens
Manager,Environmental Affairs
823-646-6141
[e-mail]
Enclosure: SSO Form for flood event
Environmental Group
175 Main Street . PO Box 4000
Canton,North Carolina 28716. 828-646-2000
Raising Your Expectations

Contact:Robert Williams,Director-Regulatory Affairs BLUE RIDGE
Ridge Paper Products Inc.
Phone:(828)646—2033 PAPER PRODUCTS INC.
Email:willib®blueridceoaoer.com
For Immediate Release
City of Canton's Municipal Waste Returned to Full Treatment
Canton, NC -- September 22, 2004 -- On September 16, 2004 Haywood County and Western North
Carolina again received floodwaters. Hurricane Ivan caused the shutdown of Blue Ridge Paper
Products' wastewater treatment plant. Manufacturing operations at the Canton Mill were still in
curtailment from the floods associated with Hurricane Frances that occurred on September 8d' The
Blue Ridge wastewater treatment plant also receives municipal waste from the Town of Canton. As a
result of this shut down untreated waste from the Town of Canton was released to the Pigeon River.
On September 21, 2004 Blue Ridee Paper Products was able to fully restore wastewater
treatment operations. Town of Canton and Blue Ridge Paper personnel worked diligently and
non-stop to restore wastewater services following the flood.
Representatives of the Haywood County Health Department, the North Carolina Department of
Environment and Natural Resources, and Haywood County Emergency Services were notified of
flood damage to Canton and Blue Ridge wastewater treatment systems. These agencies closely
monitored actions to restore essential wastewater services and provided valuable assistance with the
flood response effort.

YCCz . H-%,VLr,
Temporary Results Summary-Wastewater Treatment
BRPPI 22-Sep-04
Flow PI Color SE Color MLSS MLVSS Wst Sludge PI TSS PE TSS SE BOD-5 SE TSS SE NH3-N
Date mad m Ibs/da m Ibs/da m m m m m m Ibs/da m Ibs/da mqA
Limits
Max day 3,205 12,459
Month av 29.9 52,000 10,897 49,560
9/7-9/11/04 Frances flood,WTP down or samples/data lost
9/1212004,,..., _._,.__..___,12:0....................371 ,..,,,,,,,,,,37,130,.__...,..,,,,,.....190 ...,,,,,,.,..19,015......____,2;000__............1,560,,,,,,,,,,,,,..no waste_...... .....610 140 14 1,401 49 4,904
.... ... ..................................................................................................................................................................... .........................
9/13/2004 _13_6, .504 _ 57,166 147 16.673 2,700 2,120 6,900 1,600 110 9 1,021 38 4,310
.....__ ._.'__....._._ _..._............................................................. ._................................................................._._..._..___. ....._.........................._.. ..._...................._..._..........................................................
9/14/2004 .16. .326 44,589 184 25,167 2,500 1,790 no waste 1,800 140 10 1,368 58 7,933
........_._.._.................................................._ _.............................................."-- __._..._._....._...___..............................._._.................. ._ ............
....._
9/15/2004..._ ..............................._.._..........._501..............73.957...............231............_34:100.............._2.700__2.060............._no,waste......................._.._6.__............_280........___.__.........................._...._... ...................._.. _......3.100............._�.:14
9/16/2004...... ................._Po:e..................._403.............69.909..................._293..........._50,827 samples.Iostlolvan.flood............................................._....................................
9/17/2004...... .._SeoonU,flood from Ivan.WTP down................................................................ ............................. .................................................................. ...................................................................................................
......................................................................................................
9/18/2004 Second flood from Ivan,WTP down
............................. ....................................................................................................................................................... ............................. ............................................................................................................................................................................................................................................................................
9/1 912 0 0 4 Second flood from Ivan,WTP down
.............................. ....................................................................................................................................................... ........................................................................................................................................................................................-...................................................................._.........................................
.
9/20/2004 Second flood from Ivan,WTP down
.................................__...........................................................................................................................................___...___................................................................__. _....................................._........................_.._._............_................_.................................
9/21/2004 ,_Second flood.from.Ivan,WTP down (restarted at-12 noo. .
9/22/2004
_........._........__ _....................................................... _._.............................................................._...
3/2004 .........._..._.__
9/2
.............................. ............................. ................................................................................................................................_.._............ ................................................................................................ ...................................._.................................................. ............................. .........................................
...__......
9/24/2004
............................. ................................................................................................................................................... ............................. ....................................................................................................................................................................................................................................................I........................
9/25/2004
.............................. .................................................................................................................................................... ............................. ...................................................................................................................................................................................................................... ............................................-........
9/26/2004
............................................................ ............................. ......................................................................_..-..__...... ..............._...................................................................................................................................................................... ..................................................................................................................
9/27/2004
...................._._............................. .._..._.._......_..........................................-....................._._.___._. __..........
9/28/2004
9/29/2004
... .._ ....................................................._........_._W__.._...........___...._._..._.....................................................__.__
9/30/2004
Ibs/day=flow(mgd)x conc(ppm or mg/1)x 8.34
tempflowcolor.xls,Temp Sum Pace 1 of 1 Printpri a/22/2004

9/22/2004 7:55:54 AM Morning Report-WTP Page 1
Canton Mill WWTP Database
9/1/2004 TO 9/30/2004
Date Flw. 12MN SE.TSS SE.TSS SE.BOD SE.BOD SE.COD SE Col ST SE.Color SE.DO SE.pH SE.pHI.Min
an d mg/1 lb/daym /1 Ib/da mg/1 mg/1 °lb/day' mg/1 H H
9/1/2004 24.51 27.00 5,519.39 7.58 1,549.52 234.00 47,834.69 7.81 7.70 7.60
9/2/2004 24.27 8.00 1,619.03 6.78 1,372.13 213.00 43,106.61 7.78 7.70 7.60
9/3/2004 23.74 8.00 1,583.93 197.00 39,004.35 8.54 7.70 7.50
9/4/2004 22.74 8.00 1,517.21 185.00 35,085.55 7.76 7.80 7.70
9/5/2004 23.70 8.00 1,581.00 211.00 41,698.80 8.46 7.70 7.60
9/6/2004 24.62 19.00 3,900.65 205.00 42,085.98 10.39 7.30 7.10
9/7/2004 33.21 12.00 3,323.86 260.00 72,016.90 8.97 7.30 7.30
9/12/2004 10.56
9/13/2004 9.03
9/14/2004 9.64
9/15/2004 10.98
9/16/2004 7.08
Average 25.25 12.86 2,720.72 7.18 1,460.82 215.00 45,833.27 8.92 7.60 7.49
Total 176.78 90.00 19,045.07 14.36 2,921.64 0.00 1,505.00 320,832.86 107.00 53.20 5240
Minimum 22.74 8.00 1,517.21 6.78 1,372.13 185.00 35,085.55 7.08 7.30 7.10
Maximum 33.21 27.00 5,519.39 7.58 1,549.52 260.00 72,016.90 10.98 7.80 7.70

9/22/2004 7:55:54 AM Morning Report-WTP Page 2
Canton Mill WWTP Database
9/1/2004 TO 9/30/2004
Date SE.pH.Max SENH3comp SE.Res.P SE DS PI.TSS PI.TSS PI.BOD PI.BOD PI Col ST PI.Color PI.Temp
H m /I mg/1 Ibs/da m /1 Ib/da m /1 Ib/da mg/1 "Ib/da " de C
9/1/2004 7.70 0.11 1.09 642.00 131,238.76 256.83 52,501.64 280.00 57,238.09 44.50
9/2/2004 7.70 0.08 1.39 548.00 110,903.39 290.42 58,774.75 321.00 64,963.48 46.40
9/3/2004 7.70 0.09 1.04 602.00 119,190.94 287.00 56,823.59 46.20
9/4/2004 7.80 0.07 0.51 596.00 113,032.35 367.00 69,602.14 45.80
9/5/2004 7.80 0.06 0.43 622.00 122,922.53 369.00 72,923.49 46.60
9/6/2004 7.60 0.08 1.79 474.00 97,310.99 381.00 78,218.32 47.80
9/7/2004 7.60 0.08 1.06 604.00 167,300.80 264.00 73,124.85 44.10
9/12/2004
19.00
9/13/2004
19.10
9/14/2004
19.00
9/1 512 0 0 4
25.00
9/16/2004
28.90
Average 7.70 0.08 1.04 584.00 123 128.54 273.63 55,638.19 324.14 67,656.28 36.03
Total 53.90 0.57 7.31 0.00 4,088.00 861,899.75 547.25 111,276.38 2,269.00 472,893.96 432.40
Minimum 7.60 0.06 0.43 474.00 97,310.99 256.83 52,501.64 264.00 56,823.59 19.00
Maximum 7.80 0.11 1.79 642.00 167,300.80 290.42 58,774.75 381.00 78,218.32 47.80

9/22/2004 7:55:55 AM Morning Report-WTP Page 3
Canton Mill W WTP Database
9/1/2004 TO 9/30/2004
Date PE.TSS PE.TSS PE.BOD PE.BOD Waste.SS WasIa.SS MLSS MLVSS ML.%Vol F/M.BOD MCRT
m /1 Ib/da mg/1 Ib/da mg/1 Ib/da mg/1 mg/1 % days
9/1/2004 83.00 16,967.00 186.60 38,145.10 1,972.00 17,762.20 2,213.00 1,874.00 84.68 0.37 5.23
9/2/2004 62.00 12,547.46 178.20 36,063.84 2,136.00 19,239.38 2,155.00 1,835.00 85.15 0.36 5.69
9/3/2004 46.00 9,107.61 2,040.00 13,610.88 2,101.00 1,774.00 84.44 7.61
9/4/2004 69.00 13,085.96 1,920.00 12,810.24 2,043.00 1,755.00 85.90 7.85
9/5/2004 49.00 9,683.61 1,844.00 12,303.17 2,101.00 1,855.00 88.29 8.33
9/6/2004 63.00 12,933.74 2,332.00 15,559.10 2,100.00 1,860.00 88.57 5.94
9/7/2004 58.00 16,065.31 1,904.00 12,703.49 2,053.00 1,796.00 87.48 7.05
Average 61.43 12 912.96 182.40 37 104.47 2,021.14 14 855.49 2,109.43 1,821.29 86.36 0.36 6.81
Total 430.00 90,390.70 364.80 74,208.93 14,148.00 103,988.46 14,766.00 12,749.00 604.52 0.73 47.70
Minimum 46.00 9,107.61 178.20 36,063.84 1,844.00 12,303.17 2,043.00 1,765.00 84.44 0.36 5.23
Maximum 83.00 16,967.00 186.60 38,145.10 2,332.00 19,239.38 2,213.00 1,874.00 88.57 0.37 8.33

9/22/2004 7:55:55 AM Morning Report-WTP Page 4
Canton Mill WWTP Database
9/1/2004 TO 9/30/2004
Date SVI.30 %Recycle Pri%BODrm BOD.T.%Rm Plymr-Sec Poly SDMs %WAS->SDM CaFlw Avg Ca.BOD CA DO Avg
mU % % % m Ibs/ton %, an d m 1 m /1
9/1/2004 355.63 27.34 97.05 5.30 11.92 119.57 7.59
9/2/2004 365.20 38.64 97.67 6.80 14.78 216.52 7.41
9/3/2004 384.10 5.66 10.25 193.90 7.98
9/4/2004 427.31 7.98 10.18 140.90 7.80
9/5/2004 418.85 6.37 9.10 122.80 7.45
9/6/2004 382.38 9.01 13.78 124.09 7.28
9/7/2004 386.26 3.66 7.06 7.61
9/12/2004 8.54
9/13/2004 8.76
9/14/2004 8.65
9/16/2004 8.68
9/16/2004
8.30
Average 388.53 32.99 97.36 6.40 11.01 152.96 8.00
Total 2,719.73 0.00 65.99 194.71 0.00 44.78 77.07 917.78 0.00 96.05
Minimum 355.63 27.34 97.05 3.66 7.06 119.57 728
Maximum 427.31 38.64 97.67 9.01 14.78 216.52 8.76

9/22/2004 7:55:55 AM Morning Report-WTP Page 5
Canton Mill WWTP Database
9/1/2004 TO 9/30/2004
Date Ca.pH Ca Col ST Ca.Temp Delta T. Fi.Temp FLpH FLBOD AC DO Avg BC DO Avg HeFlow Av HE Col ST
H mg/1 de C de C de C H m 1 mg/1 m /1 an d mg/1
9/1/2004 7.20 19.00 20.40 2.70 23.10 7.50 6.06 245.60 66.00
9/2/2004 6.90 18.00 19.50 0.30 19.80 7.00 6.44 442.08 34.00
9/3/2004 6.90 18.10 1.20 19.30 7.10 7.87 383.91
9/4/2004 6.80 18.70 2.10 20.80 7.10 7.51 286.96
9/5/2004 6.90 19.10 2.50 21.60 7.30 7.08 255.30
9/6/2004 6.40 18.80 4.00 22.80 6.80 6.50 241.08
9/7/2004 7.00 17.40 3.80 21.20 7.10 6.95
9/12/2004 7.70 15.70 0.10 15.80 7.80 9.09
9/13/2004 7.50 15.00 -0.40 14.60 7.40 9.21
9/14/2004 7.20 14.40 0.10 14.50 7.50 8.91
9/15/2004 7.20 9.00 14.90 -0.10 14.80 7.60 9.01 8.00
9/16/2004 7.20 17.00 16.40 0.70 17.10 7.60 8.21 - 12.00
Average 7.08 15.75 17.37 1.42 18.78 7.32 7.74 309.16 30.00
Total 84.90 63.00 208.40 17.00 225.40 87.80 0.00 92.83 0.00 1,854.93 120.00
Minimum 6.40 9.00 14.40 -0.40 14.50 6.80 6.06 241.08 8.00
Maximum 7.70 19.00 20.40 4.00 23.10 7.80 9.21 442.08 66.00

9/22/2004 7:55:56 AM Morning Report-WTP Page 6
Canton Mill W WTP Database
9/1/2004 TO 9/30/2004
Date 140Col ST T140CoIST SE Tot N IF DO 1st FI DO 2nd Fi DO 3rd AC DO 1st AC DO 2nd AC DO 3rd SC DO 1st BC DO 2nd
m /1 m /l m /l m /I mA mA m /I m /I m /I m /l mA
9/1/2004 13.00 13.00 7.64 6.06 6.05
9/2/2004 14.00 14.00 7.88 6.45 6.43
9/3/2004 8.49 7.88 7.86
9/4/2004 8.30 7.52 7.50
9/5/2004 8.60 7.07 7.09
9/6/2004 8.71 6.52 6.48
917/2004 8.92 6.96 6.94
9/12/2004 9.17 9.08 9.10
9/13/2004 9.29 9.22 9.20
9/14/2004 9.18 8.90 8.91
9/15/2004 10.00 10.00 9.44 9.02 8.99
9/16/2004 11.00 11.00 8.42 8.20 8.22
Average 12.00 12.00 8.67 7.74 7.73
Total 48.00 48.00 0.00 104.04 0.00 0.00 92.88 92.77 0.00 0.00 0.00
Minimum 10.00 10.00 7.64 6.06 6.05
Maximum 14.00 14.00 9.44 9.22 9.20

9/22/2004 7:55:56 AM Morning Report-WTP Page 7
Canton Mill WWTP Database
9/1/2004 TO 9/30/2004
Date BC DO 3rd H3PO4 Fed FI Temp 1 FI Temp 2 FI Temp 3
m /I lb/daydeg.C deg.C de .C
9/1/2004 0.00 23.10
9/2/2004 0.00 19.80
9/3/2004 0.00 19.30
9/4/2004 0.00 20.80
9/5/2004 0.00 21.60
9/6/2004 2,063.25 22.80
9/7/2004 0.00 21.20
9/12/2004 15.80
9/13/2004 14.60
9/14/2004 14.50
9/15/2004 14.80
9/16/2004 17.10
Average 294.75 18.78
Total 0.00 2,063.25 225.40 0.00 0.00
Minimum 0.00 14.50
Maximum 2,063.25 23.10

State of North Carolina
Department of Environment `� •
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor NCDENR
William G. Ross Jr., Secretary
Alan W. Klimek, P.E., Director NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
September 2,2004
CANTON MILL
ATTN:LOUIE JUSTUS,OR SUCCESSOR
PO BOX 4000
CANTON, NC 28716
Subject: NPDES Stormwater Permit Renewal
Canton Mill
Permit Number NCS000105
Haywood County
Dear Permittee:
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000105. This permit expires
on Apri130,2005. North Carolina Administrative Code(15A NCAC 2H.0105(e))requires that an application for
permit renewal be filed at least 180 days prior to expiration of the current permit. In order to assure your continued
coverage under your permit,you must apply to the Division of Water Quality(DWQ)for renewal of your permit.
To make this renewal process easier,we are informing you in advance that your permit will be expiring. Enclosed
you will find an individual permit renewal application form,supplemental information request, and Stormwater
Pollution Prevention Plan certification.
Filing the application form along with the requested supplimental information will constitute your application for
renewal of your permit. As stated above,the application form must be completed and returned along with all
requested information by in order for the permit to be renewed by April 30,2005.
Failure to request renewal by may result in a civil assessment of at least$500.00. Larger penalties may be
assessed depending on the delinquency of the request. Discharge of Stormwater from your facility without
coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could
result in assessments of civil penalties of up to$25,000 per day.
If you have any questions regarding the permit renewal procedures please contact Bill Mills of the Stormwater and
General Permits Unit at(919)733-5083,ext.548.
Sincerely,
Bradley Bennett,Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater and General Permits Unit Files Eonsumer
np f�' DAsheville-RegionalOffice V l57 2004ITY SE TIO CE1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-73CiIAn Equal Opportunity Affirmative Action Employer 50%a recycled/10per 11

January 15, 2003
To: Derrick Brown
From: Bobby Cogdill
Subject: Leachate Haul Record
Derrick:
Here are the leachate haul records for 1999 through December 2002.
July-December 1999 50 300,000 gals.
January-June 2000 96 576,000 gals.
July-December 2000 27 162,000 gals.
January-June 2001 60 360,000 gals.
July-December 2001 70 420,000 gals.
January-June 2002 166 996,000 gals.
July-December 2002 174 1,044,000 gals.
This is a total of 643 loads for a total of 3,858,000 gallons. We are currently on track to
pull at least 174 loads over the next six months unless something changes. I hope this
along with the leachate analysis reports will be the information you need . Please call if
you need additional information. My number is 627-8042.
Thank You,
Bobby Cogdill

Pace Analytical Services, Inc.
2225 Riverside Drive
aceAnalytical® Asheville, 2
Phone:[phone]
www.pacelabs.com Fax:[phone]
Lab Project Number: 9332954
Client Project ID: WHITE OAK LANDFILL
Lab Sample No: 931351829 Project Sample Number: 9332954-004 Date Collected: 09/26/02 13:10
Client Sample ID: LEACHATE Matrix: Water Date Received: 09/27/02 09:00
Parameters Results Units Report Limit Analyzed By CAS No. Qual ReaLmt
Field Services
Monitoring Well Data Method:
Field pH 7.48 09/27/02 MPS
Field Specific Conductance 3700 09/27/02 MPS
Field Temperature 18.4 09/27/02 MPS
Metals
Mercury, CVAAS Method: EPA 245.1
Mercury ND mg/l 0.00020 10/08/02 EWS 7439-97-6
x.
Metals, ICP, trace-level Prep/Method: EPA 3010 / EPA 6010
Chromium 0.034 mg/l 0.0050 10/11/02 EWS 7440-47-3
Lead NO mg/l 0.010 10/11/02 EWS 7439-92.1
Selenium NO mg/l 0.020 10/11/02 EWS 7782-49-2
Date Digested 10/09/02 10/09/02
Thallium, AAS Furnace Prep/Method: EPA 3020 / EPA 7841
Thallium NO mg/l 0.0020 10/08/02' EWS 7440-28.0
Date Digested - 10/08/02 10/08/02,
Wet Chemistry
Total Dissolved Solids Method: EPA 160.1
Total Dissolved Solids 3000 mg/l 10. 10/02/02 WCB
Cyanide, Total, Water Method: EPA 335.4
Cyanide 0.0025 mg/l 0.0020 10/10/02 ALA 57-12.5
Total Kjeldahl Nitrogen Method: EPA 351.2
Nitrogen, Kjeldahl, Total 130 mg/l 1.0 10/04/02 WWB
Nitrogen. Nitrate plus Nitrite Method: EPA 353.3
Nitrogen. NO2 plus NO3 NO mg/l 0.10 10/08/02 ALA
Biochemical Oxygen Demand. 5 d Prep/Method: / EPA 405.1
BOD, 5 day 210 mg/l 2.0 10/02/02 DEJ 1.2
Date Prepared 09/27/02 09/27/02
Chemical Oxygen Demand Method: EPA 410.4
Chemical Oxygen Demand 1300 mg/l 50. 09/30/02 WCB
Date: 10/17/02 Page: 4 of 23
Laboratory Certification IN REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs
NC Wastewater 40 TN Drinking Water 02980
NC Drinking Water 37712 This report shall not be reproduced,except in full, SC Environmental 99030
without the written consent of Pace Analytical Services, Inc.
�`nelac:�

Pace Analytical Services,Inc.
2225 Riverside Drive
aceAnalytical® Asheville, 2
Phone:[phone]'
www.paceiabs.com Fax:[phone]
Lab Project Number: 9332954
Client Project ID: WHITE OAK LANDFILL.
Lab Sample No: 931351829 Project Sample Number: 9332954-004 Date Collected: 09/26/02 13:10
Client Sample ID: LEACHATE. __ ___ __ Matrix: Water Date Received: 09/27/02 09:00
Parameters Results Units Report Limit Analyzed By CAS No. Qual ReoLmt
Nitrogen, Total Method: Standard Methods
Nitrogen 130 mg/l 0.20 10/09/02 ALA 7727-37-9
Date: 1e/17/02
Page: 5 of 23
Laboratory Certification IDS REPORT OF LABORATORY ANALYSIS Laboratory Gertification IDS
NC Wastewater 40 This report shall not be reproduced,except in full, TN Drinking Water 02980
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. SC Environmental 99030
"01

Pace Analytical Services, Inc.
2225 Riverside Drive
aceAnalytical® Asheville, NC 28804
Phone:[phone]
www.pacelabs.com Fax:[phone]
Lab 'Project Number: 9332954
Client Project ID: WHITE OAK LANDFILL
Lab Sample No: 931351829 Project Sample Number: 9332954.004 Date Collected: 09/26/02 13:10
Client Sample ID: LEACHATE - - - _ Matrix:_Water___ _ ___Date Received_ 09/27/02 09:00
Parameters Results Units Report Limit Analyzed By CAS No. Dual ReaLmt
Field Services
Monitoring Well Data Method:
Field pH 7.48 09/27/02 MPS �
Field Specific Conductance 3700 09/27/02 MPS
Field Temperature 18.4 09/27/02 MPS
�i %
Metals
Mercury, CVAAS Method: EPA 245.1 '
Mercury ND mg/1 0.00020 10/08/02 EWS 7439.97-6
Metals, ICP, trace-level Prep/Method: EPA 3010 / EPA 6010
Chromium 0.034 mg/1 0.0050 10/11/02 EWS 7440.47-3
Lead ND mg/l 0.010 10/11/02 EWS 7439.92-1
Selenium ND mg/l 0.020 10/11/02 EWS 7782-49.2
Date Digested 10/09/02 10/09/02
Thallium, AAS Furnace Prep/Method: EPA 3020 / EPA 7841
Thallium ND mg/l 0.0020 10/08/02 EWS 7440-28.0
Date Digested - 10/OB/02 10/08/02•
Wet Chemistry
Total Dissolved Solids Method: EPA 160.1
Total Dissolved Solids 3000 mg/l 10. 10/02/02 WCB
Cyanide, Total. Water Method: EPA 335.4
Cyanide 0.0025 mg/l 0.0020 10/10/02 ALA 57.12.5
Total Kjeldahl Nitrogen Method: EPA 351.2
Nitrogen, Kjeldahl, Total 130 mg/l 1.0 10/04/02 WWB
Nitrogen, Nitrate plus Nitrite Method: EPA 353.3
Nitrogen. NO2 plus NO3 NO mg/l 0.10 10/OB/02 ALA
Biochemical Oxygen Demand, 5 d Prep/Method: / EPA 405.1
BOD, 5 day 210 mg/l 2.0 10/02/02 DEJ 1,2
Date Prepared 09/27/02 09/27/02
Chemical Oxygen Demand Method: EPA 410.4
Chemical Oxygen Demand 1300 mg/l 50. 09/30/02 WCB
Page: 4 of 23
Date: 10/17/02
Laboratory Certification ID s REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs
NC Wastewater 40 TN Drinking Water 02980
This report shall not be reproduced,except in:full,
NC Drinking Water 37712 SC Environmental 99030
without the written consent of Pace Analytical Services,Inc.
.' 6r t

Pace Analytical Services, Inc.
2225 Riverside Drive
ace Analytical® Asheville,NC 28804
Phone:[phone]
www.pacelabs.com Fax:[phone]
Lab Project Number: 9332954 ,
Client Project ID: WHITE OAK LANDFILL
Lab Sample No: 931351829 Project Sample Number: 9332954-004 Date Collected: 09/26/02 13:10
Client Sample ID: LEACHATE .Matrix: Water Date Received: 09/27/02 09:00
Parameters Results Units Report Limit Analyzed By CAS No. Qual RegLmt
Nitrogen, Total Method: Standard Methods
Nitrogen 130 mg/l 0.20 10/09/02 ALA 7727-37-9
Page: 5 of 23
Date: 10/17/02
Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS �-r-atgTy'Qgrlification IDs
0
NC Wastewater 40 This report shall not be reproduced,except in full, TN Drinking Water 903 9
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. SC Environmental 9030
nelac

Pace Analytical Services, Inc.
54 Ravenscroff Drive
ace Analytical' Asheville, 28801
Phone:[phone]
www.pacelabs.com Fax:[phone]
Lab Project Number: 9328608
Client Project ID: White Oak Landfill
Lab Sample No: 931187264 Project Sample Number: 9328608-012 Date Collected: 04/15/02 12:30
Client Sample ID: LEACHATE 4/15 Matrix: Water Date Received: 04/16/02 16:40
Parameters Results Units Report Limit Analyzed by CAS No. Ftnote Reg Limit
Field Services
Monitoring Well Data Method:
Field pH 6.71 Std. Units 04/16/02 MPS
Field Specific Conductance 265 umhos/cm 04/16/02 MPS ^
Field Temperature 20.1 deg C 04/16/02 MPS ®Q�
Metals
Mercury, CVAAS Prep/Method: EPA 245.1 / EPA 245.1.
Mercury ND mg/l 0.00020 04/29/02 TRW 7439.97-6
Metals, ICP, trace-level Prep/Method: EPA 3010 / EPA 6010
Chromium 0.034 mg/l 0.0050 04/25/02 21:05 TRW 7440-47.3
Lead NO mg/l 0.010 04/25/02 21:05 TRW 7439-92-1
Selenium ND mg/1 0.020 04/25/02 21:05 TRW 7782-49.2
Date Digested 04/25/02
Thallium, AAS Furnace - Prep/Method: EPA 3020 / EPA 7841 -
Thallium NO mg/l 0.0020 04/30/02 TRW 7440-28-0
Date Digested 04/29/02
Wet Chemistry
Total Dissolved Solids Prep/Method: EPA 160.1 /,EPA 160.1
Total Dissolved Solids 2300 mg/l 10. 04/19/02 AAB
Cyanide, Total, Water Prep/Method: EPA 335.2 / EPA 335.4
Cyanide 0.0060 mg/1 0.0020 04/29/02 JDA 57-12-5
Total Kjeldahl Nitrogen Prep/Method: EPA 351.2 / EPA 351.2
Nitrogen., Kjeldahl, Total 96. mg/l 1.0 04/24/02 JDA
Nitrogen, Nitrate plus Nitrite Prep/Method: EPA 353.2 / EPA 353.3
Nitrogen, NO2 plus NO3 0.30 mg/1 0.10 04/30/02 JDA
Biochemical Oxygen Demand, 5 d Method: EPA 405.1
BOD, 5 day 740 mg/l 2.0 04/22/02 KHJ
Date Prepared 04/17/02
Chemical Oxygen Demand Prep/Method: EPA 410.4 / EPA 410.4
Page: 12
Date: 05/03/02
Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS Laboratory Certification IDS
NC Wastewater 40 This report shall not be reproduced,except in full, TN Drinking Water 02980
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. SC Environmental 99030
�i S

Pace Analytical Services, Inc.
54 Ravenscroff Drive
aceAnalytical' Asheville, NC 28801
Phone:[phone]
www.pacelabs.com Fax.,828.254.4618
Lab Project Number: 9328608
Client Project ID: White Oak Landfill
-ab Sample No: 931187264 Project Sample Number: 9328608-012 Date Collected: 04/15/02 12:30
:lient Sample ID: LEACHATE 4/15 Matrix: Water Date Received: 04/16/02 16:40
Darameters Results Units Report Limit Analyzed by .CAS No. Ftnote Reg Limit
Chemical Oxygen Demand 1400 mg/l 50. 04/24/02 AAB
Nitrogen, Total Method: Standard Methods
Nitrogen 96. mg/l 0.20 04/30/02 JDA 7727-37-9
00
Date: 05/03/02 Page: 13
Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS Laboratory Certification IN
TN Drinking Water
NC Wastewater 40 This report shall not be reproduced,except in full, 0
9903
NC Drinking Water 37712 without the written consent of Pace Analytical Services,Inc. SC Environmental 9030

Pace Analytical Services, Inc.
54 Ravenscroft Drive
aceAnalytical' Asheville, NC 28801
Phone:[phone]
www.pacelabs.com Fax:[phone]
Lab Project Number: 9323432
Client Project ID: White Oak
ab Sample No: 93986412 Project Sample Number: 9323432-018 Date Collected: 09/18/01 13:10
lient Sample ID: LEACHATE Matrix: Water Date Received: 09/18/01 16:00
arameters Results Units Report Limit Analyzed CAS No. Ftnote Reg Limit
Petal s
Mercury, CVAAS Prep/Method: EPA 245.1 / EPA 245.1
Mercury ND mg/l 0.00020 09/26/01 TRW 7439.97-6
Metals. ICP, trace-level Prep/Method: EPA 3010 / EPA 6010 �®
Chromium 0.023 mg/l 0.0050 09/26/01 16:05 TRW 7440-47.3
Lead NO mg/l 0.010 09/26/01 16:05 TRW 7439-92-1
Selenium 0.034 mg/l 0.020 09/26/01 16:05 TRW 7782.49.2 >.
Date Digested 09/21/01
Thallium, AAS Furnace Prep/Method: EPA 3020 / EPA 7841
Thallium NO mg/l 0.0020 09/27/01 TRW 7440-28.0
Date Digested 09/26/01
Wet Chemistry
Total Dissolved Solids - Prep/Method: EPA 160.1 / EPA 160.1
Total Dissolved Solids 2700 mg/l 10. 09/25/01 AAB
Cyanide, Total, Water Prep/Method: EPA 335.4 / EPA 335.4
Cyanide 0.0060 mg/l 0.0020 09/25/01 JDA 57.12-5
Total Kjeldahl Nitrogen Prep/Method: EPA 351.2 / EPA 351.2
Nitrogen, Kjeldahl, Total 160 mg/l 0.10 09/25/01 JDA
Nitrogen, Nitrate plus Nitrite Prep/Method: EPA 353.3 / EPA 353.3
Nitrogen, NO2 plus NO3 NO mg/l 0.10 09/26/01 JDA
Biochemical Oxygen Demand. 5 d Method: EPA 405.1
BOO. 5 day 200 mg/l 2.0 09/24/01 KHJ
Date Prepared 09/19/01
Chemical Oxygen Demand Prep/Method: EPA 410.4 / EPA 410.4
Chemical Oxygen Demand 510 mg/l 50. 09/25/01 AAB
Nitrogen. Total Method: Standard Methods
Page: 18
Date: 10/03/01
Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs
TN Drinking Water 02980
NC Wastewater 40 This report shall not be reproduced,except in full, SC Environmental 99030
NC Drinking Water 37712
without the written consent of Pace Analytical Services, Inc.
1� LC[py

Pace Analytical Services,Inc.
54 Ravenscrolf Drive
aceAnalXjcal" Asheville,,NC 28801
Phone:[phone]
www.pacelabs.com Fax. 828,254.4618
Lab Project Number: 9323432
Client Project ID: White Oak
Lab Sample No: 93986412 Project Sample Number: 9323432-018 Date Collected: 09/18/01 13:10
Client Sample ID: LEACHATE Matrix: Water Date Received: 09/18/01 16:00
Parameters Results Units Report Limit Analyzed CAS No. Ftnote Reg Limit
Nitrogen 160 mg/l 0.20 10/01/01 .IDA 7727-37.9
00
Date: 10/03/01 Page: 19
Laboratory Certification IN REPORT OF LABORATORY ANALYSIS Laboratory Waterificati02IDS
NC Wastewater 40 This report shall not be reproduced,except in full, TN Drinking Water 02980
NC Drinking Water 37712 without the written consent of Pace Analytical Services,Inc. SC Environmental 99030
1M��CCpyO'
C�M1�� =i
W�;_i'_ I.

Pace Analytical Services, Inc.
54 Ravenscrolt Drive
aceAnalytical Asheville,NC28801
Phone:[phone]
www.pacelabs.com Fax:[phone]
Lab Project Number: 9319558
Client Project ID: White Oak Landfill
Lab Sample No: 93837094 Project Sample Number: 9319558-012 Date Collected: 04/09/01 11:20
Client Sample ID: LEACHATE Matrix: Water Date Received: 04/09/01 17:10
Parameters Results Units PRL Analyzed Analyst CAS# Ftnote Limit
Field Services ryry
Field Grab Data Method: iV o l
Field pH 8.1 Std. Units 04/09/01 MPS
Field Temperature 15 deg C 04/09/01 MPS
Field Specific Conductance 3600 umhos/cm 0 04/09/01 MPS
Wet Chemistry
Mercury. CVAAS Method: EPA 245.1 Prep Method: EPA 245.1
Mercury ND mg/l 0.00020 04/11/01 TRW 7439-97-6
Metals, ICP, trace-level Method: EPA 6010 Prep Method: EPA 3010
Chromium 0.010 mg/l 0.0050 04/12/01 11:47 TRW 7440-47-3
Lead NO mg/l 0.010 04/12/01 11:47 TRW 7439-92-1
Selenium 0.21 mg/1 0.020 04/12/01 11:47 TRW 7782-49.2
Date Digested 04/10/01
Thallium. AAS Furnace Method: EPA 7841 Prep Method: EPA 3020
Thallium ND mg/l 0.0020 04/18/01 TRW 7440-28.0
Date Digested 04/13/01
Total Dissolved Solids Method: EPA 160.1 Prep Method: EPA 160.1
Total Dissolved Solids 5000 mg/l 1 10. 04/16/01 MPS
Cyanide. Total, Water Method: EPA 335.4 Prep Method: EPA 335.4
Cyanide NO mg/l 0.0020 04/18/01 JDA 57-12-5
Total Kjeldahl Nitrogen Method: EPA 351.2 Prep Method: EPA 351.2
Nitrogen, Kjeldahl, Total 120 mg/l 0.10 04/18/01 JDA
Nitrogen. Nitrate plus Nitrite Method: EPA 353.3 Prep Method: EPA 353.3
Nitrogen, NO2 plus NO3 NO mg/1 0.10 04/20/01 JDA
Biochemical Oxygen Demand, 5 d Method: EPA 405.1
BOD. 5 day 240 mg/l 2.0 04/16/01 08:30 KHJ
Date: 04/24/01 Page: 12
Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs
NC Wastewater 40 TN Drinking Water 02980
NC Drinking Water 37712 This report shall not be reproduced,except in full, SC Environmental 99030
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
(�5acieAnalytjcalw Asheville,NC28801
Phone:[phone]
www.pacelabs.com Fax.,828.252.4618
Lab Project Number: 9319558
Client Project ID: White Oak Landfill
Lab Sample No: 93837094 Project Sample Number: 9319558-012 Date Collected: 04/09/01 11:20
Client Sample ID: LEACHATE Matrix: Water Date Received: 04/09/01 17:10
Parameters Results Units PRL Analyzed Analyst CAS# Ftnote Limit
Date Prepared 04/11/01
Chemical Oxygen Demand Method: EPA 410.4 Prep Method: EPA 410.4
Chemical Oxygen Demand 430 mg/l 50. 04/12/01 MPS
Nitrogen, Total Method: Standard Methods
Nitrogen 120 mg/l 0.20 04/24/01 JDA 7727.37-9
�® al
Date: 04/24/01 Page: 13
Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs
NC Wastewater 40 TN Drinking Water 02980
NC Drinking Water 37712 This report shall not be reproduced, except in full, SC Environmental 99030
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
;aceAnalyfical' 54 RaVe*e,NC(Drive
Asheville,NC 28801
www.pacelabs.com Phone:[phone]
DATE: 10/04/00 Fax:[phone]
PAGE: 14
I
Pace Project Number: 9315373
Client Project ID: White Oak Landfill
Pace Sample No: 93666501 Date Collected: 09/18/00 Matrix: Water
Client Sample ID: LEACHATE Date Received: 09/18/00
Parameters Results Units PRL Analyzed Analyst CAS# Footnotes
--------------------------------- ---------- --------- -------- ----- ---------- .
Metals
Mercury, CVAAS Method: EPA 245.1 Prep Method: EPA 245.1 ®O
Mercury NO mg/l 0.0002 10/03/00 TRW 7439-97-6
Metals, ICP, trace-level Method: EPA 6010 Prep Method: EPA 3010
Chromium 0.012 mg/l 0.005 10/02/00 TRW 7440-47.3
Lead NO mg/l 0.01 10/02/00 TRW 7439.92.1
Selenium NO mg/l 0.02 10/02/00 TRW 7782-49-2
Date Digested 09/22/00
Thallium, AAS Furnace Method: EPA 7841 Prep Method: EPA 3020
Thallium 0.002 mg/l 0.002 10/02/00 JDA 7440-28-0
Date Digested 09/20/00`
Wet Chemistry
Total Dissolved Solids Method: EPA 160.1 Prep Method: EPA 160.1
Total Dissolved Solids 2500 mg/l 1 09/21/00 JMS
Cyanide. Total, Water Method: EPA 335.4 Prep Method: EPA 335.4
Cyanide 0.007 mg/l 0.002 09/27/00 JDA 57-12-5
Total Kjeldahl Nitrogen Method: EPA 351.2 Prep Method: EPA 351.2
Nitrogen, Kjeldahl, Total 140 mg/l 0.1 09/29/00 JDA
Nitrogen, Nitrate plus Nitrite Method: EPA 353.3 Prep Method: EPA 353.3
Nitrogen, NO2 plus NO3 0.10 mg/l 0.1 09/26/00 JDA
Biochemical Oxygen Demand, 5 d Method: EPA 405.1 Prep Method:
Biochemical Oxygen Demand, 5d 170 mg/l 2 09/25/00 JMS
Date Prepared 09/20/00
Chemical Oxygen Demand Method: EPA 410.4 Prep Method: EPA 410.4
Chemical Oxygen Demand 760 mg/l 50 10/02/00 AAB
Nitrogen, Total Method: Standard Methods Prep Method:
Nitrogen 140 mg/l 0.2 10/02/00 JDA 7727-37-9
Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs
NC Wastewater 40 TN Drinking Water 02980
NC Drinking Water 37712 This report shall not be reproduced,except in full, SC Environmental 99030
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscrolt Drive
;57ceAnalyfical� Asheville;NC 28801
Phone:[phone]
DATE: 05/16/00 Fax.[phone]
PAGE: 8
Pace Project Number: 9312454
Client Project ID: White Oak Landfill
Pace Sample No: 93538015 Date Collected: 04/24/00 Matrix: Water
Client Sample ID: LEACHATE Date Received: 04/24/00
Parameters Results Units PRL Analyzed Analyst CAS# Footnotes
--------------------------------- ---------- --------- ---------- -------- ----- ---------- ----------
Field Services
Monitoring Well Data Method: Prep Method:
Field pH 7.8 Std. Units 04/24/00 MPS ®/iyVV O
Field Specific Conductance 2600 umhos/cm 04/24/00 MPS
Field Temperature 11 deg C 04/24/00 MPS
Metals
Mercury, CVAAS Method: EPA 245.1 Prep Method: EPA 245.1
Mercury 0.0003 mg/l 0.0002 05/04/00 TRW 7439-97.6
Metals, ICP, trace-level Method: EPA 6010 Prep Method: EPA 3010
Chromium 0.013 mg/l 0.005 05/03/00' TRW 7440-47-3
Lead ND mg/1 0.01 05/03/00 TRW 7439-92-1
Selenium NO mg/l 0.02 05/03/00 TRW 7782-49-2
Date Digested 05/01/00
Thallium, AAS Furnace Method: EPA 7841 Prep Method: EPA 3020
Thallium 0.002 mg/l 0.002 05/09/00 TRW 7440-28-0
Date Digested 05/04/00
Wet Chemistry
Total Dissolved Solids Method: EPA 160.1 Prep Method: EPA 160.1
Total Dissolved Solids 2700 mg/1 1 04/25/00 JMS
Cyanide, Total, Water Method: EPA 335.4 Prep Method: EPA 335.4
Cyanide 0.013 mg/l 0.002 05/02/00 JDA 57-12-5
Total Kjeldahl Nitrogen Method: EPA 351.2 Prep Method: EPA 351.2
Nitrogen, Kjeldahl, Total 95 mg/l 0.1 05/04/00 JDA
Nitrogen, Nitrate plus Nitrite Method: EPA 353.3 Prep Method: EPA 353.3
Nitrogen. NO2 plus NO3 0.30 mg/1 0.1 04/27/00 JDA
Biochemical Oxygen Demand. 5 d Method: EPA 405.1 Prep Method:
Biochemical Oxygen Demand. 5d 190 mg/1 2 05/01/00 JMS
Date Prepared 04/26/00
Laboratory Certification IDs REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs
NC Wastewater 40 TN Drinking Water 02980
This report shall not be reproduced, except in full, SC Environmental 99030
NC Drinking Water 37712
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
aceAnalXical- 54 Ravel Drive
Asheville,-NC 28801
Phone:[phone]
DATE: 05/16/00 Fax:[phone]
PAGE: 9
Pace Project Number: 9312454
Client Project ID: White Oak Landfill
Pace Sample No: 93538015 Date Collected: 04/24/00 Matrix: Water
Client Sample ID: LEACHATE Date Received: 04/24/00
Parameters Results Units PRL Analyzed Analyst CAS# Footnotes
--------------------------------- --------- ---------- -------- ..... ---------- ......----
Chemical Oxygen Demand Method: EPA 410.4 Prep Method: EPA 410.4
Chemical Oxygen Demand 670 mg/l 50 05/01/00 AAB
Nitrogen, Total Method: Standard Methods Prep Method:Nitrogen 95 mg/l 0.2 05/09/00 JDA 7727-37-9 J O Y O
Laboratory Certification IDS REPORT OF LABORATORY ANALYSIS Laboratory Certification IDs
NC Wastewater 40 TN Drinking Water 02980
NC Drinking Water 37712 This report shall not be reproduced,except in full, SC Environmental 99030
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscrofl Drive
Pare Analytical Asheville.NG28801
Tel:[phone]
Fax:[phone]
DATE: 10/11/99
PAGE: 12
Pace Project Number: 938071
Client Project to: White Oak
Pace Sample No: 93362077 Date Collected: 09/21/99 Matrix: Water
Client Sample ID: LEACHATE Date Received: 09/21/99
Parameters Results Units PRL Analyzed Analyst CAS# Footnotes
--------------------------------- ---------- --------- ---------- -------- ----- ---------- ..........
Metals l
Mercury, CVAAS Method: EPA 245.1 Prep Method: EPA 245.1
Mercury NO mg/t 0.0002 09/27/99 TRW 7439-97-6
Metals, 1CP, trace-levet Method: EPA 6010 Prep Method: EPA 3010
Aluminum 1.7 mg/l 0.25 09/30/99 TRW 7429-90-5
Antimony ND mg/1 0.01 09/30/99 TRW 7440-36-0
Arsenic NO mg/1 0.01 09/30/99 TRW 7440-38-2
Barium 0.18 mg/l 0.005 09/30/99, TRW 7440-39-3
Beryllium ND mg/1 0.002 09/30/99 TRW 7440-41-7
Boron - 1.1 mg/l 0.01 09130/99F TRW 7440-42-8
Cadmium 0.0018 mg/L 0.001 09/30/99 TRW 7440-43-9
Calcium 27 mg/l 0.1 09/30/99 TRW 7440-70-2
.Chromium 0.043 mg/1 0.005 09/30/99 TRW 7440-47-3
Cobalt 0.0097 mg/l 0.005 09/30/99 TRW 7440-48-4
Copper NO mg/1 .0.005 09/30/99 TRW 7440-50-8
Iron 9.9 mg/L 0.02 09/30/99 TRW 7439-89-6
Lead NO mg/1 0.01 09/30/99 TRW 7439-92-1
Magnesium 75 mg/l 0.1 09/30/99 TRW 7439-95-4
Manganese 1.8 mg/L 0.005 09/30/99 TRW 7439-96-5
Molybdenum 0.01 mg/1 0.005 09/30/99 TRW 7439-98-7
Nickel 0.041 mg/1 0.005 09/30/99 TRW 7440-02-0
Potassium 18 mg/l 0.5 09/30/99 TRW 7440-09-7
Selenium NO mg/l 0.02 09/30/99 TRW 7782-49-2
Silicon 0.61 mg/L 0.1 09/30/99 TRW 7440-21-3
Silver NO mg/1 0.002 09/30/99 TRW 7440-22-4
Sodium 15 mg/l 0.25 09/30/99 TRW 7440-23-5
Thallium NO mg/l 0.02 09/30/99 TRW 7440-28-0
Tin 0.01 mg/l 0.01 09/30/99 TRW 7440-31.5
Titanium 0.13 mg/1 0.005 09/30/99 TRW 7440-32-6
Vanadi urn 0.011 mg/1 0.005 09/30/99 TRW 7440-62-2
Zinc 0.086 mg/1 0.01 09/30/99 TRW 7440-66-6
Date Digested 09/24/99
Thallium, AAS Furnace Method: EPA 7841 Prep Method: EPA 3020
Thallium NO Wt. 0.002 09/24/99 TRW 7440-28-0
Date Digested 09/24/99
Wet Chemistry
f aboralory Certification IDS laboratory Certification IDS
NC Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980
NC Drinking Water 37712 This report shall not be reproduced,except in full, SC Environmental 99030
...af..,.n 6._ANen n-f of Ger<OnnlNlcal Rn rvirAR Inn.

Pace Analytical Services. Inc.
54 Ravenscrolt Drive
Pace Analytical Asheville.NC28801
Tel:[phone]
Fax:[phone]
DATE: 10/19/99
PAGE: 13,
Pace Project Number: 938071
Client Project ID: White Oak
Pace Sample No: 93362077 Date Collected: 09/21/99 Matrix: Water
Client Sample ID: LEACHATE Date Received: 09/21/99
Parameters Results Units PRL Analyzed Analyst CAS# Footnotes
--------------------------------- ---------- -----'--- ---------- -------- ----- ---------- -_--------
Total Dissolved Solids Method: EPA 160.1 Prep Method: EPA 160.1 I A
Total Dissolved SoLids 1900 mg/L 1 09/28/99 PJS y` Q
Total Kjeldahl Nitrogen Method: EPA 351.2 Prep Method: EPA 351.2 I
Nitrogen, Kjeldahl, Total 41 mg/l 0.1 09/24/99 JDA
Nitrogen, Nitrate plus Nitrite Method: EPA 353.3 Prep Method: EPA 353.3
Nitrogen, NO2 plus NO3 ND mg/1 0.1 09/29/99 JDA
Biochemical Oxygen Demand, 5 d Method: EPA 405.1 Prep Method:
Biochemical, Oxygen Demand, 5d 105 mg/L 2 09/27/99 PJS 1
Date Prepared 09/22/99,
Chemical Oxygen Demand Method: EPA 410.4 Prep Method: EPA 410.4
Chemical Oxygen Demand 600 mg/1 50 09/27/99 AAB
Nitrogen, Total Method: Standard Methods Prep Method:
Nitrogen 41 mg/L 0.2 10/11/99 WB 7727-37-9
Laboratory Certification IDS I aboratory Certification IDe
NC Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980
NC Drinking Water 37712 This report shall not be reproduced,except in full, SC Environmental 99030
...;Ohni a rho w.inon rnnsent of Pare Analvlir i Semims_Inc.

Pace Analytical Services, Inc.
54 Ravenscr0fl Drive
Pace Analytical Asheville,NC28801
Tel.[phone]
Fax:[phone]
DATE: 05/12/99
PAGE: 37
Pace Project Number: 935303
Client Project ID: White Oak
Pace Sample No: 93244481 Date Collected: 04/27/99 Matrix: Water
Client Sample ID: WO LEACHATE Date Received: 04/27/99
Parameters Results Units PRL Analyzed Analyst CAST: Footnotes
_________________________________ __________ _________ __________ ________ _____ __________ _________
Metals
Metals, ICP Method: EPA 6010 Prep Method: EPA 3010 r
Barium 0.30 mg/l 0.1 05/11/99 KEK 7440-39-3
Cobalt ND mg/L 0.05 05/11/99 KEK 7440-48-4
Copper NO mg/l 0.01 05/11/99 KEK 7440-50-8
Magnesium 63 mg/l 0.1 05/11/99 KEK 7439-95-4
Nickel NO mg/l 0.05 05/11/99 KEK 7440-02-0
Silver NO mg/l 0.05 05/11/99 KEK 7440-22-4
Vanadium NO mg/L 0.04 05/11/99 KEK 7440-62-2
zinc NO mg/I. 0.01 05/11/99 KEK 7440-66-6
Date Digested - 04/28/99
Antimony, AAS Furnace Method: EPA 7041 Prep Method: EPA 3020
Antimony ND mg/l 0.005 05/11/99 KEK 7440-36-0
Date Digested 05/03/99
Arsenic, AAS Furnace Method: EPA 7060 Prep Method: EPA 3020
Arsenic NO mg/1 0.005 05/11/99 KEK 7440-38-2
Date Digested 05/03/99
Beryllium, AAS Furnace Method: EPA 7091 Prep Method: EPA 3020
Beryllium NO mg/1 0.001 05/11/99 KEK 7440-41-7
Date Digested 05/03/99
Cadmium, AAS Furnace Method: EPA 7131 Prep Method: EPA 3020
Cadmium NO m9/l 0.001 05/11/99 KEK 7440-43-9
Date Digested 05/03/99
Chromium Furnace Method: EPA 7191 Prep Method: EPA 3020
Chromium 0.006 mg/l 0.002 05/11/99 KEK 7440-47-3
Date Digested 05/03/99 ,
Lead, AAS Furnace Method: EPA 7421 Prep Method: EPA 3020
Lead NO mg/l 0.005 05/11/99 KEK 7439-92-1
Date Digested 05/03/99
!rcury in Water Method: EPA 7470 Prep Method: EPA 7470
Mercury NO mg/l 0.0002 05/03/99 KEK 7439-97-6
Laboratory Certification IDs Laboratory Certification IDs
NC Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980
NC Drinking Water 37712 This report shall not be reproduced,except in full, _ SC Environmental 99030
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services,Inc.
54 Ravenscroft Drive
Para Analytical Asheville,NG 28801
Tel:[phone]
Fax:[phone]
DATE: 05/12/99
PAGE: 38
Pace Project Number: 935303
Client Project ID: White Oak
Pace Sample No: 93244481 Date collected: 04/27/99 Matrix: Water
Client Sample ID: WO LEACHATE Date Received: 04/27/99
Parameters Results Units PRL Analyzed Analyst CAS# Footnotes
--------------------------------- ---------- --------- ---------- -------- ----- ---------- ----------
Selenium, AAS Furnace Method: EPA 7740 Prep Method: EPA 3020
Selenium 0.008 mg/1 0.005 05/11/99 KEK 7782-49-2 q
Date Digested 05/03/99 `
Thallium, PAS Furnace Method: EPA 7841 Prep Method: EPA 3020
Thallium NO mg/l 0.002 05/05/99 KEK 7440-28-0
Date Digested 05/03/99
Wet chemistry
Total Dissolved Solids Method: EPA 160.1 Prep Method: EPA 160.1
Total Dissolved Solids 1200 mg/1 1 04/30/99 SLG
:yanide, Total, Water Method: EPA 335.4 Prep Method: EPA 335.4
Cyanide NO mg/1 0.002 05/04/99 TRW 57-12-5
Total Kjeldahl Nitrogen Method: EPA 351.2 Prep Method: EPA 351.2
Nitrogen, Kjeldahl, Total 90 mg/1 0.5 05/06/99 TRW
Nitrogen, Nitrate plus Nitrite Method: EPA 353.3 Prep Method: EPA 353.3
Nitrogen, NO2 PLUS NO3 NO mg/1 0.1 04/30/99 TRW 1
Biochemical Oxygen Demand, 5 d Method: EPA 405.1 Prep Method:
Biochemical Oxygen Demand, 5d 100 mg/L 2 05/03/99 KEK 1
Date Prepared 04/28/99
Chemical Oxygen Demand Method: EPA 410.4 Prep Method: EPA 410.4
Chemical Oxygen Demand 310 mg/1 50 05/05/99 KEK
Nitrogen, Total Method: Standard Methods Prep Method:
Nitrogen 90 mg/l 1 05/10/99 TRW 7727-37-9
Laboratory Certification IDS Laboratory Certification IDs
NC Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980
NC Drinking Water 37712 SC Environmental 99030
- This report shall not be reproduced,except in full,
without the written consent of Pace Analytical Services,Inc.

