NC0000272_ReportEnv.Perf.Update_20010314

Canton Mill
Environmental Performance Update
Prepared by:
Blue Ridge Paper Products Inc.
Canton Mill
Prepared For
USEPA
Technology Review Workgroup
March 14, 2001

BLUE RIDGE PAPER PRODUCTS INC.
Copy: Betsy Bicknell
Eastern Research Group
Avion Lakeside Dr.
14555 Avion Parkway
Chantilly,VA 20151-1102
Dan Bodien
10048 138'h Avenue NE
Kirkland,WA 98033
Neil McCubbin
N.McCubbin Consultants,Inc.
140 Fisher's Point
Foster, Quebec
CANDA, JOE IRO
Mr.Paul Davis,Director
TN Department of Environment and Conservation
Division of Water Pollution Control
6'h Floor, L&C Annex
401 Church Street
Nashville,TN 37243-1534
Mr. Dave Goodrich
NPDES Unit Supervisor
NC Division of Environment
and Natural Resources
512 North Salisbury Street
Raleigh,NC 27604
Mr. Keith Haynes
Water Quality Section
Asheville Regional Office
59 Woodfin Place
Asheville,NC 28802
Mr. Dave McKinney
TN Wildlife Resources Agencies
Ellington Agricultural Agency Center
P.O.Box 40747
Nashville, TN 37204
Karrie-Jo Shell
EPA—Region IV
61 Forsyth Street SW
Atlanta, GA 30303-3104
(Mr.Forest ,estall�
Water Quality Section
Asheville Regional Office
59 Woodfin Place
Asheville,NC 28802

a
BLUE RIDGE
PAPER PRODUCTS INC.
r�
March 5, 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: Technology Review Workgroup's request dated February 23, 2001
Dear Mr. Anderson:
Enclosed is the information you requested for the Technology Review Workgroup's
March 14, 2001 meeting with Blue Ridge Paper Products Inc. We are pleased to share
our progress and look forward to your visit to the Canton Mill.
Per your request, pulp production for the Canton Mill averaged 1,317 ADTP (Air Dry
Tons Pulp) for 1999 and 2000 and paper and paperboard production averaged 1,543 tons
per day. Pulp production capacity is 1,420 ADTP.
Please do not hesitate to contact me at(828) 646-2033 if there are any questions.
Sincerely, a
e4*V4
W
Robert V. Williams
Director—Environmental,Health and Safety Affairs
xc: Technology Review Workgroup
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations

�- Canton Mill
Environmental Performance Update
Prepared by:
Blue Ridge Paper Products Inc.
Canton Mill
Prepared For
USEPA
Technology Review Workgroup
March 14, 2001
1

Table of Contents
Executive Summary
Canton Mill Secondary Effluent Color Performance Chart
Section 1: Wastewater Characteristics
Monthly Average Data Summary for 2000
- Figure 1.1: Secondary Effluent Color Performance
- Figure 1.2: Secondary Effluent Color (Ibs/day)
- Figure 1.3: Secondary Effluent Flow (MGD)
- Figure 1.4: Primary Influent Color (Ibs/day)
- Figure 1.5: True Color in the Pigeon River at State Line
- Figure 1.6: True Color in the Pigeon River at Hepco
- Figure 1.7: Primary Influent BOD (Ibs/day)
- Figure 1.8: Secondary Effluent BOD (Ibs/day)
- Figure 1.9: Secondary Effluent AOX (kg/tonne)
- Figure 1.10: Primary Influent TSS (Ibs/day)
- Figure 1.11: Secondary Effluent TSS (Ibs/day)
- Figure 1.12: Secondary Effluent COD (Ibs/day)
- Figure 1.13: Secondary Effluent Chronic Toxicity (NOEC %)
Section 2: Mill Color Balance— 1996—2000
Annual Average PI, SE and Unaccounted Color (Ibs/day), 1996 - 2000
- Figure 2.1: 1996 Mill Sewer Color Pie
- Figure 2.2: 1997 Mill Sewer Color Pie
- Figure 2.3: 1998 Mill Sewer Color Pie
Figure 2.4: 1999 Mill Sewer Color Pie
- Figure 2.5: 2000 Mill Sewer Color Pie
- Figure 2.6: New NCASI Color Method vs Mill Sewer Data
Section 3: In-Mill Sewer Areas
Color Reductions in Mill Sewer Areas over 1996 NPDES Permit term
Canton Mill Sewer Diagram
- Figure 3.1: #1 Sewer Color (1,000 Ibs/day)
- Figure 3.2: #2 Sewer Color Concentration (mg/1)
- Figure 3.3: Combined Condensate Color (Ibs/day)
- Figure 3.4: Contaminated Condensate Color(Ibs/day)
- Figure 3.5: 2B Sewer Color (Ibs/day)
- Figure 3.6: 3A Sewer Color (Ibs/day)
- Figure 3.7: Hardwood Eo Recycle Rate (gpm)
- Figure 3.8: 5B Sewer Color (1,000 Ibs/day)
- Figure 3.9: 6A Sewer Color (1,000 Ibs/day)
Section 4: BFRTm Update
- Figure 4.1: BFR % Closure
- Figure 4.2: MRP % Uptime
- Figure 4.3: CRP Sewer Color (Ibs/day)
- Figure 4.4: CRP Purge Rate (gpm)
March 14, 2001
TRW Visit
Canton Mill
Blue Ridge Paper Products Inc.

Section 5. June 1, 1998 Report
1' Section 6: Low Flow Contingency Plan
Section 7: Eo Recycle Evaluation
Section 8: January 1, 2001 Color Limit Feasibility Report
I March 14, 2001
TRW Visit
Canton Mill
Blue Ridge Paper Products Inc.

Executive Summary
Blue Ridge Paper Products Inc. - Canton Mill
March 14, 2001
Technology Review Workgroup Visit
This information summarizes the important color reduction activities that have
been accomplished over the term of the 1996 NPDES Permit. The information
focuses on effluent color and is responsive to the Technology Review
Workgroup's requests.
Since the issuance of the Permit, the Canton Mill 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.
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
and Section 3). 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:
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. 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 thirteen year period, however, alternative technologies
(including oxygen delignification, Elemental Chlorine Free bleaching, Bleach
Filtrate RecycleTm and those technologies comprising the "Near-Term" package)
were implemented resulting in significant improvements. (See Section 2, Mill
Color Balance.)
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 (WVVfP). These
wastewater streams (See Section 3, In-Mill Sewer Areas) 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.
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
increased operating costs.

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.off.4114/94
2-172.368#/d Annual Ave.off.4114/94
3-125,434#/d Monthly Ave.e#.12/12/96
4-98,168#/d Annual Ave off.12/12/96
6-95,000#/d Monthly Ave efl.1/1198
300,000 6-69,000#/d Monthly Ave.e8.1211/98
T 7-60,000#1d Annual Ave.e0.12/1/98
al 8-48,000-52,000#/d Target Annual Ave
N
250,000
`0 1
0
U
v 200,000
0
E
w
D150,000 2
0
u
N 3
100,000
4 5
50,000 6
7 8
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000
Permit Limitaions t SE Color Annual Ave.#/d
Blue Ridge Paper Products, Inc.
Canton Mill 3/6/01

Section 1
Wastewater Characteristics
The attached graphs review the Canton Mill's primary influent and secondary
effluent monitoring data for the past year (2000). There are also graphs of true
color in the Pigeon River at the Hepco station (River Mile 42.6) and the NC/TN
state line (River Mile 24.7).
Since October of 1996, true color in the Pigeon River at Hepco has been less
than 50 mg/I at all monthly average river flows greater than 330 cfs (as described
in paragraph 25 of the Settlement Agreement).
At the state line, true color in the Pigeon River has a monthly average of 22.8
color units and has been less than 50 color units for the entire 1996 NPDES
Permit term.

Section 1 -Wastewater Characteristics
Monthly Average Secondary Effluent and Primary Influent Data
Jan -Dec 2000
PI TSS Ibs/day SE TSS Ibs/day PI BOD Ibs/day SE BOD Ibs/day SE AOX kg/kkg SE Color(Ibs/day)
Jan-00 157,309 3,951 78,034 1,401 0.080 42,326
Feb-00 144,998 2,496 71,587 991 0.064 43,418
Mar-00 136,228 3,696 76,249 1,277 0.134 45,449
Apr-00 140,561 3,330 82,344 1,191 0.074 43,099
May-00 164,232 3,686 86,704 1,312 0.241 53,019
Jun-00 161,731 2,891 81,506 1,174 0.095 58,009
Jul-00 134,064 3,183 81,621 940 0.088 43,296
Aug-00 141,122 2,623 76,012 1,188 0.092 41,290
Sep-00 143,061 2,023 We-.844 71�?.2$ 867 0.091 39,670
Oct-00 184,592 2,226 72,748 923 0.058 38,793
Nov-00 190,217 2,327 68,099 733 0.040 33,693
Dec-00 171,201 2,705 78,053 1,270 0.202 38,564
Canton Mill 3/5/01
Blue Ridge Paper Products Inc.

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.eft.4114/94
2-172.368#/d Annual Ave.e6.4114/94
3-125,434#/d Monthly Ave.eft.12/12/96
4-98,168#/d Annual Ave e8.12112/96
6-95.000#/d Monthly Ave off.1/1198
300,000 6-69.000#/d Monthly Ave.e6.12/1198
a 7-60.000#1d Annual Ave.e6.1211/98
D 8-48.000-52,000#/d Target Annual Ave
N
250,000
`0 1
0
v
Y
d 200,000
7
I:
W
9 150,000 2
c
0
u
N 3
100,000
4 5
50,000 6
7 8
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000
Permit Limitaions tSE Color Annual Ave.Wd
Blue Ridge Paper Products, Inc.
Figure 1.1
Canton Mill 3/6/01

Secondary Effluent Color (Ibs/day) from Daily Composite
1996 - 2000
300000
"Pre" (1996 and 1997)Average=72,585 Ibs/day
"Post' (1999 and 2000)Average=42,221 Ibs/day
See Section 3 for Pre to Post discussion.
250000
200000
5Z
A
v
m
a 150000
0
0
U
100000 —
Ul-
50000
0
\ cb \9 \ 9 \ 9 \ 9^\9..\0 \ 9 \ 9 \9 \ �^\ ^\0\ 9 \ � \ � \ 0^\0^\ 0 � 9 � 9 \ p� O O O\ g^\ g^\ \ \ NO \ ON
Cb
—39-Sec Eff Color
Blue Ridge Paper Products Inc. Canton Mill 3/5/01
Figure 1.2

Secondary Effluent Flow in mgd for the Canton Mill
Monthly Averages from 1/88-12/00
50.0
45.0 -- ----- --- - -- -------------------------------------------------------------------------- ......... --------- -
40.0 -------------------------------------------------..... .... ------------- ------------------------------------------- -------- - -
10
en
t3
35.0 -------------------- ---------------------- - -
3
0
w Permit Limit = 29.9 mgd as of 1/1/97
30.0 ---------------------------- -------------------------------------------------------- ------------------------------------------- -
25.0 -- ----------------------------------------- ---------- ----- - -- ---- - -- ------
20.0
4550�}50p30tp f50 pP`Pp p 04�?^4'0ry ° a00bpaoo-Nb o&9 �� 1 1vl1P&�0ot`0�-&P`&\Oo &� SPP.OP\pP'p
�\ 4`S -Yac ° a: � & � vV � � ° � ,V �\ ae 1O �
)° � \
) P � 0 �OPQ ) P � P 0 Y � � PQ � o � Po � PQ � � P Po � P
Blue Ridge Paper Products, Inc.
Canton Mill MSH 3/4/01
Figure 1.3

Primary Influent Color (Ibs/day) from Daily Composite
1996 - 2000
500000
"Pre"(1996 and 1997)Average=94,345 Ibs/day
450000 "Posy'(1999 and 2000)Average= 55,998 Ibs/day
See Section 3 for Pre to Post discussion.
400000
350000
300000
ro
9
W
a 250000
0
U 200000
150000 -
100000
50000
0
^\9rh\��\ ',\9°j\9^\c6 ,\Cb C, N\C, 11 4(1 \9^\9�\ 9�49 \ \9Cb ^\ ^\9�\��\�A\,, C N\p�k\p�\ p�\ pA\, C\ O^\ O
—38-Pri Inf Color
Blue Ridge Paper Products Inc. Canton Mill 3/5/01
Figure 1.4

Actual Measured Color in the Pigeon River
at the NC/TN Line for the Canton Mill
225 Including Background River Color(Upstream of Mill
Monthly Averages from 1/88-12/00
200
175
J
E 150
C
0
m 125
c
100
0
v
`0 75
0
v
50
25
0
0� 00 00 00 00 CP 0ry 00 00 0� CP 9h 00 00 06 9A 01 00 00 00 00 00 00
)01
) ) ) ) ) ) ) ) ) ) ) ) )
—.—ACTUAL MEASURED TN140 CLR ST mg/l mon avg a Canton Color
Blue Ridge Paper Products,
Figure 1.5 Canton Mill MSH 3/6/01

Pigeon River True Color (mg/L) Hepco
Monthly Average Data: 1988 - 2000
I
350
i
300
250
m
200
E
0
U 150
100
LAA
50 -
0
)ac� )c 90 00° ° 9
° ry ° Q ' ° ° 6 ' ' �
-
SJaS\ a 09 O� AO
�; lac �J\ Sao �J\ lac �J\ lac S
—Hepco Sp.T Color
Blue Ridge Paper Products Inc.
Figure 1.6 Canton Mill 3/5/01

