NC0000272_ReviewEffluentColorDisPostModernization_19960131

State of North Carolina
Department of Environment,
Health and Natural Resources ` •
Division of Environmental Management r
James B. Hunt, Jr., Governor
Jonathan B, Howes, Secretary I D E H N F Z1
Nann B. Guthrie, Regional Manager
Asheville Regional Office
WATER QUALITY SECTION
January 31, 1996
MEMORANDUM
TO: Champion Color Variance Review Committee :
Dennis Loflin
James Gregory
John Marlar
Brent Smith
Robert Stein
FROM: Forrest Westall
SUBJECT: Review of Champion' s Effluent Color Discharge
After Mill Modernization and Other Variance Issues
During our December 14, 1995 meeting, the Committee asked the
Division to work with Champion to review the actual color discharge
data from the Canton Mill following the complete implementation of
the modernized mill . Champion prepared a statistical review of that
data and presented it to the Division on January 11, 1996 . A copy of
that review is, attached to this memorandum.
The current color variance includes an instream true color limitation
at the North Carolina/Tennessee state line, a maximum allowable
monthly mass color limitation (daily mass loading is calculated in '
the variance assuming true color values as concentrations and
applying those "concentrations" to plant effluent flow) and a maximum
allowable annual effluent mass limitation. We have briefly discussed
these aspects of the current variance at our previous meetings .
INS'T'RF.AM LIMITATION
The current instream limitation in the 'variance is 85 true color
units at the state line. The variance. .requires the Company to use
the color equation to calculate the predicted instream color level at
the state line on a daily basis and then to average those values on a
calendar week basis . The weekly average is not to exceed 85 true
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Champion Color Variance Review Committee
Page Two
color units . Because the seven-day, ten-year low flow (7/10) is the
basis for meeting many instream standards, the Company is only
required to meet the state line limitation at flows equal to or above
the 7/10 for the Pigeon River.
The NPDES Permit reflects the fact that Tennessee did not adopt the
85 true color limitation used in the variance . The permit uses the
same equation, but requires the limit to be 50 true color units on a
monthly average basis. The permit also limits application of the 50
color level at stream flows below 7/10 .
Considerable discussion has occurred about the relative
restrictiveness of these two limitations . Dan Oakley kindly provided
us a copy of Champion' s legal position that the permit is more
restrictive (see attached correspondence from J. Jeffrey McNealey)
I will not address the legal aspects of this point .
The technical question of which is most restrictive is less clear and
certainly lacks any documented rigorous analysis. However, there are
some very important points that can be made concerning the most
appropriate State line limitation. At the outset, the Committee
understands that compliance is not a critical factor. Early in this
committee' s review process Champion provided clear evidence that they
have more than complied with both requirements . In determining the
appropriate state line limitation, there are several other practical
aspects of this question that should be kept in mind. First, the
real difference between the two is likely insignificant and not
worthy of additional analysis . Second, Tennessee accepted the color
limitation in the current NPDES Permit as "compliant" with their
interpretation of the color standard for the Pigeon River and
maintaining that state' s concurrence with the NPDES Permit is very
important . Third, a monthly average limitation is much more in line
with the accepted color equation and more technically defensible in
using that equation to predict color at the state line. Fourth,
North Carolina plans to reissue the Champion permit within the next
year and our variance should by all means agree with the permit that
North Carolina finally presents for reissuance . Fifth, Champion' s
current performance in relation to reduced color discharges is such
that the 50 color limit at the state line is not a controlling
factor. In addition, if Champion' s BFR (TM) process proves
effective, the Company' s color discharge performance will improve
further.
Based on the practical aspects of determining the appropriate state
line limit, I recommend that the variance be modified to reflect the
state line limitation in Champion' s NPDES Permit-the 50 true color
limitation on a monthly average basis.