BLUE RIDGE
PAPER PRODUCTS INC.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5320
19 Oct 2004
Forrest R. Westall, PE D
Water Quality Regional Supervisor OCT 2 0 2004
North Carolina Department of Environment
and Natural Resources WATER QUALITY SECTION
Division of Water Quality ASHEVILLE REGIONAL OFFICE
2090 US Highway 70
Swannanoa, NC 28778
_.Subject: NPDES NC 0000272
CRP Color Report—Extension Request Due to Floods
Blue Ridge Paper Products, Inc.
fl� Canton, NC
Dear Forrest:
Part I, Condition A.(8).9 of the subject permit requires that Blue Ridge Paper Products evaluate
color reduction technologies associated with the Chloride Removal Process (CRP) wastestream
and submit a report by December 1, 2004. Because of the September 2004 floods, we will not
be able to meet the I December deadline. We respectfully request an extension until lApril
2005 to complete this work and submit the CRP Color Reduction Report.
As you are aware, the Blue Ridge Paper Products mill in Canton, NC was hit by the remnants,of
three hurricanes (Frances, Ivan and Jeanne) and by back-to-back historic floods during the month
of September 2004. Our wastewater plant and parts of the mill were flooded twice. Mill
operations were disrupted for several weeks and all of our resources since Hurricane Frances on
8 September 2004 have been devoted to flood repairs, additional flood preparations and
recovery. We are only now getting back to normal operation of our process and wastewater
treatment systems. The floods destroyed our wastewater lab, and we have not yet restored all the
lab capability that we need to support color trial work.
Blue Ridge Paper has been working on evaluations for the CRP report since 2002. Our
technology review, bench scale tests and preliminary field trials led to a pilot-scale field trial in
July and August 2004 for chlorine dioxide bleaching of the CRP wastestream. Our goal was to
operate for a least 30 days with the pilot system in continuous operation. However, the July and
August field trials experienced various operational issues with chemical feed and chloride
dioxide generation that prevented a sustained period of continuous operation. The longest
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

P19
est Westall, NC DENR ARO DWQ
ct 2004, Page 2
continuous run obtained was 4 days. As a result, no conclusions could be drawn on the exact
technical, economic and operational feasibility of this technology.
The field trial was terminated on 27 August 2004. The field test plan was modified and
enhanced to overcome the operational issues associated with chlorine dioxide generation that
prevented a successful trial during August. Hurricane Frances hit on 8 September 2004. We had
to postpone restart of the CRP bleaching field trial until we are able to restore normal mill
operations. We are currently in discussions with the supplier of the field chlorine dioxide
generator to see what dates this equipment and operators are available.
In summary, the floods of September 2004 interrupted our schedule for completing field trials on
color reduction from our CRP waste stream. We need the field trial data to complete the CRP
color report required by permit conditions. We request an extension until 1 April 2005 to
complete this work and submit the CRP Color Reduction Report.
Sincerely
Paul S. Dickens
Manager, Environmental Affairs
828-646-6141
dickei)@blueridgepaper.com
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5337
19 Oct 2004
Forrest R. Westall, PE
Water Quality Regional Supervisor
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
2090 US Highway 70
Swannanoa, NC 28778
Subject: NPDES NC 0000272
BOD Excursion 14 Oct 2004
Wastewater Treatment Plant Recovery from Floods
Blue Ridge Paper Products, Inc.
Canton, NC
Dear Forrest:
This is the 5-day written report documenting a BOD excursion on 10/4/04. Verbal and e-mail
notifications of the BOD result were provided to Keith Haynes of your office on 10/14/04. This
letter also updates the status of permit-required equipment and instrumentation that was
destroyed by recent floods.
As you are aware, the Blue Ridge Paper Products mill in Canton, NC was hit by the remnants of
three hurricanes (Frances, Ivan and Jeanne) and by back-to-back historic floods during the month
of September 2004. Our wastewater plant and parts of the mill were flooded twice. Wastewater
treatment operations resumed on 9/11 after the 9/8 Frances flood and on 9/21 after the 9/17 Ivan
flood. Compliance monitoring after the two floods resumed on 9/12 and 9/22. Mill operations
were disrupted for several weeks and all of our resources since Hurricane Frances on 9/8 have
been devoted to flood repairs, additional flood preparations and recovery. We are only now
getting back to normal operation of our process and wastewater treatment systems. The floods
destroyed our wastewater lab, and we have not yet restored all the lab capability that we need to
do compliance monitoring in-house. We contracted with PACE Lab to analyze wastewater
process control and compliance samples during the flood recovery period.
rOASHEVILLE
EE VEEnvironmental Group CT 2 0 2004
175 Main Street • PO Box 4000Canton, North Carolina 28716 • 828-646-2000 QUALITY SECTION
REGIONAL OFFICE
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
19 Oct 2004, Page 2
BOD Excursion
On 10/13, Blue Ridge Paper Products received the analytical report from PACE Lab for the 10/4
secondary effluent (SE) composite BOD. The data were entered into our compliance database
on the morning of 10/14, and we determined that we had a BOD excursion based on mass. There
was an error on the QA portion of the PACE Lab report, so we requested that PACE review and
revise the report as appropriate. We also looked at wastewater operating data for 10/3, 10/4 and
1015. PACE Lab provided a corrected lab report and a copy of their lab bench sheet on the
afternoon of 10/14. These data confirm the previous report. Results are as follows:
Date Flow, mgd PI BOD, PE BOD, SE BOD, SE BOD, SE TSS,
m m m Ibs/day m
10/3 27.03 1200 300 45 10,144 57
10/4 25.11 660 450 110 23,036 70
10/5 23.54 370 260 48 9423 56
Our operating data indicate a DO sag in our aeration basins that started on the evening of 10/3
and continued until the afternoon of 10/4. PI and PE BODs were also elevated for these days.
We believe that the 10/4 SE BOD result is correct. River run results for downstream DO show
no impact.
Our permit max day BOD limit is 10,897 lbs/day.
Blue Ridge Paper experienced a secondary treatment upset on the morning of 9/30/04 from a
high pH swing when a scheduled acid delivery for wastewater neutralization failed to arrive
when planned. Between 9/29 and 10/2, we also experienced an episode of high secondary
effluent color related to restart of pulp mill operations following the unplanned and extended
cold mill outage caused by the Frances and Ivan floods. We reported these events to Keith
Haynes by telephone on 9/30 and 10/1 and with follow-up written reports on 10/1 and 10/3. On
10/5, you personally visited the Blue Ridge mill and toured the wastewater treatment plant to
confirm flood damage and the status of recovery.
Based on operating data for the past two weeks, we believe that the secondary treatment plant
has recovered from upset conditions earlier in the month. Effluent parameters and color have
returned to normal range. However, because of elevated BODs and color during the first week
of October, we may have difficulty meeting the monthly average limits for these parameters.
Status of Permit-Required Equipment and Instrumentation
Blue Ridge Paper worked diligently and non-stop to restore essential wastewater treatment
facilities following the Frances and Ivan floods. The following items are now being addressed:
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
19 Oct 2004, Page 3
Wastewater samplers. The Frances flood on 9/8 damaged three of our five refrigerated
wastewater samplers. The Ivan flood on 9117 destroyed two remaining units salvaged from
Frances. We collected manual 24-hr composites using 4-hr grab samples until we could get
replacement samplers installed. As of today, we have replaced 3 wastewater samplers and 2
additional are on order. The flow-pacing signal for the secondary effluent samplers remains
down. We are running time composite samples until the effluent flow signal can be repaired.
Strip Chart Recorders. Our wastewater control room and lab were twice inundated by
floodwaters during September 2004. Totalizers and strip chart recorders for flow, pH and other
permit parameters were destroyed. Many of the flood-damaged strip charts are obsolete, and
replacements are very expensive with a long delivery time. Based on discussion with Keith
Haynes, Blue Ridge will replace strip chart recorders with electronic data logging systems that
have trend display and printing capability. This is a faster and more economical flood damage
repair. For the interim period, we established a new data-logging interface to totalize effluent
flow and are keeping a manual log for other data.
Oxygen Stations on Pigeon River. The back-to-black floods in September 2004 severely
damaged the two downstream oxygen injection stations owned by Blue Ridge Paper—Station D
in Fiberville 0.9 miles downstream and Station E in West Canton 2.1 miles downstream. These
oxygen injection stations are specified in Part I.A.10 of our NDPES permit. The stations are not
operational at this time. We notified Keith Haynes by e-mail on 9/23 that the oxygen stations
were damaged. Blue Ridge is evaluating options for repair and if two stations are still required.
We have not operated the D station for a number of years and have only operated the E station
for limited periods during flow stream flow. We have not needed any in-stream oxygen injection
during the past 2 years. Because of high stream flow, we do not anticipate needing the
downstream oxygen injection stations for water quality compliance during this fall and winter.
The oxygen post aeration system at the wastewater treatment plant is fully functional and is
operating.
Wastewater Compliance Lab. The Frances flood on 9/8 destroyed most of the equipment in our
wastewater compliance lab. Blue Ridge Paper put together a temporary lab for pH, DO, color,
conductivity and temperature and made arrangements with PACE Labs for other wastewater
process control and compliance sample analysis. As of this date, all equipment needed to restore
our wastewater lab is delivered or on order. Lab cabinets are being replaced this week and next.
We hope within the next 4 to 6 weeks to have our previous in-house capability for solids, BOD
and ammonia restored. We created and are using temporary wastewater operating logs and
bench sheets for the interim period until the former wastewater lab QA program can be restored.
Many of our original lab records for the past 5 years were flooded and destroyed. Compliance
data are kept in an electronic database that survived the floods. We also had duplicate copies of
monthly discharge monitoring reports stored in the EHS office on high ground.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716. 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
19 Oct 2004, Page 4
Summary
Blue Ridge Paper is making good progress on recovery from the September 2004 floods. Our
mill operations and wastewater treatment performance are returning to normal. We truly
appreciate your help and that of Keith Haynes with flood recovery efforts.
Sincerely
'—�P 5
Paul S. Dickens
Manager, Environmental Affairs
828-646-6141
[e-mail]
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

V
BLUE RIDGE
PAPER PRODUCTS INC.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5306
14 September 2004
Mr. Forrest Westall D QJOFFICE
Water Quality SupervisorNorth Carolina Department of EnvironmentSEP 15and Natural ResourcesAsheville Regional Office
Division of Water Quality WATER QUALIT2090 US Hwy 70 ASHEVILLE REGI
Swannanoa, North Carolina 28778
Subject: NPDES NC0000272
Flood Event of 8 September 2004
Unanticipated Bypass of Treatment
Sanitary Sewer Overflow
Blue Ridge Paper Products, Inc.
Town of Canton, North Carolina
Dear Forrest—
This is the written report required under the subject permit documenting flood damage
and loss of wastewater treatment associated with hurricane Frances on the morning of 8
September 2004. The wastewater treatment plant operated by Blue Ridge Paper Products
also treats sewage from the Town of Canton. This report is submitted for both Blue
Ridge Paper Products and the Town of Canton.
We notified DENR by telephone at 0745 on the morning of 8 September that the mill was
shut down and that our wastewater plant was flooded. We subsequently provided daily
updates on progress towards restoring wastewater treatment for the town's wastewater.
Wastewater treatment was restored on the afternoon of 11 September 2004. During the
period that wastewater treatment was down, untreated sewage from the town entered the
Pigeon River, both from the mill's influent lift station and from the town's sewage pump
stations that were submerged and damaged by floodwater. Since mill operations were
curtailed in advance of the flood and remained down, there was no release of untreated
industrial wastewater. Chemicals and oil storage on the Blue Ridge site remained secure.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
14 Sep 2004, Page 2
Flood Event
The remnants of hurricane Frances passed through Western North Carolina on 7 and 8
September 2004. The mill began a flood watch early on the morning of 7 September.
Based on water levels in Pigeon River, the mill activated its flood protection plan at 1600
on 7 September and installed floodgates in the dikes protecting the mill and wastewater
treatment plant. At— 1900 the mill began a controlled shutdown of the backend of the
mill—recovery and pulp production—as a precaution against flooding. At — 2200 based
on rapid river rise, we began a controlled shutdown of paper production as a precaution
against flooding. We also started a controlled shutdown of power boilers.
At 0253 on the morning of 8 September, floodwaters backed up into the wastewater
treatment area and overtopped the secondary clarifiers. At that time, the low lift pumps
to wastewater treatment were stopped. This started an unanticipated bypass of treatment
necessary to prevent severe property damage. At this time all mill operations were down,
and chemical and oil tanks were secure. Aerators in the aeration basins were turned off
to settle and store activated sludge.
At 0330 on 8 September, power to the mill site including wastewater treatment was
turned off to prevent damage to electrical substations and switch gear from flood water.
The mill went cold at that time, and all industrial wastewater generation stopped.
At— 0600 on 8 September, the Pigeon River crested at 21 feet, a record for Canton. The
mill's protective dike system was overtopped. There was 4 to 5 feet of water in the
wastewater area. This water flooded the influent lift station, secondary clarifiers and
switch gear rooms as well as the wastewater control room, lab and offices. The aeration
basins and primary clarifiers remained above flood level.
Downtown Canton was severely flooded, and the town's sewage pump stations along the
Pigeon River were submerged. The town's disinfection pretreatment system located at
the headworks of the Blue Ridge wastewater plant was also submerged.
Recovery
Flood waters started to recede on the afternoon of 8 September. By the morning of 9
September, Blue Ridge was able to drain and pump remaining floodwater from the
wastewater area and start work to restore wastewater treatment. The Town of Canton
also began work to repair and restore sewage pump stations damaged by the flood.
To drain remaining floodwaters from the wastewater treatment plant and from the mill,
portable diesel pumps were installed at the influent low lift pumps to the mill's
wastewater treatment system. These pumps discharged to the river.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
14 Sep 2004, Page 2
On the morning of 10 September 2004, the Town of Canton was able to restore the
disinfection pretreatment system. At that time, the town began pumping sewage back to
the mill's wastewater headworks. The disinfected wastewater was then pumped into the
river. This interim treatment had been discussed with DENR staff and was agreed as the
best measure for public health protection until full treatment could be restored.
Work by Blue Ridge personnel to restore wastewater treatment continued non-stop after
floodwaters were drained from the wastewater area. Blue Ridge was able restart
wastewater treatment operations on the afternoon of 11 September 2004. Discharge of
untreated and partially treated sewage from the Town of Canton through diesel pumps at
the mill's wastewater headworks stopped at— 1250 on 11 September. Blue Ridge
resumed compliance monitoring of the wastewater plant effluent that night.
Sanitary Sewer Overflows
The Blue Ridge wastewater treatment facilities were down from 0300 on 8 September
2004 until the afternoon on 11 September 2004. During this period, untreated sewage
from the Town of Canton was discharged to the Pigeon River, both from overflows at
damaged pump stations owned by the town and from the influent of the mill's wastewater
treatment system. Floodwaters and cleaning water from the mill and town were also
discharged to the river.
The quantity of sewer system overflow is difficult to estimate, but is greater than 15,000
gallons. The majority of the overflow was floodwater and cleaning water necessary to
restore sewage pump stations and wastewater treatment. The mill locked restrooms and
installed portable toilets during the wastewater treatment outage to avoid discharge of
domestic sewage to the river from the mill.
An SSO reporting form is enclosed for the period of wastewater treatment outage.
Summary
This event was truly a severe act of nature and overwhelmed the flood protection
structures at the Blue Ridge Paper Products mill in Canton, North Carolina. We executed
a controlled shutdown of the mill in advance of the flood and prevented release of
untreated industrial wastewater, chemicals or oil. The flood and loss of wastewater
treatment did result in overflow of untreated sewage from the Town of Canton into the
Pigeon River. We will learn from this event and make revisions to the mill's flood
protection plan.
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Forrest Westall, NC DENR ARO DWQ
14 Sep 2004, Page 2
President Bush declared Western North Carolina as a Federal disaster area as a result of
the hurricane Frances flood. Blue Ridge Paper Products and the Town of Canton worked
diligently and non-stop to restore treatment of the town's wastewater following the flood.
We were able to restore essential wastewater services within of the flood event. We
greatly appreciate DENR's assistance and understanding with the emergency recovery
efforts. In particular, we appreciate the site visit by Keith Haynes and Roy Davis of your
staff on 8 September to assess flood damage to our wastewater plant.
Sincerely—
a
Paul S. Dickens
Manager, Environmental Affairs
828-646-6141
[e-mail]
Enclosure: SSO Form for flood event
Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Paul To [e-mail]
Dickens/Canton/BlueRidge
[e-mail], Bob
10/01/2004 07:10 PM Williams/Canton/BlueRidge@BlueRidgePaper, Daryl
Whitt/Canton/BlueRidge@BlueRidgePaper,John
Pryately/Canton/BlueRidge@BlueRidgePaper, Bob
cc Shanahan/Canton/BlueRidge@BlueRidgePaper, Steve
Single/Canton/BlueRidge@BlueRidgePaper,Michael
Koerschner/Canton/BlueRidge@BlueRidgePaper,George
G a rten/Canton/B IueRidge @ B I ueRi dge Pa per
bcc
Subject Wastewater Excursions -Blue Ridge Paper Pr(ducts
a U
cn
1 Oct 2004 m
�� o
Subject: Permit Excursions rn 0
30 Sep 2004—secondary effluent pH c�
o September 2004-monthly average color C' o
NPDES NC 0000272 0 0 6
Blue Ridge Paper Products, Inc. T z Gail
0
m
Keith Haynes, NC DENR ARO DWQ—
This written report follows our telephone notifications for the permit excursions reported on 9/30
and 10/1/2004.
As you aware, the Blue Ridge Paper Products mill is restarting process operations after 3-weeks
of unscheduled cold outage caused by Hurricanes Frances and Ivan. During the last three days,
we restarted pulp mill operations and have experienced a number of process problems related to
the flood outage. Specifically, when the mill executed the emergency shutdown for the Frances
flood on the night of 9/7, we did not have time to purge the pulping process and empty digesters
and other tanks. On restart this week, we had soft pulp and fiber that washed poorly in brown
stock and bleaching stages of the mill. We tried as best we could to process and recover the fiber
and pulping chemicals left in tanks from before the floods. However, we lost an abnormal
amount of pulping materials resulting in a high pH and high color load to our wastewater
treatment plant.
We had anticipated the high pH load to wastewater treatment and scheduled round-the clock
deliveries of acid for pH neutralization. On the night of 9/29, an acid delivery scheduled for 6
pm did not arrive on time. We began to run low on acid for neutralization at the same time that
the pulp mill experienced several process upsets related to the flood. We slowed down the pulp
mill restart and began adding acid to the mill sewer from inside the mill to help control pH at our
wastewater treatment plant. At 12 midnight, the wastewater plant ran out of acid. We continued
to add acid to the mill sewer to control wastewater plant pH. The acid delivery to wastewater
treatment originally scheduled for 6 pm on 9/29 finally arrived at 2:40 am on the morning of
9/30. We resumed acid addition for pH control at wastewater treatment by 4 am. Additional
loads of acid were received on schedule during the morning of 9/30.

Wastewater pH based on grab samples for the period above is as follows:
Date and time PI PE SE
9/29 7 pm 11.4 10.7 8.2
9/29 11 pm 11.5 10.8 9.0
9/30 3 am 2.9 10.4 9.5
9/20 7 am 2.8 7.8 9.2
9/20 8:30 am 8.7
For the period between 11 pm on 9/29 until about 8:30 am on 9/30, we had secondary effluent
(SE) pH greater than 9.0. Our permit specifies a discharge pH limit of 6.0 to 9.0. Wastewater
flow during the pH excursion period was — 27 mgd. The river flow on 9/29 was 1015 mgd and
on 9/30 was 782 mgd. Our effluent during the pH excursion period was less than 5 percent of
stream flow. Our river run and visual inspection of the river downstream on the morning of 9/30
found no evidence of fish kill or other environmental harm.
As you are also aware, the back-to-back floods in Canton during September 2004 caused a total
of 9 days of wastewater plant outage and 3 weeks of pulp mill outage. We only operated
secondary treatment and monitored our wastewater discharge for 21 of the 30 days in September.
Wastewater plant operations were restored before we attempted restart of paper and pulp
production. Secondary effluent color on 9/29 and 9/30 was high and took our monthly average
color based on wastewater operating days above the permit limit of 52,000 lbs/day. Specifically,
based on 21 operating days our monthly average secondary effluent true color discharge was
58,097 lbs/day. Based on 30 days in the month of September, the monthly average true color
discharge was 40,6881bs/day, below both the annual average and monthly max color limits in the
permit. Our effluent was less than 5 percent of river flow on the high color days during
September. Based on river run samples, the true color at the Fiberville bridge on 9/29 was 25
ppm and on 9/30 was 44 ppm.
A preliminary summary of our September 2004 wastewater flow and color discharge monitoring
results is attached for your evaluation. The formal and QC-verified data will be submitted with
our September DMR.
Lpt
sep04wpt.xls �
Paul Dickens
Manager, Environmental Affairs

Blue Ridge Paper Products, Inc.
[e-mail]
828-646-6141 FAX [phone]

Temporary Results Summary-Wastewater Treatment
BRPPI 22-Sep-04
Flow PI Color SE Color MLSS MLVSS Wst Sludge PI TSS PE TSS SE BOD-5 SE TSS SE NH3-N
Date an d PPM lbs/day PPM Ibs/da m m anm L mgfL m9fi Ibs/da m lbstday m
Limits
gfl
Max day 3,205 12,459
Month avg 29.9 52,000 10.897 49,560
9/1/2004 24.5 280 .57,236 234 .47,833 see OPS 32 database
24.3 321 64,974 213 43,114
.............................. .............................
23.7 287 56.824 197 ,,,,.,.....39,004
samples lost Frances flood
9/4/2004 22.7 267 .50,637 185 .......... 35.086
samples lost Frances flood
B/5/2004 23.7 369 72.'36 211 41,706
.._....,.._- _..___.__....... samples lost Frances ilootl
9/6/2004........, 24.6 381 .............78.231 205 42,093
samples lost Frances flood
...............
.........................
............_...
9/7/2004 33.2 264 73,120 260 72.013 ,samples lost to Frances flood samples lost Frances flood
9/e 9/11/04 Frances flood,WTP down or samples/data lost
9/1 212 0 0 4 12.0..................._371 37,130 ...,190 . ___...._................................_..._..__".____....................._......................._..........__..............._............._.........................._......._._...._.................___.__......._..........._.24
9/13/2004 ................_73:6..................._504............_57.166......................147 ............_76;673.............._2.700..............._2�120......................6t900..............._1;600..................._1.1.0.... 9 1,021 38 4,310 <0.10
._........_.......... .................................................................................................................. .........................
10 9/14/2004...... ...................... ..................._326.............................. ......._25.167............................ .............._1,790.............._no.waste................_?,800 .................._740......._._........... 1,368 58 7,933 0.18
..................__........................_.._.._.._........_.....
9/15/2004___.__...17.7 50.1 ._......__73,957 231 . 34,100 2.700 2,060 no waste 690._._......__._.280..__8.__ 1.181 ...._..............._21 ._._...__3,100___ 0.14
. ....._..._____ W._..._._.__..._...._._.._......___..._
9.116/2004 20.8 403 69,909 293 50,827 samples lost to Ivan flood 0 0
............._...................................._-___.... ..........._.........................._.................. .........................__ .__.................._..........................................._..............__....._..............................................................._.......................................................................................................................................
9/17/2004 Second flood from Ivan,WTP down
......................................................................................_.............................................................................................................................................................................................................................................................._.......................................................................................................................................
9/18/2004 Second flood from Ivan,WTP down
.. _._.._........................_............._..._._..__..................._..._._. ._._._._..............................__....-_.._........................................._..__.______�_..... _-_..................._....._............_..-...__.........._.........
9/19/2004 Second flood from Ivan,WTP down
........................_.... .........._.._....................................................._.___..................................................................... .................._......... ........................................................................._-.._._._"'.......__......_.........._....._.............._.......................................................... ............................. .........................
9/2012004...... .......Second.flood,from,Ivan:.WTP,tlown................................................................ ...._...
....................................................____....__............._....................................................................................................................
9/21/2004 .Second,flood from Ivan.WTP down, re started 12 noon, co liance.and ,rocess.monitorin resumed an.9/22...__._ ......._. ..................._.._........ ......... ( p P 9 !___....._....._...__ ........................_....................._._...........__._.......__...._...._............_................._
9/22/2004 ................_...0_�....................220.._.._..__79.632. .................. .._..................................................
9/23/2.... ............_72.0 ................695 ........69.556 ...............109 .......,10.909 ........._2.584 .,,-....3.847 .........no,waste no,sample.? ................1,500 6 600 40 4,003 0.55
..... .... ..... .... ..... ........... ......... ......... ......... ......... ......... ......... .............................................................. _............................ . . ........................
9/24/2004_..... ___..._15_?........__..... 837........._706.105__._.._.__651............_82.526 3,800..............._2.110....._.._._no waste ___7�000......_. 88--"-'---4..............__._507 ............._....._25-__........._3,169 0.61
9/25/2004 ._16:4..................._231. ............_29.669..._..............._180 ..........._23,118.............._2.600...............2.230............._nowaste..................._710....................._31 0 40 5,137 0.24
. .......................... ..........._._.._..__.._ .................2 ......................................................
9/26/2004 ........-......_16:0....................420............._63.050......................._65.............12.760............................................................................................................................. ........._........................................................................0 0
/26/.............. . ........................................................................................
9/27/2004 24.4 -_................143 29,100.............._,..150 ,_...30,524,__„�3,900 2,520 no wasteA 70 3 610 25 5,087 <0.10
...... .. ._................._..._................._._..__ __._..__.._......._....................................................'-'-'-_....................._.__.._...................
9/28/2004 ........?6_?.___...__.._150_.__._.35.904..._.................121 ..........28.962_.__3,800..............._2.4...... no waste ......................34._..................................................._0._.................._34.............._8,138_...__<.0.109/29/2004 .27.3 731 166,436 1,034 235,423 3,000 1,980 no waste 340 0 44 10,018 019
9/30/2004 26.6 ............. 901 .........199.881 ... ..',409 ..........312,578 .............'2.800.................1,938 no waste . .....................500....... .... .. ................... .................... ................... ..........0...
.........._..........�_. 0 98 21,741 <0.10
Monthly Avc 20.7 69,335 58,097
Ibs/day=flow(mgd)x conc(ppm or mg/I)x 8.34
sep04wpt.xls,Sep 04 WTP Temp Sum Page 1 of 1 Printed 10/3/2004

Paul To Keith Haynes (DENR DWQ)
Dickens/Canton/BlueRidge
[e-mail], Bob
10/03/2004 02:02 PM Williams/Canton/BlueRidge@BlueRidgePaper, Bob
Shanahan/Canton/BlueRidge@BlueRidgePaper, Eddie
Plemmons/Canton/BlueRidge@BlueRidgePaper,Steve
Single/Canton/BlueRidge@BlueRidgePaper,John
Pryately/Canton/BlueRidge@BlueRidgePaper, Daryl
cc Whitt/Canton/BlueRidge@BlueRidgePaper, Michael
Koerschner/Canton/BlueRidge@BlueRidgePaper,George
Garten/Canton/BlueRidge@BlueRidgePaper, Lori
Cooper/Canton/BlueRidge@BlueRidgePaper, Michael
Ferguson/Canton/BlueRidge@BlueRidgePaper, Kevin
Hennessy/Canton/B I u e R i d g e @ B l u e R i d g ePap er,
bcc
Subject Process and Wastewater Treatment Upset -Blu Ridge
Paper y
[lam
3 Oct 2004 <m 0
Subject: NPDES NC 0000272 M c:
Process and Wastewater Treatment Upset cmi ln�n
29 and 30 Sep 2004 o
Blue Ridge Paper Products �m cn C Q
Canton, Mill 00
o n�n1
Keith Haynes, NC DENR ARO DWQ - m Z
The back-to-back floods impacting Blue Ridge Paper Products in September 2004 are unprecedented.
With heroic effort we repaired flood damage and restarted wastewater treatment and mill process
operations. The pulp mill restart after the unplanned 3-week cold outage is proving to be a challenge.
Because flood waters rose quickly, we were not able to execute a normal mill shutdown. The cold pulp
and fiber left in digesters for 3 weeks are well beyond the operating experience of any pulp mill. The
quantity of dissolved color materials is much greater than during normal mill operations . We have had
great difficulty processing fiber and pulp left in tanks from before the floods and have lost an abnormal
amount of color to the mill sewers. The mill restart after Frances and Ivan is absolutely not a normal
operating situation and does not reflect the normal color performance of the mill.
This note provides written notice required under the NPDES permit that we experienced a process and
wastewater treatment upset following restart our pine pulping process on the night of 9/29 and morning of
9130. We previously notified you about the pH excursion on the morning of 9/30 and monthly average
color results for September 2004. We confirmed on 10/1 that the 9/30 pH excursion also caused a partial
kill of our activated sludge plant. The secondary effluent(SE) color on 10/1 was also high. As a result,
Blue Ridge Paper will likely not meet the monthly color discharge limit for October 2004 and may not meet
the annual average color limit for 2004.
Color data summary for last 5 days is as follows:
Date Flow PI PE SE River at Fiberville Bridge
9/28 28.7 mgd 150 ppm 456 ppm 121 ppm no color sample,
35,904#/day 109,147#/day 28,962#/day not a river color sample day
9/29 27.3 mgd 731 ppm 1448 ppm 1034 ppm 25 ppm, flow 1015 mgd
166,436#/day 329,683#/day 235,423 #/day
9/30 26.6 mgd 901 ppm 2452 ppm 1409 ppm 44 ppm, flow 782 mgd

199,881 #/day 543,961 #/day 312,578#/day
10/1 28.6 mgd 267 ppm 1101 ppm 2266 ppm 92 ppm, flow 590 mgd
63,686#/day 262,615#/day 540,945#/day
10/2 28.30 mgd 296 ppm 553 ppm 622 ppm 53 ppm at 0919, flow 428 mgd
69,862#/day 130,520#/day 146,806#/day 25 ppm at 1450, flow 492 mgd
The daily river run checks DO conditions at Fiberville and at Clyde. The river run on 9/29 and 9/30
included HEPCO and Waterville. Downstream DO levels for the process and wastewater upset period
are well above minimum levels. DO readings for the activated sludge plant indicate that treatment
continued throughout the upset period and that our bugs are recovering. We will report 5-day BODs for
the upset period when PACE Labs has completed these analyses.
The mill's average secondary effluent color performance for the period January through August 2004 was
39,737 Ibs/day. We have demonstrated the ability to meet the annual average color limit of 42,000 Ibs/day
under normal mill operating conditions. Blue Ridge Paper is working hard to complete the mill restart and
return as quickly as possible to pre-flood color performance.
Bob Williams -the Blue Ridge Director of Regulator Affairs -will contact Forrest Westall this week to
discuss the effect of the floods and unplanned cold mill outage on our monthly and annual average
effluent color limits.
Paul Dickens
Manager, Environmental Affairs
Blue Ridge Paper Products, Inc.
[e-mail]
828-646-6141 FAX [phone]

BLUE RIDGE
PAPER PRODUCTS INC.
3 November 2004 CERTIFIED MAIL
Return Receipt Requested
Forrest R. Westall, PE 7099 3220 0007 0371 1650
Water Quality Regional Supervisor
North Carolina Department of Environment
And Natural Resources D (r� f� 110 f� D
Division of Water Quality C E V 15
2090 US Highway 70
Swannanoa, NC 28778 NOV — 4 2004
Subject: NPDES NC0000272 WATER QUALITY SECTION
Monthly Max Secondary Effluent Color Excursion ASHEVILLE REGIONAL OFFICE
Wastewater Treatment Plant Recovery from Floods
Blue Ridge Paper Products, Inc.
Canton, NC
Dear Forrest,
This is the 5-day written report required to notify your office of an excursion. The monthly SE
average color for October 2004 was 59,539 lbs/day. The permit monthly max color limit is
52,000 lbs/day. Lori Cooper of Blue Ridge Paper notified Keith Haynes via voice mail and with
a follow-up email on 1 Nov 2004 concerning the October color result.
The elevated monthly color for October was a result of the unexpected process and wastewater
treatment upset that occurred during restart of the Blue Ridge Paper Products mill following the
September 2004 floods. The upset led to an elevated color discharge between 9129 and 10/2 and
to elevated effluent BOD concentrations during the first week of October. We notified Keith
Haynes via telephone and with follow-up written reports concerning these events. The treatment
plant quickly recovered from upset conditions. Color and effluent BOD performance since the
first week of October have been good. We will report the monthly average BOD result for
October when these data are available from PACE Lab.
Blue Ridge Paper is making great progress towards restoring our on-site wastewater lab that was
destroyed in the September floods. We greatly appreciate DENR's help and understanding with
the flood recovery efforts.
Sincerely,
on W. Cooper Paul S. Dickens
WWTP/Lab Services Coordinator Manager, Environmental Affairs
828-646-2480 828-646-6141
cooyel@blueridgepa ep r.com [e-mail]
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 1643
28 Oct 2004 pp
Forrest R. Westall, PE D E C ED
Water Quality Regional Supervisor
North Carolina Department of Environment NOV - 3 2004
and Natural Resources
Division of Water Quality WATER QUALITY SECTION
2090 US Highway 70 ASHEVILLE REGIONAL OFFICE
Swannanoa, NC 28778
Subject: NPDES NC 0000272
Omitted Page- September 2004 Discharge Monitoring Report
Blue Ridge Paper Products, Inc.
Canton, NC
Dear Forrest:
We realized today that when producing the September 2004 DMR, the back page certification to
the first effluent sheet was not photocopied. A replacement page with the omitted back page is
enclosed. Please substitute this page in the DMR package submitted on 10/26.
Sincerely-
Paul S. Dickens John J. Pryately
Manager, Environmental Affairs Waste Treatment and Lab Supervisor
828-646-6141 Operator in Responsible Charge
[e-mail] 828-646-2480
pryati @blueridgepaper.com
Enclosure: Replacement First Page with Signature Backpage for September 2004
Discharge Monitoring Report
Distribution:
NC Division of Water Quality, Environmental Sciences Branch
NC Division of Water Qulaity, Central File (2 copies)
TN Dept of Environment and Conservation
Progress Energy
Keith Haynes, NC DENR ARO
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

STATE OF NORTH CAROLINA
Department of Environment, Health, and Natural Resources
Water Quality Section
59 Woodfin Place, Asheville, NC 28801
704-251-6208
File Access Record
FACILITY NAME COUNTY
I/We, have been provided
(print name)
(print name)
access to the above-named file by personnel of the Water Quality
Section. I understand that this statement shall be made a
permanent part of any file which is viewed under the Freedom of
Information provision of the North Carolina General Statutes.
(signature) (date)
(signature) (date)
name/initials of WQ staff member
permit number

Ca^Tc:
Sox C -
Cantcn - _ ;"na .__ ._ .
US hamcson - -=.;:onai Cc;ocrauon
October 5, 1998
Mr. Donald Anderson
U. S. EPA
Engineering and Analysis Division
401 M Street, S. W.
Washington, D. C. 20460
Re: BFR TM - STATUS REPORT
Champion International Corporation- Canton Mill
Dear Mr. Anderson:
As you are aware, Champion has been demonstrating its patented Bleach Filtrate Recycle
(BFRTM) process at the Canton Mill in order to meet the December 1, 1998 color
reduction objectives set forth in Part III, Section E, Paragraph 10 of NPDES Permit No.
NC0000272. This paragraph begins as follows:
"Beginning December 1, 1998, the annual average discharge of true color shall not exceed
60,000 Ibs/day and the monthly average true color loading shall not exceed 69,000 Ibs/day.
However, ifby October 1, 1998, in accordance with the Settlement Agreement and the Revised
Color Variance, the Technology Review Workgroup determines, and the NPDES Committee
agrees, that there are overwhelming technical, economic or operational barriers to the
permittee's ability to attain the above-stated color loading limits, the Technology Review
Workgroup shall recommend to the NPDES Committee the alternate interim limits to become
effective December 1, 1998."
The color limitations set forth in this paragraph are contingent upon the successful
operation of the BFR TM technology on the mill's pine line. Specifically, paragraph 7 of
the permit reads:
"Based on the results of the demonstration effort, the permittee shall continue the full operation
ofthe BFRTM technology on the mill's pine line on a continuing basis, subject to the process set
forth in Paragraph E 10"

CFamcc� — —nonal Coroornon,
Mr. Donald Anderson
page 2
In 1998, the mill's monthly and annual daily average effluent color discharge has been
consistently below the limitations set forth in the Paragraph 10. Champion is committed
to operating BFRTM on a continuing basis. This is to advise the Technical Review
Workgroup that, at this point in the demonstration, no technical, operational or economic
issues have surfaced that are viewed as insurmountable obstacles to the continuous
operation of the technology.
One issue remains outstanding, however, to assure the continuous operation.of BFRTM.
That issue is an air permit determination by the Western North Carolina"Regional Air
Pollution Bureau (WNCRAPB). In order for that determination to be completed certain
data must be collected and analyzed. To support that determination, Champion is
currently finishing its final round of required air emissions testing on both recovery
boilers. Although Champion expects to be able to obtain appropriate air operating
permits for the BFRTM process, this evaluation remains to be completed. Champion
intends to complete the permitting process as soon as the air emissions testing and
analysis is complete. The timing for the completion of this emission analysis and
determination is the end of 1998 or early 1999.
The BFRTM process can not be deemed to be operational on a continuous basis until the
permit determination is complete and any appropriate authorization is received from the
WNCRAPB. If you have any questions, please feel free to contact me at(828) 646-2033.
Sincerely,
Robert Williams
Manager, Environmental, Occupational Health and Safety - Canton Mill
xc: Mr. Forrest Westall
Regional Supervisor
Division of Water Quality
NC Department of Environmental
and Natural Resources
59 Woodfin Place
Asheville,NC 28801

Page 2
December 1, 1986 - US District Court Judge Sentelle ruled
that EPA had jurisdiction to assume
authority over Champion' s NPDES Permit .
March 4, 1987 - Champion appeal of Sentelle ruling.
April 9, 1987 - First EPA Draft (public notice) of
Champion NPDES Permit with 50 unit color
limit applicable to Champion immediately
downstream of discharge at Fiberville
Bridge.
May 22, 1987 - Second EPA public notice for permit
issuance.
January 14, 1988 - First Public Hearing in Asheville Civic
Center for NPDES Permit issuance.
January 21, 1988 - First Public Hearing in Knoxville,
Tennessee Civic Center.
March 9, 1988 - Tennessee, North Carolina, Champion, and
EPA agree on change in proposed permit
from 50 Apparent Color units at NC/TN
state line (proposed as applicable at
the Fiberville Bridge immediately
downstream of the Champion Mill) to 85
True Color Units at the State line.
. North Carolina and Tennessee to grant
variance from color stream standard to
allow permit issuance .
May 5, 1988 - Champion formally requests water quality
color standard variance from EMC NPDES
subcommittee at public hearing in Raleigh.
June 24, 1988 - Champion appeal of Sentelle decision
denied by three judge panel of 4th US
Circuit Court of Appeals - verifying EPA
authority over Champion' s NPDES permit.
Ron Levine, Director, Division of

St of North Carolina
MICHAEL F. EASLEY Department of Justice REPLY T0:Daniel C.Oakley
A7rORNEY GENEML Y. G. BOX 629 Environmental Division y
RALEIGH [e-mail]
276020629 Telephone:[phone]
Fax:[phone]
MEMORANDUM
TO: Secretary Wayne McDevitt
FROM: Daniel C. Oakley-P(,0
DATE: October 1'), 1998
RE: Pigeon River Joint Watershed Advisory Committee
The attached correspondence will remind you of North Carolina's commitment to the
Joint Watershed Advisory Committee (JWAC), as one of the provisions in the settlement of the
Champion Paper matter. Forrest Westall and I have recently discussed the establishment of the
JWAC and the appointment of the North Carolina representatives, and wanted to bring it back to
your attention.
Please review this correspondence and advise whether you are in agreement with the
outline of the committee as set out in the exchange between Tennessee Deputy Attorney General
Barry Turner and myself. If the basic format is acceptable to you, Forrest and I feel we should
try to get the JWAC up and running in early 1999. This will require four(4) appointments to be
made by North Carolina. As DENR Secretary, you are the appropriate person to make those
appointments.
Please advise as to how Forrest and I should proceed.
Thanks.
/dw
cc: Bill Holman
Preston Howard
Forrest Westall OCT 2 2 lcoq
attachment
wp/28143

1 i
REPLY TO:Daniel C.Oakley
Environmental Division
[e-mail]
Telephone:[phone]
Fax:[phone]
MEMORANDUM
TO: Secretary Wayne McDevitt
FROM: Daniel C. Oakley
DATE: October 13, 1998
RE: Pigeon River Joint Watershed Advisory Committee
The attached correspondence will remind you of North Carolina's commitment to the
Joint Watershed Advisory Committee (JWAC), as one of the provisions irthe settlement of the
Champion Paper matter. Forrest Westall and I have recently discussed the establishment of the
JWAC and the appointment of the North Carolina representatives,4�-.J
Ju r . ZtU_.Cu--
Please review this correspondence and advise whether you are in agreement with the
outline of the committee as set out in the exchange between Tennessee Deputy Attorney General
Barry Turner and myself. If the basic format is acceptable to you, Forrest and I feel we should
try to get the JWAC up and running n early 1999. This will require four (4) appointments to be
made by North Carolina. YPc�{ y�pt,�s DENR Secretary, are the appropriate person to make
those appointments.
Please advise as to how Forrest and I should proceed.
Thanks.
/dw
cc: Bill Holman
Preston Howard
Forrest Westall
attachment
wp/23 143

STATE OF TENNESSEE
Office of the Attorney General RECEIVED
SEP 1 41993
u`ncucu I A
d. :n
ti.C. Af iORMEY GENERAL
Envimnmental Division
.....
JOHN KNOX WALKUP
ATTORNEY GENERAL AND REPORTER
ANDY D. BENNETT MICHAEL E. MOORE
CHIEF DEPUTY ATTORNEY GENERAL SOLICITOR GENERAL
LUCY HONEY HAYNES CORDELL HULL BUILDING
ASSOCIATE CHIEF DEPUTY NASHVILLE. TN 37243-043S
ATTORNEY GENERAL
74
September 10, 1998 FACSIMI EE(6115))741'20091
BY FACSIMILE TRANSMISSION
Daniel C. Oakley
Senior Deputy Attorney General
State of North Carolina
Department of Justice
P.O. Box 629
Raleigh,North Carolina 27602-0629
Re: Joint Watershed Advisory Committee
Dear Dan:
I recently met with Justin Wilson, Paul Davis and David McKinney, and what follows are
our thoughts regarding the Joint Watershed Advisory Committee the Settlement Agreement
requires Tennessee and North Carolina to establish. We think the focus of this Committee is to
be on both economic and environmental issues within the watershed. Information relating to
such issues would be provided to the.Committee by the States. With regard to Tennessee,
economic information would come from the state Department of Tourism and the Department of
Economic and Community Development. We have not yet determined what types of economic
information these agencies would provide to the Committee.
Environmental information would come from the Tennessee Department of Environment
and Conservation, the Tennessee Wildlife Resources Agency, and the Tennessee Department of
Agriculture. While not an exclusive list, we think the following environmental information
relating to the watershed could be provided to the Committee: water quality monitoring reports;
biological monitoring reports; NPDES-related planning and actual discharge information; non-
point source activities; soil and water conservation programs; and other environmental program
information, e.g., RCRA and air.
In response to the information provided by the state agencies, the Committee would
consider any specific proposals involving the watershed, and if it chose to do so, could prepare
comments or other materials regarding such proposals. These would be considered by the

appropriate state agency or agencies. We envision state agency support for the Committee to
involve supplying the Committee with copies of the information noted above, and reviewing
comments or other documents submitted to the agencies by the Committee. Although officials
from these agencies would not be regularly attending Committee meetings, officials could be
available to meet with the Committee from time-to-time to discuss specific matters if the
Committee requests this.
From Tennessee's perspective, we do not have resources available to provide funds or
agency staff to assist with the operations of the Committee. We would, however, be able to
make office space in Knoxville available to the Committee for meetings, and in conjunction with
those meetings, we also could make a copy machine and a telephone available for the
Committee's use. Tennessee would support the Committee seeking grant assistance from EPA
for funds to operate.
Concerning Committee membership, we think four members should be appointed by each
State. The members would have overlapping service periods, and one of each State's
appointments would be a co-chair of the Committee. The Tennessee appointees would be: (1) a
government official from a municipality situated on the Pigeon River; (2) a government official
of Cocke County; (3) a member of the rafting outfitters' association in Cocke County; and (4) a
member of an environmental citizens' group in Cocke County.
After you have had a chance to review this, please give me a call to discuss further. I
look forward to hearing from you.
Sincerely,
BARRYI"TURNER
Depu ,Attorney General
(615)�32-2586
xe: Justin Wilson
Paul Davis
David McKinney

,uK �
3�A
State of North Carolina
MICHAEL F. EASLEY Department of Justice
ATTORNEY GENERAL P.O. BOX 629 REPLY TO:
RALEIGH Environmental Division
[e-mail]
mail.jus.state.nc.us
2 7 602-0629 Telephone:[phone]
Fax:[phone]
July 23, 1998
Mr. Barry Turner
Deputy Attorney General
425 Fifth Avenue North
Nashville, Tennessee 37243-0495
RE: Joint Watershed Advisory Committee
Dear Barry:
Pursuant to Paragraph 32 of the Settlement Agreement Regarding 1996 Water Quality Color
Variance and 1996 NPDES Permit Issued to Champion International Corporation,North Carolina
and Tennessee are required to establish a Joint.Watershed Advisory Committee. The agreement is
silent as to the details for setting up and operating the Committee, but the goal is to "foster joint
planning and public input on decisions affecting the Pigeon River."
Both states need to establish the initial requirements for membership and operation, and it
appears you and I are in the best positions to move the committee along legally. Forrest Westall,
Paul Davis, Mike McGhee and others have had a general discussion of this on May 12, 1998; and
at that time North Carolina suggested several principles to follow. They may be summarized as
follows:
North Carolina and Tennessee should appoint three or four members each (with
concurrent or overlapping service periods), with one of each State's appointments
being a co-chair of the Committee (a partnership in direction). The criteria for
appointment would have to be established, but would likely include folks that live
in the basin and that have some special local interest or leadership role (political,
educational, or interest group affiliation). Staffing support of the Committee would
have to be agreed to by the two states. Since the basic objective of this section of the
Agreement seems to be to foster community interest in the River and the
management decisions affecting the River, it is anticipated that the Committee. after
completing its initial meetings and organization efforts, would develop its own path.