I '
Primary Influent Biochemical Oxygen Demand (BOD) Ibs/day
Daily Values: January - December 2000
160000
140000
120000
100000
m
9
a 80000
O
O
m
60000
40000
20000
0
°\°° 9\°° °° 6\°° \ \°° $\°° °° \6\°° °\ \�\ ^�\ \^\ ^�\° 9\° ^4°°
^\ ^\^ ^\ry �� �ry ,h\% \ry p\ p\`Y 0 4j\`t' 6 6\ '1 1\ 1\`, g\ \ 9 9 -, �o\`y '�^\ �'�
+Prl Inf BO IIbslday
Blue Ridge Paper Products Inc. 314/01
Figure 1.7 Canton Mill

Secondary Effluent Biochemical Oxygen Demand (BOD) Ibs/day and mg/I
Daily Values: January - December 2000
50
4500
45
4000
40
3500
35
3000
30
v 2500
25 0
O
m
p 2000 20
m
1500 15
1000 10
500 5
0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
—k—Sec Eff BOD Ibs/day —Sec Eff BOD mgA
Blue Ridge Paper Products Inc. 3/5/01
Figure 1.8 Canton Mill

Blue Ridge Paper Pi As,Inc: Canton,NC
Adsorbable Organic Halide Levels in Secondary Effluent
Once per Week Data from 1/95- 12/96
Monthly from 1/97- 11/00
1.000
----- ----------------- -------------- ------------ -------------------------------- -----------
0.900
Cluster Rule Daily Max = 0.951 kg/tonne
0.800 ------------------------------------------------------------------------------------------------------------------------------
0.700 -------------------------------------
---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
q
0.600 ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
q
0
------------------------------------------------................
O
6
0 0.400 ----------------------------------------------------------------------------------------------- ------------------------------------------------------------------------------------------------------------------------------
0.300 ------------------------ ------------------------------------------------------------------ - --------------------------- ----------------1-1------------------....-. - -
0.200 ------------- -------- - --- -- - -- ---- ------ --------- ---- ----- -- --- -...... . ------------------------------------------------------- -
0.100 - -------------------------- - ----- -- - ----- ------------------------------ ....... ....... -- ---- ..... - ---
0.000
\\Cy �� yCb��\��,\���y\��\�b\�o\��,\�a\����\�y��\, \'\",0��\c, 4c,, (000\�o\���a\Cl 4c, �r4c, \b\�^ \�\q^����p����,0�\��,�p\���,a����,a���oo \(00
do N, ti� N ti ti
T SE AOX kg/tonne pulp —Final Cluster Rule
MSH 3/4101
Figure 1.9

Primary Influent Total Suspended Solids (TSS) Ibs/day
Daily Values: January - December 2000
a00o0o
700000
500000
500000
m
v
a_ 400000
w
300000
200000
100000
0
o O o O o o O o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
^\^\ �\^^\��\ry�\� p\Q b\�ry\� �\6\��\ryo�0 6\���6\^��p �\^gyp^\���p�\ry9�p�\^ry�p�\���p 9\9�p9\ry��p^o��0o\ry^�O^^\p�0^\^t$O^��Ory\^6\O�\�0�0
;--Pri InfTSS Ibs/day
Blue Ridge Paper Products Inc.
Figure 1.10 Canton Mill 3/4/01

Secondary Effluent Total Suspended Solids (TSS) Ibs/day
Daily Values: January - December 2000
25000
20000
15000
A
9
N
a_
N
N
~ 10000
5000
0
^\^\OO\^h\OO\ry�\O`^^\Ory\ry6\O�\^KP I\rybp p\40 \�^\OO�\43 h\�O\OO6\�\O6\��\O \^\O^\�h\O^\�4,�\^_\O�\ry6\O�9\9\O5\�Ory\_\�^\^6\300\�O
V'V V t Sec Eff TSS Ibs/day
Blue Ridge Paper Products Inc. 3/4/01
Figure 1.11 Canton Mill

Secondary Effluent Chemical Oxygen Demand (COD) Ibs/day
2000 Data
120000.00
100000.00 -
80000.00
A
9
60000.00
0
O
U
40000.00 -
20000.00 -
0.00
^`6\°o\ry°\°° `'\°ry^A\°°�`ry\°�\^6\°°\" \^°\°b\ry\\°h\^^\°h\ry�\°°6`\°6`ryry\°° \6\° `ry°\°° \\° \^\°�`°^\°9`^�\°°`ry°\o°`^�°o`ry6\°o^\°\°o\��\°ory�\ory\ry^�°°
-+-Sec Eff COD Ibs/day
Blue Ridge Paper Products Inc. 3/4101
Figure 1.12 Canton Mill

' 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
3/8199 100
6/14/99 100
10/14/99 100
12/6/99 75
12/28199 100
2/14/00 100
3/10/00 100
6/5/00 100
9/11/00 100
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
Figure 1.13

Section 2
1� Mill Color Balance
1996 — 2000
Annual Average Color (Ibs/day)
Primary Influent Secondary Effluent Unaccounted Color'
1996 101,205 82,851 38,824 ""
1997 87,485 62,318 33,601 3110
1998 69,204 50,123 21,847 dc'�
1999 54,437 41,086 3,740
N�df°
2000 57,558 43,355 10,732 &
New NCASI
Method
9/00 — 12/00 43,8532 371 'lw' 0 (-2,463)2
'Unaccounted Color is comprised of: sewer generated color (SGC), turbidity
interference and unmeasured color.
2Using the newly developed NCASI Color test method to remove the interference
of turbidity on the Primary Influent, the unaccounted color for this period is
actually -6% (-2,463 Ibs/day). Using the standard NCASI color test method,
unaccounted color for this same period is 6% (2,968 Ibs/day). Note: Figure 2.6
average Primary Influent and Secondary Effluent colors given for 9/00 through
12/00 are from the standard NCASI Method.
The attached graphs demonstrate the Canton Mill's color performance per sewer
area since 1996.

1996 Average Measured Color in Mill Sewers as a Percentage of Primary Influent Color
Annual Average PI Color= 101,205 Ibs/day
•• Potential Sources of Annual Average SE Color= 82,851 Ibs/day
Unaccounted Color:
1. Sewer,Generated Color
2. Turbidity interference 15%
3. Unmeasured areas of the
Mill.
�d 1:
39% ;v
■2B- Digesters, No. 1 FL: 15,493 ppd
M§t 14% © 3A- No. 1!2 Eo, N0.2FL BSW, 02 Delig: 14,398 ppd
EI PM's- 11 & 12: 3,358 ppd
■ 513- Recovery, BLO,CRP: 6,773 ppd
0 1&2 FL's D1 + Pine D2: 22,359 ppd
2
3% EI Unaccounted: 38,824 ppd
7%
22%
Blue Ridge Paper Products Inc.
Figure 2.1 1996-00 in-mill colors MSH 3/6/01

1997 Average Measured Color in Mill Sewer Areas as a Percentage of Primary Influent Color
Annual Average PI Color= 87,485 Ibs/day
Annual Average SE Color= 62,318 Ibs/day
Potential Sources of
Unaccounted Color:
1. Sewer Generated Color
2. Turbidity interference 0%
3. Unmeasured areas of 12%
the mill.
1 ■2B- Digesters, No. 1 FL: 10,342 ppd
39%
16% p 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig:
a3 14,122 ppd
" © PM's- 11 & 12: 5,120 ppd
■ 5B- Recovery, BLO,CRP: 10,871 ppd
■ 1&2 FL's D1 + Pine D2: 13,407 ppd
3
6/°
°
` ❑Unaccounted: 33,601 ppd
Wks f .
12%
15%
Blue Ridge Paper Products Inc.
Figure 2.2 1996-00 in-mill colors MSH 316/01

1998 Average Measured Color(Ibs/day) in Mill Sewers as a Percentage of
Primary Influent Color
PI Color= 69,204 Ibs/day
Unaccounted Color:Potential sources of SE Color = 50,123 Ibs/day
1. Sewer Generated Color
2. Turbidity interference
3. Minor, unmeasured areas of
the mill.
10%
111213 - Digesters, No. 1 FL: 7,222 ppd
32%
0 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig: 12,715 ppd
3e� 18% ' —
0 PM s 11 & 12: 2,658 ppd
E
® 513- Recovery, BLO,CRP: 9,787 ppd
E 1&2 FL's D1 + Pine D2: 11,128 ppd
4% ®Contaminated Condensate: 2,780 ppd
2% ®Combined Condensate: 1,066 ppd
4%
Unaccounted: 21,847 ppd
14%
16%
Blue Ridge Paper Products Inc.
Figure 2.3 Canton Mill MSH 3/6/01

1999 Average Measured Color (Ibs/day) in Mill Sewers as a Percentage of
Potential Sources of Primary Influent Color
Unaccounted Color: PI Color= 54,437 Ibs/day
1. Sewer Generated Color SE Color= 41,086 Ibs/day
2. Turbidity interference
3. Minor, unmeasured
areas of the mill.
1% 7% 10%
4%
02B- Digesters, No. 1 FL: 5,566 ppd
�
O 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig:
12,316 ppd
El PM's- 11 & 12: 2,090 ppd
23%
■ 5B- Recovery, BLO,CRP: 13,320 ppd
2706 E 1&2 FL's D1 + Pine D2: 14,619 ppd
w
■Contaminated Condensate: 2,039 ppd
❑Combined Condensate: 547 ppd
4% DUnaccounted: 3,740 ppd
24%
Blue Ridge Paper Products Inc.
Figure 2.4 Canton Mill MSH3/6/01

2000 Average Measured Color (Ibs/day) in Mill Sewers as a Percentage of
Primary Influent Color
Potential Sources of PI Color = 57,558 Ibs/day
Unaccounted Color: SE Color= 43,355 Ibs/day
1. Sewer Generated Color
2. Turbidity interference 6%
3. Minor, unmeasured areas
l<:
of the mill. 19%
" 02B - Digesters, No. 1 FL: 3,667 ppd
' E 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig: 11,021
ppd 1 /o
o ,� z ��
� � r �`� d°
3% sr e 3" « M PM'S- 11 & 12: 2,666 ppd
N 5B- Recovery, BLO,CRP: 11,500 ppd
0 1&2 FL's D1 + Pine D2: 15,671 ppd
5%
■Contaminated Condensate: 1,976 ppd
©Combined Condensate: 304 ppd
13 Unaccounted: 10,732 ppd
27%
20%
Blue Ridge Paper Products Inc.
Figure 2.5 Canton Mill MSH3/6/01

Average Measured Color of Sewer Areas as a Percentage of
New NCASI Color Method for Primary Influent
Using the newly developed NCASI Color 9/1/00 - 12/31/00
test method to remove the interference of Primary Influent =49,284 lbs/day
turbidity on the Primary Influent, the Secondary Effluent = 37,696 Ibs/day
unaccounted color for this period is
actually-6%(2,463 Ibs/day). Using the 3% 1%
standard NCASI color test method, 9%
unaccounted color for this same period is
6%(2,968 Ibs/day).
■28 - Digesters, No. 1 FL: 4,323 ppd
R 3A- No. 1/2 Eo, No.2FL BSW, 02 Delig: 12,954 ppd
38%
® PM's- 11 & 12: 1,991 ppd
28%
■ 5B- Recovery, BLO,CRP: 7,852 ppd
a
a] 1&2 FL's D1 + Pine D2: 17,345 ppd
■Contaminated Condensate: 1,591 ppd
'V El Combined Condensate: 260 ppd
4% "* Potential Sources of Unaccounted Color:
1. Sewer Generated Color
17% 2. Turbidity interference
3. Minor, unmeasured areas of the mill.
Blue Ridge Paper Products Inc.
Figure 2.6 Canton Mill MSH 3/6101

® Section 3
In-Mill Sewer Areas
Color Reductions in Mill Sewer Areas
The table below shows the color reductions in mill sewer areas that resulted from
implementation of numerous Best Management Practices (BMP's) and additional
color reduction measures outlined below in the process changes by sewer area.
The "Pre" period is that period prior to implementation of referenced BMP's, and
the "Post" period includes 1999 and 2000. Most color reduction measures were
performed in 1998, therefore, data collected in that year represents a period of
transition and is not used in the Pre to Post averages shown below.
(lbs/day) 3A Sewer 26 Sewer 6A Sewer #1 Sewer Unaccounted*
Pre Color 14,260 12,918 17,894 4,239 36,213
Post Color 11,669 4,627 15,245 2,378 7,236
% Reduction 18.2% 64.2% 14.8% 43.9% 80.0%
® *Unaccounted Color includes sewer generated color, turbidity interferences and unmeasured
color.
Process Changes by Sewer Area
#1 Sewer
Hardwood weak liquor tank containment
213
Replacement of Digester Recirculation Pumps Feb/97
Double-Chambered Pine Courtyard Spill Collection Sump 6/98
Relocation of hardwood secondary knotter accepts tank overflow line to sump
12/98
Sewer monitoring (conductivity, color and flow)
Assurance of Continued Dry Conveying of Knot Rejects
Fiberline Spill Tank Level Management Plan
Non-Contact Cooling water Diversion (from Pine Courtyard Sump) project
® Blue Ridge Paper Products Inc.
Canton Mill
3/5/01

3A
Sewer monitoring (conductivity, color and flow)
Hwd Eo recycle 12/99
Hardwood Eo recycle was instituted in December 1999. Due to outages
(scheduled and unscheduled), the average recycle rate for Eo filtrate since
December 1999 is approximately 140 gpm (see Figure ). The Canton Mill's
target recycle rate is 150 gpm, which is achieved when there are no
hardwood fiberline outages. The approximate color savings from recycling Eo
filtrate for this period is 1,700lbs/d2y.
Fiberline Spill Tank Level Management Plan
513
Oxidation Blower Coolers Project 6/98
Sewer monitoring (conductivity, color and flow)
6A
BFRTm on the Pine Fiberline 10/98
Sewer monitoring (conductivity, color, pH and flow)
Automatic flow meter installation
Condensates
Not monitored prior to 1998
Correction of Evaporator Demister Set Clogging late 1997 — reason to believe
I "Pre" Condensate Color was higher than 1998 —2000 average data
Installation of Condensate Instrumentation and Sampling Ports for Evaporator
Set—Jan 1998
General
Use of#1 Primary Clarifier for Spill Control
Operator Skills Training and On-the-Job Training
E & I Basic Care Checksheet Program
Blue Ridge Paper Products Inc.
Canton Mill
3/5/01

1
RR\� .. Hgiv
kYiKfgY 1Y1 � B. w
� ' �- � in� t�� Btl��Ed v�a �O�Ctl Xa 8� �x� ,�., r e q3z F° ; .v 4 s � ax+ �° `av � �o N•Z �€ _ p� �@
K��S � e t�� 3> :r w $�+.� �s I 4 "§ e�'"" 6 at �' � � .$� ✓ � W ��o` H� w
4'ij�
^*e;.
� l `
� 1
Lek a `t"`�r 1ra ,t ✓„' '', s t>z 3e3 � s gyp. a 1 `' fa �� .,�, ek �' `z r y, EG',` b°d wr
�d� F' ���'� °m �4pt`�� � fro p a>a w��a e t�°' q eo*��d � a� s � 15.n ,d• 4v ,x. � � :. � e C -�� £`®F se .k�.M,
�t
kd ASc
sty aVr 1 �
'� � � e � w s/.. � � n � �� �' �� :fl� ��� sr x e ,�'� y}z�{�w � ��yy� ��``••�� g,g� ' spp''v
I w
q •.'d' s �,Pr . r ��;y�a a�� a {�� 4�9 pa>r,�
son;. .