Champion Color Variance Review Committee
Page Three
MAXIMUM MONTHLY MASS COLOR LIMITATION AND ANNUAL AVERAGE MASS COLOR
LIMITATION
The color data evaluation provided by the Company and referred to
earlier appears to be a reasonable approach in trying to capture
Champion' s current color reduction performance without placing an
unreasonable compliance requirement on the Mill . In our December
meeting, we spent some time reviewing the facts related to Champion' s
overall objective to meet 501 reduction in its color discharge .
Since the reconfigured mill has done significantly better than the
original target (approximately 80o mass color reduction) , it makes a
considerable amount of sense to rethink that original target .
Champion' s evaluation looks simply at color discharge performance
from May 1994 (scheduled "beginning" , of the modernized mill
production) through November 1995 . Because the data is not normally
distributed, the Company applied a skew analysis (Log Pearson III)
and calculated the 99th percentile upper limit of the monthly average
mass loading. Using this technique, Champion has recommended that
the yearly average (daily average on an annual basis) limit for
effluent color be set at 132,341 lbs/day. This compares with the
annual average limitation in the current variance of 172 , 368 lbs/day.
This is a proposed 23% reduction in the current limit . To develop
the maximum monthly mass color limitation, Champion proposes to use
the same mathematical relationship between the current annual average
limit and the monthly maximum limitation. This results in a
recommended maximum monthly limitation on color discharge of 1-9_� wo
lbs/day.
Several Committee members voiced concerns that a renewed variance
shouldn' t place undue restrictions on the Company and that North
Carolina should support and promote the efforts made by Champion.
John Marlar stated that the Canton Mill represents the leading edge
of water pollution control efforts for existing mills of this type.
EPA' s effort to develop best available technology for this category
of industry has used the Canton Mill as an example . Considering
these factors and North Carolina' s long standing position on the
Canton Mill (to require the Company to apply the best technology
economically and reasonably available) , the variance should reflect
the effectiveness of the technology that Champion has placed in
operation and provide an acceptable "window of compliance" for the
day to day running of the mill . I believe the limits proposed by the
Company represent the best way to describe current color reduction
productivity and provide a reasonable compliance target .
OTHER VARIANCE ISSUES
Color Technology Studies :
The current variance includes a condition requiring the company to

Champion Color Variance Review Committee
Page Four
continue to study and evaluate color removal technologies and to
report to the Division on an annual basis . When the original
variance was drafted, there was no guarantee that the mill
modernization program would even go forward much less be successful
in reducing color by 500 . Therefore, it was determined that the
variance should contain a mechanism for dealing with the "what if" of
finding an alternative color technology. Those pre-conditions have
clearly changed.
Champion has adopted (and EPA and North Carolina have approved) color
reduction technology that is tied directly to its pulp and paper
production operation. Color is reduced not by "end of the pipe"
methods, but by reducing the color waste streams that previously
were directed to the wastewater treatment facility. Champion has
"gone down the road" of avoiding the creation of pollution that must
be released into the aquatic environment and has installed rather
extensive production equipment that accomplishes color reduction.
The investment has been on improved production with environmental
benefits rather than treatment benefits with no improvement of
production. (The Company did have to modify the treatment process
due to reduced flow and pollutant-mass load to the treatment plant . )
This approach has been seen both in the industry and in the
environmental regulatory community as the most appropriate way to
deal with difficult "leading-edge" pollution problems .
Champion' s efforts on dioxin and color reduction has had other
ecological benefits, as illustrated by the biological sampling
results presented in December. It is not reasonable or desirable to
"rethink" Champion' s approach to color reduction at this point . This
is even more true considering the potential of BFR (TM) to further
improve the reduction of color through improved handling of
production waste streams . An annual review of "other" technologies
is no longer of value to this effort. Continued effort by Champion
to enhance its "system" should be promoted and we should still
require the Company to let us know promptly about any "breakthrough"
in color removal technology. A report just before the EMC' s three-
year review of the variance should be sufficient . That report should
include a summary of the effectiveness of the BFR (TM) demonstration.
DIVISION STATUS REPORT TO THE COMMISSION:
If the renewed variance takes the direction recommended above for
Champion' s technology reporting, then reporting to the EMC should
follow Champion' s report and prior to the Commission initiating the
three-year review of the variance.

Champion Color Variance Review Committee
Page Five
VARIANCE REVIEW PROCESS:
Because of the nature of the EMC variance review process (under the
authority of the NPDES Committee) , there will continue to be a need
for a formal review process and technical evaluation before the NPDES
Committee takes a final action. The variance condition outlining
this requirement should be updated, but retained.
PROPOSED VARIANCE
I have taken the existing "ORDERED" section of the 1988 variance and
modified it to reflect the recommendation outlined in this
correspondence . I provide this for your review and comment :
(From the July 18, . 1988 approved variance-note that existing sections
of this portion of the document that are proposed for removal are
struck through and proposed revisions are in bold italic)
"Based on the foregoing Findings of Fact and Conclusions of Law, ,it
is hereby ORDERED that :
1 . Champion' s petition for a variance is granted,
pursuant to G.S . 143-215 . 3 (e) , as a variance to water
quality based effluent limitations for color.
2 . The Division of Environmental Management shall
reepen and '____= State reissue NPDES Permit No.
0000272, for the Canton Mill, and modify its provisions
to reflect all the conditions of the—Febr+ i-., 1988
daFa ft BP eem NPDES Permit this variance
including the following specific wording:
I . Champion shall take such action as necessary to
prevent their contribution of true color from
causing the true color at the North Carolina/
Tennessee State line from exceeding 8-5, 50 true
color units at all flows equal to or exceeding
126 cfs (81 .4 MGD) at the Hepco Gaging Station.
Compliance with this requirement shall be measured through a
calculation of instream true color levels at the North
Carolina/Tennessee state line by the following equation:
moo,
Het m 9:9
SLR = WTP /8 .34) + ( (HEf - WTP x D
HEf x 10 (-0.224 x LOG (�f + 0.781