Mr. Barry Turner
Page 2
July 23, 1998
It would initiate its own agenda for interaction with federal, State and local agencies
having land and water management responsibilities within the watershed. The
Committee would develop its own "independent" view of these decisions or
proposals and would comment directly to those agencies. It should have broad
latitude to determine its role.
The purpose of this letter is to initiate a process under which the two states can agree on
Committee membership criteria and any staffing or logistics issues. Appointments may then be
made and the Committee charged with going forward as it determines appropriate.
Please consider this proposal and call me to discuss, at your convenience. I look forward to
working with you again on this matter. With best wishes, I am
Very truly yours,
jovv, 00
Daniel C. Oakley
Senior Deputy Attorney General
DCO/dw
cc: Secretary Wayne McDevitt
Preston Howard
Forrest Westall
wp26431

Effluent
NPDES No.: NC 0000272 IDischarge No.: 001 Month: November Year: 1998
Facility Name: Champion International Corporation Class: IVI lCounty: Haywood
Operator in Responsible Charge(ORC): David M.Cody Grade: IV I Phone [phone]
Certified Laboratories: (1)Champion Int'1 #198;(2)Pace #40,#12,(3)Brooks Rand#546(4)Burlington Research#002
Check Box if ORC Has Changed Person(s)Collecting Samples: Operators on Duty
Mail ORIG'L+1 COPY to:
Attn:Central Files /
Div.of Environmental Mgt X
DEHNR (Signature of Operator in Responpi6le Charge) D
P.O.Box 29535 BY THIS SIGNATUR CERTI T THIS REPORT IS ACCURATE AND COMPLETE
Raleigh,NC 27626-0535 TO THE BEST OF NOW G
50050 00010 00400 0031 00530 31505 00300 00600
E in LL O � /r�m'•„
044 /�yz \m/ € '
E E in � � � m {t/9 0 �/ �.;` y/5� o a z
i o H Fqy��
0 0 o w / / / _
0 o LL �7nn SFia; ®mod °LL
HRS YIN MGD °C Std Units Sid Units Ib,lday- - IbJday 1 #1100mi mgf- mg1L
�1� ,:07.00. „24 ' i yN4 ' �22.$0$+.c3;'3g2,�� �aa7�,rs', ��$,,<� •'�„`r1091"`'�0.11$ �'� �Sk+:rt�,' `� ,�7�+'�B `� t�
2 0700 24 Y M 23.684 32.8 7.9 7.8 2773 < 0.082 " 4346 2 12.80
3 t 0700,;A 24 W'. ,_Y 20,528?, 33 8 . 3 g' ,s.= .$; 308 U,231 r S,0' l , ?.2 05 f
4 0700 24 Y 22.413 33.3 7.8 7.8 2882 0.239 5982 12.14
5; 0700, 2d Yx�,11 3.2TxZ4, �,A 9� 1,7:$S`..
6 0700 24 Y 22.710 33.0 7.9 7.8 3597 0.173 5493 11.67
24L 2LL L1 L 9M?a 2920 §5, ' S1Qs.z LLL ;�Lill
8 1 0700 24 N 21.721 28.8 8.0 8.0 2389 0.099 4348 11.13
485�
6ry
h�` fx`
10 0700 24 Y 22.926 31.0 7.9 7.9 2407 < 0.082 4971 10.63
11'= _0700, r}.24c t 3 $()x
12 0700 24 Y 23.158 29.7 8.1 7.9 1215 < 0.082 3476 9.87
23 „}` fit}Q82 v 366$ . #1013MOAQ
14 070024 Y 2233.(5110 331(.g2 88.0{ �7.9
� 1174
< 0{.0(8y2j 392�11 10.83
16 0700 24 Y 23.582 30.7 8.1 8.0 1280 < 0.082 2360 1 9.78
1T' 0700)' }T24 r, a .a F23452 T $ _ nc* Qy 0082: 3fL91 3 9v9$ �; �:.
18 0�7/0}0 T24
( Y 2}4.5}011 �¢30.5 g 8}.1} 8.0� 1545 ¢<1e0ry.(0�82 326}9(�j � 10.12 W
,3� 4 ?.VILQ 'b IG7S;£tf $,® § imIG etijLf,$>.Fd4RV.$ "�Y '"a'acQ4`e`SC -,t'#? (,VY r LV154. v. VY�b fW+'_11, J# 1113`+ Ri, �I -'?'�$.'
20 070{0y 24} Y 24.110 31.4 8.2 7.9 1468 < 0.082 32177 9.98
22 0700 24 N 22.848 29.4 8.0 7.9 1000 < 0.082 1906 10.43
23a�,OZDQ= r4�, �, B >�,•, �*/�t} !{, �y Q(f,�s ,'�} ry�(�r3�,`� �+�yQ .�+�e��sx Yp,,�, (�C�J ;y�
24 0700 24 1 B 23.622 31.5 7.9 7.9 1194 < 0.082 2561 10.80
25 `V,00, „24' �B ' 22AL 6 ;79
26 0700 24 N 23.122 30.4 8.0 7.9 2108 < 0.082 5014 11.10
27` ,0700` 24. .N . 231597 2$<7 86 "tl i3$= 124322833sx h[184:
28 0700 24 N 23.558 29.6 8.0 7.9 1183 0.099 2358 11.21
•29' �:0700 ';24;: ,�,tJ�� x23238: �.;�29,41� °�: �4a�`k�_T,:9 ` xf'1452_ �Q082,�! "�2713� �'��-,;� ��i�t2� .�:�A„-fir
30 0700 24 Y 24.548 29.4 8.0 7.9 1402 0.091 2866 2 12.03
f' q,+,111k
Average 23.112 30.9 1869 0.11 3719 3 10.86 4.60
Maldmgm xx_.. ;; x 24 54$, , 3 8,; t12,., .8:?_: 3673 is10 24m 5982 n 23 .,1280 460
Minimum 20.528 28.8 7.8 1 7.8 1000 < 0.08 1906 1 9.66 4.60
Comp(C)/Gr'ab"(G); G, . ,;;G` w_G, Cr`' ` C ',.Ci3 ,"G 1,Gh
Monthly Limit 29.9 9 1 6 1 3,598 '12,549 200 6

Facility Status:(Please check one of the following) ,
All monitoring data and sampling frequencies meet permit monitoring requirements.
Compliant
All monitoring data and sampling frequencies do NOT meet permit monitoring requirements.
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment,
operation,maintenance,etc. and a time table for improvements to be made.
.r
r;Y
a
e
'I certify,under penalty of law,that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel property gather and evaluate the information submitted.
Based on my inquiry of the person or persons who manage the system,or those persons directly responsible forgathering the
information,the information submitted Is,to the best of my knowledge and belief,true,accurate,and complete.I am aware that there are
significant penalties for submitting false information,including the possibility of fines and imprisonment for knowing violations'
William R.Manzer
Permittee(Please print or type)
Signature of Permittee" Date
P.O.Box C-10 Canton,NC 28716 704-646-2840 Permit Expires Nov.30,2001
Parameter Codes
00010 Temperature 00556 Oil&Grease 00951 Total Fluoride 01067 Nickel 50060 Total
00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual
00080 Color(Pt-Co) 00610 Ammonia Nitrogen 01092 Zinc Chlorine
00082 Color(ADM[) 00625 Total IGeldahl 01027 Cadmium 01105 Aluminum
00095 Conductivity Nitrogen 01147 Total Selenium 71880 Formaldehyde
00300 Dissolved Oxygen 00630 NidateslNrdites 01032 Hexavalent Chromium 31614 Fecal Colifono 71900 Mercury
00310 BOD5 01034 Chromium 32730 Total Phenolics 81551 Xylene
00340 COD 00665 Total Phosphorus 34235 Benzene
00400 pH 00720 Cyanide 01037 Total Cobalt 34481 Toluene
00500 Total Solids 00745 Total Sulfide 01042 Copper 38260 MBAs
00530 Tot Suspended 00927 Total Magnesium 39516 PCBs
Residue 00929 Total Sodium 01045 Total Iron 50050 Flow
00545 Settleable Matter 00940 Total Chloride 01051 Lead
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at(919)733-5083,extension 581 or 534.
The monthly average for fecal coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data.
ORC must visit facility and document visitation of facility as required per 15A NCAC 8A.0202(b)(5)(B).
'94 signed by other than the permittee,delegation of signatory authority must be on file with the State per 15A NCAC 2B.0506(b).

.may.. ioai. wu
Facility Name: Champion International Corporation County Haywood
ORC: David M. Cody
Persons)Collecting Samples: Operators on Duty
EFFLUENT CON'T
DO 65 00500 70301 00900 00340 M5 00080 00080 71900 01092
g
o $ m
0
d. s 2 Z, a
m E U� o 0 0 o
c x
� F O O � N O
HRS mg/L mg/L I mg/L mg/L I mg/L I umhos/cm mg/L mg/L ug1L ug/L mgA
9WIM .,
2 0700 2040 2074 3826 324 423
4 0700 2046 2060 3768 268 409 1.8
FIR l Qj.; am No no-am ROORM4WINOW
6 0700 2107 2038 186 3019 242 397
t? 2700 . 20 4
8 0700 2146 2068 3298 294 423
10 0700 1851 1739 3444 277 396
iav
12 0700 1781 1834 208 3114 246 338 <0.2 20
__
14 0700 1800 1842 2806 239 308
16 0700 1848 1857 2920 272 324
18 0700 2223 2219 3168 301 390
I M
20 0700 1986 1946 E176 3011 313 412
F o ou WEIMMM MMMMUMMMSO
22 0700 1712 1648 2421 319 399
24 0700 1868 1878 2666 356 493
r2rf'ffl
26 0700 1885 1885 2926 496 808
— t
28 0700 1732 1706 2790 Y 274 398
ry'� xi/{{'+ rv. F¢�' t ' ' ,}+r£�✓,�jy'",' ax, ,ynx'y''x -t Y � ' '
30 0700 1722 1736 2394 268 326
E `� 5}'Yt "1 u t M{' 'y# � :." R¢ey<.F 3S`.T. f .i l
� zi r"`sa'JS`a .g �* �� :a. �' � t,,
Average 0.31 1958 1935 218.00 178 3060 303 413 <0.2 20 1.8
PAaiarituri% l?3F , 2536 5 ? �9 .1 '`.38 -1 im k808_" c02; x # 48 s
Minimum 0.31 1712 1648 208 170 2394 234 290 <0.2 20 1.8
Can C GCLb� "C x, C�" m 4�� �. �`^�C�'a •��.. � ,��-.= ��s � �, >f s < � �� x�, ax..tt�gs,.
Monthly Limit 0.014~

Influent
NPDES No.: NC 0000272 Influent to WW rP Month: November IYear. 1998
Facility Name: Champion International Corporation County: Haywood
00310 00530 00080 00080
32
Y
x � � 2 a
O N y�
N � y y y
m n '
o E o m o 0 0
HRS HRS mglL mg/L mg/L mglL
NXI
7 29 Or
2 735 24 366.0 600 431 2498
3 . 41w 1 .7,7 2422
4 720 24 408.0� 710 276 1998
Egmm! _ v!c S WON
6 630 24 362.9 748 312 3100
8 630 24 408.7 758 447 1654
10 725 24 384.3 802 403 2290
mmam— =m Im NNEW—N ON ON
12 840 24 424.3 746 470 3040
7 2 y
14 900 24 350.4 468 321 1182
16 715 24 380.0 598 477 1773
18 715 24 474.4 764 774 3033
9 0
20 715 E24
319.8 666 397 2104
22 900336.1 562 322 2174
99
24 730 24 429.3 460 438 1495
.Wit„
26 930 24 346.4 592 431 1820
28 755 24 351.7 540 318 1592
30 720 24 347.4 500 �302 2658 y
Average 392.9 668 396 2042
Md'— � a 4 626 i28Q'a 16{T 3100 �' � s a k .,.
T 4<.s.3C. f'S` '"k +� .Yv� s ..,�.} f..iRx 'r ..�
Monthly Min. 289.2 460 177 1182
�k.c' i, . A -

NPDES No.: NC 0000272 Receiving Stream Month: November IYear. 1998
Facility Name: Champion Intemational Corporation County: Haywood
Stream: Pigeon River-UP
Location: Canton (River Mile -64.5)
UPSTREAM
50050 00010 00310 00300 31505 000a0 00080 00095
m
o �
m E F m g y o 0 0
LL
HRS MGD -C mglL mglL #1100ml mglL SOON r lL umhos/cm
2 805 30.9 13.10 <2.00 8:32 90 35.30
t _S 8 0 w ;
4 750 39.0 13.80 <2.00 7.95 25 54 39.50
r. N21 ^):.; _ 50
6 745 33.2 10.40 <2.00 9.04 40.00
8 900 32.1 7.90 <2.00 10.01 27.50
10 735 35.9 10.20 <2.00 9.48 19 41 37.10
12 855 54.8 10.50 <2.00 8.14 27.30
14 930 40.6 10.60 <2.00 9.13 39.30
9 _ 5 0
16 745 62.8 11.20 2.35 9.04 500 45.70
18 745 68.3 9.70 <2.00 9.65 22 52 31.60
20 740 50.0 10.00 <2.00 9.36 37.80
2, 9
22 925 42.4 7.20 <2.00 10.24 36.30
24 800 40.1 8.80 <2.00 10.07 12 34 36.10
26 947 42.8 8.70 <2.00 9.66 37.80
28 825 35.7 7.20 <2.00 10.10 37.90
30 825 36.0 6.70 <2.00 10.43 300 35.90
Wrza t�v"'�. x -j'�t t`�'.Mx �s�e,�.�t 2ra .n`� q-s�s, L ra x E
_r m,._ r-. ..3,.�.x. ��,,, �."?-� .stx�" °^�u s, �'?° � �� rr+,.u,�w
Average 47.8 9.9 2.01 9.31 233 24 5y7� 37.39
� �' to � <".f0`64r1,,, �.ax-+�.�.36�n s.' ,�.o� 1 7'7 (t�,.�.(]a Mon,9dyN12lG._. �1883 1380,.t*` �° ,..' a ';<Y r �.
Monthly Min. 30.9 6.20 <2.00 7.95 90 1 12 34 27.30

NPDES No.: NC 0000272 IDISCHARGE N0: Month: November IYear. 1998
Facility Name: Champion Intemational Corporation County: Haywood
Stream: Pigeon River-DN1
Location: Fiberville (River Mile 62.9)
DOWNSTREAM
00010 00010 00300 00300 31505 00095 00080 00080
chi L �' _c € F ¢'
E E G g
N 19 m 2 U y y
0 0
0 0 Tfi o 8 0
HRS Z25.8012.70
mglL mg/L rN100m1 mhos! mglL mg/L
O , '2 820 8.50 8.50 1300 2278:04 810 8.47 8.47 1795.0 157 243. 51 6rim Sm
6 820 22.60 12.20 9.05 9.05 1951.0
8 930 21.00 13.10 9.20 9.20 1919.0
10 800 22.60 12.40 8.94 8.94 1898.0 178 246
12 910 17.00 6.50 9.35 9.35 938.0
.,. x 0�
14 945 20.20 9.60 8.91 8.91 1402.0
16 800 17.50 6.30 9.33 9.33 110 1041.0
18 800 16.30 6.60 9.99 9.99 1146.0 106 142
�.� . . M t 9 .
20 755 18.40 8.40 9.41 9.41 1363.0
't 8d0�
22 940 17.30 10.10 10.38 1 10.38 1162.0
24 815 19.90 11.10 10.00 10.00 1291.0 170 217
°
s2815a 000
26 1003 18.40 9.70 10.20 10.20 1333.0
28 835 19.00 11.80 10.25 10.25 1571.0
29 R5
30 840 19.70 113.00 110.04110.04 20 1505.0
777777
7
v t7s` ,$a. '# = U 1��iraa .:,r. u`.�i 2wi 2
Average 19.79 9.89 9.46 9.46 145 1491.0 141 1 211
Monthly Min. 13.30 2.30 1 8.28 8.28 20 400 67 117
Month)
.<yi:ia ➢ »R

NPOES NO: NC 0000272 DISCHARGE No: MONTH: November YEAR: 1998
FACILITY NAME: Champion Intemabonal Corpora8on COUNTY: Haywood
STREAM: Pigeon River-DN2 STREAM: Pigeon River-DN3
LOCATION: Above Clyde (River Mile 57.7) LOCATION: Below Clyde (River Mile 55.5)
Downstream Downstream
00010 00300 00300 00010 om 0WW 00M 00080
C C C J
m m m F 6
44rr .2 m O $ 2 yy 6
N
0 O O O U U
HRS °C mo W HRS °C W W W W
g Ca:zt6. OWN
2 835 17.90 6.25 6.25 845 16.90 7.12 7.12
. af�0 55
4 830 18.60 5.98 5.98 840 18.00 6.46 6.46 200 239
5u° 9ME 8
6 855 14.501 6.38 6.38 845 13.20 7.24 7.24
l 0,14N10MA same mumm
8 1000 13.90 7.34 7.34 945 12.60 8.09 8.09
rem UM
10 815 16.40 6.64 6.64 825 15.30 7.32 7.32 174 ;214
�N:' 780 JM4 W W=900 a Em
12 925 12.80 8.24 8.24 935 12.10 8.63 8.63
14 955 14.80 8.08 8.08 1000 14.70 8.23 8.23
A1.
16 815 14.60 8.57 8.57 825 14.80 8.46 8.46
18 815 12.40 9.18 9.18 825 12.10 9.63 9.63 84 121
8.
20 810 14.90 8.16 8.16 820 14.40 8.31 8.31
0 rA M- 8,,
22 955 11.50 8.91 8.91 1005 10.80 9.35 9.35
24 830 15.60 7.64 7.64 840 14.70 8.26 8.26 151 179
26 1020 13.90 8.28 8.28 1025 13.50 8.90 8.90
7 887
28 850 12.60 8.43 8.43 900 11.30 9.08 9:08
30 900 12.90 7.78 7.78 915 11.90 8.33 8.33
AVWlp
14.65 7.74 7.74 13.88 8.23 8.23 144 213
y
rr .s .1sa¢r x 9,19 , 31 r . t +• w _t1,8Q0, r0 SzSs00 ', $ � ,F
1.wmnry Mn�m�n 11.50 5.89 5.89 10.80 6.46 6.46 84 121
"67aiNhltml 5 00 , 4 „ 17 r R v x ooxji,

MON01 • 1111 • • • - •-
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7C7CL�[ © 1ifCO

-I NPDES NO: NC 0000272 IDISCHARGE NO: MONTH: November YEAR: 1998
FACILITY NAME: Champion International Corporation COUNTY: Haywood
STREAM: Pigeon River-DN7 STREAM:
LOCATION: 1-40 Bridge (River Mile 24.7) LOCATION:
Downstream Downstream
000io owto 0M om 0= om
z a o
a
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4 1015 15.4 <2 8.47 48 96
x.Y'*mh: .
6
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12
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14
16
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18 1100 12.5 <2 9.98 37 62
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20
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$ r , k, ._a
Mamt,yrtinimum 11.5 <2 8.47 34 62
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PD-Powerhouse Down

NPDES No.: NC 0000272 IDischarge No.: 001 Month:November Year: 1998
Fadlity Name: Champion Intemational Corporation County: Haywood
ORC:David M.Cody
Person(s)Collecting Samples:Operators on Duty
QA / QC DATA SPECIFICATIONS
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8
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18 `
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28 7
28
30
"xsF. ' ' r',�.�. � 'R ,t .d TIM

Canton.North Carolina 28716
Champion
Champion International Corporation
December 15, 1998
Forrest R. Westall
Regional Water Quality Supervisor
NC Department of Environment and Natural Resources
Division of Water Quality, Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
RE: NPDES Permit No. NC0000272
Dear Mr. Westall:
Champion International Corporation's Canton Mill has an on-going process improvement
effort to reduce effluent color emissions. In support of this commitment, an additional
opportunity for color reduction has been identified for the hardwood secondary knotter
accepts tank overflow.
The control strategy for minimizing color losses from the hardwood secondary knotter
accepts tank overflow line is detailed in Section 4.6.1 of the June 1,"1998 Color Technology
Measures Report", that was submitted to you on May 27, 1998. The current control strategy
on this tank employs a temperature probe in the overflow line. If a tank overflow occurs, the
increase in temperature is detected by the temperature probe and a process signal
immediately alarms the hardwood brownstock operator station and appropriate action is
taken.
Planned improvements are underway to relocate the accepts tank overflow line into an
existing sump in the hardwood brownstock washing building. This will improve color
containment and the temperature probe will no longer be required for operator notification. A
sump conductivity probe will be used for operator notification in the future.
Please accept this as notification of the removal of the temperature probe and
implementation of an improvement to mill color -control. If you have any questions or
concerns, please contact me at [phone] by January 6, 1999.
Sincerely,
�Obff VVV� °
_ p
Robert V. Williams
Manager 6 ,
Environmental, Occupational Health and Safety 1 (7

State of North Carolina
MICHAEL F. EASLEY OeiJ8rtmeru of Justice
REPLY TO:Daniel C,OaAle_v
ATTORNEY GENERAL P. O. BOX 629 Environmental Division
FUM.EIGH Doakleynmail.jus.state.nc.us
27602.0629 Telephone:[phone]
Fax:[phone]
November 17, 1998
Mr. Barry Turner
Deputy Attorney General
425 Fifth Avenue North
Nashville, Tennessee 37243-0495
RE: Joint Watershed Advisory Council
Dear Barry:
Thanks for your September 10, 1998. letter regarding the formation of the Pigeon River Joint'
Watershed Advisory Council. I have discussed our exchange of correspondence with Secretary McDevitt
and Forrest Westall,and North Carolina is in agreement with you on the broad,general goals for the Council.
We have not taken the step of further discussions with EPA.
For initial membership, the four(4)North Carolina representatives will be as follows: l) a member
of a local environmental citizens group; 2) a local government representative; 3) a person with pulp and
paper knowledge and experience; and 4) a Departmental employee in the DENR Western Regional Office,
Asheville, North Carolina. The Secretary is ready to make his appointments. and will ask one of the
representatives to act as Co-Chair. We are also agreeable to overlapping service periods. Do you have a'
mechanism you prefer?
It would be timely to have the Council schedule a formation meeting in early 1999, in either
Asheville or Knoxville. Please give me a call at your convenience to discuss our next steps.
Sincerely, l
//J(/('1 �ON
Daniel C. Oakleey
Senior Deputy Attorney General
DCO/so
cc: Secretary Wayne McDevitt
Preston Howard
Forrest Westall V 0 �558
Laura DeVivo
/28866

n Mill Box C _
' BOX -10 -
Canton, North Carolina 28716
Champion
Champion International Corporation
November 20, 1998
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Health
and Natural.Resources
Water Quality Section
Division of Environmental Management
59 Woodfin Place
Asheville, NC 28801
Re: NPDES Permit No. NC0000272
Dear Mr. Westall:
As required under the,referenced permit, Part III - Special Conditions, Section E -
Requirements for Compliance and Analysis, Paragraph 13, Champion International,
Canton Mill is submitting the attached"Low Flow Contingency Plan".
If you have any questions, please call me at [phone].
Sincerely;
Robert V. Williams
Manager
Environmental, Occupational Health & Safety

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
Canton, North Carolina
I. Introduction
The following report on the low flow contingency plan details the Canton mill's progress to
fulfill the requirements of the 1997 modified Color Variance and NPDES Permit. Part III,
Paragraph E 13 of the 1997 Permit provides that:
'As the 1997 Revised Color Variance recognizes, there could still be
some periods of time, corresponding to periods of lower flows in the
river, when color at the Hepco gage might exceed 50 true color units. i
The permittee shall develop a contingency plan for mitigating the
occurrence and degree of these potential exceedances which correlates
measures designed to achieve mitigation with periods of lowest flow,
with particular attention being given to periods of higher recreational
use in the river. In developing the plan, the permittee shall evaluate
any reasonable means, including scheduling of maintenance,
intermittent treatment, and production curtailment, which would
achieve additional color reductions during temporary periods of lower
flows in the river when color at the Hepco gage might exceed 50 true
color units."
This plan fulfills the requirements of Part III, Paragraph E 13.
1

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
Canton, North Carolina
If.Color Performance Review
The mill's commitment toward continuous management of color is illustrated in Figure 1, which
shows a color reduction of over 85% from the 1988 secondary effluent annual average. The
improved color performance is due to the Canton Modernization Project and mill-wide efforts
detailed in the June 1, 1998 Color Technology Measures Report.
The January 1998 - August 1998 average secondary effluent color discharge of 50,524 pounds
per day is well below the 60,000 pound per day effluent limitation specified in Part III,Paragraph
E 10 of the 1997 Permit. During the same period, the measured monthly averages for true color
at the Hepco bridge are all below 50 standard color units(scu's), even at flows less than the 30Q2
occurring in August.
Using North Carolina's governing flow criteria (30Q2), historical flow records, and the 1998
January- August secondary effluent color discharge, it is expected that color in the Pigeon River
at the Hepco gage will be less than 50 scu's 97% of the applicable time. Therefore, Champion's
actual color performance results in significant mitigation of the occurrence and degree of color at
the Hepco gage.
2

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
Canton,North Carolina
M. Contingency Plan Discussion
Based on the current color performance, the mill is below 50 scu's 97% of the applicable time,
using North Carolina's 30Q2 flow criteria. The sustained level of low secondary effluent color
discharges has been achieved through extensive and ongoing mill-wide efforts. However, in
accordance with Part III, Paragraph E 13, the scheduling of maintenance, intermittent treatment,
and production curtailment were evaluated for further color reduction benefit during loAiest flow
periods.
3.1.1 Scheduling of Maintenance
The loss of excess color during outages and upon start-up continues to be a focus of the mill's
color minimization activity as detailed in the June I, 1998 Color Technology Measures Report.
To minimize color discharges during periods of lowest river flow and higher recreational use in
the river, no major maintenance outages will be scheduled during the months of June, July and
August.
3

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
Canton,North Carolina
3.1.2 Intermittent Treatment
A Primary Clarifier will normally be empty and available for outage or unplanned brown colored
material storage. When color cannot be reclaimed by the mill's extensive sump system, or when
unplanned process losses occur, colored material will be stored in the primary clarifier for
managed, intermittent release to the secondary wastewater treatment system. The clarifier will be
utilized for managing colored material storage and release based on information provided by
continuous sewer conductivity monitoring, daily sewer color monitoring, and normal milk
operations communication. This management tool will allow the mill to provide a relatively
stable color load to the activated sludge system and subsequent optimization of the activated
sludge color removal effect.
3.1.3 Production Curtailment
Production curtailment through reduced pulp manufacturing is not a viable color reduction
option for the Canton Mill. The mill is designed to achieve the most effective and efficient color
control at normal production rates and maximum fiberline"turndown" capacity is approximately
80% of normal production. Therefore, complete fiberline shutdown would be required to
effectively reduce pulping process effluent color during periods of lowest flow. Capital
expenditures to install a dry furnish system to replace the pulp production for one fiberline would
4

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
Canton,North Carolina
total several million dollars in addition to dry furnish pulp costs. Production curtailment is
neither a technically nor economically reasonable option for intermittent color reduction.
W. Conclusion
The Canton mill's January 1998 - August 1998 average secondary effluent color discharge of
50,524 pounds per day, coupled with the measures detailed in the June 1, 1998 Color Technology
Measures Report, demonstrate the Canton Mill's commitment toward brown colored material
management. Using North Carolina's governing flow criteria (30Q2), historical flow records,
and the January 1998 - August 1998 secondary effluent color discharge, it is expected that color
in the Pigeon River at the Hepco gage will be less than 50 true color units 97% of the applicable.
time. The mill's commitment to not schedule major maintenance outages during June, July and
August, the months of greatest recreational river use, and optimizing use of the primary clarifier
for brown colored material storage and management will result in mitigation of the occurrence
and degree of color during periods of lowest river flow.
5

Champion International Corporation - Canton, NC
Figure 1: Canton Mill Secondary Effluent Color Performance
Annual Averages: 1988- 1997
Monthly Averages:January 98 October 98
400000
350000
v 300000 SE Color
�N December 1, 1998 Limits:
G —60000 Annual
a.
O 250000 —r-69000 Monthly
U
y 200000
w
.1 150000
v
o 100000
d
50000 h I
0
0o 0) O r N M 1* U) W n 00 00 Co 00 00 00 Co 00 00 Co
00 00 0) 0) 0) 0) O) 0) 0) O) 03 0) 0) 0) 0) 0) 0) O) a) 0)
r r r r r r r r r r 10 10 C W V
LL Q ' Q W 0
December 1, 1998 Report - Low Flow Contingency Plan

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
November 23, 1998
NCDENR 198
Mr. John J. Pryately
Champion International WWTP Lab.
..JAMESB.HUNTJR�YN P.O. BOX 4000
=r.
GOVERNOR �1.',:y,`�I Canton, NC 28716
r 1 r
SUBJECT: Deleting Parameter(s) from Certificate
TWA`Ti+R_`MCDEYITf J� COD
kr-SECFIETARY .�v-„��
Dear Mr. Pryately:
E
Per your request we are deleting the above parameters from your certificate.
r ._ ResTDHHor Enclosed is an updated certificate reflecting this change which is effective on
fpsq:�IR 'P �Y •.
C1�>'9 �r"� •S� November 23, 1998.
-. If you have questions or we can be of any further assistance, please contact us at
z4 [phone].
^:GI INti�:
Sincerely,
Bernard E. Sims, Ph.D.
Chief, Laboratory Section
rj
BES:mod
exit` �:
_ Enclosure
cc James W. Meyer
Gary W. Francies
Marilyn O. Deaver
�•Y4��jQ�y C
14r Y
y��y��_VVnn♦gyp T,;
'Y?4•"a'I�iR,�',v LABORATORY SECTION
4405 REEDY CREEK ROAD,RALEIOH,NORTH CAROLINA 27607-6445
{ •'.S
PHONE'BI B-733-3906 FAX BIB-]33.6241
AN EQUAL O PPOgTUNITY/AFFI RMATI V E ACTION EMPLOYER-SOX RBCYCLED/10X P09T-CON9tlMER PAPER

Attachmentl
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Champion International WWTP Lab. Certificate Number. 198
,,.rces P.O. Box 4000 Effective Date: 1/1/96
r'y Canton,NC 28716 Expiration Date: 12/31/98
Date of Last Amendment: 11/23/98
The above named laboratory,having duly met the requirements of 15A NCAC 2H.0e00,is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANIC
SOD
COLOR,PLATINUM COBALT
CONDUCTIVITY
AMMONIA NITROGEN
pH
RESIDUE,TOTAL
RESIDUE,DISSOLVED 180 C
RESIDUE,SUSPENDED
r
This certification requires maintance of an acceptable quality assurance program,use of approved methodology,and satisfactory pertomrance on evaluation samples. Laboratories are
subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.oam

• Canton Mill
Box
Canton.North Carolina 28716
ampion
�III
Champion International Corporation
November 16, 1998
`VERt«��vR
Mr. Bradley Bennett
Supervisor, Stormwater and General Permits
North Carolina Department of Environment and Natural Resources
P. O. Box 27687
Raleigh,NC 27611-7687
Subject: Request for Designation of Representative Outfall Status.
Champion International Corporation, Canton Mill, Haywood County
Stormwater Permit NCS000105
Dear Mr. Bennett:
The purpose of this letter is to request representative status for stormwater outfall 6-16
with 5C-17 and 513-20 being considered typical for closed landfills, as granted in our
permit for analytical sampling.
Outfall 6-16 is a new outfall. This outfall collects stormwater from the closed and capped
in accordance with the Division of Solid Waste approved plans Cell H at the No. 6
Landfill (see attachments ). Our"Stormwater Pollution Plan"has been revised to reflect
the addition of the new outfall and to include the outfall in our facility inspection .
If you have any questions or need additional information, please contact me at(704)646-
2372.
Sincerely, �
Louie Justus
Senior Envirogme al Engineer
xc: Mr. Forest Westall Mr. William R. Manzer
NCDENR Vice-Pres./Operations Manager
Water Quality Section Champion International Corp.
59 Woodfin Place 175 Main Street, P.O. Box 4000
Asheville,NC 28801 Canton,NC 28716

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Landfill #6
General Location Map
Outfall # 16

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Drawing Legend: Outfall # 16 (Landfill # 6 )
Total Drainage Area: 230,868 Square Feet (See Note, Below) -
Drainage Area Outline:
Drainage and Discharge Structures: Drop Basins
Culvert Pipes "5
Impervious Surfaces: Roads -
Buildings -
Stormwater'Structural Control Measures: Rip-Rap
Springs
Hazardous Waste Storeage Area
Satellite Hazardous Waste Storage Area
Materials Loading and Access Areas LOAD
Note: New outfall added 11/10/98 due to capping of cell H at landfill
No. 6
r

C&M--ma.
P.O. BOX 37564 • RALEIGH, NORTH CAROLINA 27627 '
September 26, 1997 � n 1
7 �d 1n
Governor James B. Hunt, Jr.. w��i� ,� �4r�•
The Capitol
Raleigh, N.C. 27611
Re: CHAMPION PAPER MILL -- Canton
Dear Governor:
The U.S. Environmental Protection Agency is presently reviewing the variance granted by
the State to the Champion International Paper Mill in Canton. I am writing today to Carol
Browner to deny the variance as EPA has done before.
The Pigeon River will never begin the long restoration process it needs for fish, wildlife and
people without a significant change in the way Champion does business. Compliance with
the relevant wastewater discharges should be at the discharge pipe, not several miles
downstream. A recent study shows that can reduce its pollution discharges by almost
50% without any significant cost to the company.
I hope you and your staff had an opportunity in Europe to visit some of the paper mills
there. They use much more efficient, less polluting processes. North Carolina could be a
leader in bringing this technology to the rest of this country, n
Thank you for your consideration. IN ���� U
Sincerely,
OCT 0 6 1997
VVA I k�7 QUALITY` nn SCCTiON
John D. Runkle �� �
President
G
CC. Wayne McDevitt
Preston Howard
Dan Oakley
e
i,\

State of North Carolina `
Department of Environment,
Health and Natural Resources 1 •
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary p E HIV R
A. Preston Howard, Jr., P.E., Director
Asheville Regional Office
WATER QUALITY SECTION
August 21, 1997
Mr . Glen Goodrich
1863 Barnard Road
Marshall, North Carolina 28753
Subject: Requested Information
Pigeon River Color Data
Haywood County
Dear Mr. Goodrich:
Per your request, please find attached the data concerning
improvements in the color of the Pigeon River before and after
modernizations to Champion' s Canton Mill . Hopefully, this is
enough information for your needs . If it is not, or if you have
questions concerning what the numbers actually indicate, please
do not hesitate to contact me at 251-6208 .
Si erelyZ � +
D. Keith Hayne
Environmental Specialist
Interchange Building,59 Woodfin Place ` 4FAX [phone]
Asheville,North Carolina 28801 Nif An Equal Opportunity/Affirmative Action Employer
Voice 704-251-6208 50%recycles/100/.post-consumer paper

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Canton Mill -
Box C-10
Canton,North Carolina 28716
V Champion
Champion International Corporation
September 10, 1998
CFo �
4/4qR
y pUA
Mr. Keith Haynes AS -!lt�REG;o wrlo
North Carolina Department of NA[0 F
Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: Petroleum Release at Champion International Corporations Canton Mill on
September 7, 1998
Dear Mr. Haynes:
Champion .International Corporation is providing written notification of a release''- of
approximately 5 galloffs of hydraulic fluid. The release was discovered on September 7,
1998, at approximately 5:00 a.m. This letter is a follow-up to our telephone notification on
September 7, 1998 at 9:55 a.m. to the NCDENR in Raleigh.
Hydraulic fluid leaked from a pump coupling at the Beaverdam Creek pump system. The
pump system automatically shut-off on low hydraulic fluid as designed. Most of the fluid was
contained behind the underflow pump intake structure. A contractor (NEO Corporation)
used absorbent booms and pads to absorb the fluid. No sheen was observed downstream
of the pump. The coupling was tightened and a permanent system of oil booms was
installed around and downstream of the pump.
On Tuesday, September 9, 1998, McAusland, the pump supplier/manufacture was
dispatched from Florida and a new type of coupling was installed on the hydraulic line to the
pump to further prevent any future losses.
If you need further information regarding this release please contact me at [phone]
or Jim Giauque at [phone].
Sincerely,
Louie•Justus,--- -- . Jim Giauque
Senior Environmental Engineer Senior Environmental Engineer

Canton Mill
Box C-10
Canton,North Carolina 28716
V Champion
Champion International Corporation
a 1 r�
October 6, 1998 r su u i�
s OCT — 1998
Mr. Keith Haynes _
NCDENR 'RATER QUALITY SECTIC2i
SFIZT REGIONAL OFFICE
Division of Water Quality — --
59 Woodfin Place
Asheville,NC 28801
Subject: Petroleum Release at Champion's Canton Mill on October 6, 1998.
Dear Mr. Haynes:
Champion International Corporation is providing written notification of a release of approximately
450 gallons of lubricating fluid (machine oil) at the Canton Mill. The release was discovered on
October 6, 1998, at approximately 1:15 AM.
Machine oil from the Canton Mill 19 Paper Machine had been leaking from a containment area
sump designed to return it to the storage tank but this pump was not functioning. The sump filled
and overflowed to the in mill sewer. Upon discovery at 1:15 AM on October 6, the machine oil
storage area re-circulation pump was repaired by 2:00 AM. The machine oil traveled through mill
sewers to the Waste Treatment Plant. Waste Treatment Plant personnel have not seen evidence
of a machine oil spill on the clarifiers or on the river.
If you need further information regarding this release please contact me at 704-646-6814 or Jim
Giauque at 704-646-2028.
Sincerely,
Chns Leitsch Jim Giauque
Air Group Coordinator Senior Environmental Engineer

Canton Mill
Box C-10
Canton,North Carolina 28716
V Champion c'`�-
Champion International Corporation
September 25, 1998
Mr. Keith Haynes
North Carolina Department of
Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: Petroleum Release at Champion International Corporation's Canton Mill on September 22, 1998
Dear Mr. Haynes:
Champion International Corporation is providing written notification of a release of less than
800 gallons of paper machine lubrication oil. The release was discovered on September 22,
1998, at approximately 7:50 a.m. This letter is a follow-up to our telephone conversation on
September 23, 1998.
The oil was released from the overflow line of a 6000 gallon bulk storage tank. The overflow
line shutoff valve had been inadvertently left in the open position. The oil flowed into the
tank containment where most of the oil was contained. The released oil flowed out of the
containment to the mill sewer system through an open drain line. The contained oil was
removed by a contractor. The open drain line will be permanently closed. No oil was
observed at the Wastewater Treatment Plant as a result of this release.
If you need further information regarding this release please contact me at [phone]
or Jim Giauque at [phone].
Sincerely,
Derric Brown Jim Giauque
Environmental Supervisor Senior Environmen?alEngineer

(� Canton Mill
(�►`t/''� Box C-10
4 Canton,North Carolina 28716
��
V Champion
Champion International Corporation
August, 31, 1998
gs�glF ,3'99S
Mr. Gary Francies HFV(�R�QUq�(
NCDENR Division of Water Quality RfCro �FCI(Qy
Laboratory Section �FF(CF
59 Woodfin Place
Asheville, NC 28801-2414
Subject: Total Nitrogen&Total Phosphorus sample out of hold time.
Dear Mr. Francies,
This letter is notification that the July 1998, sample for total nitrogen and total
phosphorus did not meet sample holding time requirements. The sample was collected,
preserved, and refrigerated on July 16, 1998. The sample was left in the refrigerator and
not sent for analysis until the error was discovered August 20, 1998. No other preserved
sample was available that met the 28 day holding time requirement. The test results from
this sample were qualified on the July DMR as not meeting holding time requirements.
Corrective action taken to prevent this problem for future samples is to match retained
chain of custody forms for periodic testing done by contract laboratories to the posted
schedule for periodic testing. Taking this action will bring to our attention in a timely
manner any deviations from the testing schedule established to meet regulatory
requirements.
If you have any questions, comments, or need additional information please contact me
at 704-646-6720.
Sincerely,
JPryately
Laboratory Supervisor
cc: Derric Brown, Mike Cody, Joe Deschene,
Bob Williams,Bill Manzer,
Keith Haynes, James W. Meyer,Marilyn Deaver

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
• DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
—� September 4, 1998
CD,ENR I ..
�JntAEs 6.HLINT.IFi.'
faOVERNOR
Mr. Derric Brown
Champion - Canton Mill
BOX C-10
Canton, North Carolina 28716
��WyY"JE,M�nEvm -
.•.a'�
v Subject: Acceptance of Activated Sludge
.` Canton Mill
•P.E blrtEcrG NPDES Permit No. NC0000272
Haywood County
Dear Mr. Brown:
µ •
I
This Office does not foresee a problem with your waste
water treatment accepting activated sludge from the Town of
Maggie Valley. It is suggested that you maintain a record
of all sludge received including the date and number of
gallons .
If you have any questions concerning this matter or if
14
you require additional information, please do not hesitate
1 to contact me at 251-6208 .
" Sin rel ,
D. Keith Haynes
Environmental Specialist
xc: Al Matthews
champmv.let
p�P INTERCHANGE BUILDING,59 WOOOFIN PLACE,ASHEVILLE,Na 28801-24 1 4
Y'"• l• PHONE [phone] FAX[phone]
e{1 AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-50%RECYCLED/10q POST-CONSUMER PAPER
R'� ti

Canton Mill
Box C-10
Canton,North Carolina 28716
UChampion
Champion International Corporation
September 2, 1998
Mr. Keith Haynes
Environmental Specialist
Division of Environmental Management
Water Quality Section
59 Woodfin Place
Asheville, NC 28802
RE: Bark Boiler Ash/Clinker Handling System Overflow at Champion's
Canton Mill on August 29, 1998
Dear Mr. Haynes:
Champion International is providing written notification of a release of approximately
8,500 gallons of bark boiler ash/clinker system sluicing water that occurred on
August 29, 1998. Your office was notified of the release at approximately 10:05
a.m., August 30, 1998 and this is a follow-up to our conversation.
Attached is the Water Quality Section report with additional details. If you have any
questions or require additional information, please call Jim Giauque at (828) 646-
2028.
Sincerely,
m Giauque
Senior Environme al Engineer
copy: Derric Brown
Dick Carlow
Louie Justus

Sanitary, Sewer, Pump Station and WWTP Spill or Bypass Report Form
(Please Print or Type-Use Attachments if Needed)
Permittee; Champion International Corp_ Permit Number, NC0000272 County : Haywood
Incident Started: Date: 8/29/98 Tithe: After 9 p.m. Incident Ended: Date: 8/30/98 Time:Approx.7 a.m.
Source of Spill/Bypass(Check One): O Sanitary Sewer X Pump Station O Waterwater Treatment Plant
Level of Treatment(Check One): O None A Primary Treatment O Secondary Treatment O Chlorination Only
Estimated Volume of Spill/Bypass: Approx.8,500 gallons (A volume must be given even if it is a rough estimate.)
Did the Spill/Bypass reach the Surface Waters? O Yes g No If yes,please list the following:
Volume Reaching Surface Waters: w1A_ Surface Water Name :Did the the Spill/Bypass result in a Fish Kill? O Yes O No A,, ,—
Location of the Spill/Bypass:
The bark boiler ash/clinker handling system. Due to the designed nature of this system the heavier solids would settle and
would not be present in the overflow.
Cause of the Spill/Bypass:
The primary sump pump was pumping slow and was unable to keep up with the influent ash sluicing water.
Describe the Repairs Made:
A contractor was mobilized with a portable sump pump to pump water from the settling system.
Action taken to contain spill,clean-up waste and remediate the site:
The water was pumped(still in process at 10 a.m.8/30/98)and the ash/clinkers will be removed by the normal procedure for
disposal in the Champion Landfill.
Action taken or proposed to be taken to prevent future spills at this location:
The spare emergency pump was out of service for maintenance repair. A back-up spare emergency pump will be maintained
to minimize the possibility of future spills.
Other Agencies Notified: Voice mail to Keith Haynes @ 10:05 a.m., 8/30/98
Person Reporting Spill/Bypass: Derric Brown Phone Number: [phone]
Signature : Date: 8/30/98
For DWQ Use Only:
Oral Report Taken By: Report Taken: Date: — Time:
DWQ Requested an Additional Written Report: O Yes O No
If Yes, What Additional Information is Needed :

LABORATORY SECTION
August 26, 1998
MEMORANDUM
TO: Forrest Westall
FROM: Gary W. Francies w �G
Laboratory Section, ARO
SUBJECT: Holding Time Compliance Violation
Please be advised that Pace Analytical has analyzed Total Nitrogen
and Total Phosporus samples, at the clients request, which were out
of holding time. Per 15A NCAC 2H . 0805 (a) (7) (N) any time a
sample is received which does not meet sample collection, holding
time, or preservation requirements, the laboratory must notify the
sample collector or client and secure another sample if possible.
If another sample cannot be secured, the original sample may be
analyzed but the results reported must be qualified with the nature
of the infraction(s) and the laboratory must notify the State
Laboratory about the infraction(s) .
The following information was supplied by Pace Analytical:
Client name: Champion, International
Contact person: John Pryately
Address: P. 0. Box 4000 Canton, NC 28716
Telephone: [phone]
Sample dates : 7/16/98
The client has been notified by the enclosed letter. Please let me
know if I can be of further assistance.
If you have questions or need additional information contact me at
(828) 251-6208 extension 285.
Attachment
cc: James W. Meyer
Marilyn Deaver

N a
NORTH CAROLINA DEPARTMENT OF
., •�, oT:�1' ENVIRONMENT AND NATURAL RESOURCES
w �
-4 = DIVISION OF WATER QUALITY
ASHEVILLE- REGIONAL OFFICE
CDEM R August 26, 1998
' � a• b '�r 198
JAAI ES S.HUNr](i;"�� '
:GOVERNOR Tz MR. JOHN PRYATELY
TV
CHAMPION INTERNATIONAL WWTP LAB
xaan:
P.O. BOX 4000
CANTON, NC 28716
� a
WAYjJ E, CDEVITi
;�SpecRET` v Dear Mr. Pryately:
We have been notified that on August 20, 1998, you submitted
a*
Total Nitrogen and Total Phosphorus sample(s) for analysis of '
to Pace Analytical Laboratory. At your request the sample was
analyzed out of holding time.
Please be advised that under provisions of N. C. Regulations
15A NCAC .0805 (a) (7) (N) , anytime a laboratory receives samples
''a;, . �•^'*; -x r t" that do not meet sample collection, holding time, or preservation
requirements, the laboratory must notify the sample collector or
_ ? client and secure another sample if possible. If another sample
cannot be secured, the original sample may be analyzed but the
results reported must be qualified with the nature of the
" •�. ,'� infraction(s) , and the laboratory must notify the State Laboratory
about the infraction(s) . The notification must include a statement
indicating corrective actions taken to prevent the problem for
future samples.
We are requesting that you take the appropriate steps to
avoid recurrence of this in the future. All sample preservation
is P' ti and holding requirements must be met in accordance with the
'-• f r' Federal Register, July 1, 1995; 40 CFR 136.
7 ('
I *•� � ^'d Thank you again for your cooperation. Contact us at (828)-251-
. 6208 extension 285 if you have questions.
^id _ ri
L
�.... _....yl-
_ __ _ — a Sincerely,
FJ
_ Gary rancies
Laboratory Section
`L
T
t b
" cc: James W. Meyer
-, Maril n Deaver
AS'717i eg a ye
�� - 2 J!J r. INTERCHANGE BUILDING,S9 WOODFIN PLACE,ASHEVILLE,NC 28801-2414
PHONE 828-ZSI.6200 FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-50%RECYCLED/10% POST-CONSUMER PAPER

NORTH CAROLINA DEPARTMENT OF
e 1
(\').T '"'' ENVIRONMENT AND NATURAL RESOURCES
s .P D
KS,al', EY✓'' ,. AJ\ DIVISION OF WATER QUALITY
/v ASHEVILLE REGIONAL OFFICE
August 26, 1998
5
'21�`,JAF1ES HLINT.1Rd` Tom`
GOVERNOR "' 198
MR. JOHN PRYATELY
^2 .- .•_. s' CHAMPION INTERNATIONAL WWTP LAB
P.O. BOX 4000
1 T - CANTON, NC 28716
` wyf1It C`,DEvITT
ser�"'ke. ETASRY
Dear Mr. Pryately:
Your letter dated August 13, 1998 that describes corrective
' n REcrQ actions for your analytical procedures has been received and
-/ >*- reviewed. The actions taken are acceptable for your North Carolina
1145w, Was laboratory certification. We can accept
your MDL (Method Detection Limit) study. 'It is recommended that
this MDL study be done annually along with the verification of the
standard curve stored in the memory of the spectrometer.
Thank you again for your cooperation. Contact us at (828)-251-
,I_� : 'd 6206 extension 285 if you have questions.
' il I. A Sincerely,
Gary Francies .
Laboratory Section
s,{
W t:
r
cc: James W. Meyer
.. . . - --
�-t� _
i pA4 �y y"t'x'�y INTERCHANGE BUI4DINGp59 WOODFIN PLALE,A9HEVILLE,NC 28801-2414
PHONE [phone] FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-509'.RECYCLED/I C19G POST-CONSUMER PAPER

V ATFR r .
ASy:V(L1FQ0f(( 1 RT Q
I
FAX COVER SHEET
ENVIRONMENTAL, OCCUPATIONAL,
HEALTH AND SAFETY
CHAMPION INTERNATIONAL CORPORATION
CANTON MILL
FROM:
DATE: S J.30�ga
NUMDER OF PAGES:
(INCLUDING COVER) a S
NOTE: S
The material contained in this communication is intended only for the use of the addressee.
It may contain information that Is confidential, proprietary, attorney-privileged, and exempt from
disclosure under applicable law. If the reader of this communication Is not the intended recipient,
you are hereby notified that any dissemination,distribution or duplication of this communication is
prohibited. If you have recti,ed this communication In error, please notify us immediately by
telephone and return,by mall,the original message to us. Thank you,
SENDERS PHONE NUMBER: (828) 04"700
FAX NUMBER: [phone]
FAX PROBLEMS: (828) 64"700
10' d i00' oN 2S:6 86.0£ 9f1H Z689-9V9—VO4:GI SH03 NDI&1UH3

-� 3►,ft
-"cASHNUEMI NACU 40
�y/?''rR
- �F t� .UAL! �•�
nita v ewer. PumpStationd V P * r ..V 1 Re p nySFCTjp r
(Pltase Priet or Ygpc • Use Attacmnerns ti.leedod
permitter: 5"a T.r kerr.o\a+o\ Cor permit Number: bL D 011 Count;::
:idea[Started:Date-13-J991% Time A pr, Incident Faded:Date �f, 4� �e d ,, n ,
SourceTC-
of Spill/Bypass (Check One): :C Sanitary sewer Pumo Stauon t]Wastetivater'I rcatment P ant
Level of Treatment(Check One)::^,Nono Primary Treatment C Secondarv''i naatment hlorination Only
Estimated Volume of Spili/Bvpass: W , ('A volume must be given even if it is a tough estimate.)
Did the Spill/Bypass reach the Surface Waters' Yes No : If yes,please list the following:
Volume Reaching Surface Waters: _ Surface Water Name:
Did the Spill/Bypass result in a Fish Kill? ^� ems 0 No ;
Location t 1
"Ike. bark bo.\e.r as\,l C�inker tno .�\art oe �o �e c.05. r.
4 5`�seer-t, S� ` � t
r,0.A,Jre a[C +v' zE, SZ56�em {-Me heaa,er`y So\`.a 6 �o�\a Se'X\e. drJ, tZOA. , V%6V �r
of the,$gill/Ryp-cs Presentr '.n A4v`e rwer -\oa. `\
e. �r,Mar.� Sor•,p i�am`J tw7G.s` PJ M�;fJ S`o.nl 4nA vZ4S .]nCMC
ko keep
De,5cribe the gepni]M
� �JMp Wa�4t- '�w+tn fiche. 5e��.+-cam SvJS�@,rn.
Action non M C QUIRin58 an Un Waste mri Rem .fiat the Site:
I^V\ >, ww�er vna"s �o�nPea process a1r `tDa«, 8 �30)
and 'Y``e_ Q tN% I C.\"4\k4_r-s W:\\. �2 •remb,4, �. 10� -Sb.rt, hDrtnc.`
yeoCeO.Jre -inr p:.sOOSa1 :n 5rr.¢. C.l�c....�P:a✓, Gwn��'•l\
Action Taken or Pro ced to bq Taken to Prevent Fu trP Cnin� hr rh' r�C_r
W'.\\ �'o\\o..�- uP or, � act �r•.�c�.-• v'e(ao.�' o., -�i.5 i�£?v1.
Other Agencies Notified: VUIL4 Mr+•\ k:oe-' \\a res @ 1u�oS t{$
Person ReportingSpiU/Bypa_ss: DP-rr",t_ 'Qvb,on PhoneNurnber: _L&2g) 64(6-aQ19
Signature Date: �12o1Ja
For DWQ 1 se Only: / -_
Oral Report Taken by: Report Taken: Date ZSme
WQ Requested an Additional Written Report: es O o
If Yes,What Additional Ittformation is Needed:
SpfflMypass Repotting Ftmn W97
ZO' d i"0 ON 8S: 6 86.0£ 9f1H Z689-9b9-D0L=9I SH03 N0IdHUH9

NORTH CAROLINA DEPARTMENT OF
., ._ ENVIRONMENT AND NATURAL RESOURCES
- DIVISION OF WATER QUALITY
ASHEVILLE-REGIONAL OFFICE
$ ® WATER QUALITY SECTION
September 4, 1998
HUNT.I ` '
..•'faOVERNOR
Mr. Derric Brown
2 -•:; Champion - Canton Mill
..
Box C-10
E .1�4DEvlrT Canton, North Carolina 28716
A7 ,, 1
ECR Y
,
Subject: Acceptance of Activated Sludge
a _ Canton Mill
IRE , NPDES Permit No. NC0000272
Haywood County
�ecC�c
Dear Mr. wn:
This Office does not foresee a problem with your waste
`4 water treatment accepting activated sludge from the Town of
Maggie Valley. It is suggested that you maintain a record
of all sludge received including the date and number of
gallons .
If you have any questions concerning this matter or if
you require additional information, please do not hesitate
to contact me at 251-6208 .
Sin rel ,
D. Keith Haynes
Environmental Specialist
Post-KO Fax Note 7671 Date pages,
FrOM
.r
CoMept Co. -DW
xc: Al Matthews
Phone# Phone# •l51 _ (qz C3
Fax# /1. I pn Fax# o� l b
r., champmv.1et --
INTERCHANGE BUILDING,58 WOODFIN PLACE,ASHEVILLE,NC 28801-2414
PHONE [phone] FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-SO,p RECYCLED/10%POST-CONSUMER PAPER

Faux C-Mill / /Jo /—
^ Canton;North Carolina 28716 .l t�a4
\' v AUG 18 1998
Champion
nal Corporation
�J U+=C,".'TORY SECTION
Certification Number 198 August 13, 199
Mr. James W. Meyer
NCDENR, Division of Water Quality
9G r�
Laboratory Section
4405 Reedy Creek Road
-6445
Raleigh, North Carolina 27607 lyF�oPs
9
Subject Laboratory Certification Maintenance Inspection Response °o
July 16, 1998 Letter and Attached Inspection Report.
Dear Mr. Meyer.
The laboratory inspection report from July 2, 1998 by Mr. Gary W. Francies
contained a comment that needed a reply. This correspondence is the response,,to
your letter dated July 16,1998 and received July 21, 1998 that includes the reply to
the comment.
COLOR
COMMENT: The signal reading on the low standard is not sufficiently greater than
the blank (.002 absorbance units obtained on a 10.c.u. standard). This makes the
lower limit of detection or reporting limit questionable due to inviable signal readings.
REQUIREMENT: The lab must obtain a signal in which the constituent concentration
in reagent water is 2(1.645)s above the mean of blank analysis (Lower Limit of
Detection). The constituent concentration that produces a signal sufficiently greater
: : than the blank, that it can be detected within specified limits, by good laboratories,
during routine operating conditions, is the Limit of Quantitation. Typically it is the
concentration that produces a'signal 10s above the reagent water blank signal. In
most cases, this requires an absorbance value greater than .005 units, preferably
greater than .010 units. Reference: Standard Methods, 18th Edition - Method 1010
C. And 1030 E.
RESPONSE: The Hach DR4000 instrument used to perform the color tests has a
very sensitive detector that enables the user to perform low level color tests that are
statistically valid. Replicate blank analysis were performed to determine the mean
and standard deviation of the blank, this data was used to calculate the ( Lower Limit
of Detection ) and the ( Limit of Quantitation) see Table 1 for raw data.