#1 Sewer Color (1,000 Ibs/day) from Daily Composite
1996 - 2000
50
45
40
35
a 30
N
a
0 25
C
`0 20
0
U
15
10
5
0
^\6 49,
\0 ^\6 ^\0 ^\0 ^\6 ^\^ ^ ^ ^\� ^\1 ^ ^\m^\0 ^\ ^\ ^\ ^\ ^\O ^\9 ^\9 ^\0 ^\9 ^\0 ^\O ^\O ^�O ^\O �\O ^\O
\9 \ O \ 9 \ O \ O^\ 0^\ 9 \ 9 \ 9 \ 9 \ 9^\ 9 \ 9 \O \ O \ O \ O^\ O^\ p� � 9 � 9 � 9 �O^\ 0^\ O \ O \O \ O \ O^\ O
—480-Color#1
Blue Ridge Paper Products Inc. 315/01
Figure 3.1 Canton Mill

#2 Sewer Color Concentration (mgll)
1996 - 2000
12000
10000
m 8000
E
c
0
c 6000
m
0
c
0
U
`0
0 4000
U
2000
()o o <n cn w co co o ao o rn rn rn rn rn rn o 0 0 0 0 0
rn rn rn rn rn rn rn � � rn rn rn rn rn rn m � � rn � rn rn m rn o 0 0 0 0 0
—479-Color#2
Blue Ridge Paper Products Inc. 3/4/01
Figure 3.2 Canton Mill

Combined Condensate Color (lbslday) from Daily Composite
No. 2 Sewer Area
1998 - 2000
10000
9000
8000
7000
6000
9
N
a 5000
r
0
ci 4000
3000
2000
1000 -
o rn rn rn rn rn rn o 0 0 0 0 0
rn rn rn rn rn � rn rn rn rn rn rn o 0 0 0 0 0
\ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
N N N N N N N N N N N N N N N N N N
—Combined
Blue Ridge Paper Products Inc. 314/01
Figure 3.3 Canton Mill

4 � �
Contaminated Condensate Color (lbs/day) from Daily Composite
No. 2 Sewer Area
1998 - 2000
16000
14000
12000
10000
m
9
N
a 8000
0
0
v 6000
4000
2000
0� � m rn rn � rn rn rn rn rn rn o 0 0 0 0 0
N N N N N N N N N N N N
—Contaminated
Blue Ridge Paper Products Inc. 3/4/01
Figure 3.4 Canton Mill

2B Sewer Color (1,000 Ibs/day) from Daily Composite
1996 - 2000
200
180
160
140
m
0
m 120
o.
0
0 100
U
N
a
0 80 -
0
0
60
40
20
0 cn cn o o ao oo co ao rn rn rn rn rn rn o 0 0 0 0 0
rn rn rn rn m rn rn rn rn rn rn rn rn rn m rn m m rn � rn rn rn rn o 0 0 0 0 0
\ M t( n
—477-Color 2B
Blue Ridge Paper Products Inc.
Figure 3.6 Canton Mill 3/4/01

3A Sewer Color (1,000 Ibs/day) from Daily Composite
1996 - 2000
150
130
110
b
0 90
d
a
0
o 70
U
U)
a
0 50
0
30
10
-1 O o co 0 0 co r ro oo w rn rn rn rn rn rn o 0 0 0 0 0
rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn m rn m rn rn o 0 0 0 0 0
—478-Color 3A
Blue Ridge Paper Products Inc. 3/4/01
Figure 3.6 Canton Mill

Monthly Average Hardwood Eo Filtrate Recycle Rate
3A Sewer Area
December 1999 - December 2000
200
Target Eo Recycle Rate is 150 gpm during normal operation.This data includes all hours in a month
(running and downtime).
180
160
140
a 120
t7
d
m
6 100 Semi-Annual Outage was
T
held in November 2000.
p 80
w
60
40
20
o p o 0 0 0 0 0 0 0 0 0 0 0
I
j
Blue Ridge Paper Products Inc. 3/5/01
Figure 3.7 Canton Mill

5B Sewer Color (1,000 Ibs/day) from Daily Composite
1998 - 2000
100
90
80
70
a 60
N
a
0 50
0
0 40
0
U
30
20
10
0
—481 -Color 5B
Blue Ridge Paper Products Inc. 3/4/01
Figure 3.8 Canton Mill

6A Sewer Color (1,000 Ibs/day) from Daily Composite
1996 -2000
100
90
80
70
60
N
a
0 50
C
`0 40
0
v
30
20
10
0 �n co co o m ao oo m ao rn rn rn rn rn rn o 0 0 0 0 0
rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn rn o 0 0 0 0 0
—482-Color 6A
Blue Ridge Paper Products Inc. Canton Mill 3/4/01
Figure 3.9

Section 4
Update on BFWm Performance
BFkTm continues to operate on the mill's Pine fiberline. Average % Uptime for
MRP since October 1998 is approximately 86% (see Figure 4.2).
However, the Canton Mill continues to have capacity and reliability issues with
the operation of the Metals Removal Process (MRP) due to the following factors:
• Media filters plugging
• Softener screens plugging and scaling
• Laterals failing in filters
• Strainer failures
• Whole system plugging
• Regeneration pump failures
• -Softener-Resin-failing-from fiber and scale-accumulation
The Canton Mill has established a task group to comprehensively assess these
recurring problems. The goal of this group is to manage the above issues to
consistently achieve the target closure of 80%.
Average % Closure on the Pine Fiberline since October 1998 is approximately
74% (see Figure 4.1 ).
Operation of the Chloride Removal Process (CRP) has been extremely reliable,
though it contributes approximately 6,000 Ibs of color to 5B sewer per day on
average (see Figure 4.3). Average purge rate since September 1999 is 9.1 gpm
(see Figure 4.4).
Blue Ridge Paper Products Inc.
Canton Mill
3/6/01

i

� . i '. . �
1ii� � �. � ry � 'i
� � �. �� �

i
AdEkL
Chloride Removal Process (CRP) Sewer Color (lbs/day) from Daily Composite
1998 - 2000
18000
16000
I
14000
12000
a 10000
N
`0 8000
0
U
6000
4000
2000
0 -4 1
^\0 ^\O ^\� ^\� '`\O ^\O ^\9 ^\O ^\O ^\O ^\9 ^\9 ^\O ^\O ^\O ^\O ^\O ^\O
O 9 0 9 9 0 9 9 0 0 9 C O O O O O O
^^\ ^\ ry\ pj\ .\\ ^ram\
—272-CRP Color
Blue Ridge Paper Products Inc. Canton Mill 3/4/01
Figure 4.3

Monthly Average CRP Purge Rate, GPM
September 1999 - January 2001 .
(note: flowmeter was not installed on purge stream until Sep. 99)
14
12
10
Semi-Annual Outage held in
November 2000.
IL 8
m
m
IL 6
4 -
2 -
0 rn rn rn rn o 0 0 0 0 0 0 0 0 0 0 0
rn rn rn rn o 0 0 0 0 o 0 0 0 0 0 0 0
I I I I I I 1 I I 16 I I I I
Blue Ridge Paper Products Inc. 3/4/01
Figure 4.4 Canton Mill

I
.;LMDion i^temli
May 27, 1998
Mr. Forrest Westall
NC Department of
Environment and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
RE: NPDES Permit Modification - Permit No. NC0000272
Dear Mr. Westall:
' In accordance with the above referenced permit, we are forwarding herewith the report to
meet the requirements of Part III-E, Paragraphs 7, 8 and 9. Included with this is a
progress report on Champion's Bleach Filtrate Recycling (BFRTM) technology
demonstration.
If you have any questions regarding this submittal, please contact me at [phone].
Sincerely,
Robert V. Williams
Manager
Environmental, Occupational Health & Safety
Enclosure
xc: EPA Technology Review Workgroup (Please see attached list)
d ata\bobw\n pdes\mod if\west598

1998 COLOR TECHNOLOGY MEASURES REPORT
PREPARED FOR
NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
512 NORTH SALISBURY STREET
RALEIGH, NORTH CAROLINA
AND
TECHNOLOGY REVIEW WORKGROUP
(do ■
Champion
Champion International Corporation
MAIN STREET
CANTON, NC 28716
JUNE 17 1998

Table of Contents
Executive Summare i
1.0 Introduction I
1.1 Purpose 1
1.2 Historical Backsround 2
2.0 1997 NPDES Permit Part III, Paragraph E 8 Requirements - 5
June 1, 1998 Report Submittal
3.0 1997 NPDES Permit Part III,Paragraph E 9 Requirements- 6
BMPs
3.1 Part III, Paragraph E 9- Best Management Practices (BMP) Required Projects 6
3.2 General Discussion 6
3.3 Replacement of Digester Recirculation Pumps 6
3.4 Double-Chambered Pine Courtyard Spill Collection Sump 7
3.4.1 Project Description 7
3.4.2 Project Justification 9
3.5 Weak Black Liquor Tank Containment Project 9
3.6 Additional Operational Measures. ` 11
3.6.1 Correction of Evaporator Demister Set Clogging 11
3.6.2 Installation of Condensate Instrumentation and Sampling Ports for 12
Evaporator Set
3.6.3 Assurance of Continued Dry Conveying of Knot Rejects 12
4.0 1997 NPDES Permit Part III,Paragraph E 7 Requirements - 14
Additional Color Reduction Measures
4.1 Part III,Paragraph E 7-Additional Color Reduction Measures 14
4.2 General Discussion 14
4.3 Further Upgrading and Integrating of Sewer Monitoring 16
4.3.1 Sewered Condensates 16
4.3.2 Chloride Removal Process (CRP) 17
4.3.3 Pine Bleach Plant Automatic Flow Meters 18

4.4 Automated Mill Process Control Systems ... 19
4.4.1 Electrical and Instrumentation (E & 1) 19
4.4.2 Fiberline Spill Tank Level Management Plan 20
4.5 Continued Operator Training 22
4.5.1 Pulp Mill 22
a) Operator Skills Training (OST) Program 22
b) On-the-Job Training(OJT) Program 23
4.5.2 Recovery 25
a) Operator Skills Training (OST) Program 25
b) On-the-Job Training(OJ7) Program 25
4.6 Additional Controls for Unmeasured Sources of Liquor Losses 27
4.6.1 Hardwood Secondary Knotter Accepts Tank Overflow 27
4.6.2 Miscellaneous Field Work 28
4.7 Diverting Clean Water Discharges 29
4.7.1 Digester Area Project 29
4.7.2 Oxidation Blower Coolers Project 29
4.8 Capturing&Recycling Liquors During Fiberline Disruptions 30
4.8.1 Detailed Scheduling of Planned Outages 30
4.8.2 Contingency Planningfor Unplanned Outages 32
L4.9 Primary Influent Turbidity Interference Study 33
4.10 Sewer Generated Color 35
4.10.1 General Discussion 35
4.10.2 Previous Research&Findings 36
4.10.3 Research Plan for 1999. 37
5.0 Bleached Filtrate Recycling (BFRTn Process on Pine Fiberline 39
6.0 Conclusion 41

June 1. 1998 NPDES Report
Executive Summary
The follo.ving report cn color reduction measures details the Canton Mill's progress to fulfill the
requirements of the 1997 modified Color variance and NTPDES Permit. Althoueh the BFRm
demonstration is not complete. the mill is currently meeting the effluent limits set forth in Part
III. Paragraph E 10 of the 1997 Permit. Figure One illustrates Champion's success in reducing
color discharges to the Pigeon River since 1988 includine the monthly average performance for
1998.
The 1998 color performance improvement is discussed throughout this report. In addition to the
on-going BFR'" demonstration project, the mill has completed implementation of all Best
Management Practices projects required by Part III, Paragraph E 9:
BMP Projects Total Cost gtatus
Digester Recirculation Pump Replacement $537,000 Complete
Double-Chambered Pine Courtyard Spill Collection Sump $275,000 Complete
Weak Black Liquor Tank Containment P
596,500 Complete
Additional Operational Measures: Status
• Correction of Evaporator Demister Set Clogging Complete
• Installation of Condensate Instrumentation& Evaporator Set Sampling Ports Complete
• Assurance of Continued Dry Conveying of Knot Rejects Complete
The additional color reduction requirements listed in Part III. Paragraph E i of the 1997 Permit
are either completed or currently under study. The report reviews the additional color reduction
measures completed including: enhanced sewer monitoring, diverting clean water discharges and
planned and unplanned outage contingency planning. Operator training has been conducted on
operationai color impacts and permit compliance, BMP operation and outage planning. Studies
on primary influent turbidity interference, known to have a false positive effect on influent true
color,and sewer generated color are continuing.
i