Champion Color Variance Review Committee
Page Six
Where: WTP� = Monthly average waste treatment.
plant discharge color. (e.g. )
Calculated as the average
of all daily loading values (pounds
of true color per day) for a
calendar month.
WTPf = Monthly average waste treatment
plant discharge flow (mgd) .
HEf = Monthly average HEPCO, North Carolina
flow (mgd) - daily flow values less than
81 .4 mgd shall be entered as 81 .4 mgd.
SLC = Monthly average Instream true color
at North Carolina/Tennessee border
(state line) .
Dc = Color concentration of all dilution
streams (13 C.U. ) .
The SL, shall be calculated en - daily basis for each
calendar month. The average _f any __le=aav e,. (cc_`: aal-
ef ealeu a SLC values for each month shall
not exceed &5 50 true color units. Any exceedance of
&S 50 true color units for this average value shall
be considered a violation of this permit/variance
emeept
as previded in
Tomefa !I! e f this ._4
II . The average daily discharge of true color for
each calendar month shall not exceed ^S�945
198,948 pounds per day. The average annual
/ effluent true color loading shall not exceed
172, 268 132,341 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 .
III . Champion is not required to reduce the daily
effluent true color loading to less than
124, 923 pounds per day to comply with the
50 true color State line limit .
IV. The method of analyses used to measure true
color shall be the procedure referenced in
FR 39 430 . 11 (b) (May 29, 1974) .

r <
Champion Color Variance Review Committee
Page Seven
3 . The Division of Environmental Management
shall include review of this variance as a
specific item in its Triennial Water Quality
Standards review, as required by the Federal
Clean Water Act, and make appropriate recommend-
ations to the NPDES Committee.
4 . Champion shall continue to study and
evaluate color removal technologies and shall
report its findings to the Division of
Environmental Management i...•n_dlately upe
aiseevei-y and annually en eL- be€ewe April Be
cif e--_h yea-_ Prior to the Division
undertaking its Triennial Water Quality
Standards review.
5 . The Division will provide a status
summary report on color removal at the
Canton Mill to the NPDES Committee = ,ll
en-er-be€ere Jane 90 ef eaeh year prior
to completion of the Triennial Water Quality
Standards review.
6 .
a-i-id In conjunction with the first subsequentL�.___
triennial water quality standards reviews after
star _ _p, and ___ _____ _-__-..___g „__`.___._..._
per}ed, the Division will nominate a variance
review committee. The NPDES Committee will
have final approval of the selection of this
committee. wwi It Committee membership may
consist e f Natu_,l Reseu==== and ..e__u=it..
^--•-lepme ` Department Staff and a�� e
_ � . -_ter...---�
individuals considered authorities on pulp and
paper technology or environmental aspects of
that industry from the university or research
communities . That review committee' s
report and recommendation will be examined by
the NPDES Committee for a decision on the
adequacy of the existing variance. The NPDES
Committee will determine if changes in the
variance are warranted due to the effectiveness
of the treatment system or because of advances
in color reduction technologies for this type
wastewater. All revisions adopted by the NPDES
Committee will require the modification of the
Company' s State NPDES Discharge Permit .

Champion Color Variance Review Committee
Page Eight
7 . The variance, proceeding, and NPDES Permit
No. 0000272, shall at all times be subject to
reopening in order to modify the color require-
ments based upon any breakthrough in color
removal technologies . Such breakthroughs shall
be brought to the NPDES Committee for consider-
ation, by Champion and the Division of
Environmental Management, as soon as they are
discovered.
S . This variance shall extend for an indefinite
period of time, subject to consideration of the
three-year reviews and the e____ual reperts . aixd
Any modification or termination based thereon
shall be subjected to the public hearing process
required by G.S . 143-215 . 3 (e) . "
I appreciate the opportunity to review these issues with the
Committee. If you have any questions, please let me know.