Champion International Corporation
Table 1
Hach DR4000 Color Test Replicate Blank Analysis
Test Replicate Color Units
Set Up Blank 0.00
1 0.30
2 0.35
3 1.05
4 0.70
5 0.56
` 6 1.05
7 0.48
The mean of the blank analysis is 0.64 c.u., the standard deviation is 0.309 c.u., and
the highest blank value is 1.05 c.u..
The Lower Limit of Detection is 2(1.645)(0.309) + 0.64 = 1.66 c.u.
The Limit of Quantitation is 10(0.309) + 1.05 =4.14 c.u.
The statistical analysis based on the Hach DR4000 replicate blank testing
demonstrates that the low standard of 10 C.U. is a viable standard sufficiently greater
than the blank. Based on this information the Canton mill will continue to use 10 c.u.
as the low standard for DMR reporting.
If.you have any questions, comments, or need additional information, I can be
contacted by phone at 704-646-6720 or by fax at 704-646-2993.
Sincerely,
a l l
John J. Pryately
Laboratory &WWfP Supervisor

Canton Mill
Box C-10 �(
Canton,North Carolina 28776
l�J Champion
Champion International Corporation
August 26, 1998 �d
'9s�'9T L9/
l '
Mr. Keith Haynes °tigFCr
North Carolina Department of
Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: Petroleum Release at Champion International Corporations Canton Mill on August 22, 1998
Dear Mr. Haynes:
Champion International Corporation is providing written notification of a release of
approximately 10 gallons of hydraulic fluid. The release was discovered on August 22, 1998,
at approximately 7:00 a.m. This letter is a follow-up to our telephone conversation on
August 24, 1998.
Hydraulic fluid leaked from the pump head of the Beaverdam Creek pump system. The
pump system automatically shut-off on low hydraulic fluid as designed. Most of the fluid was
contained behind the underflow pump intake structure. A contractor used absorbent booms
to absorb the fluid. No sheen was observed on the creek, nor was there any effect observed
on aquatic life.
If you need further information regarding this release please contact me at [phone]
or Jim Giauque at [phone].
Sincerely,
butam
Derric Brown Jim Giauque
Environmental Supervisor Senior Environmental Engineer

Imo" NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
�ENR DIVISION OF WATER QUALITY
F�;C Y
JAMES B.HUNTJR.,GOVERNOR
WAYNE MCDEVITT,SECRETARY
A PRESTON HOWARD,JR.,P.E.,DIRECTOR
July 16, 1998 41
198 vG �e*
Mr. John J. Pryately Frye
Champion International WWTP Lab: <<99l
P.O. Box 4000 f9Fc,9�s
Canton, NC 28716
SUBJECT: Laboratory Certification Maintenance Inspection �F
Dear Mr. Pryately:
Enclosed is a report for the inspection performed on July 2, 1998 by Mr. Gary W.
Francies. A response is not required if there were no violations cited. A response is not
required for comments or recommendations unless specifically requested. We appreciate
the fine job you and your staff are doing. As a certification requirement, your laboratory
must continue to carry out the requirements set forth in 15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from
this office. Thank you for your cooperation during the inspection. Please contact us at
919-733-3908, if you have questions or need additional information.
Sincerely,
s1
James W. Meyer
=t Laboratory Section
Enclosure
cc: Gary W. Francies
Marilyn O. Deaver
LABORATORY SECTION
4405 REEDY CREEK ROAD,RALEICH,NORTH CAROLINA 27 6 07-6 44 3
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/AFPIRMATIVEACTION EMPLOYER-30 RECYCLZWIO%POST.CON.UMER PAPER

ON- SITE INSPECTION REPORT
LABORATORY NAME: Champion International Corp. WWTP Laboratory
ADDRESS : P. O. Box 4000
'Canton, NC 28716
CERTIFICATE #: 198
DATE OF INSPECTION: 7/2/98
TYPE OF INSPECTION: Maintenance
EVALUATOR(S) : Gary Francies
LOCAL PERSON(S) CONTACTED: John Pryately, Derric Brown
Mike Cody, Chad Salisbury, Heather Hager
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the
requirements of 15A NCAC 2H . 0800 for the analysis of environmental
samples .
II. GENERAL COMMENTS :
The laboratory is spacious and well equipped. All equipment is well
maintained. Two new desiccators have been obtained. Records are well
kept and most data appeared accurate. The lab analyzes quarterly
performance evaluation samples for all parameters . Since the last
inspection, control limits have been set for duplicate sample analyses
for all parameters . Also, most of the forms, logs, and bench sheets
have been updated. The staff has done an excellent job of maintaining
the laboratory certification program.
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
S COLOR
COMMENT : The signal reading on the low standard is not sufficiently
greater than the blank ( . 002 absorbance units obtained on a 10 c.u.
standard) . This makes the lower limit of detection or reporting limit
questionable due to inviable signal readings . We request a reply to
this comment.
REQUIREMENT:- The lab must obtain a signal in which the constituent
concentration in reagent water is 2 (1. 645) s above the mean of blank
analyses (Lower Limit of Detection) . The constituent concentration
that produces a signal sufficiently greater than the blank, that it
can be detected within specified limits, by good laboratories, during
routine operating conditions, is the Limit of Quantitation. Typically
it is the concentration that produces a signal 10s above the reagent
water blank signal . In most cases, this requires an absorbance value

Page 2
greater than . 005 units, preferably greater than . 010 units . Ref :
Standard Methods, 18th Edition - Method 1010 C. And 1030 E.
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory
bench sheets and contract lab reports to DMRs submitted to this
Division. Data were reviewed for these months : March, April, and May
1998 . No errors were noted. It appears the facility is doing a good
job of accurately transcribing data .
V. CONCLUSION:
This laboratory is doing a good job overall . The staff is
cRn.gratulated for doing an excellent job of maintaining the laboratory
program.
Report prepared by: Gary Francies Date : 7/6/98
S:
e_�

NORTH CAROLINA DEPARTMENT OF
' ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
41i r WATER QUALITY SECTION
CDENR :_: August 11, 1998
:JAMEs 6.HUNTJ1q Mr. Derrlc Brown
OVERNOR i--T "•" Champion International Corporation
Canton Mill
Post Office Box C-10
Canton, North Carolina 28716
I.P[k .•
P E.MCDEVITT � -
tF'sect a-ad5
SEcxrwaY * Subject : Performance Audit Inspection
PAI Grade: "A"
. rc a Canton Mill WWTP
` NPDES Permit No. NC0000272
k•�„aP�REs,oNdrnA, JR„ __ Haywood County
3 r
4; ,.
Dear Mr. Brown:
On July 2, 1998 Mr. Gary Francies of the Division' s
Regional Office Laboratory and I conducted a Performance
Audit Inspection on Champion' s Canton Mill wastewater
£ treatment program. Personnel present from the Mill during
' the inspection were: Derric Brown, Chad Salisbury, John
P' Pryately, Melanie Hager, and Mike Cody. It should be noted
that the effluent samples were collected on July 22, 1998 .
The purpose of this inspection was to determine the
quality of the self-monitoring program being conducted by
the Mill and assess the reliability of its reported data.
The inspection consisted of evaluation of the following:
flow monitoring equipment, sample collection and
r' ti preservation techniques, and of laboratory analytical
rtiH1 i techniques, record keeping and data reporting procedures .
--- The self-monitoring program being conducted by the Mill
- was shown to be operating according to applicable standards .
Flow measurement and sampling procedures were acceptable .
The Performance Audit Inspection (PAI) rating for this
facility is "A" . A PAI rating sheet is attached for your
review.
a 4 INTERCHANGE BUILOINO,59 WOODFIN PLACE,ASHEVILLE,NC 28 801-241 4
PHONE [phone] FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-SO RECYCLED/10q POST-CONSUMER PAPER

Mr. Derric Brown
August 11, 1998
Page Two
A. FIELD EVALUATION
1 . FLOW MEASUREMENT: Flow is measured prior to the
001 covered discharge structure using an eight
foot free flow Parshall flume in conjunction with
a Fischer & Porter Ultra-sonic flow meter with
Foxboro recorder and totalizer.
2 . The effluent sampling devices for outfall 001 are
three ISCO model 3710 composite samplers with
refrigeration. Proportional composite samples are
collected for every 250, 000 gallons of effluent .
one of the samplers is used for special studies .
Sampler tubing is changed on a monthly basis .
The two influent composite samplers are both ISCO
model 3170 with refrigeration. The temperature in
each of the samplers was 40C or less .'
3 . RECORD MAINTENANCE: Records and data handling
procedures appear to be satisfactory and
consistent with self-monitoring requirements
contained in the NPDES Permit .
4 . PERMIT VERIFICATION: The Permit was issued with
an effective date of January 1, 1997 .
B. LABORATORY EVALUATION
1 . FACILITIES AND EQUIPMENT: Laboratory space is
adequate for testing performed for the facility.
All equipment is well maintained. The lab
routinely conducts NPDES testing for temperature,
ammonia nitrogen, pH, five-day biochemical oxygen
demand (BODS) , dissolved oxygen, total suspended
solids, total dissolved solids, total solids,
chemical oxygen demand (COD) , total hardness,
color, and settleable matter. Burlington Labs,
performs testing for effluent toxicity. Dioxin
analysis is performed at Quanterra. Zinc,
hardness, nitrite, nitrate, fecal coliform and TKN -
analyses are performed at Pace Labs in Charlotte,
NC. AOX is performed by Galbriath in Knoxville,
Tennessee. Mercury by Brooks Rand.

Mr. Derric Brown
August 11, 1998
Page Three
2 . METHODOLOGY: All testing procedures are based
upon Standard Methods 18th edition. Any concerns
are discussed in detail in the attached ON-SITE
INSPECTION REPORT completed by Mr. Francies as
part of the Laboratory Certification Program.
3 . RECORDS KEEPING: Laboratory record keeping
generally was appropriate and consistent with good
laboratory practice .
Should you have any questions concerning the Report,
please do not hesitate to contact me at 251-6208 . The
assistance provided to me by all Mill personnel involved
during the inspection was greatly appreciated.
Si cere1
D. Keith Hayne
Environmental Specialist
Attachment
xc : Roger Pfaff, EPA
Gary Francies

United States Environmental Protection Agency Form Approvev,
Washington, D.C.20460 OMB No. 2040-0003 '
PA NPDES Compliance Inspection:Report Approval Expires 7-31-85
-Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type inspector Fac Type
1 IN 1 215 I 3 1 NC0000272 11 12 98/07/03 17 18 Iq I 19 20 �z
u u Remarks u u u
I I I I I I I I - I I I I I I I I I I I I I I I I I I I
31 Reserved Facility Evaluation Rating BI QA
J Reserved
67 LI 69 70 J 71 IonI 72 ) ] 73 LJ 74 75L LL 80
Section B:Facility Date
Name and Location of Facility Inspected Entry Time Permit Effective Date
Champion International Corp. 9:00 am 970101
Canton Mill
Canton, Haywood County Exit Time/Date Permit Expiration Date
3:30 pm 011130
' Name(s)of On-Site Representative(s)/Title(s) Phone No(s)
Derric Brown - Environ. Supervisor 704-646-2318
Name,Address of Responsible Official Title
Mr. William Manzer Vice-PresidentlOperations Mgr.
PO Box 10-C
Canton, NC 28716 Phone No. Contacted
No
Section C:Areas Evaluated During Inspection CODES S---Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated/Not applicable
$ Permit $ Flow Measurement qS
Pretreatment $. Operations &MaintenanceRecords/Reports $ Laboratory Compliance Schedules $ Sludge Disposal
SFacility Site Review E$ Effluent/Receiving Waters Self-Monitoring Program Other:
Section D:Summary of Findings/Co; menfs (Attach additional sheets if necessary)
Effluent Data ARO Mill Permit Limits(Daily Avg/Mon Avg)
BOD, 6.1 mg/I 4.26 mg/I 30.0 mg/I - 45.0 mg/I
TSS — 6 mg/I 7 mg/I 30.0 mg/I - 45.0 mg/I
TDS — 1400 mg/I 1280 mg/I
TR — 1400 mg/I 1304 mgA
NH, — 0.60 mg/I 0.63 mg/I
Fecal Coliform 12/100 ml 13/100 ml
Three of the four aeration basins were in operation, with the other one in the digester mode. The remainder of the plant was in full operation. The Parshall
Flume/flow meter is calibrated quarterly. Effluent flow at the time of sampling was26.3 MGD. Maintenance records are kept by computer in the treatment
•• maintenance shop. Effluent samples were split with the facility on July 22. All sampler refrigeration units were operating at or below the proper temperature.Twc
of the four belt presses were in operation.
Name(s)and Signature(s) Inspector(s) Agency/Office/Telephone Date i-
D. Keith Haynes
DWQ/ARO 828-251-6208
Signatur Rev' wer Date
DWQ/ARO 828-251-6208
' Regulatory Office Use Only C
Action Taken Date Compliance Status
13 Noncompliance
Compliance

IAO
State of North Carolina
MICHAEL F. EASLEY Department of Justice
ATTORNEY GENERAL P.O:BOX 629 REPLY TO: .
RALEIGH Environmental Division
[e-mail]
27602-0629 Telephone:919nl6-6600
Fax:919nl6-6767
July 23, 1998 _
Mr. Barry Turner ��- )
Deputy Attorney General ,.
425 Fifth Avenue North
Nashville, Tennessee 37243-0495
RE: Joint Watershed Advisory Committee
Dear Barry:
Pursuant to Paragraph 32 of the Settlement Agreement Regarding 1996 Water Quality Color
Variance and 1996 NPDES Permit Issued to Champion International Corporation,North Carolina -.
and Tennessee are required to establish a Joint Watershed Advisory Committee. The agreement is
silent as to the details for setting up and operating the Committee, but the goal is to "foster joint
planning and public input on decisions affecting the Pigeon River."
Both states need to establish the initial requirements for membership and operation, and it
appears you and I are in the best positions to move the committee along legally. Forrest Westall,
Paul Davis, Mike McGhee and others have had a general discussion of this on May 12, 1998; and
at that time North Carolina suggested several principles to follow. They may be summarized as
follows:
North Carolina and Tennessee should appoint three or four members each (with
concurrent or overlapping service periods), with one of each State's appointments
being a co-chair of the Committee (a partnership in direction). The criteria for
appointment would have to be established, but would likely include folks that live
in the basin and that have some special local.interest or leadership role (political,
educational, or interest group affiliation). Staffing support of the Committee would
have to be agreed to by the two states. Since the basic objective of this section of the
Agreement seems to be to foster community interest in the River and the
management decisions affecting the River, it is anticipated that the Committee, after
completing its initial meetings and organization efforts,would develop its own path.

Mr. Barry Turner
Page 2
July 23, 1998
It would initiate its own agenda for interaction with federal, State and local agencies
having land and water management responsibilities within the watershed. The
Committee would develop its own "independent" view of these decisions or
proposals and would comment directly to those agencies. It should have broad
latitude to determine its role.
The purpose of this letter is to initiate a process under which the two states can agree on
Committee membership criteria and any staffing or logistics issues. Appointments may then be
made and the Committee charged with going forward as it determines appropriate.
Please consider this proposal and call me to discuss, at your convenience. I look forward to
working with you again on this matter. With best wishes, I am
Very truly yours,�
Daniel C. Oakley
Senior Deputy Attorney General
DCO/dw
cc: Secretary Wayne McDevitt
Preston Howard
.-Forrest Westall
wp26431
@C,
s..

f- c
't NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
�pn DIVISION OF WATER QUALITY
July 22, 1998
CDER 198
h Mr. John J. Pryately 0
Champion International WWTP Lab.
^+J/AMES B.NUNF7R.
P.O. Box 4000
{=- b
�.coveRNOR. Canton, NC 28716
.r SUBJECT: Deleting Parameter(s) from Certificate �shE4�oRATo 0
r" cD�n: RESIDUE, SETTLEABLE �FRE�jOSf0
-
Dear Mr. Pryately:
Per your request we are deleting the above parameters from your certificate.
Enclosed is an updated certificate reflecting this change which is effective on
July 22, 1998.
If you have questions or we can be of any further assistance, please contact us at
[phone].
sr s
E _ t
}' - - Sincerely,
Bernard E. Sims, Ph.D.
_ Chief, Laboratory Section .
BES:mod
- - Enclosure
_ — cc James W. Meyer
Gary W. Francies
m Marilyn O. Deaver
W
LABORATORY SECTION
4405 REEDY CREEK ROAD,RALEIGH,NORTH CAROLINA 27607-6445
_ PHONE 9I9-733-300B FAX[phone]
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Attachment I
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Lab Name: Champion International W WTP Lab. Certificate Number. 198
Address: P.O.Box 4000 Effective Date: 1/1196
Canton,NC 28716 Expiration Date: 12/81/98
Date of Last Amendment: 7/22I98
The above named laboratory,having duly met the requirements of 15A NCAC 2H.0800,is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANIC
BOD
COD
COLOR,PLATINUM COBALT _
CONDUCTIVITY
AMMONIA NITROGEN
pH
RESIDUE,TOTAL
RESIDUE,DISSOLVED 180 C
! RESIDUE,SUSPENDED
This certification requires maintance of an acceptable quellty assurance program,use of approved methodology.and safisfactory performance on evaluation samples. Laboratories ere
subject to civil pena8ies andtor decertificetlon for infractions as set foM in 15A NCAC 2H.0807.

: r NORTH CAROLINA DEPARTMENT OF '
" ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
August 11, 1998
Mr. Derric Brown
1RE3 B.HUriTJ-"
N.
,;�„E,:r„R.•. '_-_?� Champion International Corporation
Canton Mill
.. Post Office Box C-10
Canton, North Carolina - 28716
.e
•c. �E.DEvrrt'
Subject : Performance Audit Inspection
PAI Grade: "All
Canton Mill WWTP
NPDES Permit No. NC0o00272
Haywood County
'Dear Mr. Brown:
On July 2, 1998 Mr. Gary Francies of the Division' s
1' Regional Office Laboratory and I conducted a Performance
,_Audit Inspection on Champion' s Canton Mill wastewater
"treatment program. Personnel present from the Mill during
'the ' inspection were: Derric Brown, Chad Salisbury, John
Pryately,. Melanie Hager, and Mike Cody. . It should be noted
+n
J that ' the 'effluent samples were collected on July 22, 1998 .
The purpose of this inspection was to determine the
'quality of the self-monitoring program being conducted by
'the Mill and assess the reliability of its reported data.
The inspection consisted of evaluation of the following:
flow monitoring equipment, sample collection and
', t,� .•; preservation techniques, and of laboratory analytical
techniques, record keeping and data reporting procedures.
The self-monitoring program being conducted by the Mill
_ - _ was shown to be operating according to applicable standards .
Flow measurement and sampling procedures were acceptable.
_ The Performance Audit Inspection (PAI) rating for this
facility is 'IA" . A PAI rating sheet is attached for your
review.
INTERCHANGE BUILDING.39 WOOOFIN PLACE,ASHEVILLE,NC 28801-2414
PHON9028-231-6208 FAX[phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER-30%RECYCLED/10%POST-CONSUMER PAPER

s
Mr. Derric Brown
August 11, 1998 s
Page Two
A. FIELD EVALUATION "
1. FLOW MEASUREMENT:. Flow .is measured prior, t' the
001 covered discharge structure-using an eigtit'a";;.A
foot free flow Parshall flume in conjunction with.,
a Fischer & Porter Ultra-sonic flow meter with
Foxboro recorder and totalizer.
2 . The effluent sampling devices for outfall 001 are
three ISCO model 3710 composite samplers with
refrigeration. Proportional composite samples are
collected for 'every 250, 000 gallons of effluent.
One of the samplers is used for special studies.
Sampler tubing is changed on a monthly basis.
The two influent composite samplers are both ISCO
model 3170 with refrigeration. The temperature in
each of the samplers was 40C or less .
3 . RECORD MAINTENANCE: Records and data handling
procedures- appear' to .be .satisfactory and
consistent with self-monitoring requirements
?contained in the NPDES- Permit.
4 . PERMIT VERIFICATION: The .Permit was issued with
an effective date of January 1, 1997.
B. LABORATORY EVALUATION
1. FACILITIES AND EQUIPMENT: Laboratory space is
adequate for testing performed for the facility.
All equipment is well maintained. The lab
routinely conducts NPDES testing for temperature,
ammonia nitrogen, - pH, five-day biochemical oxygen
demand (SODS) , dissolved oxygen, total suspended
solids, total dissolved solids, total solids,
chemical oxygen demand (COD) , total hardness,
color, and settleable matter. Burlington Labs,
performs testing for effluent toxicity. Dioxin
analysis is performed at Quanterra. ' Zinc,
hardness, nitrite, nitrate, fecal coliform and TKN—
analyses are performed at Pace Labs in Charlotte,
NC. AOX is performed by Galbriath in Knoxville,
Tennessee. Mercury by Brooks Rand. '

Mr. Derric Brown
August 11, ' 1998
Page Three
2 . METHODOLOGY: All testing procedures are based
upon Standard Methods 18th edition. Any concerns
are discussed in detail in the attached ON-SITE
INSPECTION REPORT completed by Mr. Francies as
part of the Laboratory Certification Program.
3 . RECORDS KEEPING: Laboratory record keeping
generally was appropriate and consistent with good
laboratory practice.
- Should you have any questions concerning the Report,
please do not hesitate to contact me at 251-6208 . The
assistance provided to me by all Mill personnel involved
during the inspection was greatly appreciated.
Si cerel.
D. Keith Hayne
Environmental Specialist
Attachment
xc: Roger Pfaff, EPA
Gary Francies
I
_ I

United States Environmental Protection Agency Form Approvea'�
Washington, D.C.20460 OMB No.2040-0003
PA NPDES Compliance Inspection-Report Approval Expires 7-31.85
—Section A:National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 215 3 1 NC0000272 11 12 98/07/03 117 18 u 19 U 20IJ
Remarks
I I I I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I I I
r' Reserved Facility Evaluation Rating _ _ BI CA Reserved 66
67 69 !70L� 71 72 at 73 LLJ74 - 75 80
Section B: Facility Date
Name and Location of Facility Inspected Entry Time Permit Effective Date
Champion International Corp. 9:00 am 970101
Canton Mill
Canton, Haywood County .. Exit Time/Date Permit Expiration Date
3:30 pm 011130
Name(s)of On-Site Repmsentative(s)/Title(s) Phone No(s)
Derric Brown- Environ_Supervisor 704-646-2318
Name,Address of Responsible Official _ Title
Mr.William Manzer Vice-President/Operations Mgr.
PO Box 10-C
Canton, NC 28716 Phone No. Contacted
11 No
Section C:Areas Evaluated During Inspection - CODES yr S-Satisfactory M-Marginal U-Unsatisfactory N-Not evaluated(Not applicabl
$ Permit $ Flow Measurement S Pretreatment $ Operations &Maintenant
$ Records/Reports Laboratory :3. $ Compliance Schedules S Sludge Disposal
$ Facility Site Review - $ Effluent/Receiving Waters $ Self-Monitoring Program Other.
Section D:Summary of Findings/Comments (Attach additional sheets if necessary) ,
Effluent Data ARO Mill Permit Limits(Daily Ave/Mon Avg)
BODs - 6.1 mgA 4.26 mgA 30.0 mg/I - 45.0 mgA
T55 - 6 mgA 7 mg/I 30.0 mgA - 45.0 mgA
TDS - 1400 mgA 1280 mg/1
TR - 1400 mg/I 1304 mgA
NH, - 0.60 mgA 0.63 mgA
Fecal Coliform 12/100 ml 13/100 ml '
Three of the four aeration basins were in operation, with the other one in the digester mode. The remainder of the plant was in full operation.The Parshall
- Flume/flow meter is calibrated quarterly. Effluent Sow at the time of sampling was 26.3 MGD. Maintenance records are kept by computer in the treatment
maintenance shop. Effluent samples were split with the facility on July 22. All sampler refrigeration units were operating at or below the proper temperature.Tv
of the four belt presses were in operation.
Name(s)and Signatur s) Inspector(s) Agency/Office/relephone Date .tj.
D. Keith Haynes _
DWQ/ARO 828-251-6208
Signatur Rev' wer Agency/Office Date -
DWQ/ARO 828-251-6208 8
Regulatory Office Use Only 14
Action Taken Date Compliance Status
Noncompliance
Compliance

ALT 71.9% NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
■ B. TJ E"R DIVISION OF WATER QUALITY
JAMES B.HUNJR.,GOVERNOR
WAYNE MCDEYITT,SECRETARY
A.FRESTON HOWARD,JR.,P.E.,DIRECTOR
July 16, 1998 41
198 ��/� lop
Mr.Mr. John J. Pryately
Champion International WWrP Lab:
P.O. Box 4000
Canton, NC 28716
SUBJECT: Laboratory Certification Maintenance Inspection
.s
Dear Mr. Pryately:
Enclosed is a report for the inspection performed on July 2, 1998 by Mr. Gary W.
Francies. A response is not required if there were.no violations cited. A response is not
required for comments or recommendations unless soecifically requested. We appreciate
the fine job you and your staff are doing. As a certification requirement, your laboratory
must continue to carryout the requirements set forth in 15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from
this office. Thank you for your cooperation during the inspection. Please contact us at
919-733-3908, if you have questions or need additional information.
Sincerely,
' /�/
Gv" v( ��
James W. Meyer
Laboratory Section
Enclosure
cc: —Gary W. Francies
Marilyn O. Deaver
"k
= 1
\i LABORATORY SECTION
4405 REEDY CREEK ROAD,RALEIGH,NORTH CAROLINA 27607-644S
PHOHE919-733-3908 FAX [phone]
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ON- SITE INSPECTION REPORT
LABORATORY NAME: Champion International Corp. WWTP Laboratory
ADDRESS : P. O. Box 4000
Canton, NC 28716
CERTIFICATE #: 198
DATE OF INSPECTION: 7/2/98
TYPE OF INSPECTION: Maintenance
EVALUATOR(S) : Gary Francies
t LOCAL PERSON(S) CONTACTED: John Pryately, Derric Brown
3
Mike Cody, Chad Salisbury, Heather Hager
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the
requirements of 15A NCAC 2H . 0800 for the analysis of environmental
samples .
II. GENERAL COMMENTS:
The laboratory is spacious and well equipped.- All equipment is well
maintained. Two new desiccators have been obtained. Records are well
kept and most data appeared accurate. The lab analyzes quarterly
performance evaluation samples for all parameters . Since the last
inspection, control limits have been set for duplicate sample analyses
for all parameters . Also, most of the forms, logs, and bench sheets
have been updated. The staff has done an excellent job of maintaining
the laboratory certification program.
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
COLOR
COMMENT: The signal reading on the low standard is not sufficiently
greater than the blank ( . 002 absorbance units obtained on a 10 c.u.
standard) . This makes the lower limit of detection or reporting limit
questionable due to inviable signal readings . We request a reply to
this comment.
REQUIREMENT: The lab must obtain a signal in which the constituent
concentration in reagent water is 2 (1 . 645) s above the mean of blank
analyses (Lower Limit of Detection) . The constituent concentration
that produces a signal sufficiently greater than the blank, that it
can be detected within specified limits, by good laboratories, during
routine operating conditions, is the Limit of Quantitation. Typically
it is the concentration that produces a signal 10s above the reagent
water blank signal. In most cases, this requires an absorbance value

Page 2
greater than .005 units, preferably greater than . 010 units . Ref:
Standard Methods, 18th Edition - Method 1010 C. And 1030 E .
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory
bench sheets and contract lab reports to DMRs submitted to this
Division. Data were reviewed for these months : March, April, and May
1998 . No errors were noted. It appears the facility is doing a good
job of accurately transcribing data .
V. CONCLUSION:
This laboratory is doing a good job overall . The staff is
_ congratulated for doing an excellent job of maintaining the laboratory
program.
Report prepared by: Gary Francies Date : 7/6/98
;a'

August 3, 2001
Memorandum
Subject: Additional Color Removal Opportunities, Blue Ridge Paper's (BRP) Canton,NC
Bleached Kraft Paper Mill, 2001 NPDES Permit Renewal
From: Technology Review Workgroup
Donald Anderson, Chair, EPA
Karrie-Jo Shell, EPA Region IV
Paul Davis, Tennessee
David McKinney,Tennessee
David Goodrich, North Carolina
Forrest Westall,North Carolina
To: North Carolina Division of Water Quality and the NC Environmental
Management Commission's NPDES Sub-Committee
In accordance with the 1997 NPDES Permit Agreement for the Canton Mill, the Technology
Review Workgroup (TRW) has examined the progress made at the facility in relation to reducing
the color content of the Mill's effluent and the potential for additional color reduction at the
plant. The focus of this examination includes a review of reports submitted by Blue Ridge Paper
(BRP), a visit to the Mill on March 14, 2001 by EPA's Tech Team, consultation among the EPA
Tech Team and the Workgroup's members, consideration of the separate Mill evaluation and
Licbergott report (Bleach Environmental Process Evaluation and Report) dated June 8, 2001, and
comments from environmental interest and other stakeholder groups (including Clean Water
Fund of North Carolina, American Canoe Association), and EPA's Tech Team Memorandum on
this subject dated July 25, 2001.
It is the finding of the TRW that the EPA Tech Team Memorandum represents an appropriate
evaluation of the potential for additional color reduction at the Mill over the next permit cycle
(December 1, 2001 through November 2006). As a result of this finding, the TRW includes with
this memorandum a copy of the subject report for use by the Division of Water Quality and the
Environmental Management Commission's NPDES Sub-Committee as guidance for the
development of the effluent limitations for color and related special conditions of the draft
NPDES Permit renewal and North Carolina's Effluent Color Variance.
As the purpose of the TRW is to provide a review of the possible technology options available to
the Mill to further reduce the color discharge to the Pigeon River, the EPA Tech Team

Memorandum provides a solid foundation for developing specific conditions and limitations for
the Mill's next NPDES permit. In making this point, the TRW recognizes that not all of the
options outlined in the Tech Team Memorandum can be predicted to achieve specific color
reductions with complete accuracy. Consequently the Memorandum provides estimates of
possible reductions and in some cases a range of likely color reduction from the application of
specific technologies. The TRW also notes that several individuals and organizations provided
alternate estimates to the EPA Tech Team. Again, the difference between"technological
likelihood" and "regulatory limit" is an important distinction that must be considered in
"enforcing"permit conditions. When considering the potential color reduction options provided
in the Tech Team Memorandum in developing a draft NPDES Permit and Color Variance, the
TRW recommends that the following points be considered:
1. The highest priority for additional color reduction moving toward achieving the North
Carolina water quality standard for color rests with additional in-mill improvements,
particularly considering the success already achieved by continuing improvements in leak
and spill prevention and control (Best Management Practices—BMPs) and process
modifications. End-of-pipe technologies reflect significant economic, technical, and non-
water quality environmental impact problems at this mill.
2. The Tech Team Memorandum identifies by degree the "certainty" of three possible
categories of options that the Mill could undertake to further reduce color in the mill's
effluent. The "regulatory risk" of being able to achieve the reductions under these
categories increases as the certainty decreases. Any regulatory limitations/conditions
need to reflect this consideration.
3. The TRW recommends that the options identified in the Tech Team Memorandum as
having the "highest certainty"(i.e., improvements in reliability of the existing bleach
filtrate recycle system (BFR) and leak and spill prevention and control -BMPs, and
process optimization) should be implemented first and the permit/variance should reflect
a very specific level of reduction. The time necessary for the Mill to implement these
"primary" options should realistically reflect the ability of BRP to design, fund and install
the outlined options to achieve these color reductions. The TRW recommends up to two
years as a reasonable period of time for implementing these options. In determining the
actual color reduction"limit"to be placed in the permit the recommendations of the Tech
Team Memorandum should form the general basis of that decision. It may be appropriate
to consider the second tier of options identified in item 4 in setting the limitation
applicable to the implementation of the"highest certainty"options.
4. The process improvement options needing further study and identified as having
"reasonable certainty"of success (second stage oxygen delignification on the softwood
fiber line; ozone addition to chlorine dioxide bleaching on the hardwood fiber line)
should be incorporated in the permit/variance as an additional increment of color
reduction to be demonstrated by the Mill. BRP should be required to evaluate the
technologies identified by the Tech Team and to develop an implementation plan that
would either utilize these technologies or identify other options that would result in
similar increments of color reduction. Because the Tech Team could not estimate at this
time with high certainty the color reduction achievable by these options, the

permit/variance needs to include a mechanism of application similar to that used in the
1997 Permit Agreement. That procedure involves review of a proposed plan from the
Mill, approval of the plan, a schedule for placing selected option(s) into service, a period
of demonstration of the effectiveness of the option(s), followed finally by setting
limitations considering the"target"reduction range but consistent with the actual effluent
color loadings achieved (see paragraph 6). The TRW recommends the option(s) selected
should be installed, operational, and appropriate limits developed within the next permit
term.
5. The potential additional color reduction in treatment of the Chloride Reduction Process
(CRP) purge stream was considered as an option with"lowest certainty" of success.
While this conclusion is supported by the preliminary treatability study already attempted
by BRP to remove color from this waste stream, the TRW recommends that the
permit/variance include requirements that the Mill continue to evaluate all technologies
that might result in significant reduction of this source of color in the Mill's sewers.fiffi—EN
rpproacMereristdirecteditEUcuriDgiwhateve aaddirionalrreductions;ate possible based-on3i
ra idemonstratedtechnologythat works :one. otential,technology in[the.L'iebergotty,
report-,was suggested).and,-can-bezeconomicallynayplied tmthis=color source Full-scale
implementation of'the results of this evaluation should logically follow those options
considered to have higher certainty of success.
6. It should remain the objective of the regulatory agency to monitor, evaluate and apply the
color reduction performance achieved at the Mill from application of pollution prevention
process technologies and BMPs. As the color reduction efforts outlined in the
permit/variance are put into operation at the Mill, the actual performance as measured by
daily effluent color loadings should be statistically evaluated to develop appropriate
limitations for the Mill including a long term average and a revised maximum monthly
average which captures actual variability. The Division of Water Quality should apply
those limitations under the permit through formal notification.
7. The permit/variance should continue to require BRP to report on or identify any
"breakthrough" color reduction technologies developed at the Mill or that become
available within the industry or the research community.
8. To the extent possible, the TRW recommends to North Carolina that the in-stream
compliance point for color be moved as close to the point of discharge as possible (e.g.,
Fiberville Bridge). This compliance point must be related to the end-of-pipe color
loadings to be achieved by the technologies identified in this recommendation or
alternative technologies identified by the Mill as reflected in limitations included in the
permit/variance. The TRW further recommends that the compliance point ultimately be
moved to the Mill's end-of-pipe discharge point to the Pigeon River, and the format of
the limitations also be reviewed as it relates to capturing effluent variability.
9. The TRW believes it is important for the re-issued permit/variance to require a formal
evaluation by BRP of the Mill's efforts during this cycle (2001-2006) to comply with
North Carolina's water quality standard for color. This evaluation should be an important
part of the reporting requirements of the permit/variance.
10. The role of the TRW should continue through the next permit cycle, the re-issuance
process in 2006, and until the Mill has achieved compliance with North Carolina's in-

stream color standard (a variance is no longer needed). As a"clearinghouse" for the
reports and information submitted by BRP under the reissued permit, the TRW provides
an objective view that is useful to the two States, the parties to the 1997 Permit
Agreement, and other stakeholders. This advisory role is important to fostering the
cooperative completion of the color reduction process at the Mill.
In presenting these recommendations to the Division of Water Quality and the Environmental
Management Commission's NPDES Sub-Committee, the TRW wishes to acknowledge the
excellent success achieved since the 1997 Settlement Agreement and the continued effort ofBRP
to improve on this excellent record. The substantial decrease in effluent color since the 1997
Settlement Agreement to the current levels of color observed day to day both at the Canton Mill
and downstream in Tennessee is a testament to the efforts of everyone involved in this process.
While the Canton Mill is among world leaders in the pulp and paper industry as measured by the
quality of its treated effluent, the commitment of the Company and the continued interest and
participation in this process by the regulatory agencies, stakeholder public and environmental
interest groups, and the general public makes additional improvement possible, ultimately
leading to elimination of the variance.
If there are questions concerning this recommendation, please feel free to contact the TRW.
Attachment: Memorandum from EPA Tech Team to the TRW, entitled, Additional Color
Removal Technologies and Their Economic Impacts on Blue Ridge Paper
Products, Canton,NC, dated July 25, 2001

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON,D.C.20460
'SgIeD sN 'le
A
MEMORANDUM
DATE: July 25, 2001
SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue
Ridge Paper Products, Canton,NC
FROM: EPA Tech Team'
TO: Technology Review Workgroup
Purpose of this Analysis
As required by the 1997 Settlement Agreement, this memorandum presents a summary of an
analysis of available technologies that may be employed to further reduce color discharges from
the Blue Ridge Paper Products, Inc. (Blue Ridge) mill in Canton, NC. The analysis also includes
a summary of the economic impact("gross margin test") of the cost of implementing identified
color reduction technologies.
Members of the Tech Team visited the Canton mill on March 14, 2001 to observe and gather
information and data on the status of technologies implemented and color discharges at the mill
since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered
from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical
and financial data. This final memorandum is based on the May 4, 2001 preliminary draft
memorandum, and revisions to the July 10, 2001 draft final memorandum, based on a review of
Blue Ridge's comments, the June 8, 2001 Bleach Environmental Process Evaluation and Report
(BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group, Inc,
and additional comments from the Clean Water Fund of North Carolina, and the States of
Tennessee and North Carolina. This memorandum presents to the Technology Review
' EPA Tech Team is comprised of--Mark Perez,EPA/EAD;Karrie-Jo Shell,EPA Region 4;Don Anderson,
EPA/EAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,subcontractor to
ERG.

Workgroup (TRW) process improvements evaluated by the Tech Team and considered to be
available technologies and briefly addresses relevant technologies evaluated in the BEPER.
Background and History
Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton,NC, which it
purchased from Champion International Corporation in May 1999. Operations at the mill began
in 1908, but the mill has been extensively modernized, most recently in 1993. The mill currently
operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking,
pulp from each line is further delignified in single-stage oxygen delignifrcation systems installed
in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence; pine pulp is bleached
with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery
(BFRTM)process, developed by Champion. A portion of the hardwood line bleach plant Eo-
stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated
paper including offset, tablet and envelope grades. The mill also produces 281,000 tons per year
of bleached paperboard used for liquid packaging and paper cups, including FDA approved
grades for milk and juice cartons. Since November 2000, pulp production has been reduced by
approximately 30 percent as the result of a major project to upgrade the No. 19 bleached
paperboard machine.
Continued Color Reduction Opportunities Since the 1997 NPDES Permit
The Canton Mill's 1997 NPDES permit included a schedule requiring continued study,
evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge
submitted a series of reports to the NC Department of Environment and Natural Resources,
Division of Water Quality, evaluating the performance of the BFRTm process, end-of-pipe color
reduction technologies, and practices for minimizing color losses from manufacturing processes.
Since 1997 Blue Ridge has:
• continued full-scale operation of BFR for the pine line;
• concluded that full-scale BFR is not feasible for the hardwood line, but
implemented partial reuse of a portion of the Eo-stage filtrate as an effective
color-reduction approach;
• identified and implemented several practices for reducing losses of highly-colored
black liquor from manufacturing processes; and
• evaluated 16 end-of-pipe color removal technologies and determined that they
were presently economically and/or technically infeasible for the Canton mill.

Page 3
Process Improvements Analyzed by the Tech Team
The Tech Team identified five mill improvements capable of further reducing the discharge of
color in the mill effluent. For each of these improvements, technical feasibility, capital and
operating costs, and potential color reduction were reviewed. Each improvement can be
implemented independently of the others or in any combination. The costs incurred to
implement the improvements are additive,however separate evaluations are necessary to
accurately estimate the associated color reduction achieved by implementing any combination of
improvements. End-of-pipe color treatment technologies (e.g., chemically assisted clarification
with sludge dewatering and disposal)typically require initial capital investment and ongoing
operating expenses,not savings, and are likely to incur non-water quality environmental impacts.
For this reason, the Tech Team focused on pollution prevention approaches that offer the
potential to be more cost-effective: color reduction in low flow, highly color-concentrated
wastestreams, through manufacturing process changes or in-process treatment.
The first two process improvements, discussed below (improvements in BFR reliability and leak
and spill prevention and control -Best Management Practices (BMPs)), are improvements which
the Tech Team concludes offer the highest certainty for technical feasibility and color reduction.
Blue Ridge also identified these technologies as feasible color reduction opportunities that will
be implemented, but differed from the color reduction estimates included in this memorandum.
The next two process improvements (ozone addition to an existing chlorine dioxide bleaching
stage on the hardwood fiber line; adding a second stage to the current oxygen delignification
system on the softwood fiber line) also were evaluated by Liebergott, et. al., as feasible color
reduction opportunities. Additional technical evaluation and/or laboratory testing would be
appropriate to reliably determine the technical details of how to incorporate these processes into
the existing fiber lines and to more accurately predict their achievable color reduction, and the
relationship of these technologies to BFR. Additional analyses would be appropriate to
determine the most cost-effective design and the most economically feasible schedule for
implementing one or both of these improvements.
The fifth process improvement, color treatment for the chloride removal process (CRP)purge
stream (one of the two key components of the BFR process), has the potential for additional
color reduction. However, based upon initial bench-scale treatability studies by Blue Ridge,
further study of additional color treatment technologies is necessary. Process optimization on
both the hardwood and softwood fiber lines, as recommended in the BEPER, is anticipated to

Page 4
provide additional color reduction and is identified as the sixth process improvement. It was
concluded that the process optimization option was among those with the highest certainty for
technical feasibility and color reduction.
All color reductions resulting from the mill improvements are estimates based solely on available
data and information. While the Tech Team has concluded that these technologies would reduce
the color discharge from the Canton mill,there is a lack of directly comparable operating
experience with these technologies in other bleached papergrade kraft mills that can be used to
develop precise predictions of the extent of the color reduction benefits.
The BEPER evaluated additional in-process technology options for color discharge reduction
potential, including the implementation of a hot pressurized peroxide-enhanced extraction stage
in both fiber line bleach plants. At this time, the Tech Team does not have sufficient information
to confirm the applicability of this technology at the Canton mill nor relevant data to predict its
potential color discharge reduction capabilities. Therefore,while this memorandum does not
address this technology option, it may be feasible for implementation by Blue Ridge and
contribute to reducing color. In addition,the Tech Team did not analyze nor did the BEPER
recommend a Totally Chlorine-Free (TCF) bleaching option because of the high cost of this
technology and the lack of experience in producing and successfully marketing products made
by Blue Ridge at the Canton mill.
1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal
Process (MRP). Blue Ridge has found that this process element has been more challenging and
expensive to maintain than originally planned. The target BFR recycle rate (percent closure) for
the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and
metallurgy problems (e.g., erosion of multi-media filtration tank lining) in the MRP, however,
the pine line closure has averaged only 74 percent from October 1998 to the present. Blue Ridge
has undertaken improvements to the MRP system in order to maintain the process closure rate
and increase operating time. Improvements include rebuilding piping and valves, and changing
construction materials and metallurgy to better withstand the chemical and physical stress
experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80
percent, annual average final effluent color discharge will be reduced by 1,000 to 1,200 lbs/day.
At this time, the Tech Team has no means of making an alternative quantitative prediction of
final effluent color reduction to compare to the Blue Ridge estimate.

Page 5
2. Improved black liquor leak&spill collection and control (BMPs). The Canton mill has an
extensive spill recovery system. Sumps in this system, including one sump added in the court
yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped
with pumps that are activated automatically when sensors detect wastewaters with high
conductivity and color. High conductivity material is routed to the recovery system. Further
improvements to the black liquor collection system include:
• continuous improvement of operating practices so more leaks and spills are
recovered rather than discharged to sewer;
• further improvement in preparation for planned outages to maximize capture of
tank clean-out waste and routing to recovery;
• further reducing clean water that continuously runs into sewers to prevent dilution
of smaller spills and facilitate recovery of highly colored wastewaters; and
• further improvement in the equipment used for handling of knots rejects to
prevent black liquor leaks into the recovery sumps.
The plot below shows the color of wastewater treatment influent at the Canton mill. The
variability of influent color discharge to wastewater treatment is attributed to color discharge
peaks that represent, in part, unplanned spills or leaks discharged to sewers or intentional
diversions of highly-colored black liquor or other color sources routed to sewers during mill
equipment shutdowns.
100
kg/t
Figure 1
75 Daily color at influent to W WTP for Canton
so
25
0 30 60 90 120 150 180

Page 6
Due to the nature of the manufacturing processes and practical equipment operation and
reliability, all spills and color losses to sewers cannot be fully anticipated, predicted, and
completely contained. However, a comparison of the variability of the Canton mill influent color
data to available primary influent color data at another bleached papergrade kraft mill indicate
that a detailed review of the spill prevention and recovery system at the Canton mill (by mill
staff or external consultants), including involvement by the mill operators, can further uncover
the causes of and better quantify black liquor losses and other color sources that can be avoided
or recovered. This will result in an overall reduction in color discharge,both in long-term
average and variability. Through improved planning of mill equipment shutdowns, continuing
efforts to minimize process operation variability, and increased recovery of highly-colored leaks
and spills, discharges of highly colored material to the wastewater treatment system can be
reduced more consistently below existing levels.
Further reducing peaks in color discharges within the mill and preventing highly colored flows
from reaching the wastewater treatment system will further reduce the variability of color
discharges from the wastewater treatment system to the Pigeon River. For example, limiting the
color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to
improve the mill's BhV system and process operations would reduce the color loadings from
mill processes to the end-of-pipe wastewater treatment system by more than 8,000 lb/day. The
Canton mill operated under this primary clarifier influent color threshold approximately 74
percent of 2000, excluding November through December 2000. This time period was considered
not to be representative of steady-state operations because of the reduced pulp production
resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average
reduction of 45 percent across this wastewater treatment system for"brown" color derived from
black liquor, this would result in a minimum decrease of 4,400 lb/day in the average final
effluent color load.
Clean water, such as packing gland water,presently flows in several sewers with recovery
sumps. These colorless streams dilute other colored wastestreams, such as small black liquor
leaks and spills, to the point where the in-stream conductivity is too low to trigger recovery. By
eliminating clean water streams or diverting them away from sewers that collect black liquor
leaks and spills, wastewater streams with elevated color can be recovered more readily, resulting
in a reduction in color discharge to the end-of-pipe wastewater treatment system. Also, the
unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can
be recovered.

Page 7
At this time, the Tech Team has no basis for determining an accurate correlation between
unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill
Environmental Performance Update presented by Blue Ridge during the March 14, 2001 Tech
Team Canton mill visit. During the March 14 visit, Blue Ridge staff indicated that results of
studies of sewer generated color showed a relationship between bleach plant filtrate pH and
temperature and unaccounted color generated in mill sewers. By operating within the range of
pH and temperatures identified during the studies the Canton mill has had some success in
controlling this source of unaccounted color. Based on this information, the Tech Team
concludes that by further reducing process operation variability, including operating within the
pH and temperature range identified during the studies, the mill can continue to also minimize
sewer generated color, thereby reducing one source of unaccounted color. Reducing overall
color discharges through BMPs and other management practices will likely further reduce
remaining unaccounted color. However, additional studies are necessary to further develop any
relationship between accounted and unaccounted color sources.
As noted above, analysis of primary clarifier influent color loading data demonstrates that color
loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during
steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and
intentional discharges of colored streams and continuing efforts to minimize process operation
variability, the Canton mill can achieve further reduced primary clarifier influent color loads and
subsequent final effluent color discharge within this range on a more consistent basis than
demonstrated in 2000 (i.e., more than 74 percent of the time). On this basis, the Tech Team
concluded it is feasible to reduce final effluent color by more than 5,000 lbs/day through
improved black liquor leak and spill collection and control.
3. Ozone/Chlorine dioxide stage for hardwood bleach line. Ozone is used in more than ten kraft
mills around the world to bleach pulp, including two in the US and one in Canada. There are
several process configurations,but the most common is to operate an ozone (Z) mixer and
reactor immediately upstream of a chlorine dioxide reactor,without any washing between the
application of the two chemicals. This is known as a"ZD" stage. A system of this type was
retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999.' Bleaching with ozone on
the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 27 percent reduction in
the discharge of color in the combined mill treated effluent.' The conversion to a ZD stage
Z Munro,Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching Sequence,Tappi,2000.
Ibid.

Page 8
would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for
ozone. The energy requirements for ozone production would be offset by the energy savings
from less chlorine dioxide and caustic production, resulting in a net reduction in energy
consumption with the ZD stage.
As of September 2000, the long-term average color discharge from Canton's hardwood bleach
line was 12,800 pounds/day'. The Espanola experience suggests that implementation of a ZD
stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by
3,000 to 6,400 lbs/day. Based on comments received, the Tech Team acknowledges that
operating parameters, such as wood species processed and technology supplier performance
guarantees, may influence the practical color reduction achievable through implementation of a
ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are
based solely on the demonstrated performance and the Tech Team's assumption of color sources
at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada
(PAPTAC)meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible
communication between Blue Ridge and Domtar staff would be necessary to reliably predict the
achievable color reduction possible with this option for the Canton mill.
The technical evaluation of this process improvement included in the BEPER yielded a
hardwood filtrate color discharge reduction within the range of Tech Team estimates.
4. 2"d stage OD for pine line. Oxygen delignification (OD) on the Canton Mill pine line is a
single stage system installed in 1993. It has been concluded that retrofitting a second OD stage
for the pine line could contribute to reduced color discharges in two ways. The first would be a
reduction in color for those filtrates presently not captured and reused in the BFR process. The
second would be a color reduction in the Chloride Removal Process (CRP) purge stream as a
result of less chloride from chlorine dioxide used for bleaching.
Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed
upstream of the existing reactor. Previously, the Tech Team anticipated increasing the kappa
number(lignin content) of the cooked pulp from 24 to 32 and utilizing a two-stage OD system to
reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two-
stage system. Based upon comments from BRP and further technical analysis, and review of the
BEPER, it was concluded that it is technically feasible for a two-stage OD system at the Canton
4 Jacobs Engineering Group,2001 Color Removal Technology Assessment,February 2001.

Page 9
mill to achieve an overall reduction of 50 percent in kappa number, rather than 65 percent as
previously anticipated. Therefore,with the Canton mill continuing to pulp to a kappa number of
24, the new two-stage OD system would reduce pulp kappa number into the bleach plant from
the current output of 16 to about 12, corresponding to a 50 percent kappa number reduction from
the current digester output of 24. The quantity of color released from the bleach plant will be
reduced in proportion to the reduction of the input kappa number.
By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a
two-stage OD system, the quantity of chemicals required in the first two stages of the bleach
plant can be reduced, because there is less lignin present in the incoming pulp to remove by
bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional
reduction in chloride load to the CRP and reduce color discharged from the purge stream in
proportion to the reduction in chloride being treated.
In response to comments received, it has been concluded that implementing a two-stage OD
system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve
a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving
greater delignification with the proposed two-stage OD system. However, operating a two-stage
OD system with a higher than 50 percent delignification rate and a digester kappa number higher
than currently employed at the Canton mill is commonly seen at comparable bleached
papergrade kraft mills. Therefore,the Tech Team anticipates that additional process engineering
will maximize the benefits of a two-stage OD system at the Canton mill and enable the mill to
capture the increased delignifeation and yield gain potential of this technology and achieve
annual wood cost savings of up to approximate $950,000 from up to a 1.5 percent yield increase
across the proposed two-stage OD system.
Based on additional information supplied by Blue Ridge regarding operational limitations of the
BFR system, the Tech Team concludes that a two-stage OD system would not have a significant
impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on
a day-to-day basis.
For this analysis, it was estimated preliminarily that a second OD stage could reduce total
influent color-discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from
reductions in pine line bleach plant filtrate color and CRP purge stream color.