Champion InternationalOporation - Canton, NC
Figure 1: Canton Mill Secondary Effluent (SE) Color Performance
Annual Averages: 1988- 1996 YTD
Monthly Averages:Jan 98-April 98
400,000
350,000
T 300,000 " SE Color
0
N =69000 Monthly
250,000 -60000 Annual
0
U ~
C 200,000
N
w
150,000
0
0
CO100,000
50,000
0)
CMS 5/27/98

June 1, 1998 NPDES Report
1.0 Introduction
1.1 Purpose
This report on in-mill color reduction measures at Champion International
Corporation's Canton, North Carolina integrated pulp and paper mill is submitted in
accordance with the requirements of Part 111, Section E, Paragraph 7, 8 and 9 of the
mill's 1997 NPDES Permit (the 1997 Permit). Following a brief historical background of
the 1997 modification of the NPDES permit and associated Color Variance, Sections 2.0,
3.0 and 4.0 of this report cover the specific requirements listed in Part III, Section E,
Paragraphs 7, 8 and 9 of the 1997 Permit. All four Best Management Practices (BMP)
projects required by Paragraph 9 of the 1997 Permit have been completed and are
discussed in Section 3.0. Each of the projects listed in Paragraph 7 have been completed
by the mill and are discussed in Section 4.0 of this report. The status of the Bleached
Filtrate Recycling (BFRTm) process on the mill's pine fiber line is discussed in Section
5.0. Finally, the report concludes in Section 6.0, with a summary of the mill's overall
color reduction efforts.
The report identifies a strategy and timeline for each project to further reduce
color discharges from the Canton Mill. Color reduction projects completed include:
gathering more extensive and detailed data on sources of color within the Mill to
substantially improve the accuracy of measurements; improvements in the Mill's existing
Best Management Practices (BMP) program and completion of efforts to identify,
quantify and improve the accuracy of a mass balance of sources of process black-liquor
losses, including unmeasured sources and discharges during periods of fiber line
disruption. Each section includes an explanation of and rationale for the strategy being
implemented. Although the BFRTM demonstration is not complete, the mill is currently
meeting the effluent limitations set forth in Part 111, Section E, Paragraph 10 of the 1997
Permit.
1

1.2 Historical Background
Champion's Canton Mill discharges treated wastewater from pulp and paper
production processes at the Mill to the Pigeon River about 37 miles upstream from the
North Carolina-Tennessee border. In the mid-1980s, the State of Tennessee objected to
the issuance of an NPDES permit for the Mill because of color in the effluent. As a result
of Tennessee's objections, EPA withdrew permitting authority from North Carolina and
proposed a true color limit of 50 platinum cobalt units at the point of discharge. Because
there was no demonstrated and cost-effective technology capable of meeting such a limit
at the point of discharge, Champion sought variances from the North Carolina and
Tennessee water quality standards for color, both of which are narrative rather than
numerical standards. North Carolina granted a variance in July 1988 (the 1988 Variance),
but Tennessee did not. The North Carolina variance required the Canton Mill to meet the
Tennessee water quality standard for color at the Tennessee border, using a predictive
model. EPA approved the North Carolina variance in August 1988, and incorporated it
into the federal NPDES permit issued to Champion in October 1989 (the 1989 Permit).
Following administrative appeals filed by third parties representing a citizen group in
Tennessee, the 1989 permit was upheld in 1992.
In March 1990, prior to final approval of the 1989 permit, Champion began the
Canton Modernization Project (CMP), a $330 million effort to dramatically improve the
mill's effluent quality and meet the stringent new requirements of the variance and
permit. The project, among other improvements, involved the elimination of elemental
chlorine in the bleaching process with the complete substitution of chlorine dioxide and
oxygen delignification. Additional process changes were implemented to "tighten up" the
Mill with regard to losses of colored process waters. Once completed in 1994, the CMP
reduced the mill's wastewater discharge from an average of 45 Million gallons per day
(mgd) to an average of less than 29 mgd, as well as reducing color in the Mill's effluent
by almost 80 percent. Figure One illustrates the reduction in color discharges to the
Pigeon River since 1988. Of particular note are the more recent reductions following
Itsuccessful implementation of the CMP in 1994.
2

Under the terms of the 1988 Variance. Champion was required to submit an
annual review of developments in color reduction technologies to the North Carolina
Department of Environmental Management (NCDEM). The 1988 Variance called for the
establishment of a Variance Review Committee (VRC), consisting of water quality staff
and experts in the pulp and paper industry, after startup and completion of the CMP. The
VRC was charged with reviewing the variance and reporting to the North Carolina
NPDES Committee regarding adequacy of the existing variance. The NPDES Committee
reviewed the variance in 1993 and made no changes to it.
In May 1995, in conjunction with the first triennial review of water quality
standards following the completion of CMP, the NPDES Committee appointed the VRC
to review the adequacy of the variance. After reviewing the variance in late 1995 and
early 1996, the VRC recommended in March 1996 that the effluent limit for color at the
point of discharge be reduced by 23 percent from the variance and 1989 Permit.
Following public hearings on the recommended changes to the variance and draft NPDES
permit, the NPDES Committee adopted the hearing officer's recommendations and
modified the variance, establishing new limits for color discharge of 124,933 pounds per
day (daily average on annual basis) and 132,341 pounds per day (monthly average)
decreasing from 172,368 and 258,945 pounds, respectively. The modification of the
Y.
variance was transmitted to EPA on October 17, 1996 and EPA advised the State of
North Carolina that the agency would approve the variance modification. On December
11, 1996, following further discussions between Champion, EPA and the States of North
Carolina and Tennessee, the NPDES Committee adopted an amended order for
modification of the color variance, further reducing the discharge limit for color to 98,168
pounds per day (daily average on annual basis) and 125,434 pounds per day (monthly
average). The amended order included numerous additional requirements for further
color reduction. The Division of Water Quality issued the NPDES permit the next day,
incorporating the variance as modified and amended. On December 26, 1996, EPA
finally approved the changes to the variance.
On January 13, 1997, the State of Tennessee filed a petition for a contested case in
the North Carolina Office of Administrative Hearings challenging the NPDES permit and
3

the variance. Tennessee's objections, and those of other intervenors were resolved by
so
issuance of the February 20. 1998. Settlement Agreement in State of Tennessee et al. v.
North Carolina Dep't of Environment and Natural Resources et al. Pursuant to that
agreement. the 1996 permit was further modified providing for. beginning December 1,
1998, an annual average true color not to exceed 60,000 pounds per day and a monthly
average not to exceed 69,000 pounds per day, unless Champion's patented Bleached
Filtrate Recycling (BFRTn technology is not successful. with an ultimate target annual
average true color loading within the range of 48,000 - 52,000 pounds per day.
Additional study and reporting requirements, as stated in the Settlement Agreement and
1997 modified NPDES permit, are covered in Sections 2.0, 3.0 and 4.0 of this report.
r,
4

2.0 1997 NPDES Permit Part III, Paragraph E 8 Requirements -
June 1. 1998 Report Submittal
The language of this paragraph of the 1997 Permit provides that:
"The permittee shall provide a report to the Division of Water Quality,
the Technology Review Workgroup and the NPDES Committee no later than
June I. 1998. This report will identify a strategy and time line for implementing
those color reduction measures identified in Paragraph E 7 until the target
effluent limitations in Paragraph E 12 [48-52,000 lbs/dav annual average] are
met or all measures in Paragraph E 7 have been fully implemented. The report
will include an explanation of and rationale for both the implementation strategy
and the proposed time line. The report will also identify those measures which
will be implemented in the event that the effluent limitations set out in Paragraph
E 10 [60,000 lbs/dav annual. 69.000 lbs/dav monthly] are not achieved by the
color reduction measures specified in that paragraph."
This report fulfills the requirements of Part 111, Paragraph E 8. Each of the
projects listed in Paragraph E 7 has been completed or is currently under study.
Although the BFRT`" demonstration is not yet complete, the mill is currently achieving
the effluent limitations set forth in Part 111, Section E, Paragraph 10 of the 1997 Permit.
The requirement listed in Paragraph E 11 of the 1997 Permit [Hardwood Eo Recycle]
will be completed in 1999 as a part of the continuing effort to meet the target effluent
limitations established in Paragraph E 12.
5

3.0 1997\'PDES Permit Part III, Paragraph E 9 Requirements - BMPs
3.1 Part III. Paragraph E 9 - Best Management Practices (BMP) Required Projects
The language of this paragraph of the 1997 Permit provides that:
"Four BMPs which have already been identified as having both a high
potential for achieving color reduction and a high level of implement ability are:
(a) installation of replacement digester recirculation pumps and a spill collection
sump: - (b) [installation of a double-chambered courtyard 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. The permittee shall fully implement all four of these BMPs by
June 1, 1998."
3.2 General Discussion
Part III. Paragraph E 7 of the 1997 Permit requires the implementation of four
Best Management Practices (BMP) projects by June 1, 1998. All four of the BMP's
listed above were completed before June V. The digester spill collection sump and pine
courtyard Parshall flume slide gate were combined into a single project involving the
installation of a double-chambered sump in the pine courtyard and is discussed in Section
3.4. The color reduction benefits from these projects will be evaluated after collection of
sufficient operational data.
3.3 Replacement of Digester Recirculation Pumps
Approval to replace the black liquor recirculation pumps for all 18 batch digesters
was received in early March 1996. Installation of these pumps began in April 1996 and
took place during the annual inspection for each digester. All 18 recirculation pumps
were installed and operating by February 1997 for a total cost of$537,000. The previous
recirculation pumps were 1950's vintage centrifugal units unique to the Canton Mill. The
Justification and Technology Review Workgroup approval of this project are provided in Appendix A2.
6

replacement of these pumps has reduced the quantity of concentrated colored material
from the digester area as shown in the secondary effluent trend in Figure 1.
3.4 Double-Chambered Pine Cournlard Spill Collection Sump
3.4.1 Project Description
The pine courtyard and digester area of the mill did not have spill collection
systems; such systems were incorporated as a BMP requirement of the 1997 Permit. The
pine courtyard and digester area (2B area) includes the following source areas: the
digester building including portions of the hardwood blow tank and accumulator, the
hardwood brownstock building including the hardwood oxygen delignification area and
the pine blow tank and accumulator area. Based on a short-term color contribution mass
balance performed within this area in April 1997, the digester area and hardwood
brownstock area each contribute approximately 25% of the color while the remaining
50% of the color comes from the courtyard area. Therefore, two BMP projects for the
digester and courtyard area were included in the 1997 Permit as covered in Section 3.1 of
this report. The two projects were to install a digester spill collection sump and install a
pine courtyard Parshall flume slide gate. In early 1998, with the approval of EPA, North
Carolina and Tennessee, these hvo projects were combined into one project, a double-
chambered courtyard sump. The justification for this project is discussed in the following
section.
Funding for the two-chambered pine courtyard sump was approved in February
1998 at a total cost of $275,000. The sump provides a system to detect, collect and
1Preclaim colored materials from the digester building and pine courtyard area based on
7

conductivity control. The completed sump is located in the pine courtyard area. The
sump is 8 ft. square x 10 ft. deep and constructed of reinforced concrete. The sump is
divided into three sub-compartments. Two of the three sub-compartments are designed
as pump compartments with the third serving as a discharge weir into the U-drain flowing
to the 2B Parshall flume. The mro pump compartments are the collection points for the
two sources of flow in this area. One compartment receives flow from the digester
building and the other compartment receives flow from the courtyard and hardwood
brownstock area. Engineering drawings of this sump and U-drain system can be found in
Appendix Al.
The digester compartment and the pine courtyard compartment have independent
conductivity monitoring. The digester area is typically a low volume, high concentration
color contributor whereas the courtyard area is typically a low concentration, high
volume contributor. Each compartment is designed to pump a maximum of 400 gallons
per minute. Manual slide gates were installed,which allow cross-connection of the sumps
to facilitate maintenance activity in one of the compartments. In the event of upset
conditions the manual gates may also be configured to briefly increase the total sump
collection capacity to 800 gallons per minute. However, total typical flow from both the
digester and courtyard area is approximately 425 gallons/minute. The sump is covered
with a steel plate to allow maintenance traffic to pass over the sump area.
The sump pumps for each of the two compartments are equipped with
independent conductivity probes which are connected to the Distributive Control System
(DCS). The conductivity set points trigger the sump pumps to turn on to minimize the
loss of detected colored material. Collected material from the sump is pumped to the
8