Page 10
The technical evaluation of two-stage OD included in the BEPER yielded reduction in color
discharge influent to the wastewater treatment system within the range of the Tech Team
estimates.
5. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP)purge is a low
flow, highly concentrated waste stream. Color is typically 50,000 pcu, in a 10 gpm (0.01 MGD)
flow. The CRP purge contributes up to approximately 5,000 lbs/day (13 percent) to the total mill
loading to the wastewater treatment system influent,but only 0.06 percent of the discharge flow.
It was originally speculated that it may be feasible to reduce the color in this stream by
precipitating the colored organic material with lime at a dosage of 20 g/L5, and burning the
resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials
would be necessary to test the feasibility of color removal from the CRP purge stream by lime
treatment.
Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium
compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The
preliminary results of these trials show that at a dosage of 20 g/L,none of the compounds tested
reduced color in the CRP purge stream. Although color removal was demonstrated at higher
dosage rates, increased chemical usage would result in substantially higher operating costs,
require larger sized equipment at higher capital cost, and also result in a higher production rate of
sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not
burned must be landfilled at additional cost.
Based on preliminary laboratory trials, Blue Ridge concluded that lime treatment of the CRP
purge is not a feasible color reduction option for the Canton mill. However, the Tech Team
recommends additional review of other innovative technologies for treatment of color in the CRP
purge stream, such as the application of the X-Filter process recently implemented at a totally
chlorine free (TCF) mi116. By minimizing color contributions from this stream, the potential
exists to achieve a significant reduction in primary influent color discharge of up to 5,000
lbs/day.
5 NCASI Technical Bulleting No.239,The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching
Effluents with Lime.1. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970.
6 Comments on the Draft Report on Additional Color Removal Technologies and Economic Impacts for BRPP,Hope
Taylor,Clean Water Fund of North Carolina,July 18,2001

Page 11
6. Process Optimization. The BEPER identified sixteen recommendations for optimizing the
hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching
operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the
first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood
line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction
of up to 700 lbs/day from the hardwood line and up to 4001bs/day from the softwood line. The
Tech Team estimated an additional color reduction from the CRP purge stream of 600 lbs/day
resulting from the decreased chlorine dioxide usage. At this time, the Tech Team has no means
of making an alternative quantitative prediction of bleach filtrate color reduction to compare to
estimates presented in the BEPER. Therefore, it is estimated that through efforts by mill staff to
maximize the color reduction benefits from the process optimization opportunities identified by
Licbergott, et, al., the Canton mill would achieve a total color reduction of 1,700 lbs/day in
wastewater treatment system influent.
Color Reduction Summary
The Tech Team estimates that by improving BFR reliability and black liquor leak and spill
collection and control, the Canton mill final effluent will be reduced by more than 5,000 lbs/day.
Process optimization, as outlined in the BEPER,would result in a further final effluent color
reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45
percent across the existing wastewater treatment for the CRP purge stream and other"brown"
color sources derived from black liquor and no reduction in color from bleach plant filtrates.
Table 1 presents a summary of the estimated reductions in final effluent color attainable with the
highest certainty by implementing improved BFR reliability, improved BMPs, and process
optimization.

Page 12
Table 1: Summary of Process Improvements and Associated Color Reductions
(Highest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
1 BFR reliability improvement --- 1,000-1,200
2 Improved black liquor leak & spill collection and --- > 5,000
control
6 Process Optimization 1,700 1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION >7,400
Additional potential mill improvements to reduce color discharge at the Canton mill were also
identified. These process improvements require further study to more accurately determine
achievable color reduction and thus are not recommended at this time for immediate
implementation. These improvements include a ZD stage in the hardwood bleach plant, with a
preliminary estimate of a 3,000 to 6,400 lbs/day color load reduction in influent to the
wastewater treatment system, and a second OD stage for the pine line, with a preliminary
estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment
system. Table 2 presents a summary of preliminary estimates of color reductions for these two
additional process improvements that need further study. Reductions presented in Table 2 are
preliminary estimates with reduced certainty compared to those presented in Table 1, but are
based upon identified technology options available for the Canton mill.

Page 13
Table 2: Summary of Process Improvements and Associated Additional Color Reductions
Needing Further Study (Reasonable Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400
line
4 2 d stage OD for pine line 1,500-2,000 1,100-1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 - 7,800
Table 3 presents a preliminary estimate of color reduction potential for the removal of color from
the CRP purge stream. The Tech Team recommends this stream for additional review of
potential color reduction technologies but cannot identify a particular technology option at this
time. Potential for additional color load reduction up to 2,750 lbs/day in final effluent to the
Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty.
Table 3: Summary of Additional Potential Color Reductions Needing Further Study
(Lowest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(lbs/day) (lbs/day)
5 1 Color Treatment of CRP Purge Stream #5,000 #2,750
TOTAL ADDITIONAL POTENTIAL FINAL EFFLUENT COLOR #2,750
REDUCTION

Page 14
Economic Analysis
The estimated capital and operating costs for the process improvements one through four were
estimated and are summarized below. Costs could not be developed at this time for process
optimization or CRP treatment and thus are not presented. However, costs for these
improvements should be modest.
Table 3: Estimated Costs
Process Improvement Capital Cost Annual O&M
($) ($/year)
1 BFR reliability improvement $1,300,000 $85'0006
2 Improved black liquor leak & spill collection and $100,000 $50,000
control
3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000)
line savings
4 2"a stage OD for pine line $2,000,000 ($2,100,000)
savings
Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven
plants (including the Canton Mill) from Champion International Corporation. Blue Ridge Paper
Products is owned 55 percent by KPS Special Situations Fund, L.P. and 45 percent by the
employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the
1997 report EPA documented substantial losses over five years for the Canton Mill and
Champion had just announced its intention to sell or close the mill. However, because of the sale
of the mill to the Blue Ridge, the previous data are not comparable to the more recent data.
Further, the data submitted by Blue Ridge is still confidential, so this report cannot present as
much detail as the 1997 report.
The current analysis is based on information submitted by Blue Ridge covering part of
1999 (May-December) and all of 2000 (all of the existing financial data for the company). The
results may be relatively uncertain because of the lack of data and the company may be too
young for the current data to reflect its ultimate financial health. EPA used three measures of
financial health (gross profit test, discounted cash flow, and Altman's Z)7 to assess the impact of
'See Interim Economic Guidance for Water Quality Standards: Workbook,EPA 823-B-95-002,March 1995,and
Economic Analysis for the National Emission Standards for Hazardous Air Pollutants for Source Category:Pulp and
Paper Production;Effluent Lim tations Guidelines,Pretreatment Standards,and New Source Performance
Standards: Pulp,Paper, and Paperboard Category—Phase 1.

Page 15
air emissions control technologies and devices (not addressed in this memorandum, such as
MACT H and regional NOX control) and wastewater compliance costs (separate and combined)
on the mill and company. The costs for the wastewater control options presented in Table 3 do
not change the financial status of the mill or company. However, the costs for some of the air
emissions control options do impact the health of one or both entities. When the wastewater
costs are added to costs for air emissions control, the impacts of the water costs do not change
the financial status of either the mill or company when compared to the impact of the air costs
alone.
References
Blue Ridge Paper Products, Inc. Canton Mill Canton Mill Environmental Performance Update,
Prepared for U.S. EPA Technology Review Workgroup. March 14, 2001.
Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic
Analysis of Blue Ridge Paper Products, from Bob Williams, May 18, 2001 (CBITS 00003911-
01)
Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown, Blue Ridge,
to Don Anderson, EPA, May 18, 2001
Comment Clarification of May 18, 2001 Blue Ridge Responses to EPA Questions, from Derric
Brown, Blue Ridge, June 4, 2001
Comments on Draft Final Tech Team Report, from Bob Williams,Blue Ridge, to Don Anderson,
EPA, July 13, 2001
Comments on Draft Final Tech Team Report, from Derric Brown, Blue Ridge, to Don Anderson,
EPA, July 17, 2001
Comments on Draft Final Report, email from Forrest Westall,North Carolina DENR, to Don
Anderson, EPA, July 17, 2001
Comments on Draft Final Report on Additional Color Removal Technologies and Economic
Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001

Comment on Draft Final Tech Team Report, email from Paul Davis, State of Tennessee, to Don
Anderson, Julyl8, 2001
Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott, to
Don Anderson, EPA, July 19, 2001
Jacobs Engineering Group, 2001 Color Removal Technology Assessment, Blue Ridge Paper
Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001.
Liebergott,Norm, and Lew Shackford, Bleach Environmental Process Evaluation and Report,
June 8, 2001
McCord, Aimee,A Laboratory Analysis of Color removal Across a Pulp and Paper Mill
Wastewater Treatment Facility, Canton, North Carolina, Duke University, School of the
Environment, 1995
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.
NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of
Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching
Effluent. July, 1970.
Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater
Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina, Duke University, School
of the Environment, 1996
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry. Page 182
Wiley Interscience, 1986.
Springer, Alan M. ed. Industrial Environmental Control, Pulp and Paper Industry, 3 d edition.
Page 286. TAPPI Press, 2000.

Appendix 1: Color Balance (911100 to 12/31/00)
Figure 2.6, Presented by Blue Ridge on March 14, 2001
Sewer Description Color Load
ID (lbs/day)
213 Digester area sewer: Digesters, HW 4,323
line, knot rejects
3A Alkaline sewer: Pine and HW Eo, 12,954
Pine line BSW, 02 Delig
1 PMs11 & 12,HW weak liquor tank 1,991
513 Recovery,BLOx, CRP* 7,852
6A Acid sewer: Pine and HW D1 17,345
filtrate+Pine D2 filtrate
Contaminated Condensate 1,591
Combined Condensate 260
Total 46,316
Primary Influent (PI) 49,284**
Unaccounted Color 2,968
(PI minus Total)
Secondary Effluent 37,696
Percent Removal in Treatment 23 %
* CRP contributes 5,000 to 6,0001bs/day to 5B sewer
** Measured using test method in NCASI Tech. Bull. 803, An Update of Procedures for the
Measurement of Color in Pulp Mill Wastewaters,May 2000.

Appendix 2: Table of Effluent Color Limits, 1997 to Present
Color Limit True Color(Ibs/day)
Monthly Average Annual (Long-term)
Average
1997 Permit 125,434 98,168
Settlement Agreement, February 1998 69,000 60,000
(starting December 1, 1998)
Settlement Agreement, February 1998 --- 48,000 to 52,000
(Ultimate Target)
Interim Limits, May 2001* 55,000 48,000**
* As recommended by Technology Review Workgroup (TRW) and incorporated by NC in
BRP's NPDES permit.
** Reduced end-of-pipe color discharges since November 2000 reflect, in part, reduced pulp
production (approximately 30 percent) during this period because of the ongoing project to
upgrade the No. 19 paper machine used to produce bleached paperboard.

Appendix 3: Ozone Bleaching
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.

Appendix 4: Two-Stage Oxygen Delignification
Comparison of one- and two-stage oxygen delignification systems
Item Current Single-Stage System Proposed Two-Stage System
Oxygen Reactors One two
Input Kappa Number 24 24
Output Kappa Number 16 12
Total C102 Used 28 kg/ton* 22 kg/ton*
Oxygen Used 23.4 kg/ton* 28.3 kg/ton*
Total NaOH Used 45 kg/ton* 37 kg/ton*
* air-dried metric ton of bleached pulp

1�
State of North Carolina
e� Department of Environment IVA
and Natural Resources
Division of Water Quality L
Michael F. Easley, Governor NCDENR
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Acting Director
August 3,2001
Mr. Robert Shanahan
Vice President-Mill Manager
Blue Ridge Paper Products
P.O.Box 4000
Canton,North Carolina 28716
Subject: NPDES Draft Permit
Permit No.NC0000272
Blue Ridge Paper Products Inc.
Haywood County
Dear Mr. Shanahan:
Blue Ridge Paper Products Inc.applied for an NPDES permit renewal on February 26,2001. The Division
of Water Quality's original schedule for conducting a public hearing prior to July 31,2001 was postponed in order
to allow the EPA Tech Team and the Technology Review Workgroup the necessary time to incorporate the findings
of a third party evaluation of the Canton Mill,sponsored by the Clean Water Fund of North Carolina,American
Canoe Association,Western North Carolina Alliance,Dead Pigeon River Council,Appalachian Voices,Tennessee
Environmental Council, Southern Appalachian Biodiversity Project,Dogwood Alliance and the National Forest
Protection Council. The EPA Tech Team has completed their report and provided the Technology Review
Workgroup with the`potential' color reductions available through the application of the identified process
improvements. Based on this report,the Technology Review Workgroup developed the `regulatory' basis for
additional color reductions in this permit cycle. Now that the EPA Tech Team and the Technology Review
Workgroup's color recommendations are final,the Division of Water Quality has prepared this draft permit and
scheduled a public hearing for September 6,2001 (additional details below).
After issuing a"pre-draft"permit,the Division of Water Quality prepared this draft permit and is once
again soliciting comments from the Environmental Protection Agency,the State of Tennessee, the City of Newport,
Cocke County, and other concerned stakeholders. The Division reviewed and considered all comments received
during the"pre-draft" comment period and modified the"pre-draft"permit and fact sheet accordingly. The
modifications reflected in this draft permit include the following:
The dioxin monitoring special condition has been modified. The dioxin monitoring special condition in the pre-
draft permit allowed the permittee to split samples. If the analysis of either sample was below the minimum
level,then the quality was considered zero for compliance purposes. The Division received concerns over this
allowance and has modified the condition accordingly. The decision to split samples is at the discretion of the
permittee, if samples are split,the permittee must report both values and compliance shall be judge on each
sample independently.
➢ Dates that have passed have been deleted from the Best Management Practices Special Condition.
Special Condition A. (8.)Requirements for Color Analysis and Compliance have been added. Based on the
recommendations of the Technology Review Workgroup and the EPA Tech Team Report,the Division of
Water Quality has developed the recommendations for additional color removal over the term of the permit.
The color reductions contained in this condition represent a 19%to 29%reduction in the current permitted color
load. After Blue Ridge Paper has implemented the process improvements necessary to achieve color reductions
within the targeted range,Blue Ridge Paper will evaluate the feasibility of complying with North Carolina's
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617-TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATNE ACRON EMPLOYER-50%RECYCLED/10%POST-CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Permit Number: NC0000272
color standard. Then during permit renewal process in 2006,the Division of Water Quality and the NPDES
Committee will evaluate what additional reduction,if any, are required in order to achieve compliance with
North Carolina's color standard.
Below are the Division's responses to comments received on the pre-draft permit.
There were concerns over the language in the Best Management Practices Special Condition,these include:
- Special Condition A. (6.) Section A. 1,the wording"to the maximum extent possible as determined by
the mill. The language and conditions set forth in the Best Management Practices Special Condition
were developed by the EPA as part of the new Effluent Guidelines for the Pulp and Paper Industry.
After extensive research and gathering of public comment, the EPA stipulated an industry standard for
Best Management Practices. The language contained in Special Condition A. (6.) is consistent with
the industry standard as published in the Code of Federal Regulations. Since Blue Ridge Paper meets
or exceeds the Best Management Practices standards,the Division does not feel that requiring a higher
standard is justified at this time.
- Special Condition A. (6.)Section E.3,the language"failure to take the actions required by Section E.2
as soon as practicable will be a permit violation". The comment was made that this language is
unenforceable. In addition to the comment made for Special Condition A. (6.)Section E.3,it is the
Division's understanding that the language in Section A.(6.)E.3 "failure to take the actions required
by Section E.2 as soon as practicable will be a permit violation", is a 'good faith' condition and that
any gross violations of this condition are enforceable.
- Monthly reporting of'action' level exceedence was recommended. In addition,to the comment made
for Special Condition A. (6) Section E.3,please refer to the Best Management Practices Special
Condition Paragraph E. This condition requires that Blue Ridge Paper submit an annual report to the
Division of Water Quality that summarizes Best Management Practices monitoring and action levels.
The longer time frame (annual as opposed to monthly)associated with the annual submittal required in
Special Condition A. (7.)provides the Division with a more representative analysis of operations at the
mill and is better suited for analysis and conclusions. Therefore, the Division feels that annual
reporting is appropriate.
Comments were made regarding the daily maximum BOD5 limit proposed in the pre-draft permit. The
Division's review of the instream dissolved oxygen data indicates that the limits and conditions in the permit
are protecting the dissolved oxygen standard in the River. Additionally,the Division's model predicts and
actual data supports that the lowest dissolved oxygen concentrations occur at river mile 57.7,which is above
Hepco.
The Division received comments regarding the need for nutrient limits in permits above the lake. The Division
has no evidence that nutrients are a concern in this watershed. Additionally,Blue Ridge Paper's nutrient
loading is relatively low,however,nutrient monitoring will continue as a condition for this permit in order to
assess Blue Ridge Paper's nutrient loading to the River.
The Division received comments regarding the removal of the monitoring station at river mile 53.5. Blue Ridge
Paper currently is monitoring color,temperature,and dissolved oxygen at river mile 53.5. Temperature and
dissolved oxygen monitoring at this point is required according to the NPDES permit issued to the City of
'Waynesville. Since Waynesville is already required to monitor this station, it is the Division's recommendation
that additional monitoring of temperature and dissolved oxygen by Blue Ridge Paper is not appropriate.
The color monitoring at this station was originally implemented in order to assess the impacts from Clyde's,the
Waynesville and Richland Creek. With the removal of Clyde's discharge,the Division feels that the continued
monitoring of color at river mile 62.9(Fiberville)and river mile 42.6(Hepco)is sufficient.
D The Division received a request to require dioxin isomer monitoring of the octachlorinated dioxin isomers at the
internal outfalls,sludge and landfill leachate. The Division also received opposing comments suggesting that
the dioxin and furan monitoring proposed in the pre-draft unnecessary. During the previous permit cycle,Blue
Ridge Paper was required to monitor 15 isomers of dioxin and furans. Based on a review of this data and the

Permit Number: NCO0OO272
public comments received,the Division recommends continued monitoring of 2,3,7,8,TCDD and 2,3,7,8 TCDF
on the effluent, sludge,landfill leachate, and the influent to the wastewater treatment plant.
Please review the draft permit and fact sheet carefully and submit comments to DENR—D WQ NPDES
Unit. This draft permit should not be interpreted as the Division and NPDES Committee's final decision. A 30-day
public comment period follows the release of this draft permit and will close at the discretion of the hearing officer
and will be announced at the beginning of the public hearing to be held on September 6,2001. The details on where
and when the hearing will be held is listed below:
Public Hearing on regarding the Blue Ridge Paper Products Canton Mill's NPDES discharge will be held:
September 6,2001 @ 7:00 pm
at the
Tuscola High School Auditorium
564 Tuscola School Road
Waynesville,North Carolina
Haywood County
If you have any questions concerning the draft permit for your facility,please call me at(919)733-5083,
extension 508.
Sincerely,
Michael S. Myers, EI
NPDES Unit
cc: Central Files
NPDES Files
Aquatic Toxicology Unit
Marion Dee;hake — North Carolina Environmental Management Commission, NPDES Committee
Jerry Wilde— Dead Pigeon River Council
402 W. Broadway
Newport, Tennessee 37821
Forrest Westall - Asheville Regional Office/Water Quality Section
Dan Oakley — North Carolina Attorney General, Environmental Division
Keith Haynes -Asheville Regional Office/Water Quality Section
Rob Lang — Compliance and Enforcement Unit
Diane Reid— Classification and Standards Unit
Roosevelt Childress Jr. — Environmental Protection Agency, Region IV
Karrie-Jo Shell —Environmental Protection Agency, Region IV
Don Anderson— Environmental Protection Agency, Headquarters
Mark Perez —Environmental Protection Agency, Headquarters
Justin P. Wilson— Deputy to the Governor
Tennessee State Capital, Suite G10
Nashville, Tennessee 37243
Paul Davis —Tennessee Division of Water Pollution Control
6th Floor, L&C Annex
401 Church Street
Nashville, TN 37243-1534
Charles Lewis Moore — County Executive Cocke County
360 Main Street, East
Newport, Tennessee 37821
David Jenkins—American Canoe Association
7432 Alban Station Boulevard,Suite B-232
Springfield,Virginia 22150-2311

Permit Number: NCO000272
Hope Taylor- Clean Water Fund of North Carolina
29 'h Page Ave
Asheville, North Carolina 28801
David McKinney—Tennessee Wildlife Resources
Ellington Agricultural Center
P.O. Box 40747
Nashville, Tennessee 37204
Jonathon E. Burr—Tennessee Division of Water Pollution Control
Regional Environmental Assistance Center
2700 Middlebrook Pike, Suite 220
Knoxville, Tennessee 37921
Robert Williams—Blue Ridge Paper
175 Main Street
P.O.Box 4000
Canton,North Carolina 28716
Derric Brown—Blue Ridge Paper
175 Main Street
P.O.Box 4000
Canton,North Carolina 28716
Patsy R.Williams—Chairman Newport/Cocke County Tourism Council
360 East Main Street
Court House Annex,Suite 141
Newport,Tennessee 37821
Dianne Keys—Newport/Cock County Tourism Council
360 East Main Street
Court House Annex, Suite 141
Newport,Tennessee 37821
Timothy L.Dockery—Director
City of Newport
Parks and Recreation Department
433 Prospect Avenue
Newport,Tennessee 37821
A.Dean Williams—Coordinator
Newport/Cocke County Economic Development Commission
433 Prospect Avenue
Newport, Tennessee 37821
Ray Snader—News Director
WNPC Radio AM/FM
377 Graham Street
Newport,Tennessee 27821

Permit Number: NC0000272
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In :Epli�anc�eith��he ov}sio' n ofI h arolina/33g ra�Statute 143-21� lawful s n ards and
regulatons promlg`ated an$ adopted b!y e North dar lira Environmental Management on mission,
and the Federal Vlkate Po lu{ion-Contt� ct, as amended,
Blue �"dge Paper Products II c.
is ereL authorize to di charge wastew, as fyo r a facility I cated at
Blue Ridge Paper Products Inc.
Canton Mill Wastewater Treatment Plant
Off Highway 215
Canton
Haywood County
to receiving waters designated as the Pigeon River in the French Broad River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, III and IV hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on November 30, 2006.
Signed this day � RA
Gregory J.Thorpe,Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Number: NC0000272
SUPPLEMENT TO PERMIT COVER SHEET
Blue Ridge Paper Products, Inc.
is hereby authorized to:
1. Continue operation of a 29.9 MGD wastewater treatment plant for the treatment of wastewater
associated with the Blue Paper Products Inc. pulp and paper mill, the Town of Canton's
chlorinated domestic wastewater and landfill leachate. The treatment system consists of the
following treatment units:
Grit Chamber
Bar Screen
iPd�nps
• Polymer``a tioD
• pH control injection r 2SO4 b ck p)
• Threeiprimary c an ters
• Nutrient ee�
• Aeration basins
• Three second clarifiers
Resi al bel presses
ffTneat flo measurement
• Cascade post aeration with oxygen injection
• Instream oxygen injection facilities
The facility is located at the Blue Ridge Paper Products WWTP, off Highway 215, Canton,
Haywood County, and;
2. Discharge treated wastewater from said treatment works at the location specified on the attached
map through outfall 001 into the Pigeon River, which is classified C water, in the French Broad
River Basin.
. RA

K. y
k OutFall_001
�. w y 5 \ i
_ 1•
If
Cr
/ f
• Blue Ridge Paper's Cuffall Facility Information
French Broad Hydrography Blue Ridge Paper Products, Inc. U�SteCgid:GS Canton
NR NC0000272 Subbasin: 04-03-05
Hghways Haywood County
M.INCIpaI BOUndafle5 xa �• '� 1
0 County Boundary
N 0.5 0 0.5 1 Miles BLUE RIDGE PAPER PRODUCTS INC.
A N

Permit Number: NC0000272
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge treated industrial, municipal,stormwater and landfill wastewater through
outfall(s) 001. Such discharges shall be limited and monitored by the Permittee as specified below:
.QEfflrient Characteristks EffluenYLimits Monitoring Retautrements',
—4.. e. . q.. — _ Ada'
Morithly Aaily, Measurement1,,Sample .Ype". Sample
gver`a a Maximum Fre uenc :' 1 f
9 9, y, Location. y
Flow 29.9 MGD Continuous Recording I or El
BOD, 5-day,20°C 3205 lb/day 10897 lb/day Daily Composite I,El
Total Suspended Residue 12549 lb/day 49560 lb/day Daily Composite I,El
NH3-N Daily Composite El
AO? 56,9-Wday 2822.2lb/,day, Daily,—Composite, FT
Co)or' \ \ \ Dailyl _ Oompsisite E.
Dissolved Oxygaq \ \ ` / /\ Dailyl I Grab Ei
Temperature \ \ ) Daily I I Grab I El
p I I i I / J / / \ \ Daily Grab I El
Conductivity I ( I / / \ Dailyl Grab I El
Feeal i oliform J ( I 2OGN00,ml 4007 100-m \Weekly Grab I El
COD I / / \ \ / Weekly I Composite I El
Silyerj / J \ \ / / \Qdarteriy I Composite I E(
Zinc / \. / / Quarterly Composite I El
Total Nitrogen Monthly Composite E,
(NO=-N+NO3-N+TKN)
Total Phosphorus Monthly Composite El
Chronic Toxicity Quarterly Composite E,
Cadmium Quarterly Composite El
Trichlorophenol 3.0 pg/L Quarterly Composite El
Pentachlorophenol 8.9 pg/L Quarterly Composite El
Selenium 10.6 pg/L Quarterly Composite El
2,3,7,8 Tetrachloro-dibenzo- 0.014 pg/L Quarterly Composite I,E,
p-dioxin10
Conductivity Daily Grab Pigeon River
Flow Daily Grab Pigeon River
Fecal Coliform Weekly Grab Pigeon River
Color Variable Grab Pigeon River
Temperature Variable Grab Pigeon River
Dissolved Oxygen Variable Grab Pigeon River
Footnotes:
1. Sample Location:I-Influent,El—Effluent,Pigeon River-Instream sampling as specified in A. (5.)Instream
Monitoring Special Condition. �� n
2. AOX monitoring shall be in accordance p :_W S plin 'Plan fo Cluster hle P ame ers da ed arc 19,
2001)or subsequent modifications approve, by the,)?�'vi icon. AOX datar�s}�akl��a submitted on a qu erly basis
along with other Effluent Guideline chemical;dta. e er to AA:('1!�fflu'e t Gui\i e am ng Plan pecial
Condition.
3. See A. (8.) Color Analysis and Compliance)Si ia o d ition.
4. The daily average effluent dissolved oxyg,n conce tratigr shall n t Jess than 6.O�ng/L. See A. 1 .)
Dissolved Oxygen Special Condition.
5. See A.(13.) Temperature Variance Review Special Condition.
6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0(on the standard units scale).
7. Chronic Toxicity(Ceriodaphnia)at 90%Effluent Concentration: March,June, September,December(see A.
(4.)Chronic Toxicity Permit Limit(Quarterly)).

Permit Number: NCO000272
8. Trichlorophenol and Pentachlorophenol limits and monitoring are provisionally waived since the facility has
certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include
chlorophenolic biocide, the Permittee shall notified the Division prior to use and the limits and monitoring
requirements shall become immediately effective.
9. If after 18 months selenium has not been detected,the facility may request that the Division review selenium
data for possible removal of the limitation.
10. See A. (9.) Dioxin Monitoring Special Condition.
11. See A. (5.) Instream Monitoring Special Condition.
See A.(6.) Best Management Practices(BMP) Special Condition.
See A.(11.) Town of Canton Inflow and Infiltration Special Condition.
Definitions:
MGD-Million gallons per day lb/day-Pounds per day
ml- I i iter" OD-Bioch micalOxygen errand
µ Mit;ragramss er liter AOX-Adsor�abl'e-Oigaiit'6-Hlalides
C D�Chemical oxygen defnan� o -picograms per liter

Permit Number: NC0000272
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUHZEMENTS
During the period beginning upon the effective date of the permit and lasting until expiration, the
discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
outfall(s) 002 (E21), shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
Effluent Charactensties ' ti LIri11t6-), Momtoring:°RequirementS2 r'
z
Monthly Daily Measurement Sample Type3; Sample
F ._l , w Average Mazlmum h' * :Frequency u 'fa '..,.' Location
Flo Weekly Calculated E2
Chloroform 5.15 lb/day 8.60lb/day Weekly Grab E2
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E2
p- ioxm TCDD).
2, ,7,8-Tetrachloro liibenzo- 1 31.9 p r\ \Monthly rCottTppsite =E3 r
p 4ua! (TCDF) t
Tr(chlbrosyringol , ;:` f )k 2.5 Monthly Composite E#
3,4,5-�richlorocate6hol I l < 5.0 µW \M nthly o`C mpostfe E
3, ,6-' richlorocatechol i < 5.0,µ dVthly I omposr a E}
3,j,5-Trichloroguaiac9l I N < 2.1jigl0— odthly I I Composite Ej
3,4,6-�richloroguziacol I .\< 2S µ Mont6l Composite E}g
4,N,6-Trichloroggaiacol I 2.5�g/L Motrthly I Composite El I
2,4,5-Trichlorophenol < 2.5 µg/L5 Monthly Composite E2
2,4,6-Trichlorophenol < 2.5 µg/LS Monthly Composite E2
Tetrachlorocatechol < 5.0 µg/L5 Monthly Composite E2
Tetrachloroguaiacol < 5.0 µg/L5 Monthly Composite E2
2,3,4,6-Tetrachlorophenol < 2.5 pg/L' Monthly Composite E2
Pentachlorophenol < 5.0 µg/L5 Monthly Composite E2
Footnotes:
1. Sample Location: E2—Effluent is composed of Bleach Plant Effluent-acid (acid sewer collected from tap
installed on filtrate pump from CI02 bleaching stage D-100 and from tap installed on filtrate pump from C102
bleaching stage D-2)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E.).See A.(7.)Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters(Internal Outfall 002 parameters+internal Outfall 003 parameters+AOX from Outfall
001)shall be reported on a quarterly basis or more frequently;refer to A. (7.)Effluent Guideline Sampling Plan
Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance, and report
total bleach plant flow(acid+alkaline wastestreams) in DMRs. Grab-collect separate grab samples every 4-
hours for 24-hour period from both the acid-anda aline streams which w}71 then be-composit d-separatel by
the lab,and analyzed as separate 24-hr coin sit % and alkalmesampl€sl Composite=colfeeetse azat grab
samples every 4 hours for 24-hour period pm bot e laud and alkaline/s{ri a\ins,then prepare and alyze a
single flow-proportioned composite of the acid and l,catine-waseesheatt / \
4. For compliance purposes,the permittee mush report)t}a 00 chlo ofonn mas loading ba' sed on additi n of
separate acid and alkaline chloroform mass ��oad. // \�
5. Limits are based on Minimum Levels(Ml.)specited in CFR 30 01�,
Definitions:
lb/day—Pounds per day µg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NCO000272
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration,the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
outfall(s) 003 (E31), shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
>
Z 'Efl og'Rm t
�K �
"e = Monthly Daily Average _Measurement ' SampleType3 £ Sample;,
Average Frequency Location-
Flow Weekly Calculated E3
Chloroform 7.14lb/day 11.93lb/day Weekly Grab E3
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E3
p-groxm DD), F— r 1 �
2, ,7,8-Tetrachl ro-Uibenzo- 31.9 pg/IJ /\ \Monthly ( �otl[1T-sl —Ej
p-Ir (TCDF)1
Tr ichlbrosyringol 1 4 I . ) k 2.5 µg/L'I i4onthly I I Composite E#
3,4,5- richlorocatechol I < 5.0 µg/Lt Mpnthly Uomposita E# I
3,4,,6-xrichlorocatedhoj I —\ ` < 5.0 µg dnthly I ompost a E# I
3,4,5-�richloroguaiacol I < 2.�'µ otithly I I Composite Et{
3,1,6,�richlorogu5iacol I \< 215 µg/L Mont ly 1 , I Composite E# I
4,5�,6-Trichloroguaiacol j 1.5lig/L Mo�tthly I Composite E# I
2,4,5-Trichlorophenol < 2.5 pg/L' Monthly Composite E3
2,4,6-Trichlorophenol < 2.5 pg/L' Monthly Composite E3
Tetrachlorocatechol < 5.0 pg/L' Monthly Composite E3
Tetrachloroguaiacol < .5.0 µg/L' Monthly Composite E3
2,3,4,6-Tetrachlorophenol < 2.5 µg/L' Monthly Composite E3
Pentachlorophenol < 5.0 pg/L' Monthly Composite E3
Footnotes:
1. Sample Location:E3—Effluent is composed of Bleach Plant Effluent-acid (acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100)and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage E.). See A.(7.)Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters(Internal Outfall 002 parameters+internal Outfall 003 parameters+AOX from Outfall
001)shall be reported on a quarterly basis or more frequently;refer to A.(7.)Effluent Guideline Sampling Plan
Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance, and report
total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab samples every 4-
hours for 24-hour period from both the acjd-andalkalinelstreams which will then bc-composited-separately by
the lab, and analyzed as separate 24-hr coin�josite� 'd annc all ftfie ampl�M `Comp 3i�ite=cultdctae rate grab
samples every 4 hours for 24-hour periodQm bo a c*d and j aline/s tioadit
s,tl}e prepare and p alyze a
single flow-proportioned composite of d abid and 1'ca]inewastes&e r 4. For compliance purposes,the permittee m t report e o 1 ctt o ofo g based on add ti n of
separate acid and alkaline chloroform moadin�es
5. Limits are based on Minimum Levels(Mll s ecr ed in (�CFR�SOOI�
Definitions:
lb/day—Pounds per day µg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NCOOOO272
A. (4.) CHRONIC TOXICITY PERMIT LIMIT(QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia duhia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the"North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised February 1998,or subsequent versions or
"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent
versions. The tests will be performed during the months of March,June,September,December.Effluent sampling
for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit,then multiple-concentration testing shall be performed at a minimum,in each of the two following months as
described in"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or
subsequent versions.
The c' hranic Yalue for multiple n' centration tests will be determined using a geome` ' mn£Yh 'ghest_J
con�Icentration n g�ro detect ble impairm�ent�f reproduction o)�survival and the lowest concentration that does
Ir e a detectable �pa yment o reproduction on survival
/The hefmition of`d etectable impairment," co legion
m thods, exposure regunes,an�further statistical methods�e specified. tRe` orth Caro lina Phase II Ch onic
Whole Effluent Toxici . Test Pro�are'r(R Pro -February 1998)dr subse uent versions.
Al{toxicity testing es Its required as past o this permit condition wil be entered on the Effluent Discharg
Monitoring Form -1)fort le months in w�tch teas} ere�perfortre:using the parameter code TGP�B 'or the
pals/fail)ts�nd HP3Bfo the Chronic Va]pe. tSd;itiond ally,DQ�orr AiT-3 (original)is to be sent to the
fol owin addre / u u
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,the
permittee will complete the information located at the top of the aquatic toxicity(AT)test form indicating the
facility name,permit number,pipe number,county,and the month/year of the report with the notation of"No Flow"
in the comment area of the form.The report shall be submitted to the Environmental Sciences Branch at the address
cited above.
Should the permittee fail to monitor dur ng a month n hic toxicity-monitorin is required rrtonitoring will be
required during the following month. e q ���� ���)d
yMeorth
� � �Should an test data from this monitorin°re u ment or t s er b � Cara inn rv�sto f Water
Qualityindicate potential impacts to the recei 'n stream,[h emrttlna be re-o a ed and modified to ' clude
alternate monitoring requirements or limits. f J \�y/
NOTE: Failure to achieve test conditions as specified in the cited document,such as minimum control organism
survival,minimum control organism reproduction,and appropriate environmental controls,shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Permit Number: NC0000272
A. (5.) INSTREAM MONITORING SPECIAL CONDITION
Stream Mile Location Description Parameter Frequency
Designation Marker
UP 63.8 Pigeon River upstream of the Temperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the Conductivity Daily
discharge) Color' 2/Week
Flow Daily
Fecal coliform Weekly
DNl 62.9 Pigeon River at Fiberville Bridge Temperature Daily
D.O. Daily
Conductivity Daily
Color t 2/Week
DN2' 57.7 Pi eon River Above Clyde Temperature Daily
D.O. Daily
DN3 \ 55\5 Pigeon Rives Below Clydc\ See Footnote 3 See Footnote 3
DN4 3.5 Pigeon River at NCS71625` See IT othote 3 See Fogto'te 3
I bridge ) .) \ ` I I `
DN5 42.6I —Piged—n Ri dr at HepJco ( \ \Temperature i Weekl
D.O. Weekl
Color 2)Wee
Flown F Daily
Waterville RgservoiV' See Footnote 4 Annually
DN�6.0 U Pigeon Ri�er p,Lor fo mixing with Color j Variableu
Big Creek
BC —26.0 Mouth of Big Creek prior to Color Variable
mixing with the Pigeon River
DN7 24.7 Pigeon River at Browns Bridge Temperature Weekly
(—NC/TN State Line) D.O. Weekly
Color Variables
All instream samples shall be grab samples.
1. Color(See A. (8.) Color Analysis and Compliance Special Condition) All instream samples collected
shall be representative of the Pigeon River and Big Creek, respectively. Both true and apparent color
shall be monitored using the methods specified in A. (8.)Color Analysis and Compliance Special
Condition. Samples shall be collected at stations DN6, BC, and DN7 only when at least one generator
at CP&L is in operation and releasing water to the Pigeon River.
2. Flow monitoring is necessary, as specified above, for the True Color calculation stipulated in A. (8.)
Color Analysis and Compliance Special Condition.
3. Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9
(DNI), 57.7 (DN2),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 (See A. (M) Dissolved Oxygen Special Condition). If
the dissolved oxygen drops below 5.0 g/1._ tati n5 —7— t en mom oring h;Lb�equire at tations
55.5 (DN3) and 53.5 (DN4).
4. See A. (12.) Waterville Reservoir Sam ling Spec ial IEGndi"t n. � `\
5. Sampling is required 2/week during t},e�summer a d on per wcel�unng thewmr. Sum er is
defined as the period from April 1 th loYt�c obnler� 31,wh le winis� of ed as Novem�er 1
through March 31.

Permit Number: NC0000272
A. (6.) BEST MANAGEMENT PRACTICES(BMP) SPECIAL CONDITION
The permittee must implement the BMPs specified in Section A below. The primary BMP objective is to
prevent leaks and spills of spent pulping liquors, soap, and turpentine. A secondary objective is to
contain, collect, and recover at the immediate process area, or otherwise control,those leaks, spills, and
intentional diversions of spent pulping liquor, soap, and turpentine that do occur. BMPs must be
developed according to best engineering practices and must be implemented in a manner that takes into
account the specific circumstances at the mill.
Section A. BMP Implementation Requirements
1. The permittee must return spilled or diverted spent pulping liquors, soap, and turpentine to the
process to the maximum extent practicable as determined by the mill,recover such materials outside
the process, or discharge spilled or diverted material at a rate that does not disrupt the receiving
was ewater-treatmen sY s em.
,
2. The-permit�ee ust es tablislraprog�a to identify�n repair lea ing�quipment items-This ogram
must include}(i Regular daily visual inspections of rocess area if h equipment items in sp nt
i t I 7 u � I l
pulping liquo , soap, �n turpentin�se�ice; (ii�I�medi ;e repair o�leaking equipment it m ,when
possible. Leaking equipment-items tlt at canno b repaired durin normal-operations muss H
identified, te4orarylmeans-for mitigating thf leaks muAe provided and-the,leaking equipment
items repaired during the next maintenance g to e; iii Ideetificatidn of conditions underlwlich
production'(VJ11 die curtailed or ha k ko repair leaking equipment items or to prevent pulping liquor,
soap,and-t rpentine teal:s and spills- and 9v),A means for�tracking repairs over time to idcnt fy those
Le items where cpgrade or rI lacement may be warranted based on frequency and se ierity of
leaks, spills, or failures.
3. The permittee must operate continuous,automatic monitoring systems that the mill determines are
necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap,
and turpentine. These monitoring systems should be integrated with the mill process control system
and may include, e.g.,high level monitors and alarms on storage tanks; process area conductivity(or
pH)monitors and alarms; and process area sewer,process wastewater, and wastewater treatment plant
conductivity(or pH) monitors and alarms.
4. The permittee must establish a program of initial and refresher training of operators, maintenance
personnel, and other technical and supervisory personnel who have responsibility for operating,
maintaining, or supervising the operation and maintenance of equipment items in spent pulping
liquor, soap, and turpentine service.The refresher training must be conducted at least annually and
the training program must be documented.
5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor,soap, or
turpentine that is not contained at the immediate process area and any intentional diversion of spent
pulping liquor, soap, or turpentine that is not contained at the immediate process area. The report
must describe the equipment items involved, the circumstances leading to the incident, the
effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion,
and plans to develop changes to equipment and operating and maintenance practices as necessary to
prevent recurrence. Discussion of the teportst�ust e-included as part\of the;annual-refreshertra}ning.
6. The permittee must establish a program to rev any planned modifications o theme pulpind
chemical recovery facilities and any c� stmcti�rl activitiesiolthe1plp�ir�g and chl emical re very areas
before these activities commence. Th urpos f�uch- e iew is tQplevent leaks-a�i d spil s of spent
pulping liquor, soap, and turpentine d ring t) la ed mod�fic�tions and to gsure that c struction
and supervisory personnel are aware c ossi liq r diverSt s and o e requirement t revent
leaks and spills of spent pulping liquors, soap, and urpentine duffing construction.
7. The permittee must install and maintain secondary containment(i.e., containment constructed of
materials impervious to pulping liquors)for spent pulping liquor bulk storage tanks equivalent to the .
volume of the largest tank plus sufficient freeboard for precipitation.An annual tank integrity testing
program, if coupled with other containment or diversion structures, may bd substituted for secondary
containment for spent pulping liquor bulk storage tanks.

Permit Number: NCOOOO272
8. The permittee must install and maintain secondary containment for turpentine bulk storage tanks.
9. The permittee must install and maintain curbing, diking or other means of isolating soap and
turpentine processing and loading areas from the wastewater treatment facilities.
10. The permittee must conduct wastewater monitoring to detect leaks and spills, to track the
effectiveness of the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must
be performed in accordance with Section E.
Section B. BMP Plan Requirements
1. The permittee must prepare and implement a BMP Plan. The BMP Plan must be based on a detailed
engineering review as described in this section. The BMP Plan must specify the procedures and the
practices required for the mill to meet the requirements of Section A,the construction the mill
determines is necessary to meet those requirements including a schedule for such construction, and
the monitoring program (including the statistically derived action levels that will be used to meet the
re uirementssof Section E. The BMp lan also m st s ecify the eriod of time that the mill
d termmes the�ctio �le}'elr s establishe under Secf�n may be xceeded ut trigger n the
rgspo�ec it-ed n Section E.
2. Tpe permitteelmust c6ii uct a detailed/8ngineermprev\iew of the�ul'pinQ and chemical re Iov�ry
operations--including but not limi�d �o process gquipr ent, storap tanks, pipelines and pum)ing
systems, loading and�unlo�ac i'ng�fac�ities, and other-appurttnant puling and chemical recQve�y
equipment items in spe�t pulping�liq or, soap,,and-turpe�tige se;�ice--for the purpose of determining
tl�e magnitude and routing of poregtia leaks, spills, and i to tional diversions of spent pu p�t{g
li r , soap an tur�eritine during he olfowing periods f�per�ation: (i)Process start-ups and shut
owns;(iiyMaintenance; (in)Production-grade changes; iv}Storm or other weather events, (v)
Power failures; and (vi)Normal operations.
3. As part of the engineering review, the permittee must determine whether existing spent pulping liquor
containment facilities are of adequate capacity for collection and storage of anticipated intentional
liquor diversions with sufficient contingency for collection and containment of spills.The engineering
review must also consider: (i)The need for continuous, automatic monitoring systems to detect and
control leaks and spills of spent pulping liquor, soap, and turpentine; (ii)The need for process
wastewater diversion facilities to protect end-of-pipe wastewater treatment facilities from adverse
effects of spills and diversions of spent pulping liquors, soap, and turpentine; (iii)The potential for
contamination of storm water from the immediate process areas; and (iv)The extent to which
segregation and/or collection and treatment of contaminated storm water from the immediate process
areas is appropriate.
4. The permittee must amend its BMP Plan whenever there is a change in mill design, construction,
operation, or maintenance that materially affects the potential for leaks or spills of spent pulping
liquor,turpentine, or soap from the immediate process areas.
S. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP
Plan is prepared and,except as provided in Section BA., once every five years thereafter. As a result
of this review and evaluation, the permittee must amend the BMP Plan within three months of the
review if the mill determines that any new or modified managementpractices and engineered controls
are necessary to reduce significantly t liklike��ood o =spent ulping ai nor, Opp,-an rpentne eaks,
spills or intentional diversions from t ih mined t rocess a eas /S�u ding a schedule for
implementation of such practices and ¢ntrols.) J //
6. The BMP Plan, and any amendments h reto,mist b�re 16 ed yrth&s is cc mcal man ger at the
mill and approved and signed by the rii I ma a�er.my p rson Wing he MP Plan or iIs
amendments must certify to the Divis onsnder per a ty of I&W Lt the BMP, lan(or its amendments)
has been prepared in accordance with good engineering practices and in accordance with this
regulation. The permittee is not required to obtain approval from the Division of the BMP Plan or any
amendments thereto.

Permit Number: NC0000272
Section C. BMP Recordkeeping Requirements
1. The permittee must maintain on its premises a complete copy of the current BMP Plan and the
records specified in Section C.2 and must make such BMP Plan and records available to the Division
for review upon request.
2. The permittee must maintain the following records for three years from the date they are created: (i)
Records tracking the repairs performed in accordance with the repair program described in Section A;
(ii)Records of initial and refresher training conducted-in accordance with Section A; (iii) Reports
prepared in accordance with Section A; and(iv)Records of monitoring required by Sections A and E.
Section D. Establishment of Wastewater Treatment System Influent Action Levels
1. The permittee must conduct a monitoring program per Section D.2, for the purpose of defining
wastewater treatmentrsystem influent characteristics or action levels , described in Section D.3 that
will trigger requirements to initiate investigation on BMP effect veness and to to a corrective action.
2. The permittee must etnp oy—the following procedu r& in order to deVelop the action levels rerzethe
y
S ction D: � } � /
• Monitoring parameters.The permittee must/ ollect�2 ;hour Iomposite samples and analsamples for a measur' orgairic content�(e.g;Ehemical Ox,'ge Demand(COD)or {o
Organic Carbon 'r6C)). Aliemutivelygiie/mill-ma)vse\a meas re related to spent pulp g liquor
ure losses easd continuously na average over 24 hours (e. pecifrc conductivity r olor).
• nitoring locations.The permittee must conduct monitorin,a the point influent en ersi the
stervvater treatment system. For-thie-purposes of this regIiirement,the permittee ma elect
alternate monitoring point(s) in order to isolate possible sources of spent pulping liquor, soap, or
turpentine from other possible sources of organic wastewaters that are tributary to the wastewater
treatment facilities(e.g.,bleach plants,paper machines and secondary fiber operations).
3. By the permit effective date,the permittee must complete an initial six-month monitoring program
using the procedures specified in Section D and must establish initial action levels based on the
results of that program.A wastewater treatment influent action level is a statistically determined
pollutant loading determined by a statistical analysis of six months of daily measurements. The action
levels must consist of a lower action level,which if exceeded will trigger the investigation
requirements described in Section E, and an upper action level,which if exceeded will trigger the
corrective action requirements described in Section E.
4. By January 15,2002, the permittee must complete a second six-month monitoring program using the
procedures specified in Section D and must establish revised action levels based on the results of that
program. The initial action levels shall remain in effect until replaced by revised action levels.
5. Action levels developed under this Section must be revised using six months of monitoring data after
any change in mill design, construction, operation, or maintenance that materially affects the potential
for leaks or spills of spent pulping liquor, soap, or turpentine from the immediate process areas.
Section E. BMP Monitoring, Corrective ction a d Re Ie o�rti�e uirements
1. The permittee must codduct daily moq'i oring f,h 3nfluen o thI�4\s\� ewa ertreatment s rtemin
accordance with the procedures descnb d in S�c io otthe pddSuse'o�detecti�eaks nh spills,
tracking the effectiveness of the BMP$,Hai nd detects tren st'n p�rentt ppulpmg iquor losses
2. Whenever monitoring results exceed the loy a mti level o, �e period ofitune specific .1 the
BMP Plan,the permittee must conduct an investigation to determine the cause of such exceedance.
Whenever monitoring results exceed the upper action level for the period of time specified in the
BMP Plan,the permittee must complete corrective action to bring the wastewater treatment system
influent mass loading below the lower action level as soon as practicable.
3. Although exceedances of the action levels will not constitute violations of an NPDES permit, failure
to take the actions required by Section E.2 as soon as practicable will be a permit violation.