hardwood brownstock spill collection tank. The sump compartments will normally
overflow the third compartment's discharge weir to a U-drain flowing to the 213 Parshall
flume. It is important to note that 50-100 gallons of clean. non-contact cooling (NCC)
water no longer flow through the courtyard due to the diversion project discussed in
Section 4.7.1. Details on this sump project are located in Appendix A.
3.4.2 Project Justification
As stated in the 1997 modified NPDES Permit, the mill was required to install a
digester spill collection sump and a pine courtyard Parshall flume slide gate by June 1,
1998. The mill concluded the above design was an improvement to the sump and
Parshall flume slide gate conceptual design and submitted this design to the Technology
Review Workgroup for approval. A copy of the documentation sent to NCDWQ and
TRW in February 1998 for approval of the new sump design is located in Appendix A2.
While this sump configuration cost more than the original conceptual design, it offers
better operational performance and maintenance reliability.
3.5 Weak Black Liquor Tank Containment Project
With the completion of the Canton Modernization Project in 1994, all of the
black liquor storage tanks are contained and have reclaim sumps on conductivity control,
with the exception of the hardwood weak liquor storage tank. Due to the potential for
colored losses from this tank, a containment system was identified as a BMP during the
1997 Permit discussions.
Funding to construct the hardwood weak black liquor(WBL) containment system
was approved in January 1998 at a total cost of $96,500. Work on this project
9

commenced immediately following project approval and was completed in May 1998.
The containment volume is sufficient to contain most losses based on historical events.
Additional containment capacity is constrained by existing process equipment in this area
and maintenance of the WBL tank.
This project provides a'concrete containment wall for the WBL storage tank as
well as the associated Soap tank. Within the containment area a new stainless steel sump
was installed as a designed low point. Additional concrete work was, required on the
existing-slab—to-control-the-direction of-flow toward the new sump. A four inch Stainless
Steel pipe connects the sump to the mill sewer. A manual valve and an automatic valve
were installed in the sewer overflow connection to prevent released material from
entering the mill sewer.
The control systems for this project are a sump level switch, sump conductivity
probe and tank overflow temperature switch. A level switch is installed on the
containment wall above the sump in order tosdetect any fluid level within the area above
the top of the sump and alarm the operators. The conductivity probe was installed in the
sump to determine the presence of black liquor and initiate an operator alarm. A
temperature switch was installed in the tank overflow line as an early warning of tank
overflow. The operator alarms for all of the instrumentation are sent by the DCS to the
Evaporator Control Room as well as the Hardwood Fiber Line Brownstock Operator's
Station. The DCS simultaneously closes the sewer connection automatic control valve.
The manual valve is a backup to the automatic valve and allows for maintenance of the
automatic valve.
10

A piping connection for a portable sump pump was installed from the sump to the
top of the WBL tank. This project provides detection. operator alarm(s), containment and
reclaim capability to manage the infrequent colored losses from the weak black liquor
storage tank. The engineering drawings for this BMP project are located in Appendix B.
3.6 ,additional Operational Measures
3.6.1 Correction of Evaporator Demister Set Clogging
Evaporator condensates are generated as a result of"boiling' the water out of the
black liquor entering the evaporator set. Periodically, color is carried over into the
evaporator condensates as a result of entrained black liquor in the water vapor
(condensate) driven off the evaporator in the vapor dome. The primary source of the
entrained black liquor is fouling of the leading-edge of the evaporator set demisters.
When the demisters were washed, the evaporator condensate color concentration
decreased.
T.
Operations determined that the black liquor fiber filter performance was
important to prevent demister leading edge fouling. The recovery area operations staff
addressed this issue and corrected the problem during the last quarter of 1997. Due to
improved management of fiber filter up-time, communication and monitoring of the fiber
filters, condensate color has decreased as demonstrated by the reduction in secondary
effluent color. In addition, manways were installed in the evaporator vapor domes to
provide access to wash the evaporator demisters.
11

3.6.2 Installation of Condensate Instrumentation & Sampling Ports for Evaporator Set
As discussed above. evaporator condensates can periodically cam over colored
material as a result of entrained black liquor in the water vapor (condensate) driven off
the evaporator in the vapor dome. The individual contributions of color from the sewered
combined and contaminated condensates were previously unmeasured. To quantify the
daily color contribution from these sources, automated solenoid valve samplers were
installed on both the combined and contaminated evaporator condensate sewered streams
—in-January,1998�I hese samplers collect a-24=hour composite which is analyzed for color
concentration and incorporated into the mill's Plant Information (PIT" System for data
analysis and trending.
There are also eight conductivity probes within the evaporator condensate
atcollection and segregation system that provide operations notification of any change in
operation that can cause an increase in sewered color. Corrective action to minimize the
loss of colored material is initiated based on these internal conductivity readings.
However, these probes cannot necessarily indicate gradual increases in sewered color
from evaporator condensates. To identify such problems requires the information
generated via the continuous samplers discussed above. The conductivity probes support
the daily sewered condensate color data by providing the mill with information to
respond to the performance of the evaporator systems and manage color for this source.
3.6.3 Assurance of Continued Dry Conveying of Knot Rejects
Sealed pressure knotters were installed during the CMP in 1993 to minimize color
IPlosses from the knot system. The knotter is not designed to use water to transport knots
12

to the rejects bin. The cause of a stream of discolored water from the Hardwood fiber
line Secondary Knotter into the rejects bin was identified and corrected in early 1998.
Occasionally, a piece of foreign material would hang in the throat of the valve and
damage the valve seat. A spare valve is maintained on-site for the Hardwood fiber line
secondary knotter and the knotter is inspected during each shift in order to assure the
valve is properly closing and sealing completely. In addition. flow from this area is
discharged to the new double-chambered pine courtyard spill collection sump.
13

4.0 1997 NPDES Permit Part III, Paragraph E 7 Requirements -
Additional Color Reduction Measures
4.1 Part III. Paragraph E 7 - .additional Color Reduction Measures
The language of this paragraph of the 1997 Permit provides that:
"Working with the Technology Review Workgroup, Champion has
already begun the process of identifying and implementing possible prevention
and control measures which can be taken to further reduce color discharges from
the mill. The perminee is directed to further evaluate mill operation so as to fully
identify opportunities for preventing and controlling measurable black liquor
leaks and spills (best management practices - BMPs). This evaluation will
include gathering more extensive and detailed data on sources of color within the
mill to substantially improve the accuracy of measurements, to improve the
mill's existing BMP program. and to complete efforts to identify, quantify and
substantially improve the accuracy of a mass balance of sources of leaks and
spills of black liquors. including unmeasured sources and discharges during
periods of fiber line disruption. Such BMPs include: further upgrading and
integrating of sewer monitoring(e.g., additional flow measurement and sampling
stations to facilitate more comprehensive and daily monitoring of sources) and
automated mill process control systems with operational procedures and
management oversight to reduce black liquor leaks and spills; continuing
operator training; identifying and implementing additional controls for known
but unmeasured sources (e.g., evaporator set, knot rejects bin, etc.) of liquor
losses; modifying the digester area to facilitate capturing leaks and spills;
diverting clean water discharges; and capturing and recycling liquors during fiber
line disruptions through detailed scheduling of planned outages and contingency
planning for unplanned outages. The permittee also is directed to thoroughly
evaluate additional measures to modify its process operations and controls to
remove or reduce sewer generated color."
4.2 General Discussion
The Canton Mill has one of the most extensive sewer monitoring programs for
color in the industry. The mill monitors, on a daily basis, the color load (lbs/day)
contributions from the following sewer areas: 213 (Hardwood Brownstock washing,
Digesters and Pine Blow Heat Recovery area), 3A (Pine and Hardwood Eo filtrate and
Pine Brownstock washing and Oxygen Delignification), 5B (Recovery, Black Liquor
Oxidation and Chloride Removal Process (CRP)), No. 1 (No 11 and 12 Paper Machines),
�- Hardwood and Pine Acid and Alkaline bleach plant filtrates and Combined and
14

Contaminated Condensates. Other areas of the mill are measured on a concentration
basis.
The "unquantified" fraction of Primary Influent color was a focal point during the
1997 Permit discussions. The mill defines unquantified color as a component of primary
influent color resultine from turbidity, sewer generated color and minor contributions
from unmeasured areas of the mill. The discussions focused on quantifying
"unquantified" color in order to evaluate the potential for additional color reduction
activities. This "unquantified" portion accounts for approximately 40% of the mill's
primary influent color. The "unquantified" fraction is attributed to three independent
reasons; 1) turbidity (color test method interference which is a false-positive
representation of true color), 2) sewer generated color and 3) color from unmeasured
areas of the mill.
In order to quantify this fraction, the mill increased its color monitoring program.
Automated samplers were installed on the black liquor evaporator combined and
contaminated condensates. Samples also are collected from the CRP purge stream.
Automated flow meters were installed on the Pine D1 and Eo stages to provide sewered
flow measurements for calculating bleach plant color loads to the wastewater treatment
plant rather than using a mass balance approach. This new color data has reduced
unquantified color. All major process areas now have daily color monitoring. The four
BMPs discussed in Section 3.0 have addressed the evaporator set, knot rejects bin and
digester area requirements. Current data indicates that the majority of the remaining
"unquantified" primary influent color is due to the effects of turbidity and sewer
generated color. Plans to further quantify and characterize turbidity interference and
15

sewer generated color are discussed in Sections 4.9 and 4.10. Turbidity interference and
sewer generated color research projects are scheduled for the summer of 1998. In
addition. the mill is currently working in cooperation with NCASI on an industry
sponsored turbidity interference study.
4.3 Further Upgrading and Integrating of Sewer Monitoring
4.3.1 Sewered Condensates
Evaporator condensates are generated as a result of"boiling' the water out of the
black liquor entering the evaporator set. Periodically, color is carried over into the
evaporator condensates as a result of entrained black liquor in the water vapor
(condensate) driven off the evaporator in the vapor dome. Historically, Sewered
combined and contaminated condensate were discharged to the main No. 4 sewer line
where only the color concentration was measured. Therefore the color contribution from
these condensate streams was not independently quantified. To quantify the daily color
loadings from these streams, continuous samplers were installed on both the combined
and contaminated condensate streams.
Automated solenoid valve samplers were installed on both the combined and
contaminated condensate sewered streams in the black liquor evaporator area in January
1998. These samplers collect a 24-hour composite which is analyzed for color
concentration on a daily basis.
The samples are analyzed for color concentration by wastewater treatment plant
personnel, recorded in the laboratory data files and entered into the mill's PITm System.
The color concentration is then multiplied by the calculated daily average sewer flow in
16

order to generate the daily combined and contaminated condensate color contribution in
pounds per day. This value is monitored daily by both Operations and Environmental
personnel. Data trends are available on the PIT" System.
4.3.2 Chloride Removal Process (CRP)
The Chloride Removal Process (CRP) is an integral component of the Bleached
Filtrate Recycle (BFRT`f) process at the Mill. Details of the BFRT'^ process, including
CRP, are included in Appendix H. The Chloride Removal Process is designed to separate
chlorides and potassium from the recovery boiler ash solution that contains primarily
saltcake and black liquor. Colored material from the recovery boiler ash carries over into
the salt cake filtrate which is then sewered to purge chloride and potassium. The salt
�® cake is returned to the recovery boilers as a make-up chemical for the kraft process. In
® order to meet the required process levels of potassium and chlorides while maintaining an
overall low level of process equilibrium, up to 15 gallons per minute of this filtrate is
w
sewered. Since the amount of color from the CRP is variable, it is important to monitor
the amount of color that enters the sewer from the CRP process.
Color monitoring of this purge is accomplished in two ways. The first method
looks at the amount of color in the 5B sewer before and after the CRP U-drain and uses
the difference to calculate CRP color. The second method is to collect a grab sample
from the "purge stream' daily and measure both the color concentration and sewered flow
rate. A daily color mass (lbs/day) is calculated, trended and monitored.
The CRP samples are analyzed for color concentration by wastewater treatment
plant personnel, recorded in the laboratory data files and entered into the PITm System.
17

As with the condensates, an automated solenoid valve sampler was installed on the purge
stream within the CRP building in September 1997. The sampler collected a 24-hour
composite which was analyzed for color concentration on a daily basis. However, due to
the nature of the purge stream the sampler became plugged and difficult to maintain after
several months of operation. Based on insignificant differences between single grab and
24-hour composite sample color data. it was concluded that grab samples adequately
characterized the color contributions from CRP. Thus. the use of the automated sampler
was discontinued in March 1998. The concentration is then multiplied by the daily
average CRP purge rate within the PIT" System in order to generate a daily loading value
in pounds of true color per day. This value is monitored and trended daily by both
Operations and Environmental personnel.
4.3.3 Pine Bleach Plant Automatic Flow Meters
Automatic flow meters were installed on the D 100 and Eo stages of the Pine fiber
line in June 1997. The flow meters measure the sewered flows from the pine fiber line
D100 and Eo filtrates. Data collection from the flow meters began in July 1997 and was
integrated into the Pine fiber line's DCS. The flow data allows the Pulp Mill to control
the degree of BFRTM closure by selecting the sewered flow of both DIN and Eo 'stage
filtrates. Previously, the D100 and Eo sewered daily average flow rates were calculated
based on filtrate mass flow balances. Direct measurement provides an accurate daily
average flow rate to calculate the Pine bleach plant color loading.
The BFRTM control strategy adjusts these flows through process operation and
control in order to achieve a target closure on the Pine fiber line and simultaneously
I8

prevent filtrate tank overflow during normal operation. The mill currently targets for
80% closure of the first two bleaching filtrate stages in the Pine fiber line. Higher closure
rates introduce process variability which have resulted in an overall increased level of
.bleach plant color. The configuration of controlling the ratio of sewered D100 to Eo
filtrate, and associated filtrate tank level override control, allows the mill to change the
closure target and prevent filtrate tank overflow. The benefit to the mill is improved
accountability of color discharge from the Pine bleach plant and the operation of a much
more stable bleach plant and fiber line filtrate system.
4.4 Automated Mill Process Control Systems ...
4.4.1 Electrical and Instrumentation (E & 1) Preventative Maintenance Plan
The Electrical and Instrumentation (E & I) Section of the Canton Mill's
Maintenance and Engineering Department is responsible for the maintenance and
calibration of all control instrumentation within the mill such as conductivity probes,
Y.
flow meters, temperature probes, level .transmitters, etc. Some of these instruments are
important for management of the process to minimize mill color losses. In order to
assure this instrumentation is operating properly, the Canton Mill E & I Section
developed a preventative maintenance program which is located in Appendix C: The
program addresses two key elements: 1) the identification of equipment to minimize
color losses and 2) a specific preventative maintenance program for such equipment.
For the program the E & 1, Environmental, Pulp Mill and Recovery Operations
Departments developed a list of color control instrumentation including: conductivity
transmitters, level transmitters, temperature probes and overflow alarms. The program
19

consists of a computerized instrument calibration system and routine check sheets for
routine calibration which should increase the reliability of the instrumentation. The
computerized instrument calibration system will store calibration specifications for each
instrument, including calibration range and acceptable tolerance. Routine calibration
schedules and manufacturer's specifications allow the technicians to determine the drift
in each instrument and re-calibrate if necessary. The check lists will be used to schedule
and document E & I preventative maintenance tasks and will be kept on file by the area
—maintenance-planner.—This program-will--be implemented by July 1, 1998.
4.4.2 Fiberline Spill Tank Level Management Plan
Over the past two years the reduction in brown color losses from the pine fiber
line has contributed to decreased effluent color as illustrated in Figure 1. Pulp Mill
Operations and Environmental personnel worked on two projects to further minimize and
control brown color losses from the pine fiber line. These projects are a spill tank level
Y;
management plan and reconfiguration of ilie pine fiber line's spill collection sump. The
final configuration of the spill collection sump was completed and operational during
mid-November 1997 while the Spill Tank Level Management Plan went into effect in
early December 1997. Both projects have resulted in reduced brown color losses from
the pine fiber line.
Data collected on color losses from the pine fiber line indicate that some of the
mill's losses occur during mechanical failures (i.e. the primary knotter). Therefore, the
availability of brownstock spill tank capacity is important to spill recovery and recycle.
20