Permit Number: NC0000272
4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to
Section E.1. Such reports must include a summary of the monitoring results,the number and dates of
exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to
respond to such exceedances. Submission of such reports shall be annually, by March 31"of the
following year.
Section F. BMP Compliance Deadlines
1. The permittee is subject to the following BMP deadlines:
• Prepare BMP Plans and certify to the Division that the BMP Plan has been prepared in
accordance with this regulation not later than the permit effective date.
• Implement all BMPs specified in Section A that do not require the construction of containment or
diversion structures or the installation of monitoring and alarm systems not later than the permit
effective date.
• Establish�nitial action levels req 'red by Sec ion not later han the ermit a fective date.
r--�
• Commence�cperatio�t of any new o[[upgrade c6t nuous, an omatic monitoring systems that the
mill dete Ines to be necessaryim er Section A., (other than I hose associated with construction of
containment ordive Sion structure)not later(han the permit�effective date.
• Complete cc structim and commence operation o�ar� spen pulping liquor, collection,
containment(diversion, oi-ot er facilities; including an associated continuous monitoring
systems a essary't�fully ii pl� nt BMPsspeeifi\p Se �tion A not later than the i eirit
y \b
effectiv da�e.
EM151is revised action levels re red b/Section D ads s on as�ossible after fully implementing
the-BMPs specifi- n Section A, 4hot later than January 15;2002. CJ
Submit Annual Reports required by Section EA to the Division by March 31`of the following
year.
Section G. BMP Definitions
1. Action Level: A daily pollutant loading that when exceeded triggers investigative or corrective action.
Mills determine action levels by a statistical analysis of six months of daily measurements collected at
the mill. For example,the lower action level may be the 75th percentile of the running seven-day
averages(that value exceeded by 25 percent of the running seven-day averages) and the upper action
level may be the 90th percentile of the running seven-day averages (that value exceeded by 10
percent of the running seven-day averages).
2. Division: North Carolina DENR, Division of Water Quality, 1617 Mail Service Center,Raleigh,
North Carolina 27699-1617.
3. Equipment Items in Spent Pulping Liquor, Soap,and Turpentine Service: Any process vessel, storage
tank,pumping system, evaporator, heat exchanger, recovery furnace or boiler, pipeline,valve, fitting,
or other device that contains, processes,transports, or comes into contact with spent pulping liquor,
soap, or turpentine. Sometimes referred to as"equipment items."
4. Immediate Process Area: The location at the mill where pulping, screening knotting, pip washing,
pulping liquor concentration, pulping liquor prgces i g,a�� hem( as recov facilities-ark locAted,
generally the battery limits of the afor entio)ed r cesse$. 'Imm• dtlihte prlo�es:area" inullides spent
pulping liquor storage and spill contr I anks I tAdLLLLLLat they ill, i �et�i�r or bt the are 1 �clated in the
immediate process area.
5. Intentional Diversion:The planned rerr�� v�I of s e I t pu�lpi I 'uor so o tu' rpentine fr�
equipment items in spent pulping liquor soap or turpe' ntinesede by the ;mill for any pulp�ose
including, but not limited to, maintenance, grade changes,or process shutdowns.
6. Mill: The owner or operator of a direct or indirect discharging pulp, paper, or paperboard
manufacturing facility subject to this section.
7. Senior Technical Manager: The person designated by the mill manager to review the BMP Plan. The
senior technical manager shall be the chief engineer at the mill,the manager of pulping and chemical

Permit Number: NC0000272
recovery operations, or other such responsible person designated by the mill manager who has
knowledge of and responsibility for pulping and chemical recovery operations.
8. Soap: The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the
wood, which precipitate out when water is evaporated from the spent pulping liquor.
9. Spent Pulping Liquor:For kraft and soda mills "spent pulping liquor" means black liquor that is used,
generated, stored, or processed at any point in the pulping and chemical recovery processes.
10. Turpentine: A mixture of terpenes,principally pinene, obtained by the steam distillation of pine gum
recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft
pulping process. Sometimes referred to as sulfate turpentine.
DD 1 �
LD
D -RA

Permit Number: NC0000272
A. (7.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION
The bleach plant effluent samples (Outfalls 002 and 003)shall be analyzed for 2,3,7,8-TCDD in
accordance with EPA Method 1613. A single sample,from each of the bleach plant effluents, may be
analyzed to determine compliance with the daily maximum effluent limitation.
The bleach plant effluent samples (Outfall 002 and 003) shall be analyzed for the 12 chlorinated phenolic
compounds in accordance with EPA Method 1653. A single sample, from each of the bleach plant
effluents,may be analyzed to determine compliance with the daily maximum effluent limitation. The
Minimum Levels for each of the 12 chlorinated compounds are the same as the Daily Maximum
concentrations listed on the effluent pages for the respective outfall(s).
The final wastewater treatment plant effluent sample (Outfall 001)shall be analyzed for AOX in
accordance with EPA Method 1650, or subsequent test methods approved by the Division.
Tl�e permittee-�na request g modifica�t''o s to the Effluent Guideline requirement
inclining 1) use•of ECF cert fication iAeu of monitoring�?r chloro'orm in the bleach plant cffl ents
(Oiu ll(s) 002 and 003)whn this rules promulgated by\EP`A;2)demonstrating compliance�stg
samp es collected,less frequently-tha every four hours; 3)wsmg automated composite volatile samplers
fo cliloroform samplling;land-4)-ugingd61omated/( ositL s�nplers for ehlorophenolic, 2,3, ,8 TCDD
an 2I3,7,8 TCDF sainpling.� Such tur\requesis will be evalu ted in accordance with 15A2i.0 1 � Ind
ITheflow calcpla ions for internal Outfal (s) 0 2 003 shall not be subject to accuracy requ�rements
specified under Part II, Section D.3. This exclusion is similar to that provided for pump log flow
calculations.
Chemical data for Effluent Guideline parameters (Outfall(s) 002 and 063 parameters+AOX from Outfall
001) shall be submitted to the Division on a quarterly basis or more frequently (January-March,April-
June, July- September, October-December). Quarterly submissions shall be due 60 days following the
last day of each quarter(Due dates=May 31, August 31,November 30, and February 28). Chemical data
shall be submitted on Division-approved DMR forms,with a separate form provided for each month.
D j %A

Permit Number: NC0000272
A. (8.) REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE SPECIAL CONDITION
1. The average daily discharge of true color for each calendar month shall not exceed 55,000 pounds per
day. The annual average effluent true color loading shall not exceed 48,000 pounds per day. For the
purpose of this permit/variance only, "pounds of true color" is calculated by the following equation:
Effluent Flow(mgd)x Effluent True Color Level
(Platinum Cobalt Units)x 8.34.
2. All samples collected for color analysis and for use in the above calculation shall be measured and
reported as true color and apparent color using the procedure referenced in FR 39 430.11 (b) (May 29,
1974)-true and apparent color or as amended by the EPA.
3. ul e_Rid'ge,Paper has a red y egu`n he process of icientifying an imp ementrng posst a process
optimization measures ti clt cair-be taken to fucfhdr reduce colordischfi gas Prom`the rnlll.
permittee is directed to continue evaluating mi1L/opleatt4ons with he goal of fully identifyi�pg
opportunitiest€or,preve ing and controlling measarablAlack liq, of leaks and spills(Besf
Management Practices-BMPs}_§ucli BMPsAnclude`burare not lliri ited-ro.
>I Continuous improvement,Qf oR eating practices `or`leak) al d spillsare recovere i ra her than
discharged to sewers \\\
➢; Improvement in preparation for planne�outages to maximize ca ture of tank clean-out vJaste and
routing to recovery;
eductin of clean I ater that continuo-us ly runs into se e s tb prevent dilution of smilllel spills
and facilitate recovery of highly colored wastewaters; and
Improvement in the equipment used for handling of knot rejects to prevent black liquor leaks into
the recovery sumps.
4. By October 1, 2003,Blue Ridge Paper shall submit to the North Carolina Division of Water Quality a
report including a statistical analysis of the Blue Ridge Paper's monthly average color discharge, mill
performance as related to color, all available data necessary to derive the lowest achievable monthly
average color loading limits. By November 1, 2003,the Division of Water Quality(in consultation
with the Technology Review Workgroup) shall recommend, considering the statistical analysis report
submitted by the permittee and the demonstrated performance of the mill, the lowest achievable
monthly average color loading effluent limitations. The monthly average effluent limit and the flow
criteria used for instream color determined to be achievable shall become effective on December 1,
2003, by written notification from the Director.
5. Beginning December 1, 2003,the annual average discharge of true color shall not exceed 42,000
pounds per day and the monthly average color shall not exceed the limit established according to
Special Condition A.(8.)Paragraph 4.
However, if by October 1,2003,the Division of Water-Quality (DVl+fl), in consultation with-t e
Technology Review Committee, and the NPD`E1S ommitte�agre4 t}at therelare overwhelming
technical, economic, or operational barriers to th ermittee� abi�ity to�attain the2bove-sta�ed color
loading limits, DWQ shall recommend o the P S C- nfmittee,alternate interim-limits tc become
effective December 1,2003. At that tim�,DWlshal recom(rtetid a new effective date for achieving
an annual average color loading limit 4t 2-,O poili5ds per\&,�Ahese recommendations 4 all be
based on what DWQ concludes Blue Ridge Paper can reasonably achieve, giving consideration to the
actual demonstrated color levels discharged and process optimizations implemented pursuant to
The Technology Review Workgroup shall act in an advisory role to the Nortt Carolina Division of Water Quality,
and NC DWQ shall consult with Technology Review Workgroup prior to mg any decisions regarding color
reduction activities at the Canton Mill.

Permit Number: NC0000272 r•
Special Condition A. (8.) Paragraph 3. Based on DWQ's recommendations,the NPDES Committee
will determine the alternate interim limits to become effective on December 1, 2003, and the new
effective date for achieving an annual average color loading limit of 42,000 pounds per day. After the
NPDES Committee's final decision, the NPDES Permit will be modified in accordance with North
Carolina's permitting process.
6. The permittee shall submit to the Division of Water Quality,the Technology Review Workgroup and
the NPDES Committee by December 1, 2003, a report on the feasibility of achieving a target annual
average color loading within the range of 34,000 pounds per day and 39,000 pounds per day. This
report shall include identified process improvements and any other actions that would result in
additional color reductions, actions taken by the permittee to reduce color loading(since permit
issuance), and the technical, economic, and operational feasibility of implementing the identified
process improvements on a continuous or intermittent basis, in order to achieve a target annual
avera a within the range of 34 000 pounds per day and 39,000 pounds dav_The report shall
identi specic economic and impleljtentation issues ssociated iw th the tm royelnents. The re ort
shall also protect expected adds t not al color reduciiori�f�Qr each tectnolog}�e evaluated ul ted and max mum
color reducti n Possible using the iden`fied tec(indlo ies The re ort shall also include a pro osed
schedule for iinp�ementation of pr9Ees5 impro ementss re uired t a hieve an effluent color loading
w'ithin the targeted range. The pe tt�ee shallj�,gvide�hig evaluaiion/report,together with ar updated
report on the estilts of o�gotng a d additiona•l planner-col r reduction a h ties,to the Division of
Water Quality, the Technology Review Workg oup amd Te�IPDES Committee.By Februar} 1, 2004,
DWQ (ink nstOation tiith the Te�ehnology Review Workgroup) 3hall approve or modify Mule Ridge
Papui recommended an for achieving t�34,000—39,b0O-, ouu per day target annua, average.
If the limits determined to be achievable, pursuant to Special Condition A.(8.) Paragraph 7, by the
Division of Water Quality(in consultation with the Technology Review Workgroup) are not within
the target range,the Permit shall be modified in accordance with North Carolina's permitting process
to reflect those limits.
7. By December 1, 2005,Blue Ridge Paper shall submit as related to the implementation of the process
improvements evaluated according to Special Condition A. (8.)Paragraph 6, a statistical analysis of
Blue Ridge Paper's effluent and a feasibility report on color reduction technologies associated with
the Chloride Removal Process. This report shall include a statistical analysis of the Blue Ridge
Paper's monthly average and annual average color discharge,mill performance as related to color, all
available data necessary to derive the lowest achievable annual average and monthly average color
loading limits. By January 1, 2006, the Division of Water Quality(in consultation with the
Technology Review Workgroup)shall recommend, considering the statistical analysis report
submitted by the permittee and the demonstrated performance of the mill,the lowest achievable
annual average and monthly average color loading effluent limitations. If the limits determined to be
achievable are within the target range established pursuant to Special Condition A.(8.) Paragraph 6,
the limits shall become effective on March 1, 2006, by written notification from the Director. If the
limits determined to be achievable by the Division of Water Quality_(in consultation with the
gY Workgroup) P gl? I g ge,the'llSennit hale Ibe mfied to
Technology Review Work rou are Jot wit t th tar et.
accordance with North Carolina's e I�ttin Ir ce� to refl`ec�t thosse�I" its.
This report also shall evaluate and reportt on coa r duto�techn/d �e as oct' 'ated with tie Chloride
Removal Process(CRP)wastestream.� he C - an�alysts � I cop e�to o� the technical,
economic, and operational feasibility f._impleinen"Ig the Me }" ied tee tnb(o�ies. The report shall
identify specific economic and implementation issues associated with the improvements. The report
shall also project expected additional color reduction for each technology evaluated and maximum
color reduction possible using the identified technologies. The Division of Water Quality (in
consultation with the Technology Review Workgroup) shall evaluate the feasibility of implementing
identified technologies for further color reduction and shall submit to the NPDES Committee by

Permit Number: NC0000272
December 1, 2005,DWQ's recommendations regarding color reductions associated with the
treatment of the CRP wastestream.
8. By March 1, 2006, the permittee shall submit a report to Division of Water Quality,the Technology
Review Workgroup and the NPDES Committee on the comparative evaluation of the color reduction
efforts as part of the Variance review process (Triennial Review of North Carolina's Water Quality
Standards). This report shall also include an evaluation of color in the Pigeon River at the Fiberville
Bridge, and an evaluation on the feasibility of complying with North Carolina's Color Standard.
9. The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco
USGS gauge station. The new effluent limits in this permit are more stringent than the provisions in
the 1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is
possible to calculate the monthly flow at the Canton gage station above which instream color at the
Fiberville Bridge will not exceed 50 true color units. Using the 55,000 pounds perms monthly
average true color loadin limit im lemented on the effective date of the ermit the flow at the
Canton s ation,�w ich�owi&for color legs han 50 true Dolor units at the Fbervil e Bridge
is 171.8 MUD. �herefo e, the monthlylaverage/coioi.m�the Pigeon rver at the Fiberville Badge will
be less than 54 true c�lo units whenever the mbnthly}average flow !at the Canton gage static ) is
greater than I 1.�MGD. b i }
10! The governing flow w Iriterion for rue color at Canton-is 58.2 MGD (30Q2 stream flow). The flow
established4upuant'to §pecial Condition A. (B.) Paragraph`9, islgreater than this 30Q2 stream flow,
tli-erefore, for flows less than the 171,8�dl)at the Canton Uage tation but greater than 1i93�3 MGD
—(30Q2-flo�t the Hepco gage station,—the-rnonthly average-coloHn the Pigeon River at Hepco will
be less than 50 true color units.
11. Beginning December 1, 2003,the monthly average color in the Pigeon River at the Fiberville Bridge
will be less than 5.0 true color units whenever the flow at Canton is greater than the flow established
using the following equation and based on the monthly average effluent limit established per Special
Condition A.(8.)Paragraph 4:
(Monthlykerage_Effbent—Color Limitjb/day-12468.3)
Flow_at_Ca�ton_USGSiNIGD)= — +31.6+2.4
308.58
For flows at the Canton Gage station.less than the flow established here but greater than 193.3 MGD
at the Hepco gage station,the monthly average color in the Pigeon River at Hepco will be less than 50
true color units.
12. The potential exist that there could still be periods of time corresponding to periods of lower flow in
the river,when color at Fiberville might exceed 50 true color units. Therefore, the permittee shall
continue to implement the approved Low Flow Contingency Plan for mitigating the occurrence and
degree of these potential exceedences. _
rn1 �1 . �--
13. The permittee shall not increase the mil s�pul roduction capact /du mg t g term of this permit,
unless the permittee can demonstrate�ha't the c eese�tp,oductio> a he a(hte`ve-while reducing
color loading. In addition, increasing th, ,e mill��u�p;prodb q:capaclma . require perm�t revision
in accordance with North Carolinas DEES,P/'ermu+r,ng ru es.
14. The NPDES Permit shall be subject to reopening in order to modify the color requirements based
upon the following and in association with the required triennial reviews:
➢ Any breakthrough in color removal technologies. Such breakthroughs shall be brought to the
NPDES Committee for consideration, by Blue Ridge Paper and the Division of Water Quality, as
soon as they are discovered.

Permit Number: NC0000272
An acceptable statistical analysis of effluent color discharge data demonstrating significantly
better color removal performance than that currently prescribed in the variance and permit.
Successful application of end-of-pipe color reduction technology or in-mill color minimization
effort that results in significant and measurable reduced mass color discharge.
15. The transfer of this NPDES permit will not proceed until any successor—in—interest to the current
owner has agreed to accept the provisions of this permit and request and received from the NPDES
Committee a transfer of 2001 Revised Color Variance.
U \v
RA

�i
Permit Number: NC0000272
A. (9.) DIOXIN MONITORING SPECIAL CONDITION
The permittee shall perform the analyses for 2,3,7,8 TCDD and 2,3,7,8 TCDF as outlined below:
SainplingPoi Wn"itoring,
Re_-ti r -inents
s Measurement, Sampleiype ,
Fre uenc"i
Influent to Wastewater Quarterly Composite
Treatment Plant
Effluent Quarterly Composite
Sludge Annual Composite
L��andfi�ll�L�eachate Annual Composite ��
The samp' les shall lie analyzed fo,3�8- '�CDD apel ,
8 TCDF in actor' dance with EPA ethod
1613.1 A single sample may�be analyzed. 4lternatilsample volumes may be collected to enable
th sample to be split(du lieate.analy s)JIhe Mi} ittaum I in the e luent for-2,3,7,8-TC D and
2,I,7,I TCDF by PA Meth $ 13 i�3'0 pg/l.
� \ /
If ,31,7,8 TCDD or 2,37, TCDF'u�e�etected�nn the effluent above the quantitation le el the
permute eshadi hate note frequent\m—om�ng of sludge and iu fill leachate.
Additional Requirements
Fish tissue analysis shall be performed in accordance with the Division of Water Quality approved
monitoring plan, which will be reviewed as necessary. The monitoring plan is an enforceable part of this
permit. All dioxin data collected as part of this monitoring requirement will be reported as required in the
plan, no later than 180 days after sampling.
D L)
J \

Permit Number: NC0000272
A. 10. DISSOLVED OXYGEN SPECIAL CONDITION +
( )
The permittee shall maintain an average daily dissolved oxygen concentration of not less than 5.0 mg/1
with a minimum instantaneous value of not less than 4.0 mg/1 at River Miles 62.9 (DN1) and 57.7 (DN2).
The permittee shall 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, as necessary, to comply with this
requirement. 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. Blue Ridge Paper shall report the
date and duration of oxygen injection use as a supplement to the monthly Discharge Monitoring Report
(DMR)forms. If the dissolved oxygen drops below 5.0 mg/L at station DN2 then monitoring shall be
required at stations DN3 and DN4.
A. (11.) TOWN OF CANTON INFLOW AND INFILTRATION SPECIAL CONDITION
The-permitte,e shall maker or orts to promote-re uction of i flawlinfiltration to-thesown-of
Cant n s—wastewvla er coll ections-yst=..\ /J�`
A. (12� ) A El LE RESERVO R SAMP 1 G S ECIAL CONDITION
// .
Sampling for Waternlle Reservoirshall�eI conducte�onch aannuallyun1tig2002-atid 2004. S I
ling
shall.�e performed dsring a ow-flow�enods to corresponcj with the is tissue-study (see A. ( ) toxin
M�niioring Special�ond�ti�n). \\ 46ir
�Sa piing shall,be performe at Waterv\ille Res prior to a rel ranch, Waterville Reservoir near
W lkins ree and Watervil e Reservoir nX&dam. Each loc�aion�all be sampled for the following
pararni;ters:�•
I PARAMETEhS ,
Temperature
Dissolved Oxygen
Conductivity
pH
Total Nitrogen
Nitrite+Nitrate
Ammonia
TKN
PO4
Total Phosphorus
Chlorophyll-a
Secchi Depth
All samples shall be collected at 0.1 meters beneath the surface of the water in the lake.
A. (13.) TEMPERATURE VARIA ERE L PECI CO ION r
� i �, I ��
During the next permit renewal, Blue Rid Paper Ishal camp' e an analyg i of em er tuTanshall
submit a balanced and indigenous specieperature/variande
dy, no 1/at r aha \May 1:,2007 s arty f this anAl sis, Blue
Ridge Paper shall submit a complete temL repo nd men t G need for a y�optinned
temperature variance. LJ L1 LI LJ
The study shall be performed in accordance with the Division of Water Quality approved plan. Request
for revisions to this plan shall be submitted for approval no later than March 1, 2005. The temperature
analysis and the balanced and indigenous study plan shall conform to the specifications outlined in 40
CFR 125 Subpart H and the EPA's Draft 316a Guidance Manual, dated 1977.

Pe ar..fr';!ent of Enviro(tment and Natural Resources oFVAre
F
l� ality �
1 ll
ac� S�' s Permit NC0000272 0 <
Facility Information
Applicant/Facility Name4: Blue Ridge Paper Products Inc.
Applicant Address': P.O. Box 4000
Facility Address": 175 Main Street
Permitted Flow2,4'7: 29.9 MGD
Type of Waste ,'J: Industrial, domestic, stormwater, and landfill leachate
Facility/Permit Status': Renewal
Coun&.4,1: Haywood
Miscellaneous
Receiving Stream2,': Pigeon River
Stream Classifications': C
303(d) Listed?': Yes - Fish Advisory, Dioxins
Subbasin2: 04-03-05
Drainage Area (mi2�: (calculated] 130 mil
Summer 7Q10 (cfs) . 52 cfs at Canton and 120 cfs at Hepco
Winter 7Q10 (cfs)': 63 cfs at Canton and 183 cfs at Hepco
Average Flow (cfs)': 325 cfs at Canton and 677 cfs at Hepco
IWC (%): 100% (See Text Below)
Primary SIC Code: 2621
Regional Office: Asheville
USGS Topo Quad: Canton(E 7 SE - State Grid)
Permit Writer: Michael Myers
Date: July 24, 2001
SUMMARY
Blue Ridge Paper Products Inc. has requested renewal of their National Pollutant Discharge Elimination
System (NPDES) discharge permit NC0000272 allowing discharge of industrial, stormwater, municipal
and landfill leachate wastewaters to waters of the state. The NPDES permit will expire on November
30, 2001 and the application for renewal was received on February 23, 2001. This fact sheet
summarizes the rationale used to develop the North Carolina Division of Water Quality's
recommendations for the draft permit.
BACKGROUND
Blue Ridge Paper is an employee-owned and operated integrated, elemental chlorine free (ECF)
bleached kraft pulp with oxygen deligninifcation and bleach filtrate recycle, and paper mill in Canton,
North Carolina. Processes at the mill include a pine bleach line; hardwood bleach line, paperboard and
fine paper production lines. Pine and hardwood chips are transported to the site via rail or truck and
subsequently processed into pulp for paper or paperboard production.
In or around 1990, Champion International Corporation (Champion Paper -now Blue Ridge Paper)
initiated a $300 million dollar modernization project termed the Canton Modernization Project. This
project eliminated the use of elemental chlorine and implemented significant changes to both the pine
and hardwood bleaching lines.
The mill upgrade included two changes that dramatically improved the mill's environmental impact.
The first major change was the use of oxygen delignifrcation. This process is used to separate the
lignin from the fiber. This resulted in significant improvement in the mills environmental performance.
The second major change was the implementation of full-scale bleach filtrate recycle (BFR) on the pine
bleach line and caustic extration stage (E.) filtrate recycle (-20%) on the hardwood bleach line. For a
Fact Sheet
NPDES Renewal
Page 1

more detailed description of the mill improvements, refer to the Canton Modernization Project Section
below.
The Canton Modernization Project greatly reduced the wastewater generated and eventually discharged
to the Pigeon River. Even with these improvements, significant quantities of wastewater are generated
in the production of pulp and paper and proper treatment prior to discharge is required.
Wastewater generated by the Canton Mill, along with the Town of Canton's domestic wastewater, is
treated at Blue Ridge Paper's Wastewater Treatment Plant. The treatment plant is a 29.9 MGD
wastewater treatment system consisting of the following unit processes:
• Grit Chamber
• Bar screens
• Lift pumps
• Polymer addition
• pH control (CO2 injection or H2SO4 backup)
• Three primary clarifiers (one normally off-line)
• Nutrient feed
• Aeration basins
• Three secondary clarifiers
• Residual belt presses
• Effluent flow measurement
• Cascade aeration (with oxygen injection)
• Oxygen injection facilities
Solids at this facility are deposited into a dedicated landfill.
The history of this mill, under the ownership of Champion Paper and now Blue Ridge Paper, has been
controversial. Under Champion Paper, the environmental impacts of the Canton Mill were noted by
concerned citizens, environmental groups, the State of Tennessee, State of North Carolina, and the
United States Environmental Protection Agency (EPA). The issues raised by these individuals and
groups contributed to the Canton Mill's improved environmental performance and resulted in a
settlement agreement issued January 8, 1998. Today the relationship among the various stakeholders
has evolved to one of cooperation. The Division commends all the groups for their willingness to work
together to improve water quality. This permit has centered around four main issues emanating from
the mill's discharge: color, temperature, oxygen consuming waste and dioxin, and a brief synopsis
follows.
Color
On July 13, 1988, Champion Paper was granted a variance from North Carolina's narrative water
quality standard for color, which the EPA interpreted to be 50 color units. The EPA subsequently
issued a NPDES permit to Champion Paper facility in Canton, North Carolina.
In 1994, the EPA returned NPDES permitting authority for the Canton Mill back to North Carolina's
Division of Water Quality. During the permit renewal the original color variance was modified and
both were issued around December 11-12, 1996. As outlined above, over the course of this variance
the mill has initiated significant improvements, which have dramatically reduced the color loading and
other effluent characteristics.
Though the mill has made tremendous strides, color continues to be the focal point surrounding this
permit. The EPA chaired Technology Review Workgroup have recommended additional color
reduction for the up coming permit cycle. The recommendations issued by the Technology Review
Workgroup included the findings of a third party evaluation of Blue Ridge Paper's Canton mill and the
report issued by the EPA Tech Team'. The evaluation conducted by Dr. Norm Liebergott was co-
sponsored by Blue Ridge Paper and several environmental groups and provided valuable information
for the TRW'. In addition, to identifying areas for improvement and available technologies, Dr.
Liebergott compared the Canton mill to similar mills around the world. Dr. Liebergott concluded that
the Canton mill's environmental performance is among the best in the world.
Though incredible work has been done, there continues to be a need to reduce color further. Blue
Ridge Paper's openness and willingness to work towards continued improvements has resulted in an
atmosphere of trust and cooperation among all the interested parties. This cooperation has been
extremely valuable and will continue to be critical as the additional color reductions recommended by
the Technology Review Workgroup are implemented (see attached July 24, 2001, memo from the EPA
Tech Team to the Technology Review Workgroup).
Fact Sheet
NPDES Renewal
Page 2

The Technology Review Workgroup report identifies process improvements that will result in permitted
color reductions of 6,000 pounds per day. In addition, the report identifies process improvements that
will require further study but are likely to result in total color reductions in the range of 9,000 - 14,000
pounds per day. The mill will also evaluate the feasibility of treating the highly colored low flow
wastestream from the chloride removal process (CRP). The feasibility of additional color reductions
associated with the treatment of the CRP wastestream is highly uncertain and no color reductions have
been established for this permit cycle. The result of a feasibility study on the Chloride Removal
Process wastestream will be evaluated for possible additional color reductions for the next permit cycle.
As shown in Table 1, the 6,000 pound per day annual average color reduction will become effective on
December 1, 2003. Additionally, the mill will evaluate additional process improvements in order to
achieve an annual average effluent color loading of 34,000 - 39,000 pounds per day. If the limits
determined to be achievable are within the target range,the limits shall become effective on December 1,
2005, by written notification from the Director. In the event that the achievable limits are outside of this
range then the NPDES will be reopened. At that time,public comments will be.gathered and the permit
may be modified.
Table 1. Major Dates for Compliance/Reports.
Submittal/Compliance ate Requirement
2002 1-is issue Study Report
October 1,2003 Statisticalevaluation ot pertormance tor determination ot the monthly
average effluent color limit
December 1, 2003 First reduction in effluent color limit
December 1, 2003 keasibility report on additional process improvements tor further color
reductions
2004 is issue Study Report
December 1,2005 Statisticalanalysis and feasibility report on treatment of UXF
wastestream
March econ reduction in effluent color limit
March omparative Evaluation Report
May 1, 2006 Balancedand Indigenous Species Study Report
Temperature
The facility first requested and received a 316 (a) variance (approved by EPA) for temperature on
August 6, 1985. This determination demonstrated that the effluent limitations relating to the thermal
.component of the Champion discharge were more stringent than necessary to assure protection and
propagation of a balanced indigenous population of shellfish, fish, and wildlife in the Pigeon River.
Therefore, the 316(a) determination was approved based on protection of the appropriate use
classification of the Pit eon River. The temperature variance was reviewed and renewed as part of the
Triennial $ }r'e}ti 1• 9-
�,'
•'; j } 4I 31ue Ridge pl si1! " d a Balance and Indigenous Species Study on the Pigeon River on June 1,
2001. DWQ scien 'L-viewed the report and concluded that continuance of the temperature
,variance is approp � t ; -irefore, the Division of Water Quality is recommending continuation of the
temperature variariesa *itti�';porting requirements consistent with the previous permits (see Table 1).
' I "Oxygen Consuming Waste{'{'
t' �Ip o e�?irredicted that even with a BODS' loading of 12091b/day (5.0 mg/L at 29
¢ ;sl �:. Yx � l, xygen in the Pigeon River would not be protected. Since Blue Ridge Paper
Ic,t' j�1 1, � afi'Juch trmgent limitations, an instream method was implemented to protect the
assolved oxygen in th ra,ceiving stream. For further discussion on this subject refer to the
' !; conventional pollutants ' 'lion below.
Dioxins
Elevated levels of dioxins were found in fish tissue in the Pigeon River (around the late 1980s).
Subsequently, a fish consumption advisory was issued for sport fish, catfish and carp. The Canton Mill
has not discharged any detectable levels of 2,3,7,8 TCDD to the Pigeon River (since 1989) and dioxin
in fish tissue continue to decline. Currently, a fish consumption advisory continues for carp and
catfish. North Carolina has lifted the advisory on sport fish. However, the State of Tennessee
continues to post a precautionary fish consumption advisory for carp, catfish and red breasted sunfish.
' BOD5 is an analytical method used to estimate the biochemical oxygen demand.
Fact Sheet
NPDES Renewal
Page 3

The fish consumption advisories in North Carolina and Tennessee are currently under review for
possible modification of the advisories. The North Carolina Division of Environmental Health (DEH)
has initiated a review of the fish consumption advisory on Pigeon River and Waterville Lake. DEH is
evaluating dropping the advisory on catfish in the North Carolina portion of the Pigeon River and
limiting the advisory on Carp to Waterville Lake. A final determination may not be finalized prior to
permit renewal, therefore, recommendations presented in this permit do not reflect this evaluation.
STREAM CONDITIONS
The facility discharges to the Pigeon River near Canton, North Carolina. The Pigeon River rom
Canton to Hurricane Creek is listed as an impaired water, according to North Carolina's 20 Draft
303(d) List, due to a fish consumption advisory for dioxins. Recent data indicate that the di` j in levels
in fish tissue continue to decline. There has been no detection of 2,3,7,8 TCDD in sport fis 'since
1995 and below North Carolina's fish consumption advisory level for 2,3,7,8 TCDD in catfish since
1997, based on Blue Ridge Paper's data. 2,3,7,8 TCDD continues to be detected in carp, though levels
continue to decline and are below North Carolina's advisory level.
The Pigeon River has been experiencing extremely low flows, due to extended drought conditions in
the western part of the state, with flows often less than the 7Q10 flows of 52 cfs (near Canton). Curtis
Weaver, with the USGS, provided the updated low flow statistics noted above using data from 1933
through 1999. The low flow statistics at Canton include the influence of Lake Logan, which was
constructed in 1932 and the influence of both Lake Logan and Lake Junaluska (constructed in 1913).
This reflects the current hydrography within the watershed and does not reflect conditions prior to
construction of the lakes.
The impact of this reevaluation of the low flow statistics is that the lowest seven day average flow
expected once in ten years (7Q10) has been reduced from 54 cfs to 52 cfs. This affects the instream
waste concentration which is used to determine the limits for the toxicity testing (discussed later).
INSTREAM MONITORING
The current permit requires Blue Ridge Paper to conduct an extensive instream monitoring program
consisting of 12 monitoring sites (1-upstream of mill in Pigeon River, 3-Waterville Reservoir, and 7-
downstream of mill in Pigeon River and 1-Big Creek; See Figure 1 and Table 2).
Instream Monitoring by Parameter
Blue Ridge Paper is required to monitor fecal coliform upstream (at station UP) and downstream of the
discharge (at station DNI). Analysis indicates no discernable difference between the upstream and
downstream fecal conform levels. Upstream fecal coliform is generally in the range of 100 to 200
/100m1. The same trend is evident at the downstream sampling point. These data suggest that Blue
Ridge Paper does not contribute significant levels of fecal coliform. Monitoring of the effluent is
sufficient to monitor the mill's impact on the river. Blue Ridge Paper has volunteered to conduct
upstream sampling and this requirement will remain as a condition in the permit. Thus, the Division's
recommendation is the elimination of the downstream fecal monitoring and once per week fecal
monitoring upstream.
Blue Ridge Paper is required to monitor conductivity upstream (at station IJP) and downstream (at
station DNl). There is a significant increase in conductivity between the upstream and downstream
monitoring sites. Conductivity measurements are less than 50 umhos/cm2 at the upstream monitoring
station and generally greater than 250 umhos/crn' at the Fiberville Bridge. This increase in
conductivity is expected since conductivity is a measure of inorganic material. Thus, the Division's
recommends that conductivity monitoring continue as required.by 15A NCAC 2B .0508(d).
Fact Sheet
NPDES Renewal
Page 4

Figure 1. Instream Monitoring Stations for Blue Ridge Paper Products — Canton Mill.
/Station]o-xcrtx u., r
Ste don 25 o-ee...alp cn..
f
01 ..TSi
SMWM e].7-Above Clyde
to I. andC eh
Su0Pn02.e-F%.MH&Bride.
M1ein B.d-UP.B..m of B W NIdO.Pepn
USGS Sites
Primary Highways
Pigeon River Hydrography
NPDES Discharger
Municipal boundaries
The facility is required to monitor 5-day Biochemical Oxygen Demand (BODS) upstream at station UP
and downstream of the discharge at the station DN7. Levels of BODS have been less than 2.0 mg/L.
Based on this information and the Division's lack of need for the data, it is recommended that instream
BOD5 monitoring be eliminated from the permit.
Fact Sheet
NPDES Renewal
Page 5

Table 2. Instream Monitoring Requirements According to the 1997 NPDES Permit and Color
Variance.
[ream mile Location Description Parameter Frequency
Designation Marker
UP 3.h Pigeon River upstream of the emperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the BOD5 1/Week
discharge) Conductivity Daily
Color 2/Week
Flow Daily
Fecal coliform I/Week
Pigeon River at P iberville ri ge I emperature Daily
D.O. Daily
Conductivity Daily
Fecal Coliform l/Week
Color 2/Week
Pigeon River Above Clyde emperature Daily
D.O. Daily
Pigeon River Below Clyde TemperatureI/Week
D.O. 1/Week
Color 2/Week
Pigeon River at NCSX 1625 TemperatureI/Week
bridge D.O. I/Week
Color 2/Week
igeon River at Hepco emperaturel/Week
D.O. l/Week
Color 2/Week
Flow Daily
Waterville Reservoir Annually
DN6 26.0 Pigeon River prior to mixing Color2/Week
with Big Creek
Mouth of Big Creek prior to Color 2 Week
mixing with the Pigeon River
Pigeon River at Browns Bridge emperature ee
(—NC/TN State Line) D.O. I/Week
BOD5 1/Week
Color 2/Week
Blue Ridge Paper monitors temperature upstream at station UP and downstream at all monitoring
stations except station DN6 and station BC. Comparing upstream to downstream, see Figure 2, the
temperature difference ranged from between 1.78 °C and 11.65 'C. At no time did the monthly
average temperature of the Pigeon River exceed the permitted limits of 32 °C (summer) or 29 °C
(winter).
Blue Ridge Paper monitors dissolved oxygen (DO) at all the instream stations except station DN6 and
station BC. Over the period of review (1998 —2000), dissolved oxygen did not drop below the North
Carolina's standard of 5.0 mg/L for Class C streams at any of the instream monitoring locations.
Figure 3 summarizes the results of this analysis.
During the previous permit cycle, an EPA-approved computer model indicated that BODs limits were
required to protect North Carolina's instream dissolved oxygen standard of 5 mg/L for Class C waters.
An economically feasible end-of-pipe technology capable of consistently treating to levels necessary to
meet the limits specified by the model did not exist. North Carolina agreed with the continuation of the
requirement that Blue Ridge Paper meet the instream dissolved oxygen standard by use of sidestream
oxygen injection facilities. Blue Ridge Paper maintained these oxygen injection facilities at the effluent
and at approximately 0.9, 2.1, and 3.7 miles downstream of the discharge. The previous NPDES
permit required Blue Ridge Paper to maintain the oxygen injection facilities located 0.9 and 2.1 miles
downstream.
To ensure compliance with the above requirement, the average daily instream dissolved oxygen levels
at stations DN1, DN2 and DN3 were required to equal or exceed 5.0 mg/L and the minimum
instantaneous instream values were required to be greater than or equal to 4.0 mg/l. If dissolved
oxygen drops below the prescribed values Blue Ridge Paper shall utilize the instream dissolved oxygen
injection stations to increase the dissolved oxygen in the river.
Fact Sheet
NPDES Renewal
Page 6

This method fulfilled the requirements of 40 CFR 125.3 (f).
Blue Ridge Paper has compiled an extensive database on instream dissolved oxygen concentrations and
stream flow. These data suggest that the dissolved oxygen sag occurs at station DN2.
Figure 2. Temperature in the Pigeon River Upstream and Downstream of Blue Ridge Paper's NPDES
Discharge.
35
Permitted Limits NC 1i
30 Summer Um!=VC
WutterLmi=29°C ar-C2SC
25
L 20
-Statlon UP
o - Statlon DN,
n +Dena T
c 15
Permi9eED' =13.9°C
,0
5
0
Nov-96 Feb-99 May-99 Aug-99 Deo-99 Mar-00 Jun-00 Oct-00 Jan-01 Apr-01
Time
Figure 3. Average and Minimum Dissolved Oxygen in the Pigeon River from River Mile 63.5 to the
NC/TN State Line. (Average DO* = In (DO))
12.00
10.00
6.00 2
m
E
ii '- Average DO
6.000 a -ill-Minimum
—212ndard
a
> 'Average DO'
0
w
N
4.00 0
4P disebatge N(YIFliNShteLiae
2.00
0.00
70.00 60.00 50.00 40.00 30.00 20.00 10.00 0.00
River Mlle
Fact Sheet
NPDES Renewal
Page 7

Stations DN2 and DN3 were included because the dissolved oxygen model predicted that the DO sag
occurred in this area and because they represented monitoring locations upstream and downstream of
Clyde's discharge. The Town of Clyde has recently removed their discharge and the Division has
received a letter from the Town requesting rescission of the permit. Based on a review of the instream
data and the removal of Clyde's discharge, it is recommended that the dissolved oxygen compliance
point at station DN3 be eliminated.
The Division reviewed the 1998 through 2000 instream dissolved oxygen data. Over this time period,
Canton, North Carolina has experienced extreme drought conditions and flow in the Pigeon River has
often dropped below the updated 7Q10 stream flow. Under these conditions, the lowest dissolved
oxygen level observed in the North Carolina portion of the Pigeon River was 5.0 mg/L and occurred at
river mile 57.7. Additionally, a review of the average daily instream dissolved oxygen data and the
average over this time period indicates that the dissolved oxygen sag occurs at river mile 57.7. Based
on this analysis, the compliance point and monitoring requirement at river mile 55.5 have been
dropped. The oxygen injection facilities will continue to be maintained at the effluent, 0.9, and 2.1
miles downstream, and used as necessary to maintain an instream dissolved oxygen level of 5 mg/l.
The condition to maintain the instream dissolved oxygen stations shall remain a condition of the permit
until such time that the permitted loading of oxygen consuming waste to the Pigeon River is less than or
equal to that proposed by an appropriate water quality model.
If dissolved oxygen at station 57.7 drops below 5.0 mg/L, the facility is required to monitor dissolved
oxygen at river mile 55.5 and 53.5.
Instream monitoring continues to be required in order to assess Blue Ridge Paper 's impact on the
Pigeon River and to ensure that the dissolved oxygen standard is maintained within the river.
COLOR
The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the Hepco
USGS gauge station. The new effluent limits in this permit are more stringent than the provisions in the
1997 Permit and Color Variance and will result in reduced color levels in the Pigeon River. It is possible
to calculate the monthly flow at the Canton gage station above which instream color at the Fiberville
Bridge will not exceed 50 true color units. Using the 55,000 pounds per day monthly average true color
loading limit(implemented on the effective date of the permit)the flow at the Canton Gage station,which
will provide for color less than 50 true color units at the Fiberville Bridge is 171.8 MGD. Therefore,the
monthly average color in the Pigeon River at the Fiberville Bridge will be less than 50 true color units
whenever the monthly average flow(at the Canton gage station) is greater than 171.8 MGD. North
Carolina is recommending that the Fiberville bridge be the basis for the color variance.
The governing flow criterion for true color at Canton is 58.1 MGD (30Q2 stream flow). The flow
established is greater than this 30Q2 stream flow,therefore,for flows less than the 171.8 MGD at the
Canton Gage station but greater than 193.3 MGD at the Hepco gage station, the monthly average color in
the Pigeon River at Hepco will be less than 50 true color units.
Currently, the basis for the color variance is the Hepco station (DN5) within North Carolina, therefore
with the moving of the station from Hepco to Fiberville, DWQ recommends that the mill monitor the
Hepco station 2/week during the summer and once per week during the winter.
During the permit cycle,the effluent color limit will be reduced, therefore, the instream color criteria will
be adjusted accordingly. The monthly average color in the Pigeon River at the Fiberville Bridge will be
less than 50 true color units whenever the flow at Canton is greater than the flow established using the
following equation and based on the monthly average effluent limit established per Special Condition
A.(8.)Paragraph 4:
FlowatCanbnUSGS(MGD) _ (MonthlyAverageEfflueztColorLinit,lb/dcry-12468.3)+31.6+2.4
308.58
For flows at the Canton Gage station less than the flow established here but greater than 193.3 MGD at
the Hepco gage station, the monthly average color in the Pigeon River at Hepco will be less than 50 true
color units.
Compliance Summary
The facility has been in compliance with permit conditions during this cycle.
Fact Sheet
NPDES Renewal
Page 8

Toxicity Testing
Current Requirement: Chronic toxicity limit monitored quarterly @ 87%
In December 1999 the facility reported a chronic level of 81% (with a state split sample greater than
87%), with the following two months greater than 100. All other toxicity tests over the past four years
were greater than the stipulated 87%.
The toxicity testing requirement is placed on all major facilities and other facilities with complex
wastestreams. The toxicity limit is based on the instream waste concentration under 7Q10 conditions
(52 cfs updated April 2001). For Blue Ridge Paper, the instream waste concentration was determined
by also accounting for the out-take of surface water from the facility (31.6 MGD, as per application)
and water withdrawal by the Town of Canton (allocated 6.8 MGD). Therefore, the instream waste
concentration was determined to be 100% under 7Q10 conditions. The Division has set a ceiling on
the toxicity test of 90%. This was done because of difficulties associated with averaging toxicity test
with limits of 100%. The Division feels that 90% is sufficiently stringent to assess the chronic toxicity
of an effluent, while allowing for the averaging of multiple tests.
Recommended Requirement: Quarterly Chronic Toxicity @ 90% Mar, Jun, Sep, Dec
Blue Ridge Paper is required to perform the NC Whole Effluent Toxicity Test or an equivalent method
(as approved by the Division) on a quarterly basis at 90%. Any equivalent method shall also be
performed on a quarterly basis.
Toxicant Analysis
Using the self-monitoring data required per the NPDES permit, reasonable potential analyses were
d t d llowing toxicants: mercury, zinc, cadmium, selenium and silver. The standards
s , ,cq,�}s stem with North Carolina standards for a class C waterbod
f�C�ll � � bl� i � y.
athmrunt )�ised oft e s46, fist nalysis of self-monitoring data, this discharge does not pose a
reasonable potential to cause a vioikiz"a of the North Carolina stream standard for cadmium. Effluent
itor_i e dad iu rt hall continue; ince cadmium continues to be detected in the effluent.
(IJ�i�il1 �� �I # II; If,� 11r11 � 11; �1
Me cur p they�tvisjon��l nfalysis of self-monitoring data, this discharge does not pose a
�9.
reasonable pote t c el,a viol t i f the North Carolina stream standard for mercury.
Add'ti Hall ai> uiy s lesa 'k � d since January 1999 have been below North Carolina's
e '� < n f
dldt6con leve� of b.2 µg/L. Inc ults from the Division's 1996 Fish Tissue Mercury
Ib �} < �yr1�u ;c to Pigeon River indicate, "total mercury results were comparable to `background'
1
1'cv��s exo�e�� ��7or fish across North Carolina." Based on the findings in this report and the
`Reaso a ?e otential' Analysis, it is recommended that mercury monitoring and limitation be removed
permit.
SilJer - Based on the Division's analysis of self-monitoring data, this discharge does pose a reasonable
potential to cause an exceedence of the North Carolina's Action Level Standard for silver. Numerical
limits for silver are not being included since silver is an action level water quality standard and the
biomonitoring requirements are adequate to control toxicity due to the presence of silver. Though no
limit is proposed, if the facility experiences chronic toxicity violations, the discharge will be re-
evaluated and a silver limit may be implemented according to the Division's Action Level Policy.
Selenium — The Division's analysis indicates that the maximum predicted concentration for selenium is
greater than the allowable concentration. This analysis included only seven data points, with six data
points below the quantitation level. One sample indicated the presence of selenium, however the
concentration reported was at the quantitation level for the method. Additionally, the QA/QC data
questions the validity of this data point. However, the Division has limited Blue Ridge Paper for
Selenium. After collecting for one and half years (six data points) of data, the facility can request that
the Division review the Selenium data for possible elimination of the limit.
Zinc - Based on the Division's analysis of self-monitoring data, this discharge does pose a reasonable
potential to cause an exceedence of the North Carolina's Action Level Standard for zinc. Numerical
limits for zinc-are not being included since zinc is an action level water quality standard and the
biomonitoring requirements are adequate to control toxicity due to the presence of zinc in the facility
effluent. Though no limit is proposed, if the facility experiences chronic toxicity violations the
discharge will be re-evaluated and a zinc limit may be implemented according to the Division's Action
Level Policy. Monitoring requirements for zinc are consistent with 15A NCAC 2H .0508 (d).
Fact Sheet
NPDES Renewal
Page 9

OXYGEN CONSUMING WASTE POLLUTANTS
A site-specific Best Available Technology (BAT) based limit was calculated to determine the monthly
average 5 - day biochemical oxygen demand (BOD5) limit. A site-specific BAT approach was used
because North Carolina's Division of Water Quality continues to agree that an economically feasible
end-of-pipe technology capable of reliably meeting the water quality limit specified by the existing
model does not exist at this time and no violations.of the dissolved oxygen standard in the river have
been observed in recent years.
The North Carolina Division of Water Quality's recommendation for the draft permit BODS limit is
established based on the demonstrated level of performance for the existing treatment plant. Data on
treatment plant performance and influent loading from the Canton Mill (1998 through 2000) was
evaluated and examined for outliers. As indicated in the "Bleach Environmental Process Evaluation
and Report", the performance of this mill is among the best in the world. The maximum influent
loading and lowest treatment plant performance were used to develop the monthly average BOD5 limit.
The data set was sufficient to account for the day to day variability of the treatment system.
Over the time period evaluated, the treatment plant has performed extremely well. The lowest percent
removal was 96.9% and the highest influent loading was 414.9 mg/L. Based on this analysis, North
Carolina's Division of Water Quality recommends a monthly average BOD5 loading of 3205.0 lbs/day.
The limit presented in the draft permit represents and a 71-ton per year reduction in BOD5 loading to
the Pigeon River. Because Blue Ridge Paper has oxygen injection facilities in place to maintain the
instream dissolved oxygen standard should instream dissolved oxygen dictate a need, Blue Ridge Paper
complies with the conditions set forth by 40 CFR 125.3 (f).
The methodology used for the daily maximum 5 - day biochemical oxygen demand (BODS) limit was
recommended during the previous permit cycle. A site-specific daily maximum to monthly average
multiplier was used for determination of the recommended daily maximum limit. Using this
methodology and reviewing data since the Canton Modernization Project (1998 — 2/2001) the
recommended daily maximum limit based on a multiplier of 3.4 (daily maximum/monthly average) is
10897 lb/day. The limit proposed represents an achievable level and approximately a 12.5% reduction
in the daily maximum BOD5 limit.
Ammonia monitoring requirements are included in the permit to provide data concerning levels of
ammonia discharged to the Pigeon River (which may affect instream dissolved oxygen).
Effluent dissolved oxygen is limited at no less than 6 mg/1 based on the above discussion. Daily
monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products, Class IV facility.
NUTRIENT POLLUTANT ANALYSIS
Total phosphorus and total nitrogen monitoring is required by 15A NCAC 2b .0508 (d) (2) (A).
Monthly monitoring is required to assess the contribution of nutrients from Blue Ridge Paper and the
potential impact to Waterville Reservoir. Waterville Reservoir is to be monitored once annually
(during opposite years of CP&L's montioring) to assist in the continued characterization of nutrient
impacts to the lake.
� ,",,,,CANTS
4 Rgurrently a fah consgnption advisory due to dioxin for the Pigeon River downstream of the
dtsciE11 A It it a vi was initially in effect for consumption of all fish species, this
x ^p r s e1 , 1 H 1h rY Y P P
. d c arp and catfish species only, reflecting continued improvements in the
l ,n 9'
rr tly, Blue 12t gGG��R� a er required to monitor dioxin and dibenzofuran isomers quarterly from the
influent, sludge, land f1 'ate, and effluent. Based on an evaluation of the data, the Division is
recommending a rev o a pie special condition requiring dioxin and dibenzofuran isomers
monitoring. An improve 11giledge of the dioxin and dibenzofuran isomers indicates that only 2,3,7,8
TCDD and 2,3,7,8 TCDF are pollutants of concern. Therefore, it is recommended that the dioxin
isomer special condition be modified to require monitoring only for 2,3,7,8 TCDD and 2,3,7,8 TCDF.
Fact Sheet
NPDES Renewal
n..-- 1n

It is further recommended that the monitoring frequencies be modified based on the fact that
measurable quantities of dioxins and dioxin isomers have not been detected in the influent (since 1997),
the effluent (since 1996), sludge (since 1996) and the landfill leachate (since 1996).
The effluent limit for 2,3,7,8 TCDD has been reduced. During North Carolina's development of the
Total Maximum Daily Load for Dioxins on the Pigeon River, the EPA commented that the chronic
standard adopted by North Carolina should be applied as an effluent limit at the end of pipe. North
Carolina did not agree with this methodology, since it is inconsistent with the standard and North
Carolina rules. In addition, the management strategy implemented by North Carolina to address
dioxins in the Pigeon River for several years and the data show that this management strategy is
resulting in declining dioxin levels in the Pigeon River. The EPA, NC DWQ and Blue Ridge Paper
agreed that the TMDL requirement could be waived as long as Blue Ridge Paper's effluent was limited
at 0.014 pg/L. Therefore, the dioxin limit has been reduced to 0.014 pg/L and no TMDL will be
developed.
Annual fish tissue analysis shall continue to be performed by the facility in accordance with the
monitoring plan approved by the Division until such time that the fish advisory is lifted in both
Tennessee and North Carolina, according to North Carolina's delisting procedures.
Trichlorophenol/PentacMorophenol limits and monitoring are not required. The permittee has
certified that chlorophenolic biocides are not used at the facility. This certification eliminates the
requirement to include effluent limits for these two parameters based on 40 CFR 430 H
facility changes future operations to include chlorophenolic biocides, limits a d In i o`iii j 'i
Ie nlred. 1 "'� Y i ) 4),
�}
q V�S„ � ' �'� ���� 1�� � 111�'I � �� .�ln�l�i�l a 131
�� 1 � �, 1.
Il d la
1 I 1 { ih OC� `i��,U ��1Y1IT q ;
!!!� I c to alls� spende solids SS) ,unt s were calculated using the EPA promulgated Effluent
Guidelines for the Pulp, Paper, and Paperboard Point Source Category and compared to existing limits.
The TSS limits contained in the current NPDES permit are more stringent than the calculated federal
effluent guidelines since the current limits are based on the 1993 proposed guidelines for the oxygen
delignification process. The Division recommends that the existing TSS limits remain unchanged for
this permit cycle.
North Carolina does not have a numeric standard for TSS. The rules specifically regulate floating
solids, settleable solids, and sludge deposits [ref. 15A NCAC 2B .0211(3)(c)]. The draft permit
restricts floating solids. Both benthic and IBI studies have indicated fiirther improvement to the Pigeon
River. Therefore, a monthly average TSS limit of 12,549 lbs/dayal,5•l [!commended and a daily
('d m t S, imit f 9, 60 lbs/da is recommended. g lit
III' y 1 F I111 �J �I� �fI`I � Fln' T4 i 7Ffi "1
E� tU � �1 11► � � ��� i 3 p7t�11 �(' I �� ,�i�� lt�`. � id�)r�hil �
Ilya n urt 9Y i 6a ti A N A 0 ) Cl ss adihty tyl��� � �� r
The temperature requiremnt'is based � , a ectinjj
1 (a) Variance dete ' �i 'oi]>f�.ueQ, t �i�,j,
�d fit �y1,rP
Environmental Management Co i lion October 11, 1984 and approved by A A 4 t,6J 11., .,:
ff lli{('v
In making the recommendatioiS�t�bi Ire a "�°.he current 316(a) variance, DWQ scientist° ai�t,xted Blue
Ridge Paper's Balanced and I jigenou ��^pecies Report and concluded that temperate ['could not be
identified as prohibiting a Bal 'nced an Lidigenous population. In addition, DWQ staff reviewed
existing temperature data and althougr suime improvement in the instream temperature has occurred
(most likely due to overall effluent fl �Secrease, associated with process improvements reducing
temperature impacts), Blue Ridge Pa m�' >r itill cannot meet the North Carolina temperature requirement
as indicated in Figure 2 above. There�s`ore, DWQ is recommending that the 316(a) variance continue,
with Blue Ridge Paper conducting a Balanced and Indigenous Species Study prior to the next permit
renewal.
The flow limit is based on Blue Ridge Paper's current flow values and post-CMP production plus 0.9
MGD for the Town of Canton's wastewater. Future plant improvements may reduce the contribution
of the mill's wastewater, however the Town of Canton is proposing to increase their contribution to the
treatment plant as they expand Canton's municipal boundary.
Since flows are currently approximately 80% of the permitted capacity, the Division recommends that
the flow limit remain unchanged. During the next permit cycle the flow limit should be re-evaluated
Fact Sheet
NPDF-S Renewal
Page 11

It is further recommended that the monitoring frequencies be modified based on the fact that
measurable quantities of dioxins and dioxin isomers have not been detected in the.influent (since 1997),
the effluent (since 1996), sludge (since 1996) and the landfill leachate (since 1996).
r�Ull 1 tl
The of t ,limit for 2,3,7,8 TCDD has been reduced. During North Carolina's development of the
I01aI I.+kiiim Daily Load for Dioxins on the Pigeon River, the EPA commented that the chronic
-' !standam adopted by North Carolina should be applied as an effluent limit at the end of pipe. North
Carolina did not agree with this methodology, since it is inconsistent with the standard and North
Carolina rules. In addition, the management strategy implemented by North Carolina to address
dioxins the Pigeon River for several years and the data show that this management strategy is
resulting 1ineclining`, dioxin levels in the Pigeon River. The EPA, NC DWQ and Blue Ridge Paper
a n, d th e}1,e TMDL requirement could be waived as long as Blue Ridge Paper's effluent was limited
a�p ��P A0— Therefore, the dioxin limit has been reduced to 0.014 pg/L and no TMDL will be
Jtl de eiti ed.
Annual fish tissue analysis shall continue to be performed by the facility in accordance with the
monitoring plan approved by the Division until such time that the fish advisory is lifted in both
Tennessee and North Carolina, according to North Carolina's delisting procedures.
Trichlorophenol/Pentachlorophenol limits and monitoring are not required. The permittee has
certified that chlorophenolic biocides are not used at the facility. This certification eliminates the
requirement to include effluent limits for these two parameters based on 40 CFR 430. However, if the
facility changes future operations to include chlorophenolic biocides, limits and monitoring will be
required.
OTHER POLLUTANTS OF CONCERN
The total suspended solids (TSS) limits were calculated using the EPA promulgated Effluent
Guidelines for the Pulp, Paper, and Paperboard Point Source Category and compared to existing limits.
The TSS limits contained in the current NPDES permit are more stringent than the calculated federal
effluent guidelines since the current limits are based on the 1993 proposed guidelines for the oxygen
delignification process. The Division recommends that the existing TSS limits remain unchanged for
this permit cycle.
North Carolina does not have a numeric standard for TSS. The rules specifically regulate floating
solids, settleable solids, and sludge deposits [ref. 15A NCAC 2B .0211(3)(c)]. The draft permit
restricts floating solids. Both benthic and IBI studies have indicated further improvement to the Pigeon
River. Therefore, a monthly average TSS limit of 12,549 lbs/day is recommended and a daily
maximum TSS limit of 49560 lbs/day is recommended.
Daily monitoring is required based on 15A NCAC 2B .0508 (d), Class IV facility.
The temperature requirement is based on a Section 316 (a) variance determination issued by the NC
Environmental Management Commission October 11, 1984 and approved by EPA August 6, 1985.
In making the recommendation to retain the current 316(a) variance, DWQ scientist evaluated Blue
Ridge Paper's Balanced and Indigenous Species Report and concluded that temperature could not be
identified as prohibiting a Balanced and Indigenous population. In addition, DWQ staff reviewed
existing temperature data and although some improvement in the instream temperature has occurred
(most likely due to overall effluent flow decrease, associated with process improvements reducing
temperature impacts), Blue Ridge Paper still cannot meet the North Carolina temperature requirement
as indicated in Figure 2 above. Therefore, DWQ is recommending that the 316(a) variance continue,
with Blue Ridge Paper conducting a Balanced and Indigenous Species Study prior to the next permit
renewal.
The flow limit is based on Blue Ridge Paper's current flow values and post-CMP production plus 0.9
MGD for the Town of Canton's wastewater. Future plant improvements may reduce the contribution
of the mill's wastewater, however the Town of Canton is proposing to increase their contribution to the
treatment plant as they expand Canton's municipal boundary.
Since flows are currently approximately 80% of the permitted capacity, the Division recommends that
the flow limit remain unchanged. During the next permit cycle the flow limit should be re-evaluated
Fact Sheet
NPDES Renewal
Page 11

and if appropriate adjusted. Due to potential inflow/infiltration from the Town of Canton, the Division
continues the provision that requires Blue Ridge Paper to work with Canton to reduce III problems.
' Chemical Oxygen Demand (COD) monitoring is required to assess the potential impact of chemical
oxygen demand from the Blue Ridge Paper wastewater effluent. Neither federal guidelines nor NC
water quality standards require a limit for COD. Though no limit is proposed, the EPA has reserved
COD for potential future limits. Therefore, COD monitoring will be continued.
Limitations for fecal coliform are based on the contribution of domestic wastewater from the Town of
Canton and the requirements of 15A NCAC 2B .0211 (b) (3) (E).
Metals toxicity is a function of water hardness, since Blue Ridge Paper has demonstrated reliable
compliance with toxicity, the Division recommends the elimination of hardness monitoring.
Conductivity monitoring is required based on 15A NCAC 2B .0508 (d), Paper and Allied Products
(Water Quality Limited Facilities), for a Class IV facility.
Monitoring for total residue/total dissolved solids is required according to the existing NPDES
permit. The required conductivity monitoring is sufficient to assess Blue Ridge Paper's inorganic
loading to the Pigeon River. Therefore, the Division recommends removal of total residue and total
dissolved solids monitoring from the permit.
Limitations for pH 6.0 —9.0 are based on 15A NCAC 2B .0211 (b) (3) (G).
ISSUES ASSOCIATED WITH EFFLUENT GUIDELINE IMPLEMENTATION
Relevant Background Information
Over the past five-year permitting cycle, the maximum 12-month production occurred from May 1999
through April 2000. Table 3 outlines the total production of various products generated at the Canton
Mill over this time period.
Pulp produced at the Canton Mill is supplemented with pine and hardwood pulp purchased from off-site
and pulp produced from trim or broke paper off the paper machines. The pulp is then used in
paperboard and fine paper production using one of the four paper machines on-site.
Table 3. Itemized Production Figures for the Maximum 12 Month Average Production Period.
Product Total for 12 Month Period Units
Pine Pulp 217,634.48 Air Dried Tons
Hardwood Pulp 298,833.91 Air Dried Tons
Purchased Pine Pulp 24,306.87 Air Dried Tons
Purchased Hardwood Pulp 22,252.21 Air Dried Tons
Broke Paper or Trim Pulp 46,559.08 Air Dried Tons
Paperboard Production 313,625.90 Off Machine Tons
Fine Paper Production 321,264.00 Off machine Tons
Blue Ridge Paper has not joined the Voluntary Advanced Technology Incentives Program (VATIP) for
existing direct or new direct dischargers as outlined in 40 CFR 430 Subpart B. The VATI Program
was set up for new or existing direct dischargers whereby trills agree to accept enforceable effluent
limitations and conditions in their NPDES permits that are more stringent than the BAT limitations, in
exchange for regulatory and enforcement related rewards and incentives.
Blue Ridge Paper will use steam stripping to treat process condensates, rather than hardpiping to the
WWTP; thus interface with the Division of Air Quality is not necessary.
Relevant Issues
Daily effluent monitoring for Adsorable Organic Halides (AOX) is required. AOX is an overall test
for adsorbable organic halides, which includes chlorinated organics. Trends in concentration changes
have been observed between AOX and specific pollutants (dioxins, chlorinated organics) at pulp and
Fact Sheet
NPDES Renewal
Page 12

paper mills. Therefore, any decrease in AOX may also indicate a decrease in chlorinated organics.
Limits and daily monitoring for AOX are required in the EPA Cluster Rules. The cluster rules are the
combined air and water rules issued by the EPA for the pulp and paper industry. The
compliance/monitoring point for the AOX limits shall be as defined in the sampling plan.
During the next permit cycle, the Division will review the AOX data for possible reduction in
monitoring frequencies.
Chloroform monitoring/limits have been added to the permit. During the previous permitting cycle, it
was determined that the discharge from Blue Ridge Paper did not have a reasonable potential to exceed
the allowable level. Therefore, no effluent limit is proposed. Limits contained in the NPDES permit
on the bleach plant effluent are based on the EPA promulgated Effluent Guidelines for the Pulp, Paper,
and Paperboard Point Source Category. Since Blue Ridge Paper operates two separate fiber lines,
there shall be two compliance points for chloroform as stipulated in the sampling plan.
In addition to the dioxin limits and conditions stated, above dioxins shall be limited and monitored on
the effluent from the each bleach plant. 2,3,7,8 TCDD and 2,3,7,8 TCDF limits are based on the EPA
promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category. The
compliance/monitoring points for each bleach plant is required as stipulated in the sampling plan.
Best Management Practices (BMPs) have been added for spent pulping liquors, turpentine, and soap.
At this time, Blue Ridge Paper is in compliance with the best management practices stipulated in the
EPA promulgated Effluent Guidelines for the Pulp, Paper, and Paperboard Point Source Category with
one remaining issue.
The remaining issue deals with the BMP Plan. As part of the EPA promulgated effluent guidelines,
facilities, which fall under subpart B, must develop a BMP Plan. This plan does not require the
approval of any regulatory authority, but must be certified by the mill manager. Currently, the BMP
Plan is in the development process and it is anticipated that this requirement will be completed prior to
issuance of this NPDES permit.
Per 40 CFR 430.24, the daily maximum limits for 12 chlorinated phenolics are "less than Minimum
Level" (<ML) as specified in 40 CFR 430.01. The compliance/monitoring point shall be set at the
effluent from the bleach plants as outlined in the sampling plan.
PROPOSED CHANGES FROM THE CURRENT NPDES PERMIT
• Monthly average BOD5 limit reduced 71 tons per year to 3205 lb/day.
• Daily maximum BOD5 limit reduced 12.5% to 10897 lb/day.
• Toxicity testing concentration increased to 90%.
• Removal of downstream fecal coliform monitoring with once per week upstream fecal monitoring.
• Removal of instream BOD5 monitoring.
• Removal of instream monitoring station 55.5.
• Removal of instream monitoring station 53.5.
• Reduce monitoring frequency at NC/TN monitoring station.
• Eliminate mercury monitoring and limitation.
• Add selenium limit.
• Trichlorophenol/pentachlorophenol monitoring has been removed.
• The upstream river mile marker now indicates that the upstream monitoring location is located at
river mile 63.8.
• The dioxin special condition has been modified to require 2,3,7,8 TCDD and 2,3,7,8 TCDF
individual isomer monitoring and to reduce the monitoring frequency of the sludge and landfill
leachate.
Fact Sheet
NPDES Renewal .
Page 13

• The 2,3,7,8 TCDD effluent limit has been modified to 0.014 pg/L.
• Two internal outfalls (002 and 003) have been added.
• Removal of hardness monitoring.
• Removal of total dissolved solids monitoring.
• Removal of total residue monitoring.
• An AOX limit and daily monitoring has been added to the permit per EPA Cluster Rules.
• Dioxin, chlorophenolics and chloroform limits/monitoring have been added for the effluent from
the pine and hardwood line bleach plants per EPA cluster rule.
• -The BMP special condition has been updated according to the requirements of the EPA Cluster
Rule.
• For color recommendations refer to the July 24, 2001, memo from the EPA Tech Team to the
Technology Review Workgroup.
This fact sheet represents North Carolina's recommendations. The Division will review all pertinent
comments received during the public comment period and the September 6, 2001 public hearing. After
reviewing all public comments, the Director of the Division of Water Quality and the NPDES
Committee of the Environmental Management Commission will make their recommendations.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Public Notice Draft Permit, temperature variance, color variance and Public August 3, 2001
Hearing
Public Hearing September 6, 2001
ADDITIONAL INFORMATION
CANTON MODERNIZATION PROJECT
Prior to 1993, knotting hardwood brownstock was washed through one of two brownstock washer
lines. After washing brownstock was screened using a two-stage fine screening process and bleached
in one of the two bleaching lines. The two bleaching lines were operated independently for 'low'
brightness and 'high' brightness.
Since 1993, the hardwood fiberline has incorporated numerous modifications designed to increase mill
performance from both an environmental and product quality standpoint. Currently, the hardwood
fiberline consist of two stage knotting followed by pre-oxygen delignification washers. After pulp is
processed through the oxygen delignification unit, it is washed again prior to the four stage pressurized
fine screening. After screening, the pulp is bleached through one medium consistency bleach line.
Prior to 1992, pine (softwood)pulp was processed through one brownstock washing line prior to the
two stage screening process. After screening, pulp was processed through one of the two bleaching
lines. Similar to the hardwood fiberline, the softwood fiberline bleaching was operated independently
for 'low' brightness and 'high' brightness.
Like the hardwood fiberline, the softwood fiberline has incorporated numerous modifications in order
to enhance product quality and environmental performance. 'Currently, the softwood fiberline process
consist of two stage knotting followed by a brownstock pre-oxygen delignification line. After the initial
washing the pulp is processed through the oxygen delignification unit followed by another washing.
After the second washing pulp is screened using four stage pressurized fine screen before entering a
medium consistency bleach line.
In addition to the improvements noted,the facility has implemented full scale bleach filtrate
recycle of the pine bleach line and caustic extraction stage (Eo) recycle on the hardwood bleach
line.
Fact Sheet
NPDES Renewal
Page 14

References
1. Division of Water Quality's Basinwide Information Management System, April 20, 2001,
http://h2o enr.state.ne.us/bims/reportstbasinsandwaterbodies/alpha/Neuse.pdf
2. 1995. NPDES Regional Staff Report for NPDES Permit NC0000272, January 18, 1995,
Asheville Regional Office.
3. 2000. French Broad River Basinwide Water Quality Plan. North Carolina Division of Water
Quality, Water Quality Section.
4. 2001. NPDES Permit Application EPA Forms 1 and 2C, Blue Ridge Paper Products Inc.
5. 2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of
Water Quality, Water Quality Section. Copies obtained through Planning Branch, Archdale
I J Building, 512 N. Salisbury St., Raleigh, North Carolina.
117.
3 Low Flow Characteristics of Streams in North Carolina, United States Geological
tc :f ebc' W t¢ -Su y 1per 2403. Copies obtained at U.S. Geological Survey, Map
� 'tlP ; t ri J tp�,li ��L�5 �6 MS306, Federal Center Denver CO 80225.
atA
� ' ,1Q2 . P iS Permit. Issued to Champion Paper, expiration November 30,
2001. Copi s obd rough The Division of Water Quality, Central Files, Archdale
Building, 512 N. Sali3 ry St., Raleigh, North Carolina.
8. 2001. Bleach Environmental Process Evaluation and Report. Dr. Norman Liebergott, PhD,
ociates Liebergott and Ass Consulting, Inc, and Lew Shackford, June 8, 2001.
9. 2001. Additional Color Removal Technologies and Their Economic impacts on Blue Ridge
Paper Products, Canton, NC. July 25, 2001 Memorandum from EPA Tech Team to
Technology Review Workgroup.
State Contact
If you have any questions on any of the above information or on the attached permit, please contact
Michael�M7y,errss at [phone] ext. 508.
NAME://9 � y DATE: Z�c�
T
NPDES SUPERVISOR/
NAME: I /l^— DATE: nJ ZOoI
Fact Sheet
NPDES Renewal
Page 15

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
` WASHINGTON,D.C.20460
J�\t6D STgTFs
A
�'9C F120ZE�
MEMORANDUM
DATE: July 25, 2001
SUBJECT: Additional Color Removal Technologies and Their Economic Impacts on Blue
Ridge Paper Products, Canton,NC
FROM: EPA Tech Team'
TO: Technology Review Workgroup
Purpose of this Analysis
As required by the 1997 Settlement Agreement, this memorandum presents a summary of an
analysis of available technologies that may be employed to further reduce color discharges from
the Blue Ridge Paper Products, Inc. (Blue Ridge) mill in Canton,NC. The analysis also includes
a summary of the economic impact ("gross margin test") of the cost of implementing identified
color reduction technologies.
Members of the Tech Team visited the Canton mill on March 14, 2001 to observe and gather
information and data on the status of technologies implemented and color discharges at the mill
since the 1997 evaluation. This final memorandum incorporates analyses of the data gathered
from that visit, and Blue Ridge's response to EPA's follow-up request for additional technical
and financial data. This final memorandum is based on the May 4, 2001 preliminary draft
memorandum, and revisions to the July 10, 2001 draft final memorandum, based on a review of
Blue Ridge's comments, the June 8, 2001 Bleach Environmental Process Evaluation and Report
(BEPER) and subsequent comments by Liebergott and Associates and GL&V Pulp Group,Inc,
and additional comments from the Clean Water Fund of North Carolina, and the States of
Tennessee and North Carolina. This memorandum presents to the Technology Review
EPA Tech Team is comprised of--Mark Perez,EPA/EAD;Karrie-Jo Shell,EPA Region 4;Don Anderson,
EPA/EAD;Betsy Bicknell,ERG,contractor;Neil McCubbin,subcontractor to ERG;Dan Bodien,subcontractor to
ERG.

Workgroup (TRW)process improvements evaluated by the Tech Team and considered to be
available technologies and briefly addresses relevant technologies evaluated in the BEPER.
Background and History
Blue Ridge operates a bleached papergrade kraft pulp and paper mill in Canton,NC, which it
purchased from Champion International Corporation in May 1999. Operations at the mill began
in 1908, but the mill has been extensively modernized,most recently in 1993. The mill currently
operates an 800 tpd hardwood pulping line and a 600 tpd softwood pulping line. After cooking,
pulp from each line is further delignified in single-stage oxygen delignification systems installed
in 1993. Hardwood pulp is subsequently bleached with a DEoD sequence; pine pulp is bleached
with a DEopD sequence. Target brightness is 85 ISO. Up to 80 percent of the filtrate flow from
the pine bleach line is returned to the recovery cycle using the unique bleach filtrate recovery
(BFR )process, developed by Champion. A portion of the hardwood line bleach plant Eo-
stage filtrate flow is also recovered. Blue Ridge produces 250,000 tons per year of uncoated
paper including offset,tablet and envelope grades. The mill also produces 281,000 tons per year
of bleached paperboard used for liquid packaging and paper cups, including FDA approved
grades for milk and juice cartons. Since November 2000, pulp production has been reduced by
approximately 30 percent as the result of a major project to upgrade the No. 19 bleached
paperboard machine.
Continued Color Reduction Opportunities Since the 1997 NPDES Permit
The Canton Mill's 1997 NPDES permit included a schedule requiring continued study,
evaluation, and pursuit of effluent color reduction opportunities. Champion and Blue Ridge
submitted a series of reports to the NC Department of Environment and Natural Resources,
Division of Water Quality, evaluating the performance of the BFRTM process, end-of-pipe color
reduction technologies, and practices for minimizing color losses from manufacturing processes.
Since 1997 Blue Ridge has:
• continued full-scale operation of BFR for the pine line;
c I Waded that full-scale BFR is not feasible for the hardwood line, but
�hented 1 a portion of the Eo-stage filtrate as an effective
�� �� 1��' � i 1p
�osses of highly-colored
en e 1 im i anent �I�I� r 'E dVl
black liquor from manufAtti� ng processes, a d
• evaluated 16 end-of-pipe color removal technologies and determined that they
were presently economically and/or technically infeasible for the Canton mill.

Page 3
Process Improvements Analyzed by the Tech Team
The Tech Team identified five mill improvements capable of further reducing the discharge of
color in the mill effluent. For each of these improvements, technical feasibility, capital and
operating costs, and potential color reduction were reviewed. Each improvement can be
implemented independently of the others or in any combination. The costs incurred to
implement the improvements are additive, however separate evaluations are necessary to
accurately estimate the associated color reduction achieved by implementing any combination of
improvements. End-of-pipe color treatment technologies (e.g., chemically assisted clarification
with sludge dewatering and disposal) typically require initial capital investment and ongoing
operating expenses, not savings, and are likely to incur non-water quality environmental impacts.
For this reason, the Tech Team focused on pollution prevention approaches that offer the
potential to be more cost-effective: color reduction in low flow,highly color-concentrated
wastestreams,through manufacturing process changes or in-process treatment.
The first two process improvements, discussed below (improvements in BFR reliability and leak
and spill prevention and control -Best Management Practices (BMPs)), are improvements which
the Tech Team concludes offer the highest certainty for technical feasibility and color reduction.
Blue Ridge also identified these technologies as feasible color reduction opportunities that will
be implemented, but differed from the color reduction estimates included in this memorandum.
The next two process improvements (ozone addition to an existing chlorine dioxide bleaching
stage on the hardwood fiber line; adding a second stage to the current oxygen delignification
system on the softwood fiber line) also were evaluated by Liebergott, et. al., as feasible color
reduction opportunities. Additional technical evaluation and/or laboratory testing would be
appropriate to reliably determine the technical details of how to incorporate these processes into
the existing fiber lines and to more accurately predict their achievable color reduction, and the
relationship of these technologies to BFR. Additional analyses would be appropriate to
determine the most cost-effective design and the most economically feasible schedule for
im en m one or both of se im rove e s V
i1I i P ,� �i i]
� {III ��'•.,l.7 •. �� �i ii ll,, . .13
{ 1�•11 l� .i� I
�,I '_' .I � � �1{ 14 � 04111111the ni m oCessl v .n n color calll�hf ror td e�lo�de e, o s�' t t•4 , �i, ,t, p')�
stream (one of the two key components of the BFR process),has the potenti{ l of iiriE ]Jhl3' �t+�'
color reduction. However, based upon initial bench-scale treatability studies by Blue Ridge,
further study of additional color treatment technologies is necessary. Process optimization on
both the hardwood and softwood fiber lines, as recommended in the BEPER, is anticipated to

Page 4
provide additional color reduction and is identified as the sixth process improvement. It was
concluded that the process optimization option was among those with the highest certainty for
technical feasibility and color reduction.
All color reductions resulting from the mill improvements are estimates based solely on available
data and information. While the Tech Team has concluded that these technologies would reduce
the color discharge from the Canton mill,there is a lack of directly comparable operating
experience with these technologies in other bleached papergrade kraft mills that can be used to
develop precise predictions of the extent of the color reduction benefits.
The BEPER evaluated additional in-process technology options for color discharge reduction
potential, including the implementation of a hot pressurized peroxide-enhanced extraction stage
in both fiber line bleach plants. At this time,the Tech Team does not have sufficient information
to confirm the applicability of this technology at the Canton mill nor relevant data to predict its
potential color discharge reduction capabilities. Therefore, while this memorandum does not
address this technology option, it may be feasible for implementation by Blue Ridge and
contribute to reducing color. In addition, the Tech Team did not analyze nor did the BEPER
recommend a Totally Chlorine-Free (TCF)bleaching option because of the high cost.of this
technology and the lack of experience in producing and successfully marketing products made
by Blue Ridge at the Canton mill.
1. BFR reliability improvement. One of the two key elements in BFR is the Metals Removal
Process (MRP). Blue Ridge has found that this process element has been more challenging and
expensive to maintain than originally planned. The target BFR recycle rate (percent closure) for
the pine line is 80 percent. Due to unforeseen equipment failures (e.g., ion exchange media) and
metallurgy problems (e.g., erosion of multi-media filtration tank lining) in the MRP, however,
the pine line closure has averaged only 74 percent from October 1998 to the present. Blue Ridge
has undertaken improvements to the MRP system in order to maintain the process closure rate
and increase operating time. Improvements include rebuilding piping and valves, and changing
construction materials and metallurgy to better withstand the chemical and physical stress
experienced in the BFR system. Blue Ridge estimates that if BFR closure is maintained at 80
cept, annual average final effluent color discharge will be reduced by 1,000 to 1,200 lbs/day.
1 Ate � �1111TI,e sno means of making an alternative quantitative prediction of
r c, o
31 a �ri�aP el' nM l t 'p `uedYr C
„t r jipare to the Blue Ridge estimate.
ii
jjJ�'''i,

Page 5
2. Improved black liquor leak& spill collection and control (BMPs). The Canton mill has an
extensive spill recovery system. Sumps in this system, including one sump added in the court
yard adjacent to the digester house as required by the 1997 Settlement Agreement, are equipped
with pumps that are activated automatically when sensors detect wastewaters with high
conductivity and color. High conductivity material is routed to the recovery system. Further
improvements to the black liquor collection system include:
• continuous improvement of operating practices so more leaks and spills are
recovered rather than discharged to sewer;
• further improvement in preparation for planned outages to maximize capture of
tank clean-out waste and routing to recovery;
• further reducing clean water that continuously runs into sewers to prevent dilution
of smaller spills and facilitate recovery of highly colored wastewaters; and
• further improvement in the equipment used for handling of knots rejects to
prevent black liquor leaks into the recovery sumps.
The plot below shows the color of wastewater treatment influent at the Canton mill. The
vari il� v a i uent tole d s�harge to wastewater treatment is attributed to color discharge
�►�� , Vi fi p�„I ;; � � ,
eaks tha e t Yn �ii ned spills or leaks discharged to sewers or intentional
op
ollg''�1111syyl�lbl jol r liquor or other color sources routed to sewers during mill
100
kg/t
Figure 1
75 Daily color at influent to W WTP for Canton
50
25
0 30 60 90 120 150 180

Page 6
Due to the nature of the manufacturing processes and practical equipment operation and
reliability, all spills and color losses to sewers cannot be fully anticipated, predicted, and
completely contained. However, a comparison of the variability of the Canton mill influent color
data to available primary influent color data at another bleached papergrade kraft mill indicate
that a detailed review of the spill prevention and recovery system at the Canton mill (by mill
staff or external consultants), including involvement by the mill operators, can further uncover
the causes of and better quantify black liquor losses and other color sources that can be avoided
or recovered. This will result in an overall reduction in color discharge, both in long-term
average and variability. Through improved planning of mill equipment shutdowns, continuing
efforts to minimize process operation variability, and increased recovery of highly-colored leaks
and spills, discharges of highly colored material to the wastewater treatment system can be
reduced more consistently below existing levels.
Further reducing peaks in color discharges within the mill and preventing highly colored flows
from reaching the wastewater treatment system will further reduce the variability of color
discharges from the wastewater treatment system to the Pigeon River. For example, limiting the
color of the primary clarifier influent to less than 70,000 lb/day through continuing efforts to
improve the mill's BMP system and process operations would reduce the color loadings from
mill processes to the end-of-pipe wastewater treatment system by more than 8,000 lb/day. The .
Canton mill operated under this primary clarifier influent color threshold approximately 74
percent of 2000, excluding November through December 2000. This time period was considered
not to be representative of steady-state operations because of the reduced pulp production
resulting from upgrading the No. 19 bleached paperboard machine. Assuming the average
reduction of 45 percent across this wastewater treatment system for"brown" color derived from
black liquor, this would result in a minimum decrease of 4,400 lb/day in the average final
effluent color load.
Clean water, such as packing gland water, presently flows in several sewers with recovery
sumps. These colorless streams dilute other colored wastestreams, such as small black liquor
leaks {3 spills, to the point where the in-stream conductivity is too low to trigger recovery. By
►,��r�' ' e ,iwa �tre s o d vert3 a av f>o s ers. at GGllee ack quor �
1 _ � ,�� ill : ��� JrI F�i�� fl� � I � �� � ai'
to a r s c e e va c c e e v r_
� ;e 1 N
p R ggI ��I�I � I (� d L� • ,Ii �J ��i, ���i�� ��!�i ���
in a reduction m color discharJ ' e' c� -6rppe wastewter lystem. e
unintentional but intermittent discharge to the sewer of filtrate from knots and screen rejects can
be recovered.
''I'11� �11� �'� jb� t ;lglf.i),i1�11Ii�l I� �II i�lltil 'r
u� 1 1 ': I`
�!
, yt j I p��:IluuJlla ijJ rSa� I i��lipI'llilii,il�)�i 1 � y�bklll.' �a

Page 7
At this time, the Tech Team has no basis for determining an accurate correlation between
unaccounted color and sewer generated color, as reported in Section 2 of the Canton Mill
Environmental Performance Update presented by Blue Ridge during the March 14, 2001 Tech
Team Canton mill visit. During the March 14 visit, Blue Ridge staff indicated that results of
studies of sewer generated color showed a relationship between bleach plant filtrate pH and
temperature and unaccounted color generated in mill sewers. By operating within the range of
pH and temperatures identified during the studies the Canton mill has had some success in
controlling this source of unaccounted color. Based on this information,the Tech Team
concludes that by further reducing process operation variability, including operating within the
pH and temperature range identified during the studies, the mill can continue to also minimize
sewer generated color, thereby reducing one source of unaccounted color. Reducing overall
color discharges through BMPs and other management practices will likely further reduce
remaining unaccounted color. However, additional studies are necessary to further develop any
relationship between accounted and unaccounted color sources.
As noted above, analysis of primary clarifier influent color loading data demonstrates that color
loading to the wastewater treatment system of lower than 70,000 lbs/day is possible during
steady-state operations. Through continuing efforts to minimize unplanned spills and leaks and
nten i n i c arges ]� a stream a cn tinuing efforts to minimize process operation
17JdfIJ ' 3 t u { R ,1
ltll I til� ti I �' ail � ��' y�� r �1 it ii l,i
r! v I �ttry g Yo il c�hleve N h'e 7rg dyd 9. •�c� 7e i e;� Jor lo� d 7
` � II
^I �MC61 Ilr.� Il� ,i ! I ar6r, I II h ( ' I'�ht114k1� li a aSrJ.�
tib �c eri rfu�a effi t color n4 chargelw tfu>4 is rang ja', ,� Co
demonstrated in 2000 (i.e., more than 74 percent of the time). On this basis hey
concluded it is feasibl tr edu . f al ue�r r b 4 e than 5.000 qa't
r` { �,
�Pjbt� � a1 � � 1 �99a �� �ICG
u „ improve( black li uor an t co a ton fr(1yj�
t' IP �( I Jll�i,� 7 ^I1B3 ti '1
�i� ) ����i����' I 1���II��h� � �.
Oi! ne/ hlorine dioxide sta e fol rr ha o0d 6 each line. Ozone is used in more than ten kraft
mills around the world to bleach pulp, including two in the US and one in Canada. There are
several process configurations, but the most common is to operate an ozone (Z) mixer and
reactor immediately upstream of a chlorine dioxide reactor, without any washing between the
application of the two chemicals. This is known as a"ZD" stage. A system of this type was
retrofitted in the Domtar mill at Espanola, Ontario, Canada in 1999.2 Bleaching with ozone on
the hardwood line, one of the Domtar mill's two pulp lines, resulted in a 27 percent reduction in
the discharge of color in the combined mill treated effluent' The conversion to a ZD stage
2 Munro,Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching Sequence,Tappi,2000.
3 Ibid.

Page 8
would reduce the use of chlorine dioxide and caustic chemicals for bleaching in exchange for
ozone. The energy requirements for ozone production would be offset by the energy savings
from less chlorine dioxide and caustic production, resulting in a net reduction in energy
consumption with the ZD stage.
As of September 2000, the long-term average color discharge from Canton's hardwood bleach
line was 12,800 pounds/day°. The Espanola experience suggests that implementation of a ZD
stage in the hardwood bleach plant at the Canton mill could reduce the filtrate color discharge by
3,000 to 6,400 lbs/day. Based on comments received,the Tech Team acknowledges that
operating parameters, such as wood species processed and technology supplier performance
guarantees, may influence the practical color reduction achievable through implementation of a
ZD stage at the Canton mill, in comparison to the Espanola experience. These estimates are
based solely on the demonstrated performance and the Tech Team's assumption of color sources
at the Espanola mill, confirmed at the recent Pulp and Paper Technical Association of Canada
(PAPTAC)meeting in Thunder Bay, Ontario. Laboratory bleaching trials and possible
communication between Blue Ridge and Domtar staff would be necessary to reliably predict the
achievable color reduction possible with this option for the Canton mill.
The technical evaluation of this process improvement included in the BEPER yielded a
hardwood filtrate color discharge reduction within the range of Tech Team estimates.
4 2"d stage OD_for pine line. Oxygen delignifrcation (OD) on the Canton Mill pine line is a
single stage system installed in 1993. It has been concluded that retrofitting a second OD stage
for the pine line could contribute to reduced color discharges in two ways. The first would be a
reduction in color for those filtrates presently not captured and reused in the BFR process. The
second would be a color reduction in the Chloride Removal Process (CRP) purge stream as a
result of less chloride from chlorine dioxide used for bleaching.
Costs were estimated for a reactor with oxygen mixer and chemical charge equipment installed
upstream of the existing reactor. Previously, the Tech Team anticipated increasing the kappa
number(lignin content) of the cooked pulp from 24 to 32 and utilizing a two-stage OD system to
reduce kappa number from 32 to 11, an approximate 65 percent kappa reduction across the two-
stage system. Based upon comments from BRP and further technical analysis, and review of the
BEPER, it was concluded that it is technically feasible for a two-stage OD system at the Canton
4 Jacobs Engineering Group,2001 Color Removal Technology Assessment,February 2001.

Page 9
mill to achieve an overall reduction of 50 percent in kappa number, rather than 65 percent as
pTeviouslv ant i te The efore, with the Canton mill continuing to pulp to a kappa number of
stda; 'uld reduce pulp kappa number into the bleach plant from
Y;r• . ie currEl ou ut o 6 to a6 u 1 , corresponding to a 50 percent kappa number reduction from
the current digester output of 24. The quantity of color released from the bleach plant will be
reduced in proportion to the reduction of the input kappa number.
By decreasing the kappa number of the pulp fed to the bleach plant from kappa 16 to 12 with a
two-stage OD system, the quantity of chemicals required in the first two stages of the bleach
plant can be reduced, because there is less lignin present in the incoming pulp to remove by
bleaching. The reduction in chlorine dioxide used for bleaching would result in a proportional
reduction in chloride load to the CRP and reduce color discharged from the purge stream in
proportion to the reduction in chloride being treated.
In response to comments received, it has been concluded that implementing a two-stage OD
system without increasing the kappa number of the cooked pulp from 24 to 32 would not achieve
a 1.5 percent pulp yield gain as anticipated with increasing digester kappa number and achieving
greater delignification with the proposed two-stage OD system. However, operating a two-stage
OD system with a higher than 50 percent delignification rate and a digester kappa number higher
than currently employed at the Canton mill is commonly seen at comparable bleached
papergrade kraft mills. Therefore, the Tech Team anticipates that additional process engineering
will maximize the benefits of a two-stage OD system at the Canton mill and enable the mill to
capture the increased delignifcation and yield gain potential of this technology and achieve
annual wood cost savings of up to approximate $950,000 from up to a 1.5 percent yield increase
across the proposed two-stage OD system.
Based on additional information supplied by Blue Ridge regarding operational limitations of the
BFR system, the Tech Team concludes that a two-stage OD system would not have a significant
impact at this time on the Canton mill's ability to increase BFR closure rate above 80 percent on
a day-to-day basis.
For this analysis, it was estimated preliminarily that a second OD stage could reduce total
influent color discharge to the wastewater treatment system by 1,500 to 2,000 lb/day from
reductions in pine line bleach plant filtrate color and CRP purge stream color.

Page 10
The technical evaluation of two-stage OD included in the BEPER yielded reduction in color
discharge influent to the wastewater treatment system within the range of the Tech Team
estimates.
5. Color Treatment of CRP purge stream. The Chloride Removal Process (CRP) purge is a low
flow, highly concentrated waste stream. Color is typically 50,000 pcu, in a 10 gpm (0.01 MGD)
flow. The CRP purge contributes up to approximately 5,000 lbs/day (13 percent) to the total mill
loading to the wastewater treatment system influent, but only 0.06 percent of the discharge flow.
It was originally speculated that it may be feasible to reduce the color in this stream by
precipitating the colored organic material with lime at a dosage of 20 g/L5, and burning the
resulting sludge with the main lime mud stream fed to the mill's lime kiln. Laboratory trials
would be necessary to test the feasibility of color removal from the CRP purge stream by lime
treatment.
Blue Ridge subsequently conducted laboratory trials of color precipitation using four calcium
compounds, including lime mud, fresh lime, calcium chloride, and milk of lime. The
preliminary results of these trials show that at a dosage of 20 g/L, none of the compounds tested
reduced color in the CRP purge stream. Although color removal was demonstrated at higher
dosage rates, increased chemical usage would result in substantially higher operating costs,
require larger sized equipment at higher capital cost, and also result in a higher production rate of
sludge to be burned in the mill's lime kiln. Excess sludge produced from this process that is not
burned must be landfilled at additional cost.
Based on preliminary laboratory trials, Blue Ridge concluded that lime treatment of the CRP
purge is not a feasible color reduction option for the Canton mill. However, the Tech Team
recommends additional review of other innovative technologies for treatment of color in the CRP
purge stream, such as the application of the X-Filter process recently implemented at a totally
chlorine free (TCF) mills. By minimizing color contributions from this stream, the potential
exists to achieve a significant reduction in primary influent color discharge of up to 5,000
lbs/day.
5 NCASI Technical Bulleting No.239,The Mechanisms of Color Removal in the Treatment of Pulping and Bleaching
Effluents with Lime.I. Treatment of Caustic Extraction Stage Bleaching Effluent July, 1970.
6 Comments on the Draft Report on Additional Color Removal Technologies and Economic Impacts for BRPP,Hope
.Taylor,Clean Water Fund of North Carolina,July 18,2001

Page 11
6. Process Optimization. The BEPER identified sixteen recommendations for optimizing the
hardwood and softwood fiber lines, focusing mainly on the current OD systems and bleaching
operations. It was estimated that a reduction could be achieved in chlorine dioxide use in the
first bleaching stage of up to 27 percent for the hardwood line and 18 percent for the softwood
line. The reduction in chlorine dioxide use would result in a bleach plant filtrate color reduction
of up to 700 lbs/day from the hardwood line and up to 400 lbs/day from the softwood line. The
Tech Team estimated an additional color reduction from the CRP purge stream of 600 lbs/day
resulting from the decreased chlorine dioxide usage. At this time, the Tech Team has no means
of making an alternative quantitative prediction of bleach filtrate color reduction to compare to
estimates presented in the BEPER. Therefore, it is estimated that through efforts by mill staff to
maximize the color reduction benefits from the process optimization opportunities identified by
Liebergott, et, al., the Canton mill would achieve a total color reduction of 1,700 lbs/day in
wastewater treatment system influent.
Color Reduction Summary
The Tech Team estimates that by improving BFR reliability and black liquor leak and spill
collection and control, the Canton mill final effluent will be reduced by more than 5,000 lbs/day.
Process optimization, as outlined in the BEPER, would result in a further final effluent color
reduction of approximately 1,400 lbs/day. This assumes the average color reduction of 45
percent across the existing wastewater treatment for the CRP purge stream and other "brown"
color sources derived from black liquor and no reduction in color from bleach plant filtrates.
Table 1 presents a summary of the estimated reductions in final effluent color attainable with the
highest certainty by implementing improved BFR reliability, improved BMPs, and process
optimization.

Page 12
Table 1: Summary of Process Improvements and Associated Color Reductions
(Highest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(Ibs/day) (Ibs/day)
1 BFR reliability improvement -- 1,000-1,200
2 Improved black liquor leak& spill collection and --- > 5,000
control
6 Process Optimization 1,700 1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION >7,400
Additional potential mill improvements to reduce color discharge at the Canton mill were also
identified. These process improvements require further study to more accurately determine
achievable color reduction and thus are not recommended at this time for immediate
implementation. These improvements include a ZD stage in the hardwood bleach plant, with a
preliminary estimate of a 3,000 to 6,400 Ibs/day color load reduction in influent to the
wastewater treatment system, and a second OD stage for the pine line, with a preliminary
estimate of a 1,500 to 2,000 lb/day color load reduction in influent to the wastewater treatment
system. Table 2 presents a summary of preliminary estimates of color reductions for these two
additional process improvements that need further study. Reductions presented in Table 2 are
preliminary estimates with reduced certainty compared to those presented in Table 1, but are
based upon identified technology options available for the Canton mill.

Page 13
Table 2: Summary of Process Improvements and Associated Additional Color Reductions
Needing Further Study (Reasonable Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
(Ibs/day) (Ibs/day)
3 Ozone/Chlorine Dioxide stage for hardwood bleach 3,000-6,400 3,000-6,400
line
4 2"d stage OD for pine line 1,500-2,000 1,100-1,400
TOTAL FINAL EFFLUENT COLOR REDUCTION 4,100 - 7,800
Table 3 presents a preliminary estimate of color reduction potential for the removal of color from
the CRP purge stream. The Tech Team recommends this stream for additional review of
potential color reduction technologies but cannot identify a particular technology option at this
time. Potential for additional color load reduction up to 2,750 Ibs/day in final effluent to the
Pigeon River. Table 3 presents potential color reduction estimates with the lowest certainty.
Table 3: Summary of Additional Potential Color Reductions Needing Further Study
(Lowest Certainty)
Process Improvement Influent Final Effluent
Color Color
Reduction Reduction
hti{i ' 'ti')
"�I'II1� 1 (Ibs/day) (Ibs/day)
ent r e tF am 45,000 #2,750
tr i C. I EFFLUENT COLOR #2,750

Page 14
Economic Analysis
The estimated capital and operating costs for the process improvements one through four were
estimated and are summarized below. Costs could not be developed at this time for process
optimization or CRP treatment and thus are not presented. However, costs for these
improvements should be modest.
Table 3: Estimated Costs
Process Improvement Capital Cost Annual O&M
($) ($/year)
1 BFR reliability improvement $1,300,000 $85,000'
2 Improved black liquor leak& spill collection and $100,000 $50,000
control
3 Ozone/Chlorine Dioxide stage for hardwood bleach $1,500,000 ($350,000)
line savings
4 2"d stage OD for pine line $2,000,000 ($2,100,000)
savings
Blue Ridge Paper Products Inc. was formed in May 1999 with the purchase of seven
plants (including the Canton Mill) from Champion International Corporation. Blue Ridge Paper
Products is owned 55 percent by KPS Special Situations Fund, L.P. and 45 percent by the
employees of Blue Ridge Paper through an employee stock ownership plan. At the time of the
1997 report EPA documented substantial losses over five years for the Canton Mill and
Champion had just announced its intention to sell or close the mill. However, because of the sale
of the mill to the Blue Ridge, the previous data are not comparable to the more recent data.
Further, the data submitted by Blue Ridge is still confidential, so this report cannot present as
much detail as the 1997 report.
The current analysis is based on information submitted by Blue Ridge covering part of
1999 (May-December) and all of 2000 (all of the existing financial data for the company). The
l , 1 a may be relatively uncertain because of the lack of data and the company may be too
� � i1�j �1�
' 11' r*Zcurrent data to reflect its ultimate financial health. EPA used three measures of
t tanctal�, � s, t *p�, scIounted cash flow, and Altman's Z 7 to assess the impact of
, i , II �i
See Interim Ece notntc Guidatt le for W Gr +.10ity Standards:Workbook,EPA 823-B-95-002,March 1995,and
Economic Analysis for the N & n 01 ri ' sign I andards for Hazardous Air Pollutants for Source Category: Pulp and
Paper Production;Ef tL; to 'l1j 'Jidelines Pretreatment Standards,and New Source Performance
.Standards:Pulp,Pa j� i�i in and Category—Phase 1.

Page 15
air emissions control technologies and devices (not addressed in this memorandum, such as
MACT II and regional NOX control) and wastewater compliance costs (separate and combined)
on the mill and company. The costs for the wastewater control options presented in Table 3 do
not change the financial status of the mill or company. However, the costs for some of the air
emissions control options do impact the health of one or both entities. When the wastewater
costs are added to costs for air emissions control, the impacts of the water costs do not change
the financial status of either the mill or company when compared to the impact of the air costs
alone.
References
Blue Ridge Paper Products, Inc. Canton Mill Canton Mill Environmental Performance Update,
Prepared for U.S. EPA Technology Review Workgroup. March 14,2001.
Blue Ridge Paper Products, Comments on and Transmittal of Financial Data for Economic
Analysis of Blue Ridge Paper Products, from Bob Williams, May 18, 2001 (CBITS 00003911-
01)
Comments on Preliminary Draft Final Tech Team Report, email from Derric Brown,Blue Ridge,
to Don Anderson, EPA, May 18, 2001
Comment Clarification of May 18, 2001 Blue Ridge Responses to EPA Questions, from Derric
Brown, Blue Ridge, June 4, 2001
Comments on Draft Final Tech Team Report, from Bob Williams, Blue Ridge, to Don Anderson,
EPA, July 13, 2001
Comments on Draft Final Tech Team Report, from Derric Brown, Blue Ridge,to Don Anderson,
EPA, July 17, 2001
Comments on Draft Final Report, email from Forrest Westall,North Carolina DENR, to Don
Anderson, EPA, July 17, 2001
Comments on Draft Final Report on Additional Color Removal Technologies and Economic
Impacts for BRPP, Hope Taylor, Clean Water Fund of North Carolina, July 18, 2001

Comment on Draft Final Tech Team Report, email from Paul Davis, State of Tennessee, to Don
Anderson, July18, 2001
Comment on Draft Final Tech Team Report, email from Lew Shackford and Norm Liebegott, to
Don Anderson,EPA, July 19, 2001
Jacobs Engineering Group, 2001 Color Removal Technology Assessment, Blue Ridge Paper
Products Inc. Prepared for The North Carolina Division of Water Quality. February 2001.
Liebergott,Norm, and Lew Shackford, Bleach Environmental Process Evaluation and Report,
June 8, 2001
McCord,Aimee,A Laboratory Analysis of Color removal Across a Pulp and Paper Mill
Wastewater Treatment Facility, Canton, North Carolina, Duke University, School of the
Environment, 1995
Munro;Fred and John Griffiths,Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.
NCASI Technical Bulletin No. 239, The Mechanisms of Color Removal in the Treatment of
Pulping and Bleaching Effluents with Lime. I. Treatment of Caustic Extraction Stage Bleaching
Effluent. July, 1970.
Salisbury, Chad A Laboratory Analysis of Color Removal Mechanism Across the Wastewater
Treatment Facility of a Pulp and Paper Mill, Canton, North Carolina, Duke University, School
of the Environment, 1996
Sp )��k' 141 ed. In ustrial Environme n nl Pul and Pa er Ind stry ag ,182
1�1j Tlll�ti
1 II I `` 1 1r,I iI -
y{ Wiley to s + f)9 jd)�`�l)I�tr�!�I
b �] '1�«) Lfl� ��1111191f f"- d . . JJ � �1 ` I ..I } ��' ➢,
iW
=�i �i� `( �
piD1 I9 ��� 11 rin l{� '� ,.- 13:1I ] 11 { 1 � { ¢I ii N) i fl' 7'' , �,
I,� ' I U ++ 1�I h� tt "� 119 rd
1
Spnner Alan M. ed. Industry E' t ! 11t rot P ' F' er ct 19,311.
o d
� � 1� '��� {pf�� i 1 � �
��.6'
I I„ „ t } 'al�1. 17 1� 11di71 Ill 1 x i
14
r

Appendix 1: Color Balance (9/1/00 to 12/31/00)
Figure 2.6, Presented by Blue Ridge on March 14, 2001
Sewer Description Color Load
ID I (Ibs/day)
213 Digester area sewer: Digesters, HW 4,323
line, knot rejects
3A Alkaline sewer: Pine and HW Eo, 12,954
Pine line BSW, 02 Delig
1 PMs1 1 & 12,HW weak liquor tank 1,991
513 Recovery,BLOx, CRP* 7,852
6A Acid sewer: Pine and HW D1 17,345
filtrate+Pine D2 filtrate
Contaminated Condensate 1,591
Combined Condensate 260
Total .46,316
Primarylnfluent(PI) 49,284**
Unaccounted Color 2,968
(PI minus Total)
Secondary Effluent 37,696
Percent Removal in Treatment 23
* CRP contributes 5,000 to 6,000 Ibs/day to 5B sewer
** Measured using test method in NCASI Tech. Brill. 803, An Update of Procedures for the
Measurement of Color in Pulp Mill Wastewaters, May 2000.

Appendix 2: Table of Effluent Color Limits, 1997 to Present
Color Limit True Color (lbs/day)
Monthly Average Annual (Long-term)
Average
1997 Permit 125,434 98,168
Settlement Agreement, February 1998 69,000 60,000
(starting December 1, 1998)
Settlement Agreement, February 1998 --- 48,000 to 52,000
(Ultimate Target)
Interim Limits, May 2001* 55,000 48,000**
* As recommended by Technology Review Workgroup (TRW) and incorporated by NC in
BRP's NPDES permit.
** Reduced end-of-pipe color discharges since November 2000 reflect, in part, reduced pulp
production (approximately 30 percent) during this period because of the ongoing project to
upgrade the No. 19 paper machine used to produce bleached paperboard.

Appendix 3: Ozone Bleaching
Munro, Fred and John Griffiths, Operating Experience with an Ozone-based ECF Bleaching
Sequence, Proc. International Bleaching Conference, Halifax, Canada, 2000. TAPPI Press.

Appendix 4: Two-Stage Oxygen Delignification
Comparison of one- and two-stage oxygen delignification systems
Item Current Single-Stage System Proposed Two-Stage System
Oxygen Reactors One two
Input Kappa Number 24 24
Output Kappa Number 16 12
Total C102 Used 28 kg/ton* 22 kg/ton*
Oxygen Used 23.4 kg/ton* 28.3 kg/ton*
Total NaOH Used 45 kg/ton* 37 kg/ton*,.
* air-dried metric ton of bleached pulp

BLUE RIDGE
PAPER PRODUCTS INC.
January 24,2002
Mr.Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products Inc. Canton Mill
Dioxin Monitoring in Fish Tissue Report-2001
Dear Mr.Westall:
Attached is the final report detailing the results from Blue Ridge Paper Products' twelfth annual
Fish Tissue Study. This study, as required by our NPDES permit,consists of annual sampling of
fish at specific sites in the Pigeon River and analysis of those fish for dioxin. The actual fish
collection took place in September 2001. All surveys were conducted by EA Engineering
Science and Technology and the analyses were conducted by Sevem Trent Laboratories.
The Study Plan for the 2001 fish tissue monitoring was revised in response to the fish
consumption advisory on the Pigeon River being completely rescinded and the Walters Lake
advisory being partially rescinded. Carp in Walters Lake is the only fish species remaining under
advisory for the North Carolina portion of the Pigeon River. Ms. Coleen Sullens, Chief,Water
Quality Section,approved the primary changes to the Study Plan on August 22, 2001. A
complete revised Study Plan was submitted to the Division of Water Quality for approval on
January 7,2002.
Table 6-4 provides the summary of the Canton Mill's Fish Fillet Tissue Analysis Results of
2,3,7,8-TCDD from 1990 to 2001.
If you have any questions or comments,please call me at(828)646 2318.
Sincerely,
Derric Brown r
Manager of Environmental Affairs
J
Attachment
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone:[phone] • Fax: [phone] '
Raising Your Expectations

ATTORNEY GENERRL Fax:[phone] Jan 24 '00 15:13 P.01
&JIN
State of Norfh Carolina
MICHAEL R EASLEV I)e)utrtmunt of jusriC(:
n t'iuuner gF�gfl.v. P.0.,Box i,u9 '
RALF1 iH '
a• Phone: [phone] .
Fax: [phone]
TELECOPIFR 1PANSNIITTAL SHEET
TO: F OYV eS f WeJd�I l
AJ-6,i l l'. `2ri . 04,
FROM: Jsh CJ�I`�
DATE: r-zv-o 0
NVIVIBER OF PAGES (INCLUDIN(; TRANSMITTAL SHEE ):` $
CONFIRM RECEIPT OF DOCITMENT(S) IF iViA,RYED HERE:
COMMENTS:
dockIcle (a� mal1 vs, s�a4p. nc. u5
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rn

N.C. ATTORNEY GENERAL Fax:[phone] Jan 24 '00 15:13 P.01
State of North Carolina
MICHAU F. EASLEY Department of justice Rf:PLY TO:Daniel C.oakiLy
ATTpRNFY CEN@ML P.0.tiQX(329 Environmental Divisnm
RALEIGH dWk1ey(n}mail.jU5.SL1te.ne.us
Telephone:919/71 W,6p
27603'0629 Pax:9191716.6767
December 10, 1999
Mr. Barry Turner
Deputy Attorney General
Office of the Attorney General
425 5th Avenue North
Nashville,NC 37243
RE: Pigeon River Joint Watershed Advisory Committee
Dear Barry:
Enclosed please find copies of the appointment letters for the North Carolina members of
the Pigeon River Joint Watershed Advisory Committee. It looks like the committee is now filled
with three members from each State.
Please contact me at your convenience to discuss what the next step should be. I look
forward to hearing from you.
Very my yours,
C- Daniel C. Oakley
Senior Deputy Attorney General
'DCO/jlb
ep/37061 .