As of December 1997, a spill tank management plan was implemented for the pine fiber
line operators.
The Spill Tank Level Management Plan requires the brownstock operators, at the
first of each shift, to log the spill tank level on their daily logsheet. If the level is high,
the operators will start slowly lowering the level in the tank by pumping its contents back
into the process. This daily task was automated in March 1998. The operators are
alarmed at the beginning of each shift by the DCS if the spill tank level exceeds the alarm
level. The DCS checks the operator response three hours later by rechecking the tank
level to assure that the tank level was addressed. By maintaining low spill collection tank
levels, there should be adequate collection capacity in the tank. This management plan
was incorporated into the Operator Training Program (Section 4.5.1) for the pine
brownstock operators.
As mentioned above, the success of the Spill Tank Level Management Plan is
closely related to the performance of the sump pump as well as operator awareness. The
east brownstock sump pump for the pine fiber line was reconfigured in mid-November
1997. Pulp Mill Operations felt the performance of the pump was critical prior to
initiating the Spill Tank Level Management Plan. The redesigned sump pump now runs
continuously so pump priming is no longer an inherent problem to reliable pump
operation. The control system logic provides for recovery of material based on
conductivity control. The conductivity probe is mounted within a newly installed
recirculation line to improve the performance of the probe and reduce the potential for
fiber to "blind" the probe. When the conductivity in the sump is low the pump
recirculates flow back into the sump through the newly installed recirculation line. When
21

conductivity is above the set point. a newly installed automatic valve within the
recirculation line Nvill close and divert the material to the brownstock spill collection tank
for recycle and recovery.
Overall. the mill has seen a decrease in the daily brownstock color from the pine
fiber line contributing to reduced secondary effluent color as shown in Figure 1. The new
sump design and management plan have resulted in a reduction of color losses from the
pine fiber line.
4.5 Continued Operator Training
4.5.1 Pulp Mill
[� 4.5.1 a) Operator Skills Training (OST) Program
■yam The Pulp Mill Operator Skills Training (OST) Program has been updated to
reflect the activities in this report. This program typically involves the operators studying
and self-checking written material contained in manuals which cover specific components
of Pulp Mill Operations. The pulp mill is currently revising the manuals covering
processes which may contribute color to the sewer. The revisions will incorporate both
general color reduction information as well as any new systems or procedures. Systems
and procedures include, for example, the pine fiber line spill tank level management plan,
new 3A sewer sump configuration and a new multi-chambered pine courtyard sump.
Each process manual will discuss the implications of the specific process operation on
colored discharges. The operators train on how to effectively minimize their area's
impact on color discharges. Examples of such manuals include:
22

• Digester Contingency Operations
• Explain and Operate Hardwood Brownstock Spill Collection System
• Explain Hardwood Brownstock System Operating Concepts
• Explain Hardwood Bleaching Operating Concepts
• Explain and Operate Bleach Plant Spill Collection System
• Explain Blow Heat System
• Explain Pine Brownstock System
In addition to updating the individual process manuals. the pulp mill is creating two new
OST manuals for operator training. A learning guide was developed to explain the
operation and logic for the multi-chambered pine courtyard sump system discussed in
Section 3.4. Another learning guide was developed to outline the color impacts from the
operation of the pulp mill in general. The "Explain Pulp Mill Area Compliance and
Color Control" learning guide summary is located in Appendix D1. The learning guide
covers the pulp mill's operating plan regarding color losses during normal operations as
well as managing non-routine events. This learning guide provides training on the impact
of the pulp mill on color variance compliance. This overall OST effort provides a
foundation for color control and awareness which will be reinforced during the Pulp
Mill's On-the-Job Training Program discussed below.
4.5.1 b) On-the-Job Training (OJT)Program
Pulp Mill Operations developed an operator On-the-Job Training (OJT) Program
which began in April 1998. The OJT operator program expands upon the new OST
information to communicate the environmental impact of their operations in addition to
the training programs currently in place. A training session was developed by the Pulp
23

Manufacturing and Environmental Departments to transfer general knowledge from the
1997 Permit and operational color impacts to the Pulp operators. The training session
program is found in Appendix D2. Throughout the month of April 1998 each operating
crew received this training.
The training session begins with an overview of the 1997 Permit including the
compliance limits and dates. This provides a timeline for the operators to understand mill
effluent color limitations and future requirements. A performance history on brown and
bleach plant color losses from each fiber line is compared to the current level of
performance. This provides a benchmark for operating performance and the performance
level required to maintain compliance. The current BMP projects are discussed to update
the operators on progress, environmental impact and operational impact.
The training session continues with a discussion of the potential sources of color
in the pulp mill such as pump packing in the brownstock and digesters, screen rejects,
bleach plant color (i.e. MRP operability),,etc. The purpose of this is to stress the
importance of day-to-day awareness of operations and maintenance issues which have the
potential to result in colored discharges. The session covers the sources of color which
contribute the greatest color loading to the treatment plant and the difference in
wastewater treatment of bleach vs. brown color. Shift managers will periodically review
new plans and procedures with their operators. This training allows the operators to
understand the regulatory implications of the permit and their roles in managing and
minimizing colored losses.
24

4.5.2 Recovery
4.5.2 a) Operator Skills Training (OST) Program
The Recovery Area Operator Skills Training Program (OST) has been updated to
reflect the activities in this report. This program typically involves the operators studying
and self-checking on materials contained in manuals which cover specific components of
Recovery Operations. In order to incorporate the color reduction activities discussed in
this report, a learning guide was developed which covers recovery area processes which
can contribute color to the sewer. The "Explain Recovery Area Compliance and Color
Control' leaming guide summary is located in Appendix E1. The learning guide covers
the recovery area's color sources, monitoring and control systems, preventative
maintenance measures, spill collection systems and operating plans regarding color losses
during normal operations and non-routine events. This learning guide provides an overall
lesson on the impact of the recovery area on color variance compliance. This overall OST
effort provides a sound environmental foundation which will be further enhanced in the
Recovery Operations On-the-Job Training Program covered below.
4.5.2 b) On-the-Jab Training (OJT)Program
Recovery Operations developed an operator On-the-Job Training Program (OJT)
which began in May 1998. The program expands upon the new OST guide information
to communicate the environmental impact of their operations in addition to the traditional
training programs currently in place. A training session was developed by the Recovery
and Environmental Departments to transfer general knowledge from the 1997 Permit and
operational color impacts to the recovery operators. The training session program can be
25

found in Appendix E3. Throughout the month of May each operating crew received this
training.
The training session begins with an overview of the 1997 Permit including the
compliance limits and dates. This provides a timeline for the operators to understand the
mill effluent color limitations and future requirements. . A performance history on
Recovery, CRP and condensate color is compared to the current level of performance.
This provides a benchmark for operating performance and the performance level required
to maintain compliance. -The current BMP-projects-are-discussed to update the operators
on progress. environmental impact and operational impact. This training allows the
operators to understand the regulatory implications of the permit and their role to
minimize color losses.
The training session continues with a discussion of the potential sources of color
in the recovery area such as pump packing, CRP and evaporator boilouts, sump operation,
etc. The purpose of this is to stress the importance of day-to-day awareness of operations
and maintenance issues which have the potential to result in colored discharges. The
session covers the sources of color that have the potential to contribute the greatest color
loading to the wastewater treatment plant. Shift managers will periodically review new
plans and procedures with their operators. This training allows the operators to
understand the regulatory implications of the permit and their role to manage and
minimize color losses.
26

4.6 Additional Controls for Unmeasured Sources of Liquor Losses
4.6.1 Hardwood Secondary Knotter Accepts Tank Overflow
The Secondan, Knotter Accepts Tank for the hardwood fiber line overflowed to
the sewer twice in the past several years resulting in elevated color discharges. The
overflows occurred .when the tank level transmitter failed. In addition to the level
transmitter preventative maintenance discussed in Section 4.4.1, the mill has installed a
temperature probe with operator alarm for direct indication of tank overflow.
The Secondary Knotter Accepts Tank overflow line runs from the tank, which is
inside the hardwood fiber line brownstock washing building, to the sewer discharge point
just upstream of the 2B Parshall flume. Due to its piping configuration this potential
color source will not be collected by the new courtyard sump discussed in Section 3.4.
An engineering solution to this potential color source was identified in early
January 1998 and incorporated into the pine courtyard sump BMP project. The solution
was to install a temperature probe in the overflow line. Output from the temperature
probe is tied into the DCS. Under normal tank level conditions the temperature probe
will read the ambient temperature indicating no tank overflow. If a tank overflow occurs,
the increase in temperature will be detected by the temperature probe and the DCS will
trigger an alarm at the hardwood brownstock operator station. This will give the
operators notification to react to the situation and minimize process losses. This project
was completed at the end of May 1998.
27

4.6.2 Miscellaneous Field Work
Miscellaneous field work was conducted to improve the quantification of color
contributions from several known color sources within the mill which flow to the sewer
unmeasured. Between February 1997 and April 1997 flow measurements and color
concentrations were collected to provide estimates of colored material from several areas
of the mill including the Hardwood Bleach Plant overflow to the No. 4 sewer, 2B sewer
constituents (which are measured in total by the 2B sampler), sewered black liquor
-condensates Hardwood Accumulator losses-to No-4-sewer and-both fiber line secondary
knotters. The sewered condensates are now measured daily (Section 4.3.1) and the
digester sump project provides for recovery of the 2B courtyard contributions (Section
3.4). Color contributions from the remaining color sources tested are minimal.
i� The pine secondary knotter contribution can be picked up by the redesigned
brown spill collection system (Section 4.4.2). The hardwood secondary knotter color
contributions have been reduced by the project discussed in Section 3.6.3 and are diverted
into the new courtyard sump discussed in Section 3.4. The hardwood bleach plant
contribution is typically less than 100 pounds of true color per day. The hardwood
accumulator losses are typically less than 100 pounds of true color per day, but can at
times be greater. However, most of the flow from the hardwood accumulator area is
either diverted into the new digester reclaim sump or the existing weak liquor storage
reclaim sump.
28

4.7 Diverting Clean Water Discharges
4.7.1 Digester Area Project
As part of the two-chambered Pine Courtyard Sump Project discussed in Section
3.4, a new U-drain was installed to divert 50-100 gallons per minute (gpm) of clean, non-
contact cooling (NCC) water away from the new courtyard sump. This clean cooling
water would have previously diluted any colored material flowing from the digester area.
The new U-drain was installed to connect the existing clean cooling water U-drain
outside of the digester buil"ding t"o the existing U-drain in the courtyard area downstream
of the new digester sump. This connection eliminates 50-100 gpm of clean cooling water
from diluting any colored material entering the digester area and the new sump. A
permanent plug was installed to prevent the clean cooling water flow from entering the
digester building. The diversion of this clean water source reduces the dilution of colored
material from the digester area resulting in a higher concentration, lower volume of
colored material for reclaim by the new digester sump. Therefore the amount of material
to be reclaimed by the sump and recycled into the process as well as additional load to the
black liquor evaporators are reduced.
4.7.2 Oxidation Blower Coolers Project
A second clean water segregation project will soon be complete in the recovery
boiler area. The Black Liquor Oxidation blowers each have an associated oil cooling
system. These oil coolers together contribute approximately 50 gpm of clean, non-contact
cooling water to the recovery boiler sump system. This source of dilution water will be
® hard-piped from each cooler into a common header downstream of the recovery boiler
29

sumps. Completion of this project will eliminate approximately 50 gpm of clean water
from the reclaim sump and recovery systems. This segregation project will be installed
and operational in June 1998.
4.8 Capturing & Recycling Liquors During Fiberline Disruptions
4.8.1 Detailed Scheduling of Planned Outages
Scheduled outages are standard industry practice for maintaining the performance
of the pulp mill and recover, area operations. Fiber line outages occur about once every
four weeks. Detailed and extensive outages are periodically scheduled whereby one-half
of the pulping and recovery area is shut down for up to one week. Planning occurs prior
to each outage regardless of the duration or complexity of the outage. Maintenance work
schedules are prepared and flow-charts are prepared which illustrate when equipment is
to be shut down, repaired and started back up. Semi-annual outage information and lists
of personnel involved are generated and distributed throughout the mill. Key
x
Performance Indicators (KPI) targets for Safety, Environmental, Planning, Execution and
Cost are established before the outage, tracked to monitor outage performance and
reviewed after the outage in order to identify key leamings. Colored losses are a focus of
the outage planning.
A tank draining schedule is generated prior to the start of any outage and includes
the tank(s) to be drained including volume(s). Tanks and associated piping must be
periodically cleaned for inspection and maintenance. Provisions are made to reduce the
tank level as low as possible before shut down. Piping is emptied as much as possible
prior to cleaning.
30

Tank level and inventory management is a key tool the mill uses to minimize
colored losses during outages. The color impact of various sources of colored losses has
been estimated and incorporated into the OST learning guides for Pulp Mill and Recovery
Operations areas as discussed in Sections 4.5.1 (a) and 4.5.2 (a). These color loss
estimates are combined with the planned outage tank draining schedule to estimate the
total outage color loss. The mill is currently developing a procedure to evaluate the color
loss estimate based on the actual tank level(s) prior to the outage. This information is
—then-communicated-to the-operations areas and-wastewater treatment. Adherence to the
established schedule and detailed communication of any schedule changes are important
to minimize outage color.
The mill is incorporating the existing kraft pulping chemical inventory
management strategy as a component of the overall color management philosophy. The
E & I preventative maintenance plan discussed in Section 4.4.1 addresses the reliability
of critical color control instrumentation fo{ outages. This equipment is inspected,
calibrated and cleaned a week prior to each major annual or semi.annual outage. The
mill began collecting hourly primary influent color measurements during specific outage
periods in September 1997. The color concentration values are entered into the mill's
PITm System and verbally communicated to the recovery and pulp mill shift supervisors.
Currently, a tiered/triggered response procedure is under development to determine color
levels of concern based on the measured values with associated response actions. This
will focus mill resources on detecting and identifying sources of color to minimize
® colored losses.
31

The above mentioned efforts arc incorporated into the Pulp Mill and Recovery
area On-the-Job Training Program covered in Sections 4.5.1 (b) and 4.5.2 (b). These
efforts are being incorporated into the outage planning process and will be refined with
experience. Many of the above procedures and strategies are also integral to address non-
routine events and unplanned outages.
4.8.2 Contingency Planning for Unplanned Outages
A variety of non-routine events can occur which require an unscheduled outage
for repair. Events such as power and steam supply problems and mechanical issues are
examples of such occurrences. Tank level and inventory management is a key tool the
mill uses to minimize the color losses from such unplanned events. Minimizing tank
levels reduces the loss of colored material and increases the capacity for capturing
colored material. The Fiber Line Spill Tank Level Management Plan discussed in
Section 4.4.2 addresses this by controlling the level in the spill collection tanks. Tank
Y
levels are controlled by the management of chemical inventories between the pulp mill
and recovery area operations. Targets are set for the weak liquor inventory for operators
to adjust the feed rates to the black liquor evaporators to maintain recovery operations
during upset conditions. Together, these two operational tools maintain the flow of black
liquor through the recovery system to minimize the loss of colored material during non-
routine events.
In order to successfully manage color through an unplanned outage, clear and
concise communication must be maintained between the pulp mill, recovery and the
wastewater treatment plant. A release of colored material may require hourly monitoring
32

of the primary influent for color in order to enhance management of the situation. The
wastewater treatment plant operators must remain aware of primary influent color and
respond to elevated color. The operator must be able to respond to the situation at the
treatment plant as well as notify supervision and operations of the problem via radio
communication. Utilization of the DCS and PITM System in addition to radio
communication with operations are important to minimize colored losses.
4.9 Primary Influent Color Turbidity Interference Study
The Canton Mill has an intensive color monitoring program both within the mill
and at the wastewater treatment plant. The in-mill sewer monitoring program provides
color data used to break down the mill's process contributions to the primary influent.
Primary influent color consists of contributions from 2B (Hardwood Brownstock
washing, Digesters and Pine Blow Heat Recovery area), 3A (Pine and Hardwood Eo
filtrate and Pine Brownstock washing), 5B (Recovery, Black Liquor Oxidation and CRP),
No. 1 (No 11 and 12 Paper Machines), Acid Filtrate and Combined and Contaminated
Condensates. As previously discussed, the remaining fraction of primary influent color is
"Unquantified" color and consists of contributions from turbidity interference and sewer
generated color.
The turbidity interference occurs while measuring primary influent color
concentration in the laboratory. The EPA approved standard NCASI test method for true
color measurement requires sample filtration. There are various materials present in the
mill environment that, when present in the primary influent, are suspended in the filtered
33

solution and scatter light. This scattered light is not read by the spectrophotometer and is
interpreted as true color by the test method. These panicles do not contribute to effluent
color due to the fact that most of the turbidity interference is removed across the
wastewater treatment plant. Therefore, the true color concentration of the primary
influent is high biased by the turbidity interference effects and is not representative of the
actual true color in the sample. Material such as Precipitated Calcium Carbonate (PCC),
lime mud, dregs, Titanium Dioxide (TiO,), paper machine fillers, etc. contribute to this
turbidity interference.
A study will be conducted throughout the summer of 1998 to quantify the impact
of various turbidity levels on primary influent color. The ultimate goal of this study is to
account for the impact of turbidity interference on primary influent color in order to
quantify a portion of the unquantifed color. In addition to this mill study, the mill
participated in an industry sponsored turbidity study with NCASI from February 1998
through April 1998. The goal of the study, is to modify the current test procedure to
reduce and/or eliminate the current turbidity interference present in the test. A draft
synopsis of the purpose, objectives, approach and outcomes of this work is included in
Appendix F of this report. NCASI's final assessment will be published as a technical
bulletin by late 1998 or early 1999.
During the summer of 1998, the Canton Mill will conduct an independent
turbidity study. The purpose of this study will be to evaluate:
1) The turbidity contributions from each of the individual in-mill sewers;
2) The turbidity contributions from various in-mill materials (i.e. dregs, Ti02, PCC,
' lime mud, etc.); and
34

3) The portion of primary influent color attributed to primary influent turbidity.
Baseline in-mill sewer turbidity data is currently being collected and analyzed.
The project will consist of laboratory bench-scale studies to determine the influence of
turbidity on the color test method using known turbid materials such as dregs, TiO2,
PCC, lime mud and paper machine headbox feed solutions. The collected data will be
evaluated to quantify the effect of turbidity on primary influent color. A final turbidity
report will be generated combining Champion's and NCASI's research.
4.10 Sewer Generated Color
4.10.1 General Discussion
Sewer Generated Color (SGC) is a phenomenon which occurs due to wastewater
interactions in the mill sewer system. SGC results in a higher color than is accounted for
by the color contributions of all the individual wastewater streams. This phenomenon is
attributed to chemical reactions that occur as,the mill's acid sewer (Pine D1, Pine D2 and
Hardwood DI bleach plant filtrates) is introduced to the main mill sewer system. These
acid filtrates react under elevated pH (10-11) and elevated temperature(120 °F) within the
sewer system prior to the wastewater treatment plant. The quantity of this "unmeasured"
SGC color source is an issue for closure of the mill color balance. The Canton Mill has
done most of the research on this relatively unknown color phenomenon within the
industry. Canton's research efforts have included both mill and Corporate Technical
engineers, summer interns and two Graduate students from Duke University's Nicholas
School of the Environment. During the summer of 1998 additional research will be
35

conducted at the Canton Mill. The study plan is outlined in Section 4.10:3. A brief
discussion of past SGC research is presented in the following section.
4.10.2 Previous Research & Findings
Champion's research into the SGC phenomenon began in the early 1990's.
Champion showed that when acid filtrates from the bleach plant mix with the alkaline
sewer effluent. the color of the resultant effluent was greater than expected based on a
mass balance. Further work showed that irreversible color is created in the acid stream
by raising the pH and temperature. Simultaneously, Canton Mill environmental engineer
Susanne Koelsch began a series of experiments to analyze the impact of the wastewater
treatment plant on color removal as well as probing into the phenomenon of SGC. These
two concepts were brought together in the summers of 1994, 1995 and 1997 for further
experimentation.
Research during the summer of 1994 was conducted by Aimee McCord while the
1995 research was conducted by Chad Salisbury. Both research efforts covered a variety
of color issues beyond SGC, however only the findings relevant to SGC are discussed.
McCord's work determined that the color removal mechanism across the wastewater
treatment plant acts primarily on brown color sources, not on bleach plant color.
Salisbury's research was designed to address two questions:
1) What is the maximum potential impact of sewer generated color on color loads to the
wastewater treatment plant?
2) Is sewer generated bleach color removed at the wastewater treatment plant?
A small portion of SGC for all bleach plant filtrate combinations was found to be
removed at the wastewater treatment plant. However pine, hardwood and total bleach
36

plant effluent flows experienced a net color increase across the sewer and wastewater
treatment plant system. An undergraduate summer intern project during the summer of
1997 began the process of assessing the impact of SGC on primary influent color loads
to the wastewater treatment plant and how to minimize SGC. The objective of this work
was to determine if pH adjustment of the acid sewer prior to mixing with the alkaline
sewer would:
1) minimize the effect of the sewer generated color phenomenon on primary influent
color; and
2) result in an equivalent decrease in secondary effluent color after wastewater
treatment.
The operation of the BFRTm process at the Canton Mill was highly variable during this
® project. Limited laboratory data suggested possible color reduction benefits at both the
primary influent and secondary effluent by specific wastewater stream pH adjustment.
However, more laboratory work needs to be conducted, especially since the BFRTM
process is currently stabilized at 80% bleach plant closure. The impacts of current, and
possible increased, operational levels require further study. A graduate student began
conducting additional research on sewer generated color in May 1998.
4.10.3 Research Plan for 1998
As stated in previous sections, the Canton Mill has conducted experimental bench
scale work on the sewer generated color mechanism for three summers with the aid of
summer college interns. This cooperative effort continues this summer with another
® graduate degree candidate conducting the research. The student will spend the summer
37

conducting laboratory experiments to evaluate two questions raised through previous
research:
1) What effect does the color removal mechanism across the wastewater treatment
facility have on sewer generated color?
2) What is the potential impact on sewer generated color of pH adjustment of the acid
sewer prior to mixing with the mill's main alkaline sewer?
The goal of this project is to quantify the percentage, if any, of sewer generated'color
which is removed across the wastewater treatment facility and to understand better if pH
adjustment is a feasible option to reduce this color source. A description of the 1998
summer study plan is listed in Appendix G.
38

5.0 Bleach Filtrate Recycling (BFRT',') Process on Pine Fiberline
A full scale demonstration of Champion's Bleach Filtrate Recycling (BFRTn
process was begun at the Canton Mill in 1995. Details of the BFRTm demonstration
project are in Appendix H. The process has two major new components, the Chloride
Removal Process (CRP) and Metals Removal Process (MRP). For the BFRTm
demonstration the CRP and MRP become integral parts of the bleached kraft pulping and
recovery process. Both processes are integral in the overall goal of BFRTm to achieve
and sustain closure of the DIN and EoP bleach stages of the Pine fiber line at Canton.
The CRP provides a system to purge chloride and potassium from the recovery boiler
precipitator ash while the MRP removes minerals such as calcium, magnesium, etc. from
the DIN stage filtrate. The CRP is utilized to keep the liquor cycle chloride
concentrations similar to or less than pre-BFRTm levels. The MRP is designed to
reduce/control scale forming minerals while recycling bleach plant filtrates. The BFRT14
process components were brought on-line and independently demonstrated by the mill
prior to full BFRTm implementation. The various stages included:
1) Start-up of CRP in August 1995;
2) Initial start-up of MRP in November 1995 - D 100 filtrate treated and sewered;
3) EoP filtrate recycle commenced in March 1996;
4) MRP-treated DI00 filtrate bleach plant recycle began in August 1996.
Throughout the remainder of 1996 and through 1998 the mill continues the
BFRTM demonstration process. Mechanical and process issues encountered continue to be
addressed. The mill operated for several months at various closure levels while
39

attempting to attain full closure. To stabilize the BFRT`'' process, the mill currently
targets for 80% closure of the first two bleaching filtrate stages of the pine fiber line.
Two papers on the BFRT"process demonstration are located in Appendix H. One
article is written by Bob Caron of Champion's Applied Technologies while the other
article, written by Stratton (Champion AT) and Ferguson (Canton Mill Pulp Operations),
received the Canadian Pulp and Paper Association's 1997 Douglas Jones Award. These
articles cover the BFRT'" process mechanics, operational history and environmental
performance.
ti
40

6.0 Conclusion
The contents of this June 1, 1998 report fulfill all of the requirements of Part 111,
Section E. Paragraphs 7, 8 and 9 of the mill's modified 1997 Water Quality Color
Variance and 1997 NPDES Permit effective December 31, 1997. All four of the Best
Management Practices (BMP) Projects required by Paragraph 9 were completed by the
mill before June 1" and are discussed in Section 3.0. A list of projects, discussed in
Section 4.0, was developed and implemented by the mill to satisfy all in-mill color
reduction measures identified in Paragraph 7. Together with the continued
demonstration of the Bleached Filtrate Recycling (BFRT`) Process on the mill's pine
fiber line, these color reduction measures have resulted in color reductions in the
secondary effluent as illustrated in Figure 1.
r.
41