ATTORNEY GENERAL Fax:[phone] Jan 24 '00 15:13 P.03
I
'�r
�� RECEIVED
"°""" DEC 0 91999
STATE OF NORTH CAROLINA N.G. ATTOMEy.GENS�AL
OFFICE OF THE GOVERNOR En*01Np61Wl)hl*n
RALEIGH 27603-OMI
JAMES B. HUNT JR.
GOVERNOR December 1, 1999 .
Mr. David Dudek
Haywood Community College
185 Preedlander Drive
Clyde,NC 28716
Dear David:
The Pigeon River Joint Watershed Advisory Committee is created by Paragraph
32 of the Settlement Agreement regarding the 1996 Water Quality Color Variance and
the I996 NPDES Permit issued to Champion International Corporation.
Paragraph 32 states that North Carolina and Tennessee are required to establish a
joint watershed advisory committee. The goal is to "foster joint planning and publish
input on decisions facing the Pigeon River."
It is with great pleasure that I appoint you to serve on the Pigeon River Joint
Watershed Advisory Committee as an environmentalist who resides in,Haywood County.
Your term will begin immediately and you will serve until notified.
My warmest personal regards.
Sincerely,
James B. Hunt. Jr.
JBH:jb

N.C. ATTORNEY GENERAL Fax:[phone] Jan 24 '00 15:13 P.L,
.�4
STATE OF NORTH CAROLINA
OFFICE OF THE GOVERNOR
RALEIGH 27603-8001
JAMES B_ HUNT JR.
GOVERNOR December 1, 1999
W. Kenny Sutton
P.O. Box 1772
Canton,NC 28716
Dear Kenny:
The Pigeon River Joint Watershed Advisory Committee is created by Paragraph
32 of the Settlement Agreement regarding the 1996 Water Quality Color Variance and
the 1996 NPDES Permit issued to Champion International Corporation.
Paragraph 32 states that North Carolina and Tennessee are required to establish a
joint watershed advisory committee. The goal is to "fosterjoint planning and publish
input on decisions facing the Pigeon River."
It is with great pleasure that I appoint you to serve on the Pigeon River Joint
Watershed Advisory Committee as a representative from Blue Ridge Paper Products
(formerly Champion). Your term will begin immediately and you will serve until
notified.
My warmest personal regards.
Sincerely,
James B. Hunt,Jr.
JBH:jb

ATTORNEY GENERAL Fax:[phone] Jan 24 '00 15:14 P.05
00'�'-
STATE OF NORTH CAROLINA
OFFICE OF THE GOVERNOR
RALEIGH 27603-8001
JAMES B. HUNT JR.
GOVERNOR December 1, 1999
Mr.Jack Horton
County Manager
Haywood County Manager's Office
215 North Main Street .
Waynesville,NC 28786
Dear Jack:
The Pigeon River Joint Watershed Advisory Committee is created by Paragraph
32 of the Settlement Agreement.regarding the 1996 Water Quality Color Variance and
the 1996 NPDES Permit issued to Champion International Corporation.
Paragraph 32 states that North Carolina and Tennessee are required to establish a
joint watershed advisory committee. The goal is to "foster joint planning and publish
input on decisions facing the Pigeon River."
It is vdth great pleasure that I appoint you to serve on the Pigeon River Joint
Watershed Advisory Committee as a representative from a local government situated on
the Pigeon River. Your term will begin immediately and you will serve until notified.
My warmest personal regards.
Sincerely,
James B. Hunt, .lr.
JSi•t�jb

N.C. ATTORNEY GENERAL Fax:[phone] Jan 24 '00 15:14 P.L.
cG,; `ri,^^' STATE OF TENNESSEE
DON SWMQMST
August 19,1999 Govxx:vOn
RIEC Ell VE0
Mr.Tim Dockery
433 Prospect Avenue Asu 2 j 1999
Newport,Tennessee 37521 ?d.C. A,'STCRm� _ ?tea
zAL
Dear Tim:
It is with great pleasure that I appoint you to serve on the Pigeon River Joint Watershed
Advisory Committee as a government official from a municipality situated on the Pigeon River.
Your term will begin immediately and you should serve until notified.
I am anxious to fill our state boards and commissions with the most highly qualified people,
and it would be an honor to have your service. I have great confidence in your abilities and in the
contribution you will make.
Thank you for your willingness to serve our administration and your fellow Tennesseans. I
look forward to working with you.
Sincerely,
•
Pof
Don Sand
DS:1b
ce: Mr.Justin P.Wilson Mr.David MclCinney,Chief
Deputy to the Governor for Policy Environmental Services Section
State Capitol,Suite G-10 TWRA
Nashville,TN 37243 P.O.Box 40747
The I>:onorable Daniel C.Oakley Nashville,TN 37204
Senior Deputy Attorney General Mr.Paul Davis,Director
State of North Carolina Division of Water Pollution Control
Department of Justice TDEC
P.O.Box 629 L&C Tower,21"Tower
Raleigh,NC 27602-0629 401 Church Street
Nashville,TN 37243.0435
The Honorable Barry Turner
Deputy Attorney General
State of North Carolina
Department of Justice
P.O.Box 629
Raleigh,NC 27602-0629
State Capitol, Nashville, Tennessee 37243-0001
Telephone No. (615) 741-2D01

JTORNEY GENERAL Fax:[phone] Jan 24 100 15:14 P.07
� ` ?�•``�' STATk'. OF TENNESSEE
August 19,1999 DON SUND$UISTGOVERNOR
Mr.Charles Lewis Moore
County Executive
Courthouse Annex
360 East Main Street
'Newport,Tennessee 37821
r Dear Charles:
It is with great pleasure that Iappoint you to serve on the Pigeon River joint Watershed
Advisory Committee as a government official of Cocke County. Your term will begin immediately .
and you should serve until notified.
I am anxious to fill our state boards and commissions with the most highly qualified people,.
and it would be an.honor to have your service.•I have great confidence in your abilities and in the
contribution you will make,
Thank you for your willingness to serve our administration and your fellow Tennesseans. I
look forward to working with you.
cerely,
* w4 "
Don Sundquist
DS:jb
cc: Mr.Justin P.Wilson Mr:David McKinney,Chief
Deputy to the Governor for Policy Environmental Services Section
State Capitol,Suite G-10 TW1tA
Nashville,TN 37243 P.0.Box 40747
Nashville,TN 37204
The Honorable Daniel C.Oakley
Senior Deputy.Attorney.General Mr.Paul Davis,Director
State of North Carolina Division of Water Pollution Control
Department of Justice TDEC
P.O.Box 629 L& C Tower,21"Tower
Raleigh,NC 27602-0629 401 Church Street
Nashville,TN 37243-0435
The Honorable Barry Turner
Deputy Attorney General
State of North Carolina
Department of Justice
P.0.Box 629
Raleigh,NC 27602-0629 }
State Capitol, Nashville, Tennessee 37243-0001
Telephone No. [phone]

N.C. ATTORNEY GENERAL Fax:[phone] Jan 24 '00 15:15 P. _
»z
"`�```�` STATE OF TENNESSEE
w ter,.
August 19,1999 Dori SUNDgMSTGovzRNoR
Mr.Jerry Wilde
402 West Broadway
Newport,Tennessee 37821
Dear Jerry:
It is with great pl pasure that-I appoint you to serve on the Pigeon River Joint Watershed
Advisory Committee as-a' representative of an environmental citizens,group in Cocke County.
Your term will begin immediately and you should serve until notified.
a
I am anxious,to till our state boards and commissions with the most highly qualified people,
and it would be.an•honor to have your service. I have,great confidence in your abilities and in the
contribution you�witl make.
Thank you for your willingness to serve our administration and your fellow Tennesseans. I
look forward to working with you.
ncerely,'
Don Sundquist
DS:jb
cc: Mr.Justin P.Wilson Mr.David McMune , Chief
Deputy to the Governor for Policy Environmental Services Section
State Capitol,Suite G-10 TWRA
Nashville,TN 37243 P.0.Box 40747
The Honorable Daniel C.Oakley Nashville,TN 37204 '
Senior Deputy Attorney General Mr.Paul Davis,Director
State of North Carolina Division of Water Pollution Control
Department of Justice TDEC
P.0.Box 629 L&C Tower,21"Tower
Raleigh,NC 27602-0629 401 Church Street
Nashville,TN 37243-0435
The Honorable Barry Turner
Deputy Attorney General
State of Notch Carolina
Department of Justice
P.O.Box 629
-Raleigh,NC 27602-0629
State Capitol. Nashville, 'Tennessee 37243.6001
Telephone No. [phone]

olf -
BLUE RIDGE
PAPER PRODUCTS INC. ovow
:Poo �
February 27,2001
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment FEB 2 8 2001 �J
and Natural Resources
59 Woodfin Place WATER QUALITY SECTION
Asheville,NC 28801 ASHEVILLE REGIONAL OFFICE
Re:NPDES Permit No.NC0000272
Dear Mr. Westall: -
As required under the referenced permit,Part III Special Conditions, Section L:
Temperature Variance Review, Blue Ridge Paper Products Inc. is required to submit a
complete temperature variance review report. Section L also states"...The report shall
be submitted with the request for permit renewal,no later than June 1, 2001." This letter
is notification that the temperature variance review-report will be submitted no later than
June 1, 2001.
If you have any questions,please call me at(828) 646-2033.
Sincerely, ^
Robert Williams
Director—Environmental,Health, and Safety Affairs
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone: [phone]
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
March 5, 2001
Mr. Mike Myers
NPDES Permits
North Carolina Department of
Environment&Natural_Resources
512 North Salisbury,Street
Raleigh,NC 27604
g pe.
Dear Mr. Myers:
Please find enclosed the revised Attachment-II-A for Blue Ridge Paper Products Ines,Canton _
r a:
Mill,NPDES Permit NC0000272:.The water balance was revised from 20 to 2.0 mgd t,64eflect
an accurate white water contribution from the paper mill to the-pulp mill.• •
Please call me if you have any questions at(828) 648-2318.
Derric Brown .
Manager, Environmental Affairs 7 r�001!
MAR"� .`
�
g61�i1�J�c� '
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations ;.;;%

BLUE RIDGE PAPER PRODUCTS INC.
xc: Forest Westall
North Carolina Department of
Environment&Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville,NC 28801
Keith Haynes
North Carolina Department of
Environment&Natural Resources
59 Woodfm Place
Asheville,NC 28801

Attachment II - A
PIGEON RIVER
29.9 INCLUDES AVG.
STORMWATER FLOW
OF 0.17 MOD
31.63 EVAP 0.5
WASTEWATER
PUMP HOUSE TREATMENT
PLANT
RAW WATER USE 2.03
SLUDGE 0.30
FII TER PLANT
8.0, 0.6 0.60
MILL WTP USE
COOLING
PAPERMILL EVAP 0.7
NO. 11 PM 1.9
10.8 NO. 12 PM 1.3 8.1
NO.20 PM 1.7 --
NO. 19 PM 2.9
CHEM PREP 1.3
PCC PLANT 0.3
PULP DIST, 1.5
2.0 WHITE WATER
PULP MILL
11.5 13.50
ERCO CLO2 1.2
CHEM PREP 0.6
COOKING 1.4
BLEACHAG 4.9
RECOVERY 3A
EVAP_ 1.1
STEAM 3.9
5.0 &
POWER
GENERATION
0.9 MISCELLANEOUS 0.9
&
UNMETERED
SLUE RIDGE PAPER PRODUCTS INC.
A RTC 0.9
CANTON MII L-WATER BALANCE MTE WASTEWATER
LLAND A
PERMIT NO.-NC 0000272 LEACHATE
FLOWS INMGD DATE:2/14/01

10/10/2001 16:35 4 PAGE 02
1'tl!R9/^nnI 10:02 615-532-4644 TN GOVERNOR'S OFFICE Praha az/ez
, UTI 11 " :
STA%= OF TENP=5ZF --
,. ,..* :
-- / DON t7tntT7orn5r
GOVERNOR
October 9,2001
Secretary William G.Ross.-Jr.
North Carolina Department of Fuvirontnent and Natnrel Resources
d ...
1617 Mail Service Center F Ii
Q r�••---•-• ..
Raleigh,NC 27699-1617 t f
Re: NPD1 S Draft Permit No.NCOD00272
Blue Ridge Paper Products,Inc.
Dear Secretary Ross:
We have reviewed the most recent draft NPDES pori►7it for Blue Ridge Paper Products,Inc.on
the Pigeon River. We appreciate your agency's attention to our concerns and we are satisfied
with the result.
The revised draft permit fully addresses the five key concerns we outlined in our September 6,
2001 letter_
We appreciate your continued commitment to improving water quality, and your willingness to
work with the state of Tennessee,local citizens and the Technical Review Workgroup to achieve
Our shared,goal of a clean and clear Pigeon River.
incerely, '
J $tin P. ilson
D puty to the Governor for Policy
0 Commissioner Milton H.Hamilton,Jr.,TN DeparWient of Environment and
Conservation
Director Gary Myers,TN Wildlife kcsouieea Agency
Beverly H.Banister,Dimotor,Water Management Division,U.S.Environmental.
Protection Agency,Region 4
Mayor Roland Dykes,City of Newport '
Charles Lewis Moore,Cooke County Eitecutive
Jerry Wilde,President,Dead Pigeon Wver:Council
David Jenkins,l7lrector of Conservation and Public Policy, American Canoe
A ssocation
state Cayttot.Nuhvttto,TWWON■ n 317240-060x
Telephone No. (61111 741-2001

BLUE RIDGE.
PAPER PRODUCTS INC.
September 12, 2001 SEP 7 2ri � ' '
Ms. Marion Deerhake �- --- _
J
Lic,i OU,^CIJ ScCI•JN
Mr. Michael Myers ASH-'/p J g RFGIOiJAC ION
North Carolina Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Re: Draft NPDES Permit for Blue Ridge Paper Products Inc. / Canton Mill
Dear Ms. Deerhake and Mr. Myers;
Blue Ridge Paper Products Inc. (`Blue Ridge") appreciates the efforts of the
Division of Water Quality ("DWQ") and the NPDES Committee of the Environmental
Management Commission in preparing and issuing the Draft NPDES Permit for the
Canton Mill (the"Draft Permit'). It is Blue Ridge's position that the color limits in the
Draft Permit and the reductions scheduled during the Permit term are in keeping with the
spirit of the 1997 Settlement Agreement, and are in accord with the recommendations of
the Technology Review Workgroup and the Bleach Environmental Process Evaluation
and Report prepared by Dr.Norm Liebergott and Mr. Lewis Shackford(the"Liebergott
Report"). Except as qualified by the comments in this letter, Blue Ridge believes the
Permit should be issued in its current form, and the Color Variance and Temperature
Variance should be continued in effect.
Blue Ridge submits the following comments in response to issues raised by a
number of speakers at the Public Hearing on September 7, 2001. This letter will also
address comments submitted by the State of Tennessee and discuss the Temperature
Variance.
1. The Draft Permit is in Accord with the Settlement Agreement and 1997
Permit
Pursuant to a Settlement Agreement entered into in 1997 between EPA, the States
of North Carolina and Tennessee, the City of Newport, Cooke County, the American
Canoe Association and the Tennessee Environmental Council,the state of North Carolina
issued an NPDES Permit to the Canton Mill in December, 1997 (the "1997 Permit"). The
1997 Permit required evaluation and implementation of a number of Best Management
Practices (`BMP's") and process improvements.
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone: [phone] • Fax: [phone]
Raising Your Expectations

BLUE RIDGE PAPER PRODUCTS INC.
The 1997 Permit also required evaluation and possible implementation of
additional technologies to reduce color. Based on expected color reductions from
BMP's,process improvements and other technologies, the 1997 Permit called for color
reductions from 98,000 pounds per day (annual average) on January 1, 1998,to a range
of 48,000 to 52,000 pounds per day (annual average)by May 1,2001. Blue Ridge
implemented or evaluated all required BMP's and process improvements, evaluated
additional technologies, submitted reports on the evaluations and implementations and
met all targeted color reductions. The effluent limits in the proposed permit, 48,000
pounds per day(annual average) and 55,000 pounds per day (monthly average) are a
direct result of the process established in the 1997 Permit.
2. The Draft Permit Continues the Process Developed in the Settlement
Agreement and 1997 Permit
The Draft Permit calls for improved BMP's and process improvements in the first
phase of the Permit just as the 1997 Permit did. These improved BMP's and process
improvements are expected to reduce color to 42,000 pounds per day(annual average)by
December 1, 2003. Blue Ridge is required to submit a report, also by December 1, 2003,
as to the feasibility of achieving an annual color average between 34,000 and 39,000
pounds per day and a schedule for achieving that target. By December 1, 2005,Blue
Ridge is to submit a report with, "... all data necessary to derive the lowest achievable
monthly average and annual average color discharge and color loading limits." The
TRW continues to have a role in the process. Blue Ridge must meet the color reduction
targets unless it can demonstrate, to the satisfaction of the TRW and DWQ, that there are
"overwhelming technical, economic, or operational barriers..."to attaining color
reductions within the targeted range.
The Draft Permit continues the process of technology identification, evaluation
and implementation leading to further color reduction established in the 1997 Permit. It
also continues the role of the TRW in support of the cooperative effort by North Carolina
and Tennessee to require further color improvements in the Canton Mill's discharge. The
parties to the 1997 Settlement Agreement recognized that implementation of BMP's
requires time and capital, as does the evaluation and,implementation of process
improvements and new technologies. The Draft Permit continues that pattern by allowing
Blue Ridge two years to implement BMP's and process improvements and to study
additional technologies for color reduction.

BLUE RIDGE PAPER PRODUCTS INC.
3. The Color Numbers in the Draft Permit are Based on the Recommendations
of the TRW As Contemplated in the 1997 Permit.
The 1997 Permit also established a Technology Review Workgroup (the"TRW")
with representatives from EPA, Tennessee and North Carolina. The TRW was involved
in developing the 1997 Permit and, during the Permit term, in evaluating reports
submitted by Blue Ridge and providing recommendations to DWQ. Pursuant to the
provisions of Part III.,E.,Paragraph 14 of the 1997 Permit, Blue Ridge submitted to
DWQ and the TRW reports in March and June of 2001. In addition to these required
reports, Blue Ridge and a coalition of environmental groups led by the Clean Water Fund
of North Carolina, in an unprecedented display of cooperation, entered into an agreement
with Dr.Norm Liebergott and Lew Shackford to conduct a process audit of the bleaching
process at the Canton Mill. As a result of the audit, the Liebegott Report, referred to
previously herein, was prepared and submitted to DWQ and the TRW.
Based on the Liebergott,Report,the TRW Recommendation and Tech Team
Report, DWQ has issued a Draft Permit with an initial color limit of 48,000 lbs per day
(annual average). Some concern was expressed at the public hearing that this number
does not reflect actual performance. The 48,000 pounds per day limit was recommended
by the TRW, based on a statistical analysis of Blue Ridge's performance submitted to
DWQ and the TRW on January 1, 2001 in accordance with Part III. E.,Paragraph 12 of
the 1997 Permit. A copy of the January 1,2001 report is included with this letter.
4. Anticipated Color Reductions from Technologies Evaluated in the Liebergott
and TRW Reports Should Not Be Written into the Permit Until the
Technologies Have Been Thoroughly Evaluated on a Mill Specific Basis.
Both the Liebergott Report and the TRW Report (the"Reports") evaluated
methods for additional color reduction at the Canton Mill. The Reports concluded the
most cost effective ways to reduce color in the short term were: 1) improvements in BFR;
2) leak and spill prevention and control; and 3)process optimization. Blue Ridge is
committed to all of these BMP's. The Reports also evaluated additional technologies,
including the application of a second stage oxygen delignification system on the
softwood fiber line and ozone addition to the first chlorine dioxide bleaching stage on the
hardwood fiber line. It was the conclusion of the Reports that both of these technologies,
while promising,would require substantial further study, and that it would not be
possible to predict accurately the capital cost and possible cost savings or increases of
these technologies without such further study. Blue Ridge intends to study a second stage
oxygen delignification system on the softwood fiberline, ozone addition to the first
chlorine dioxide bleaching stage on the hardwood fiberline and other color reduction
technologies, and to report on those evaluations in accordance with the requirements of
the Draft Permit. To include a requirement that Blue Ridge implement these technologies
and a color reduction requirement based on anticipated color reductions without further

BLUE RIDGE PAPER PRODUCTS INC.
study is not recommended by the TRW or Liebergott reports and would be inconsistent
with the methodology of the Settlement Agreement and the 1997 Permit.
Likewise, estimated color reductions from the Chloride Removal Process should
not be considered in calculating color reductions for the Draft Permit. At this time there is
no identified technology,which is technically, economically and operationally feasible
for removal of color from this wastestream. Blue Ridge has already evaluated the use of
lime to remove color from this wastestream, and determined that it is not feasible.
5. Response to Comments from the State of Tennessee.
In comments submitted by Paul Davis,Tennessee Division of Water Pollution
Control, and David McKinney,Tennessee Wildlife Resources, the State of Tennessee
asked that: 1) the TRW continue its role; 2) all high certainty BMP's identified in the
TRW Report be implemented; 3) the initial reduction in the annual average for color,
42,000 pounds,be reduced to 40,000 to 42,000 pounds and that the second stage be
reduced accordingly, and 4)Blue Ridge continue monitoring for all dioxin isomers.
Blue Ridge will continue to submit copies of all required reports and evaluations
to the TRW and has no objection to a continued role for the TRW during the new permit
term. Blue Ridge is committed to implementation of the high certainty BMP's in the
TRW Report.Although 2,3,7,8—TCDD dioxin has not been detected in the Canton Mill
effluent since 1989, and the Draft Permit requires Blue Ridge to monitor the bleach plant
effluent prior to the outfall for all dioxin isomers, Blue Ridge has no objection to
continued monitoring for all dioxin isomers at the discharge. Finally, Blue Ridge does not
object to an annual average limit for color in the range of 40,000 to 42,000 pounds per
day, effective December 1,2003, with second stage reductions to be in the range of
32,000 to 39,000 pounds per day.
6. The Temperature Variance for the Canton Mill Should be Continued in
Effect.
The Temperature Variance for the Canton Mill was initially issued in 1984. Since
that time, the Variance has been reviewed during each Triennial Review of Water Quality
Standards in North Carolina. The Triennial Reviews were submitted to and approved by
EPA.
Section 316(a) of the Clean Water Act allows for a variance from a state water
quality standard for temperature where the state standard is more stringent than necessary
to assure the protection and propagation of a balanced and indigenous population of
aquatic life. Blue Ridge submitted, in accordance with the requirements of the 1997

BLUE RIDGE PAPER PRODUCTS INC.
Permit, a comprehensive balanced and indigenous species study in May, 2001. The study
found significant improvement in the fish and benthic communities below the Mill.
DWQ, through its Biological Assessment Group, concurred in continuing the
Temperature Variance. In its concurrence,DWQ noted that temperature is only one of
several factors affecting the aquatic community downstream from the Canton Mill and
that the issue of temperature impacts would warrant re-investigation after additional
pollutant reductions. A copy of a letter from Bryn Tracy with the Biological Assessment
Unit is included with these comments. The Draft permit includes a requirement that Blue
Ridge complete an analysis of temperature and submit a balanced and indigenous species
study during the next permit renewal.
7. Based on the Foregoing, Blue Ridge Requests that the Draft Permit be Issued
and the Variances for Color and Temperature be Continued in Effect.
Blue Ridge believes the Draft Permit, as issued, continues the cooperative Process
established in the Settlement Agreement and the 1997 Permit. Blue Ridge met all
milestones and targets in the 1997 Permit and worked cooperatively with DWQ, the
TRW and a coalition of environmental groups in the development of the Draft Permit.
Blue Ridge is committed to the continuation of the cooperative process and to continued
color reduction which is technically, economically and operationally feasible. Except as
qualified by these comments,Blue Ridge believes the Draft Permit should be issued and
the Color and Temperature Variances should remain in effect.
Blue Ridge appreciates the opportunity to submit these comments. Questions
should be directed to Bob Williams at the Canton Mill, 828-646-2033.
Blue Ridge Paper Products Inc.
By: Robert V. Williams
Director-Environmental,Health
and Safety Affairs

BLUER RIDGE
PAPER PODUCTS INC.
December 28,2000 !sec
9?ppO
Mr. Forrest Westall
Regional Water Quality Supervisor
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville,NC 28801
RE: NPDES Permit No.NC0000272,Blue Ridge Paper Products,Inc. Canton Mill
January 1,2001 Color Limit Feasibility Report
Dear Mr. Westall:
Attached is the January 1, 2001 Color Limit Feasibility Report required by Part III, Section E 12 of the
Canton Mill's NPDES permit. This report is also required by the Settlement Agreement, paragraph 24„
and the Revised Color Variance, paragraph 5H. Blue Ridge Paper Products is submitting this report to
you in your capacity as Regional Water Quality Supervisor for the Division of Water Quality and as a
member of the Technology Review Workgroup. Blue Ridge Paper Products would appreciate you
distributing the enclosed copies to the members of the Technology Review Workgroup.
Blue Ridge Paper Products believes that achieving.a target annual average color limit within the range of
48,000 — 52,000 pounds per day is feasible. Due to the limited data set available, Blue Ridge Paper
Products believes it is appropriate to use a 990'percentile confidence interval to extrapolate long term and
continuing monthly and annual average effluent limitations. Based on this statistical review of the
available data from January 1998 - October 31, 2000 the Canton Mill recommends an annual average
color limit of 49,612 lbs/day and an average monthly color limit of 59,796 lbs/day.
For the June 1, 2001 report, (required by Part III, Section E, paragraph 14, of the Canton Mill's NPDES
Permit),Blue Ridge Paper Products recommends using a 950'percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 950s percentile statistical review of the
limited data available from January 1998— October 31, 2000 the annual average color is 48,388 lbs/day
and the monthly average color is 55,556 lbs/day. Blue Ridge Paper Products believes the 95a'percentile
confidence interval will be appropriate with the additional color data that will be available for the June 1,
2001 analysis. The attached Table includes the summary of the 99s'and 95's percentile statistical data.
Please call me at [phone] or Derric Brown at(828) 646-2318 if you have any questions regarding
this report.
(Sincerely,
l.1_6�N a"Y`af YDI..
Bob Williams
Director-Environmental,Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton,North Carolina 28716 • Phone:[phone]
Raising Your Expectations
f

RIDGE
Copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
I. Introduction
The following report details the Canton Mill's ability to achieve a target annual average
color limit in the 48,000—52,000 lb/day range in accordance with the requirements of the
1997 modified Color Variance and NPDES Permit. Part III, Paragraph E 12 of the 1997
Permit provides in part, as follows:
'...The permittee shall submit to the Division of Water Quality
and the Technology Review Workgroup by January 1, 2001, a
report on the feasibility of achieving a target annual average
color loading limit within the range of 48,000 — 52,000 Ibs/day
based on full implementation of the Near-Term Package. This
report shall include all available data necessary to derive the
lowest achievable annual average and monthly color loading
limits... "
This report is submitted to fulfill the requirements of Part III, Paragraph E 12. Based on
the Mill's performance from January 1998 through December 2000, Blue Ridge Paper
Products believes that achieving a target annual average color limit within the range of
48,000—52, 000 pounds per day is feasible.
1

Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
400000
N
d
v
0 300000
6
V
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
SE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
Canton Mill page 2

January 1, 2001—Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
II. Color Performance
The Canton Mill has achieved a color reduction of over 850A since 1988 in the annual
average amount of color discharged, as illustrated in Figure 1. The improved color
performance is due to the Canton Modernization Project,full implementation of the
"Near-Term Package" and continuous color management by the mill.
The Near-Term Package includes the installation of BFRTm on the mill's pine fiberline,
implementation of best management practices (BMPs) detailed in the June 1, 1998 Color
Technology Report, and partial BFR(Eo filtrate recycle) on the hardwood fiberline.
These collective efforts have contributed to the mill's continuous and significant
reduction in effluent color.
The 1998 average annual color discharged was 50,386 lbs/day and the 1999 average
annual color discharged was 41,048 lbs/day. The 2000 average annual color(through
October) is 44,837 lbs/day. All of these values are within or below the target annual
average color range of 48,000—52,000 lbs/day specified in Part III,Paragraph E 12 of
the 1997 Permit.
The 48,000 - 52,000 target range was selected because it was projected to result in
significant mitigation in the occurrence and degree of color at the Hepco gage. Based
upon North Carolina's minimum flow criterion (30Q2),historical flow records, and the
January 1998 — October 2000 annual average color value of 45,4581bs/day,it is expected
that color in the Pigeon River at the Hepco gage will be less than 50 scu's (standard color
units) 100% of the time at all flows above 30Q2. At all monthly average flows greater
than the 30Q2 since January 1999, average monthly color at Hepco has been less than 50
scu's. Therefore, Blue Ridge Paper Product's actual color performance has resulted in
significant mitigation in the occurrence and degree of color at the Hepco gage as
projected by the 1997 Permit and Settlement Agreement.
3

January 1, 2001— Color Limit Feasibility Report
Blue Ridge Paper Products,Inc.
Canton,North Carolina
III. Recommended Color Limits
The January 1998 —October 2000 actual average annual color of 45,458 lbs/day and the
January 2000—October 2000 actual average annual color of 44,837 lbs/day are both
below the target annual average color range of 48,000—52,000 lbs/day specified in Part
III,Paragraph E 12 of the 1997 Permit. It was anticipated, and has now been
demonstrated,that full implementation of the Near-Term package would achieve an
annual average color within the 48,000—52,000 lbs/day range.
3.1 Review of Color Performance Data
Based on a statistical evaluation of the mill's annual color, Blue Ridge Paper Products
believes an annual average effluent color limit in the 48,000—52,000 lb/day range is
achievable. Due to the limited data set available, it is appropriate to use a 99%
confidence interval to extrapolate long term and continuing monthly and annual average
effluent limitations.
The January 1998—October 2000 annual color average using a 990i percentile
distribution is 49,612 Ibs/day. The January 2000—October 2000 annual color average
using a 990i percentile distribution is 48,911 Ibs/day. These values are both within the
48,000—52,000 lb/day range. Based on a statistical review of the data and the limited
data set available, Blue Ridge Paper Products, Inc. recommends an annual average
effluent limit of 49,6121bs/day.
The January 1998 —October 2000 monthly color average using a 990i percentile
distribution is 59,796 lbs/day. The January 2000— October 2000 monthly color average
using a 990i percentile distribution is 58,953 lbs/day. Based on a statistical review of the
data and the limited data set available,Blue Ridge Paper Products recommends a monthly
average effluent limit of 59,796 lbs/day.
4

January 1, 2001— Color Limit Feasibility Report
Blue Ridge Paper Products, Inc.
Canton,North Carolina
III. Conclusion
Blue Ridge Paper Products, Inc.believes it is feasible to achieve a target annual average
color limit within the range of 48,000— 52, 000 lbs/day. The Canton Mill recommends
an average annual color limit of 49,612 lbs/day and an average monthly color limit of
59,796 lbs/day. These recommended color limits demonstrate the Canton Mill's
commitment toward color reduction and continued color management.
Using North Carolina's governing flow criteria(30Q2),historical flow records, and the
recommended annual average color limit of 49,612 lbs/day, it is expected that color in the
Pigeon River at the Hepco gage will be less than 50 true color units approximately 97%
of the applicable time.
5

TABLE
January 1, 2001 Color Limit Feasibility Report
Monthly Average Data-Max Month Cale
Data Set= 111198-10/31/2000 1/1/2000-10131/2000
KS Normality test normal normal
Autocorrelation= 0.61
no. of obs. _ . 34 10
xbar 45478.5 44836
stddev 6145 6059
95th safe MONTH from normal dist 55556 54773
99th safe MONTH from normal dist 59796 58953
95th safe YEAR from normal dist 48388 47704
99th safe YEAR from normal dist 49612 48911
Ranked observations
95th percentile for max MONTH 56809 55514
100th percentile for max MONTH 58542 58009

r 'IF
Fax:[phone] Jul 13 101 10:45 R.02/02
Governor
1� Willian G.Ross,Jr.,Secretary
=1 Department of Environment and Natural Resources
O Y Kerr T.Stevens
Division of water Quality
MEMORANDUM July 12,2001
To: Jimmie Overton'
Forrest W estall
Through: Trish MacPherson h^'
From: Bryn H.Tracy Gib
Subject: Additional Comments on the NPDES Permit No.NC0000272, Blue Ridge Paper'Producis Inc., Canton
Mill, Balancers and Indigenous Spades Study for the Pigeon Ayer
In an earlier memorandum to Mr.Jimmie Overton and Mr. ForresbWestalt(urxtated,but written on June 12,:2001),i
provided my comments on the report--NPDES Permit No. NC000027,2, Blue Ridge raper Products Inc:,Canton Mill.,
Balanced and Indigenous Species Study forthe Pigeon River..I do not agree with the•main Conclusion,of the,report that
because a balanced and indigenous fish community exists in the Pigeon River below the mill, the thermal variance should
be continued.
However, I can not find fault in the NC DWO's continuation of grantingla thermal variance for the mill. Temperature is only
one of several factors affecting the current states of the.communities 10 the river_ Other factors mayJnclude,but not be
limited to,color,total and dissolved solids, biochemical,oxygen demarid, dissolved safts,and other constituents of the
mill's effluent. Temperature is not the sole factor for preventing balanced and indigenous'fish communities from
establishing themselves in the river below the mill. After additional politltant reductions are achieved,the issue of
temperature impacts will warrant a re-Investigation.
It is my opinion,that Blue Ridge Paper Products Inc.should continue to make every effort to reduce more of the pollutants
discharging into the river. I also believe that recolonization sources are lacking downstream of the.mill and that the darter
fauna and other flsh species in the river have been severely impacted for many decades. Consequently, Blue Ridge
Paper Products Inc. (and other responsible entities, interested parties,land resource agencies) should fund efforts to
reintroduce species that were eradicated by the mills effluent and nowi are prevented from recolonizatlon by the Walters
Dam. Such efforts are currently underway in the Tennessee portion of the river by agencies in that state. Without
intervention,the recovery of a balanced and indigenous:ffsh community below the mill in North Carolina will likely take a
long lime,i1 ever.
BHT/bht
PC: Dave Goodrich
Keith Haynd> i
Michael Meyers
QUA
Customer Service Environmamal Scianom Branch 1621 Mail Service Cfenter Ralaigh;NC 27699•1621 [phone]
1 800 823.7748
+ o -Ra rn:Rr.7rF RIDGE PAPER PRODUCTS FROM:919 733 0719 Pe2

NOV-02-01 10.44 FROM=WATER ENF SECTION 11 ID=404 S62 9692 PAGE 1/1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY'
REGION 4.
ATLANTA FEDERAL CENTER
y o= 61 FORSYTH STREET
'+t vno1 ATLANTA,GEORGIA 30303-8060
NOV 0 2 2001 — --
Gregory J.Thorpe,Ph.D. FAX R A N S M ITTA L of Pages► /
Acting Director ° ^
Division of Water Quality. g Pne
North Carolina Department'of Environment g " �
rvx
and Natural Resources'
rs��s<oman-0ase vgP�o, MCPRMMu+mwa�a+
1617 Mail Service Center ..
Raleigh,NC 27699-1617
SUBJ: Proposed Final NPDES Permit
Blue Ridge Paper-NC0000272
Dear Mr_Thorpe:- -
We have reviewed the proposed final National Pollutant Discharge Elimination System
(NPDES)permit referenced above and have no objections. Based on the technical evaluations of
the mill that have been conducted to date,we are confident that Blue Ridge Paper will achieve
significan(_cplor reductions during this next permit tetra Regarding the temperature variance
provisions we request the opportunity to review the balanced and indigenous species study plan
that Blue Ridge Paper is to submit to you by March 1, ZOOS.
Regarding the status of EPA7s review of the color variance tinder Section 303(c)of the
Clean Water Act,we expect to make a final determination prior to the effective date of this
proposed final permit.
We look forward to working with you to continue to achieve improvements in the water
quality of the Pigeon River.
Sincerely,
Bever, li.Banister,Director
Water Management Division
cc: Bob Williams,BIue Ridge Paper
Justin Wilson,TN Governor's Office
Paul Davis,TN Dept. of Environment&Conservation
Hope Taylor-Guevara,Clean Water Fund of NC
David Jenkins,American Canoe Association
Bob Seay,Dead Pigeon River Council
John Noel,Tennessee Environmental Council
Intamat Address(URL)•httpJlwww.epa.gov
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G gory J. Thorpe,Pli.D.
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North Carolina Department of Environment and Natural Resources D
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Raleigh,North Carolina 27699-1617 i
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Dear Dr. Thorpe: �ASHEVILL REGIONAL OFFICE
The purpose of this letter is to provide the results of Environmental Protection Agency's
(EPA's) Clean Water Act Section 303(c) review of the State's action to reissue the variance for
instream color for the Blue Ridge Paper Products, Inc. (Blue Ridge Paper) discharge to the
Pigeon River.
The variance for instream color was reissued by the State on October 10, 2001, with an
effective date to be the same as the effective date for reissuance of National Pollutant Discharge
Elimination System permit No. NC0000272. The October 2001 color variance was certified as
"duly adopted in accordance with N.C:G.S. §143-215.3(e) and i5A 2B.0226, following notice,
public hearing and consideration by the NPDES Committee of the Environmental Management
Commission" in a letter dated October 16, 2001 from Francis W. Crawley, Special Deputy
Attorney General, Commission Counsel to the EPA Region 4 Regional Administrator. The
basis of the State's 2001 modification to the variance is that"further reductions in color cannot
be made at this time in an economically reasonable manner, and, if required, would produce
serious hardship without equal or greater benefits to the public." [Color Variance, October 10,
2001, page 10]
EPA's initial approval of the variance, which was adopted by the State on July 13, 1988,
was based on the provisions of 40 C.F.R. §131.10(g)(6), which state:
States may remove a designated use which is not an existing use, as defined in
§131.3, or establish subcategories of a use if the State demonstrates that attaining
the designated use not feasible because . . . Controls more stringent than those
required by Section 301(b) and 306 of the Act would result in substantial and
widespread economic and social impact.
Since the State's original adoption of the variance, more restrictive color limitations have
been established, and the point of compliance with instream color requirements has been moved
Internet Address(URL)• http://www.apa.gov
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further upstream to a location closer to the Blue Ridge Paper outfall. Also, the 1996 and 1997
modifications of the variance required further evaluation and reporting of the technical,
economic, and operational feasibility of color minimization, color removal, and color treatment
(on both a continuous or intermittent basis), which served as the basis for incremental reductions
of color discharged to the Pigeon River. In regard to compliance with these historical and
current conditions of the variance, the previous discharger (Champion International) and its
successor (Blue Ridge Paper) have complied with all terms of the original variance and the 1996
and 1997 modifications of the variance.
EPA's review of the color variance reissued by the State on October 10, 2001 is based on
the provisions of 40 C.F.R. §131.20, which require the following:
Any water body segment with water quality standards that do not include the uses
specified in Section 101(a)(2) of the Act shall be reexamined every three years to
determine if any new information has become available. If such new information
indicates that the uses specified in Section 101(a)(2) of the Act are attainable, the
State shall revise its standards accordingly.
In 1997, several groups signed an agreement which established specific requirements for
the operation of the Blue Ridge Paper mill and for the wastewater treatment operations at the
mill, and governed certain actions of regulatory agencies relating to the Blue Ridge Paper facility.
This 1997 Settlement Agreement established that the Technology Review Workgroup
(Workgroup) would study available color reduction technologies and report on those
technologies prior to reevaluation of the variance in 2001. The 1997 Settlement Agreement
also recognized that the EPA Technology Team would study options for color reduction at the
Blue Ridge Paper mill, and prepare a report for the Workgroup's use in their evaluations. The
Workgroup's analysis presents a summary of the analysis of available color reduction
technologies that may be employed.at the Mill as well as a summary of the estimated economic
impact of the cost of implementing those technologies. The report included review and input
from North Carolina, Tennessee, the Clean Water Fund of North Carolina, Liebergott and
Associates and GL&V Pulp Group, Inc., and Blue Ridge Paper. The report also addresses
relevant technologies evaluated in the Bleach Environmental Process Evaluation and Report.
The Workgroup identified five process improvements capable of further reducing color
discharged from the Blue Ridge Paper Mill, and reviewed the technical feasibility, capital and
operating costs, and potential color reduction capacity of each. Due to the potentially high initial
capital investment costs and ongoing operating expenses of end-of-pipe treatment technologies,
the Workgroup focused on pollution prevention approaches such as color reduction in low flow,
highly color-concentrated waste streams, through manufacturing changes or in-process treatment.
The Workgroup reviewed the EPA Technology Team report, reviewed reports submitted
by Blue Ridge Paper, conducted a site visit to the Blue Ridge Paper Mill in March 2001,
reviewed the Bleach Environmental Process Evaluation and Report dated June 8, 2001, and

3
considered comments from environmental interests and other stakeholder groups in reaching
their conclusions and recommendations. Among other conclusions, the Workgroup found that
the EPA Technology Team report"represents an appropriate evaluation of the potential for
additional color reduction at the Mill over the next permit cycle."
The Workgroup considered these five process improvements for specific inclusion for
implementation or further study as terms of the variance as well as the recommendation of the
Bleach Environmental Process Evaluation and Report for process optimization on both the
hardwood and softwood fiber lines. Two of these five process improvements (improvements in
bleach filtrate recycle reliability and leak and spill prevention and control -best management
practices) and the process optimization option recommended in the Bleach Environmental
Process Evaluation and Report were concluded to have the "highest certainty for technical
feasibility and color reduction." Implementation activities for these three activities are required
in the conditions of the variance.
The Workgroup identified two other process improvements (ozone addition to an existing
chlorine dioxide bleaching stage on the hardwood fiber line and adding a second stage to the
current oxygen delignification system on the softwood fiber line) as having a "reasonable
certainty for technical feasibility and color reduction."
The variance requires an evaluation of these two technologies as well as a requirement for
Blue Ridge Paper to submit a proposed schedule for implementation of these two process
improvements or installation of technologies required to achieve an effluent color reduction of
3;000 - 8,000 pounds per day over and above the color reduction of the "highest certainty"
improvements. The incremental range of color reduction of 3,000 to 8,000 pounds per day is
commensurate with the range of color reduction identified by the Workgroup as possible with the
implementation of the "reasonable certainty" improvements.
The Workgroup also identified a fifth process improvement (color treatment for the
chloride removal process (CRP) purge stream) as having potential for additional color reduction.
Based on the results of previous laboratory trials of color precipitation, Blue Ridge Paper
concluded that lime treatment is not a feasible option for the CRP purge stream. However, the
EPA Technology Team recommended "additional review of other innovative technologies for
treatment of color in the CRP purge stream, such as the application of the X-Filter process
recently implemented at a totally chlorine free (TCF) mill." Based on the Workgroup's
recommendation, the variance requires that Blue Ridge Paper: (1) complete an evaluation of the
technical, economic, and operational feasibility of implementing color reduction technologies
associated with the CRP waste stream, and (2)prepare a report on those investigations, unless
Blue Ridge Paper identifies a feasible technology for treatment of this waste stream, in which
case the obligation to research additional technologies will be waived.
The conclusions of the Workgroup serve as the basis for the inclusion of color reduction
technologies and targeted ranges of color reduction as requirements in the variance, as well as the

inclusion of future steps to be completed prior to the next review of the variance.
In addition, EPA used three measures of financial health (gross profit test, discounted
cash flow, and Altman's Z) "to assess the impact of air emissions control technologies and
devices and wastewater compliance costs." Based on analysis of that assessment and the
conclusions reached by the Workgroup, the underlying rationale for EPA's approval of the July
13, 1988 variance has not changed, and there is no information presented which would serve as a
basis to conclude that Section 101(a)(2) uses, i.e., Class C uses and the supporting water quality
criteria for instream color,are attainable at the present time.
EPA initiated informal consultation with the U.S. Fish and Wildlife Service (Service) on
October 12, 2001, under Section 7(a)(2) of the Endangered Species Act. Section 7(a)(2)requires
that federal agencies, in consultation with the Service, insure that their actions are not likely to
jeopardize the existence of federally listed species or result in the adverse modification of
designated critical habitats of such species. Upon completion of consultation,EPA will notify
the State of the results.
Considering the above,the requirements of the Clean Water Act and 40 C.F.R. Part 131
in relation to attainability and the continued progress to meet the full Section 101(a)(2) use have
been met, and the State's action to continue the color variance is approved subject to the results
of consultation under Section 7 of the Endangered Species Act.
If you have questions concerning this matter, please contact me at 404/562-9326.
Sincerely,
A
Beverly H. Banister,Director
Water Management Division
cc: Francis W. Crawley

BLUE RIDGE
PAPER PRODUCTS INC.
February 27, 2001
LL
Mr. Forrest Westall FEB 2 8 2001
Regional Water Quality Supervisor
North Carolina Department of Environment WATER DUALITY SECTIOFJ
and Natural Resources ASHEVILLEREGIONALOFFICE
59 Woodfin Place
Asheville, NC 28801
RE: NPDES Permit No. NC0000272, Blue Ridge Paper Products Inc. March 1, 2001
Report On End-Of-Pipe Color Reduction Technologies and Ongoing and Planned
Color Reduction Activities
Dear Mr. Westall:
In accordance with Part III, Section E(14) of the above-referenced NPDES Permit,
Blue Ridge Paper Products Inc. (Blue Ridge) submits this report on end-of-pipe color
reduction technologies and other ongoing and planned color reduction activities.
Attached is a report prepared by Jacobs Engineering Group, Inc. on behalf of Blue
Ridge on end-of-pipe color removal technologies. With the submittal of this report,
Blue Ridge or its predecessor will have evaluated these technologies three times in
the past thirteen years in an effort to Identify either a breakthrough improvement in
color removal efficiency or reduction in cost. It is clear that, among these prescribed
end-of-pipe color removal technologies, no breakthrough in economic or technical
feasibility is likely to occur. During this same period, however, alternative
technologies (including oxygen delignification, Elemental Chlorine Free bleaching,
Bleach Filtrate Recycle and those technologies comprising the "Near-Term"
package) were implemented resulting in significant improvements. Therefore, based
upon this record, it is Blue Ridge's intention in the future to focus primarily on the
potential treatment of selected, colored wastewater streams before they enter the
wastewater treatment plant (WWTP). These wastewater streams hold the greatest
likelihood of success for future color reduction, and Blue Ridge believes its time and
resources would be better devoted to in-mill treatment of particular wastewater
streams. Blue Ridge requests that this change in focus be incorporated into the next
NPDES Permit and Color Variance Review for the Canton Mill.
Since the issuance of the Permit, Blue Ridge or its predecessor has undertaken the
following color reduction activities:
J 1. Identified and implemented certain Best Management Practices (BMP's) to
reduce color. The following BMP's were implemented before June 1, 1998,
and a report on the implementation was submitted to DWQ, the TRW and
the NPDES Committee on that date.
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

a. Installation of replacement digester recirculation pumps.
b. Installation of a double-chambered pine courtyard spill collection
sump.
c. Installation of weak black liquor tank containment, and
d. Correction of evaporate set demister clogging, installation of
condensate instrumentation and sampling ports for the evaporator
set and assurance of continued dry conveying of knot rejects.
2. Submitted Low Flow Contingency Plan to DWQ and TRW by December 1,
1998 (approved by NPDES Committee in February 1999).
3. Prior to December 1, 1998, complied with a reduced color limit in the
Permit of 60,000 lbs. per day (annual average) and 69,000 lbs. per day
(monthly average).
4. Began implementation of partial Eo stage filtrate recycle on the hardwood
line before January 1, 1999 and submitted a report on the color reduction
benefit resulting from the partial implementation and a projection of
potential color reduction benefit to be gained from full implementation of
BFR on the hardwood line to DWQ, TRW and the NPDES Committee by
December 1, 1999.
5. Submitted a color limit feasibility report to DWQ, TRW and the NPDES
Committee before January 1, 2001, which concluded that the Canton Mill
could comply with a color limit within the range of 48,000-52,000 lbs. per
day (annual average).
Implementation of these BMP's, together with improved mill operations, has reduced
color by 32% over the term of this NPDES Permit (see attached graph). As
described in the January 1st, 2001 Report, the mill has achieved a target annual
average color loading of 48,000 — 52,000 pounds per day. Based on data received
from the National Council on Air and Stream Improvement (NCASI), the Canton Mill
has the lowest color of any mill in our industry category.
In addition to the aforementioned activities, Blue Ridge has conducted the following
activities:
Polyamine trials have recently been conducted at the primary clarifier, secondary
clarifier, and colored in-mill wastewater streams. Numerous trial approaches were
conducted to comprehensively study the effectiveness of polyamine for color
removal. While treating colored wastewater streams in the pulping and recovery
area appeared to remove color, the color bodies re-solubilized and there was no
significant reduction in secondary effluent color. Treating the primary clarifier
resulted in color reductions, but sludge quality declined to an unmanageable
condition and recycled belt press filtrate solids increased significantly. Treating the
secondary effluent resulted in color reductions; however, this type of treatment
would require the installation of equipment and operating costs described in the
attached Jacobs Engineering Group, Inc. report.

As described earlier, Blue Ridge recommends a shift in the treatment technology
evaluation focus from end-of-pipe to the treatment of selected colored wastewater
streams. Blue Ridge intends to evaluate and report on the treatment of selected
colored streams in the pulping and recovery areas and requests this change in focus
be incorporated into the next Canton Mill NPDES Permit and Color Variance review.
Blue Ridge Paper Products would appreciate you distributing the enclosed copies to
the members of the Technology Review Workgroup. Please call Derric Brown,
Manager - Environmental Affairs at [phone] or the undersigned at (828) 646-
2033 if you have any questions or need additional information.
Sincerely,
u�
Robert Williams
Director — Environmental, Health, and Safety Affairs

Canton Mill Secondary Effluent Color Performance
Annual Averages: 1988 - 2000
400,000 Including Permit Limitations
Permit Limitations:
350,000 1-258,945#/d Monthly Ave.eff.4114194
2-172,368#/d Annual Ave.elf.4114/94
3-125.434#/d Monthly Ave.eff.12/12/96
4-98.168#/d Annual Ave eff.12/12196
6-95,000 Wd Monthly Ave eff.111198
300,000 6-69,000#/d Monthly Ave.elf.12/1198
T 7-60,000#/d Annual Ave.elf.12/1/98
8-.48,000-52,000#/d Target Annual Ave
N
c 250,000
`0 1
0
U
m 200,000
w
D150,000 2
0
0
u
N 3
100,000
4 5
50,000 6
7 8
1988 1989 1990 1991 1992 1993 1994 1996 1996 1997 1998 1999 2000
Permit Limitaions - s SE Color Annual Ave.Wd
Blue Ridge Paper Products, Inc.
Canton, NC 2/27/01

No
BLUE RIDGE PAPER PRODUCTS INC.
copy: Keith Haynes
North Carolina Department of Environment
Health and Natural Resources
59 Woodfin Place
Asheville,NC 28801
Technology Review Workgroup (via Division of Water Quality)