-::neon P iai
3cx C.!r
-_-ton. Ncrtn Carina dd-?: .
V >y:Nampiott
'.amoion mternauonai Gcrocra;icr.
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 6Low 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
r
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.
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
H. 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
III. 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 lowest 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 theJune 1, 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.
3.1.2 Intermittent Treatment
3

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
LOCanton, North Carolina
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 mill
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 rate&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
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.
4

December 1, 1998 Report - Low Flow Contingency Plan
Champion International Corporation
LOCanton, North Carolina
IV. 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 theJune 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

a k I n z ur mark for vou.
0_j BLUE RIDGE PAPER PRODUCTS INC.
November 19, 1999
Mr. Forrest Westall
North Carolina Department
Environmental and Natural Resources
Division of Water Quality
59 Woodfin Place
Asheville, NC 28801
Re: December 1,1999 Report
Hardwood Fiberline Color Management
Eo Recvcle Evaluation and Potential for Full BFRTM Implementation on the Hardwood Line
Dear Mr. Westall:
Please find attached the referenced report. With the submission of this report this completes
implementation of the technologies collectively referred to in the permit as the "Near Term
Package'.
As you know the Canton Mill is no longer part of Champion International Corporation. As of
May 14, 1999 the mill became privately owned and operates under Blue Ridge Paper Products
Inc. Blue Ridge is an employee owned enterprise. The company is comprised of
approximately 2200 employees with 70% of these employees residing M* Haywood County.
Blue Ridge produces uncoated free-sheet paper for printing and writing applications and
paperboard for liquid packaging. The Canton Mill is the primary asset of the new company.
If you have any questions regarding this report please contact me at(828) 646-2033.
Sincerely,
In//s L
oo
Robert V. Williams
Director, Environmental,Health and Safety Affairs
xc: Mr. Don Anderson
U.S.Environmental Protection Agency
Mail Code 4303
Room 915A, East Tower
401 M Street,SW
Washington,D.C. 20460
175 Main Street • P.O.Box 4000 • Canton, North Carolina 28716 828-646-2000

December 1, 1999 Report - Hardwood Fiberline Color Management:
Eo Recycle Evaluation and Potential for Full BFRTM
Implementation on the Hardwood Line
BLUE RIDGE PAPER PRODUCTS,INC.
CANTON,NC
1.0 Introduction
This report evaluates Blue Ridge Paper Products Canton Mill's implementation of
partial Eo filtrate recycle on the hardwood fiberline and the potential for color
reduction with full BFR'M implementation on the hardwood fiberline. This report is
submitted in accordance with the requirements of Part III, Paragraph E (11) of the
1997 modified Color Variance and NPDES Permit issued to Champion International
Corporation for its Canton Mill. The language of this paragraph provides that:
"The permittee shall begin implementation of that portion of
the BFRTM technology which involves the recycling of the Eo
stage of the hardwood line by no later than January 1, 1999. The
permittee further shall provide an evaluation of that
implementation as well as the potential for full implementation of
the BFRTM technology on the mill's hardwood line to the
Division of Water Quality, the Technology Review Workgroup
and the NPDES Committee by December 1, 1999. The
evaluation will include data reflecting the color reduction benefit
gained from the partial implementation and a projection of
potential color reduction benefit to be gained from full
implementation of the BFRTM technology on the hardwood line. "
1
r

December 1, 1999 Report - Hardwood Fiberline Color Management:
Eo Recycle Evaluation and Potential for Full BFRT'
Implementation on the Hardwood Line
BLUE RIDGE PAPER PRODUCTS,INC.
CANTON,NC
2.0 Review of Color Performance at the Canton Mill
The Canton Mill's commitment to color reduction is illustrated in Figure 1. Since 1988,
color in the secondary effluent has been reduced by more than 89% (annual average).
The color reduction can be attributed to the Canton Modernization Project (CMP) and to
continuing mill-wide efforts to reduce color, including those detailed most recently in the
June 1, 1998 Color Technology Measures Report.
From January 1999 through August 1999, color in the secondary effluent averaged
40,791 pounds per day, well below the 60,000 pound limit specified in the NPDES
Permit. For the same period, as well as that period in 1998, monthly averages for true
color at the Hepco bridge were all below 50 standard color units (scu's) even at flows less
than the 30Q2 which occurred in August 1998 and August 1999.
Using North Carolina's governing flow criteria (30Q2), historical flow records, and the
1999 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 100 % of the applicable time.
Therefore, the Canton mill's actual color performance results in significant mitigation of
the occurrence and degree of color at the Hepco gage.
2

December 1, 1999 Report - Hardwood Fiberline Color'Management:
Eo Recycle Evaluation and Potential for Full BFRTa1
Implementation on the Hardwood Line
BLUE RIDGE PAPER PRODUCTS,INC.
Le CANTON,NC
Figure 1:Canton Mill Secondary Effluent Color Performance
Annual Averages:1988-1998
Monthly Averages:Jan 99-Sep 99
400000
350000
M SE Color
^ 300000 -a-95,000 Monthly limit-effective 1/l/98-11/31198
o'
9
y �60,000 Annual limit-effective 12/1/98-present
250000 _ - 69,000 Monthly limit-effective 12/1/98-present
U
200000
W
> 150000
c
0
n 100000
50000
0 m w o a a n m m m m a m a o+ a rn m m
3.0 Hardwood Eo Recycle Evaluation
3.1 Project Description
All installation work for partial hardwood Eo recycle was completed in mid-September
1998 for a total cost of $112,200. This project involved the installation of piping and
controls to pump Eo filtrate directly to the Decker Filtrate Tank for reuse in the process.
Prior to September 1998, Eo filtrate had been sewered and contributed to the Canton
Mill's total color discharged to the Wastewater Treatment Plant. Figure 2 details the pre
and post-recycle filtrate flows.
3

December 1, 1999 Report- Hardwood Fiberline Color Management:
Eo Recycle Evaluation and Potential for Full BFRTM
Implementation on the Hardwood Line
BLUE RIDGE PAPER PRODUCTS,INC.
CANTON,NC
Figure 2: Hardwood Eo Recycle Plan-Filtrate Flow Changes for Eo Recycle
PB
Ho1140
i
Fan Cct 1b1 w
63
Eo Wakr 0Q Waler
Pr m U100 E.p 62
PB
Eic
w R.o
500 -Lli
6100 _ — — Eap
mM
© <'
6'
5W
10
su
CHH7:—:) — (—T— tT—.
6]
3N. Eo Reryck PfOpct Pertril Item
PiK Caokr Ftl.Coobr
3.2 Canton Hardwood Eo Recycle Implementation Plan
The Hardwood Eo Recycle Implementation Plan was initiated in 1997. Projected impacts
on the hardwood fiberline as well as potential color savings from partial Eo recycle were
evaluated. Past filtrate recycling trials on the hardwood fiberline resulted in significant
washer scaling and corrosion problems. To minimize scaling and corrosion problems,
and evaluate their potential and rate of occurrence, a systematic approach to partial
hardwood Eo recycle was utilized. This systematic approach involved incrementally
increasing the recycle rate each month, beginning in October 1998. This approach also
allowed the mill to identify the optimum recycle rate for maximum color reduction.
4

December 1, 1999 Report - Hardwood Fiberline Color Management:
Eo Recycle Evaluation and Potential for Full BFW'
Implementation on the Hardwood Line
BLUE RIDGE PAPER PRODUCTS,INC.
CANTON,NC
3.3 Net Color Reduction
Partial hardwood Eo recycle was instituted in mid-September 1998. Due to process
control issues, the Eo recycle flow vaned more than expected. A reliable control system
was developed and implemented prior to January 1999 that allowed the recycle flow to be
set by_the_hardwood bleach plant operator._The_average measured Eo recycle rate for
1999 was approximately 140 gpm with a net measured Eo filtrate color reduction of
approximately 1,9401bs/day.
Recycle rates during this trial period ranged from 100 gpm to 200 gpm. Eo recycle rates
were increased/decreased incrementally each month in order to determine the optimum
recycle rate for Eo filtrate color reduction with minimum scaling and corrosion problems.
A recycle rate of 150 gpm resulted in the optimum net color reduction with minimal
impact thus far from carryover (increased carryover could result in increasing bleach
plant color thereby offsetting decreased color from Eo recycle). The mill will continue to
monitor the hardwood fiberline for scaling and corrosion problems that could result from
the recycle of Eo filtrate. The average net Eo filtrate color reduction was approximately
2,200 lbs/day during the months when the recycle rate was 150 gpm. At recycle rates
greater than 150 gpm,washing efficiency declined and the net Eo filtrate color increased.
In addition to the color reduction benefit, the pumping of Eo filtrate and pre-bleach
filtrate to the decker filtrate tank reduced the need for fresh water make-up in the decker
tank by approximately 225 gpm.
5

December 1, 1999 Report- Hardwood Fiberline Color Management:
Eo Recycle Evaluation and Potential for Full BFRT"
Implementation on the Hardwood Line
BLUE ROGE PAPER PRODUCTS,INC.
CANTON,NC
4.0 Potential for Full BFR"" on Hardwood Fiberline
4.1 Projected Color Reduction
Full implementation of BFRT' technology on the hardwood fiberline would involve D-
100 stage filtrate being recycled to the brownstock washing and oxygen delignification
systems, similar to the pine fiberline.
The 1998 average color removal rate from recycling D-100 filtrate via BFI ' on the pine
fiberline was applied to the 1998 average D-100 filtrate color load to the mill sewer. A
potential primary influent color reduction of approximately 3,872 lbslday could result
from installing the full BFR7' technology on the hardwood fiberline. Assumptions made
to achieve this color reduction include: 1)The color removal rate for the hardwood
fiberline would be consistent with the color removal rate seen on the pine fiberline,
2)Carryover of recycled material into the D2 stage and paper machines would be
manageable, 3)Increased chloride recycled would be managed by the CRP additions to
the recovery cycle, and 4)No operational problems would occur in the brownstock
washing system.
4.2 Feasibility of Installing Full BFRT" on the Hardwood Fiberline
It has been estimated that full installation of 13FR'technology on the hardwood fiberline
would have a capital cost similar to the capital cost of $25,000,000 (± 25%) for
installation of BFR" on the Pine fiberline (based on 1994 dollars). Capital cost includes
construction of another Metals Removal Process (MRP), additions to the existing
Chlorides Removal Process (CRP), various piping modifications, provisions for
6

December 1, 1999 Report- Hardwood Fiberline Color Management:
Eo Recycle Evaluation and Potential for Full BFRT'
Implementation on the Hardwood Line
BLUE RIDGE PAPER PRODUCTS,INC.
CANTON,NC
additional white liquor oxidation and increased black liquor evaporation capacity. The
increased operational costs have not been included.
Implementation of the full BFRT' technology on the hardwood fiberline is considered
cost prohibitive and is not warranted.
o
5.0 Conclusion
7

December 1, 1999 Report- Hardwood Fiberline Color Management:
Eo Recycle Evaluation and Potential for Full BFRT"'
Implementation on the Hardwood Line
BLUE RmGE PAPER PRODUCTS,INC.
CANTON,NC
The mill's January 1999 - August 1999 average secondary effluent color discharge of
40,791 lbs/day has been achieved through successful implementation of extensive color
reduction projects and measures detailed in the June 1, 1998 Color Technology Measures
Report, BFRT"' on the pine fiberline and partial hardwood Eo Recycle.
Partial recycling of the Eo filtrate on the hardwood fiberline at the optimum rate resulted
in a color reduction of approximately 2,200 pounds per day. The Canton Mill will
continue partial hardwood Eo recycle and will continue to evaluate potential impacts to
the process.
This level of performance demonstrates the Canton mill's commitment toward brown
colored material management and fulfilling the requirements of the 1997 modified Color
Variance and NPDES Permit. The mill's commitment to continue partial hardwood Eo
recycle will result in additional color reduction and mitigation of the occurrence and
degree of color during periods of lowest river flow. Full BFRT' on the hardwood
fiberline, due to the potential for minimal color reductions, approximately 3,872 lbs/day,
and the excessive cost, estimated to be $25,000,000 in 1994 dollars, is considered cost
prohibitive and is not warranted.
This completes implementation of the technologies collectively referred to as the "Near-
Tenn Package." Full analysis of seasonal fluctuations in the "Near-Term Package"
process operations will be completed by June 1, 2000 and a report submitted by January
1, 2001 on the feasibility of achieving a color loading limit within the range of 48,000 -
52,000 pounds per day.
I
8

BLUE RIDGE
PAPER PRODUCTS INC. -
Fc?
December 28,2000
1?
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 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 950i percentile confidence interval to statistically
evaluate the monthly and annual average color discharge. Using a 95d'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 996' 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, .
Bob Williams
IDirector-Environmental,Health and Safety
Attachments
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716 • Phone:[phone]
Raising Your Expectations `
f

BLUE RIDGE
I
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)
l

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

I January 1, 2001 - Coll t Feasibility Report I
Monthly Average Secondary Effluent Color (Ibs/day)
January 1987 - October 2000
700000
600000
500000
c�
400000
fA
.Q
0 300000
0
V
200000
100000
0
Aug-85 Apr-88 Jan-91 Oct-93 Jul-96 Apr-99
--o— BE Color Ibs/day
Blue Ridge Paper Products, Inc. Figure 1
page 2
Canton Mill

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 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 Ibs/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 ibs/day. The January 2000— October 2000 annual color average
using a 99`'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 Ibs/day.
The January 1998—October 2000 monthly color average using a 990'percentile
distribution is 59,796 lbs/day. The January 2000—October 2000 monthly color average
using a 99a'percentile distribution is 58,953 Ibs/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 Ibs/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= 111198-1013112000 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 66656 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